Glossary · Regulation

CRE concentration

Also called: commercial real estate concentration, 300 percent test, CRE to capital

Defined by the Research desk, The Lender Report · Sources reviewed

A bank's commercial real estate loans measured against its capital. Federal guidance from 2006 flags 300 percent of total capital, with 50 percent growth in 36 months, for closer review.

Bank examiners look at how much of a bank’s capital is tied to commercial real estate. The 2006 interagency guidance gives them two screens. The second is the one most people mean by CRE concentration: total commercial real estate loans at 300 percent or more of the bank’s total capital, where the balance has also grown 50 percent or more in the prior 36 months. Total capital here means total risk-based capital from the Call Report.

The count covers construction, land development and other land loans, multifamily loans, and loans on nonfarm nonresidential property. Loans on owner-occupied property are left out.

The guidance says it does not set a limit on a bank’s CRE lending, and that the screens are not a safe harbor. A bank above the level is expected to show stronger risk management and capital, not to stop lending.

For a borrower the practical point is appetite. A bank that is high on this measure may be slower on a new investor property loan, may ask for more, or may sell part of the loan to another lender. A bank well under it may have more room. Ask the banker where the bank stands.

How it shows up in the data here

Each bank page shows CRE to capital: construction, multifamily and non-owner-occupied commercial real estate loans held, divided by tier 1 capital plus the allowance, beside the range for similar banks. This is our calculation. It is not the 2006 guidance test, which uses total risk-based capital and adds a growth condition. See banks ranked by investor CRE loans held.

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Related terms

Sources

  1. Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices, 71 FR 74580, published .

Plain definitions for orientation, not legal, tax or credit advice. A lender's own policy decides what it will do.