The Spread puts a whole corner of financial services on one chart and asks whether the thing everyone says is true. No. 2: banks and commercial real estate.
The 300% in the regulators' guidance on commercial real estate means CRE loans of three times a bank's capital. It comes from guidance the FDIC, the Federal Reserve and the OCC issued in 2006, and it is half of a sentence. The screen the agencies set out is CRE loans of 300% or more of capital together with growth in the CRE book of 50% or more over the prior 36 months.
So we counted both halves, for every one of the 4,238 FDIC-insured banks that filed a Call Report for June 30, 2026.
Source: FDIC, BankFind Suite: Call Report data, June 30, 2026 and June 30, 2023; FDIC, Federal Reserve and OCC, guidance on concentrations in CRE lending (2006). Data as of 2026-06-30. Lines mark the median change in each group. Banks with no CRE loans, or none in 2023, are left off; ratios above 600% and changes beyond −100% or +300% are drawn at the edge. Capital is tier 1 capital plus the allowance for credit losses, the denominator examiners have used since March 31, 2020.
Show the data
| Change in CRE loans over 36 months | Count | |
|---|---|---|
| Under 300% (median) | 21% | 3,677 |
| 300% or more (median) | 27% | 389 |
The first half catches 389 banks. Both halves catch 107.
Source: FDIC, BankFind Suite: Call Report data, June 30, 2026 and June 30, 2023; FDIC, Federal Reserve and OCC, guidance on concentrations in CRE lending (2006). Data as of 2026-06-30.
Show the data
| Figure | What it counts |
|---|---|
| 389 | banks with CRE loans of 300% or more of capital: one in eleven insured banks |
| 107 | that also grew CRE loans by 50% or more in 36 months: one in forty |
| 82 | of those 107 that did not absorb another bank along the way |
389 banks hold CRE loans of 300% or more of capital, one in eleven insured banks. Only 107 of them also grew their CRE loans by half or more since June 2023: 28% of the banks over the line, and one in forty insured banks. None of the 32 banks with $100 billion or more in assets is in either count.
Most banks over the line are not growing fast
The typical bank over 300% grew its CRE loans by 27% in three years. 131 of the 389 grew by less than a quarter, and 51 hold fewer CRE loans than they did in 2023.
That is the distinction the growth test draws. Two banks at the same ratio, one whose CRE book grew slowly and one whose book grew fast, are different questions.
And 25 of the 107 bought some of the growth
25 of the banks that meet both tests absorbed another bank between June 2023 and June 2026, according to FDIC records, so part of their growth is loans they acquired rather than made. The guidance does not say how a merger should be treated, and we have not adjusted for one. Leave those 25 out and 82 remain.
The other side of the line
The growth test cuts the other way too. 979 banks grew their CRE loans by 50% or more and stayed under 300%. Neither half alone describes a bank's exposure, which is the point of reading them together.
If you sit on a bank's board or in its risk function
- Which half are we near? A ratio near 300% with a flat book and a ratio of 200% with a book that doubled are different conversations.
- What did our growth include? If the bank absorbed another, ask for the growth with and without the acquired loans.
- Is construction its own question? The guidance has a separate test for construction and land loans alone, at 100% of capital, which this count does not include.
Our take
300% is a useful number and a poor summary. The agencies paired it with growth, and on our reading that pairing is the useful part: a large CRE book that grew slowly and one that grew fast are different questions, even at the same ratio. A count that uses only the first half finds 389 banks. The screen as written finds 107.
How we counted, and what it leaves out
- A screen, not a verdict. The agencies use the criteria to pick out banks for closer review. They say examiners weigh risk management, capital and the makeup of the portfolio, and so should anyone reading this.
- One charter at a time. A bank that changed its FDIC certificate in the period has no 2023 report to compare with. None of the banks over 300% is in that position.
- Mergers count as growth. We mark them and do not adjust for them.
- The construction test is not here. It needs its own count.
The 50 largest CRE lenders, with each one's ratio to capital and 36-month change, are in largest commercial real estate lenders, with the 25 highest ratios among banks with $1 billion or more of CRE loans. To compare one bank with those nearest it in size, use the free bank peer benchmark.