The 117 larger banks hold $784 billion of property loans. Eight are over the line and 53 are past twice their capital.

Eight banks are over three times capital. Fifty-three are over two times.

We took the 117 US banks with 1,000 to 4,999 employees, banks big enough to have a credit department and not only a lending desk. 109 of them report loans on commercial property; eight report none and are left out of the counts below. The 109 hold $783.8 billion of property loans, 25 % of the $3,081 billion on the books of all 4,313 reporting US banks. Of that, $613.8 billion is investor property: construction and land, apartment buildings, and commercial buildings not occupied by their owner.

We measured them by investor property loans against capital, in the June 2026 reports, and the 1,192 mid-size banks with 100 to 999 employees the same way. Eight banks are at 300 % or more of capital, 7 % of the 109, with $48.4 billion between them. In the mid-size group it is 26 %. The typical bank over the line here is at 315 %, and the highest at 426 %. The rule of thumb is 300 percent: not a limit, but the point at which an examiner asks how the bank manages the concentration.

The money is in the middle of the range. 45 banks sit between 200 and 300 % and hold $316.3 billion, 52 % of the group’s investor property loans. Add the eight over the line and 53 banks hold $364.8 billion, 59 %.

Construction and land loans, the guidance’s second trigger, are at 100 % of capital or more at two banks.

One caution on the measure, as in Review No. 4. The regulators divide by total risk-based capital and we divide by equity, which is the figure on every report, and their test also looks at how fast the book grew over three years, which we did not measure. Read the eight as the banks to look at first, not as banks the regulators have flagged. How we treat the gap

Twenty-seven banks hold about half of the dollars, and the median bank holds $5.8 billion of property loans.

Each dot below is one bank, not named. Across is investor property loans, on a log scale. Up is the concentration. 97 of the 109 banks hold $1 billion or more of investor property loans, $608.5 billion between them, 99 % of the group’s total. Only the left edge is thin.

The top is crowded. 27 banks hold $10 billion or more of property loans in all, $388.6 billion between them, about half of the group’s $783.8 billion. The ten largest hold $196.4 billion, 25 %. The median bank holds $5.8 billion, and the largest $30.4 billion.

A larger team does not mean a lighter load. The 109 banks employ 241,666 people, counting everyone and not only credit staff, and hold $3.2 million of property loans per employee. The mid-size banks of Review No. 4 hold $3.0 million. Pick a staff band to see it: the smallest of the three has the highest share past two times capital, 21 of 37, and the largest the biggest books, a median of $7.9 billion of investor property loans.

A book of this size has many loans falling due in any quarter, and each one has to be read against the property’s current rent roll and operating statement. A team can do that for a sample. Doing it for every file is the work that gets postponed.

About $100 billion of the group’s loans mature in 2026, and the banks most concentrated in property hold more that fall due later.

The bank reports do not split property loans by maturity, so we use two views. The first is national. The national survey of loan maturities counts $396 billion of commercial and multifamily mortgages held by banks and other depositories maturing in 2026, 21 % of what they hold, and $652 billion for all lenders in 2027, with no split by lender. The 117 banks hold 25 % of the property loans on bank books, so a simple pro-rata puts about $100 billion of the 2026 maturities with them. That is an order of magnitude and not a count. How we estimate it

The second view is the banks’ own reports. Every bank reports how its loans, other than first-lien home mortgages, fall due: fixed-rate loans by remaining maturity, floating-rate loans by the date the rate next resets. The table covers all business loans and not only property, and it cannot tell a maturity from a reset, so read it as how soon a loan has to be decided again. What the table is For the 109 banks, of $1,979 billion in the table, 63 % is due or resets within three months and 70 % within a year, to June 2027. Only 10 % sits in the one-to-three-year window, to June 2029.

The split that matters is by concentration. The 53 banks at 200 % of capital or more have 58 % of the table within a year; the 56 below 200 % have 76 %. In the one-to-three-year window it is 14 % against 8 %. The more property a bank holds against its capital, the more of its book is term loans falling due in 2027 to 2029 and the less is loans that reset this year. We did not test why. A book of term loans on buildings would look like this, and so would a bank whose other loans are short lines. What we can and cannot say

At bank level the spread is wide. Within a year, from 1.5 % to 98 % of the table, with a median of 58 %. 28 banks have more than 70 % inside the year, and 10 have less than 30 %.

What to do with this

If you run credit at one of the 117: the useful question is not how many loans exceed a ratio but which of the loans falling due between now and mid-2029 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.