Banks over the CRE line. 264 US banks hold $283 billion of commercial real estate above 300 % of capital.

One mid-size bank in five is over three times capital.

In December 2006 the US bank regulators wrote down when a bank should expect a closer look. One trigger is 300 percent of capital in commercial real estate loans. It is not a limit and it does not mean a bank is in trouble. It means the examiner will ask how the bank manages the concentration.

We took the 1,192 US banks with 100 to 999 employees, the banks big enough to lend on real estate at scale and small enough to have no analyst department, and measured investor property loans against capital in their June 2026 reports. 264 of them are at 300 % or more, 22 % of the group. Together they hold $283.0 billion of investor property loans, out of $713.6 billion held by all 1,192.

Investor property here means construction and land loans, apartment buildings, and commercial buildings not occupied by their owner. The typical bank over the line is at 355 %. The groups below show that most sit close to the line, and a few are far past it.

The middle of the range matters most for the money. 119 banks sit between 300 and 350 %, and they hold $109.1 billion, 39 % of the total. The tail is small in count and large in dollars: 16 banks at five times capital hold $32.1 billion.

One caution on the measure. The regulators’ ratio divides by total risk-based capital and ours divides by equity, which is the figure on every report, so ours runs higher for some banks. The regulators’ test also looks at how fast the book grew over three years, which we did not measure. Read the 264 as the banks to look at first, not as a list of banks the regulators have flagged. How we treat the gap

Three states hold 30 % of the dollars. New Jersey has the highest share of banks over the line.

The 264 banks are in at least 45 states and Guam. California, New Jersey and New York hold $82.5 billion of the $277.4 billion that sit in states we can place on the map, 30 %. Texas has the most banks over the line, 24, and the most mid-size banks of any state, 102.

The share tells a different story from the count. In New Jersey 11 of 20 mid-size banks, 55 %, are over the line, and their books are large: $28.3 billion. In California it is 18 of 48. In Texas it is about one in four.

Tap a state to see its banks, its dollars and its typical concentration. Switch the view to colour the map by banks, by dollars, or by the share of the state’s banks.

Half of the banks over the line have fewer than 250 people, and 88 of them hold more than $1 billion.

Each dot below is one bank over the line. Across is investor property loans, from $300 million to $7 billion on a log scale. Up is the concentration. Most dots sit in the lower left: a bank of a few hundred people at 300 to 400 %.

The top right is the group that matters most. 88 banks hold $1 billion or more of investor property loans, and together $182.6 billion, 65 % of the $283.0 billion. The other end is 77 banks under $500 million, $29.5 billion in all.

Pick a staff band to see what a typical bank in it looks like. A bank in the 100 to 199 band has a median book of $448 million. A bank with 500 to 999 staff has $2.5 billion. Both have the same concentration, near 350 %. The smaller one has far fewer people to review the loans.

This is why the line is hard to work with from the inside. A bank over three times capital has to show it reviews its loans on the property’s numbers: rent roll, operating statement, appraisal, the borrower’s plan. At 200 people there is no team that does this for several hundred loans a year. The second look is the work that does not get done.

What to do with this

If you run credit at a bank over the line: the useful question is not how many loans exceed a ratio but which ones carry the risk. That needs every file read against the property’s own numbers, on the new loans and on the renewals.

Titleman reads the credit file of a commercial property loan, the offering memorandum, rent roll, operating statement and collateral, and returns the issues and the questions for the borrower. The review covers every loan put in front of it, so the second look is the same for the 200th loan as for the first.