About 1,200-1,400 small and mid-sized US banks exceed CRE-concentration supervisory thresholds, and the share has been rising since 2019

Summary

Roughly 1,200 to 1,400 small and mid-sized US banks currently carry commercial real estate (CRE) loan books large enough, relative to capital, to draw the supervisory attention defined by the 2006/2023 interagency CRE concentration guidance (CRE loans exceeding 300% of capital, or construction/land-development loans exceeding 100% of capital). FDIC's own 2025 Risk Review puts the year-end-2024 count at 1,374 banks, or about 31% of all FDIC-insured banks — and reports this "resembling year-end 2023," i.e. essentially flat over that one year. An independent calculation from FDIC Call Report data run here, using a narrower single-threshold proxy (CRE loans over 300% of capital only, no ADC/construction leg) on banks under $100 billion in assets, corroborates FDIC's figure closely (1,267 banks, 28.1% of that population, at year-end 2024) and additionally shows the multi-year trend FDIC's snapshot does not: the SHARE of small/mid banks over the threshold has been rising since 2019 — from about 24% in 2019 to about 28% in 2024-2025 — even though the raw count of concentrated banks has stayed roughly flat to slightly down, because the total population of small/mid banks has been shrinking through consolidation. So: yes, on a share basis the concern has been growing; on a raw headcount basis it has been roughly stable near its post-2013 range.

What "supervisory concern" means here

The 2006 interagency guidance (reaffirmed and updated by the banking agencies in 2023) flags a bank for heightened supervisory review of its CRE risk management when either: (1) total CRE loans exceed 300% of total capital, or (2) construction and land development (ADC) loans alone exceed 100% of total capital. Crossing these thresholds does not automatically trigger an enforcement action, but it is the standard screen examiners use to decide which banks get deeper CRE-specific review. FDIC's Risk Review additionally nets in the allowance for credit losses (ACL) alongside Tier 1 capital in the denominator, which is a slightly more forgiving (larger) denominator than pure Tier 1/risk-based capital alone.

Data and method

Query used AskAmerica's banking.financials table (FDIC Call Report financials, sourced from api.fdic.gov/banks/financials; observed coverage 2013-2026, quarterly, cert x report-date grain). For each year-end report date (Dec 31), CRE exposure was computed as cre_nonfarm_nonresidential_thousands + cre_construction_land_dev_thousands + cre_multifamily_thousands, and capital as total_risk_based_capital_thousands where nonzero, else total_tier1_capital_thousands (roughly 39% of institutions elect the Community Bank Leverage Ratio framework and report 0 for standard risk-based capital, per this table's own column documentation, so Tier 1 is substituted for those banks rather than dropping them). "Small and mid-sized" was operationalized as total assets under $100 billion, which is also the exact cutoff FDIC itself uses in the Risk Review to separate "noncommunity banks < $100B" and "community banks" from the largest institutions.

The most recent data available is Q2 2026 (June 30, 2026): 1,199 of 4,264 small/mid banks (28.1%) were over the 300%-of-capital threshold on this proxy — consistent with the year-end 2025 reading, i.e. the share has plateaued around 28% for the past three years rather than continuing to climb.

Cross-check against FDIC's own published figures (2025 Risk Review, year-end 2024)

Fetched directly from FDIC's 2025 Risk Review (fdic.gov/analysis/2025-risk-review.pdf, Section 4, Commercial Real Estate):

• "CRE-concentrated is total CRE loans >300 percent, or ADC loans >100 percent, of tier 1 capital and the allowance for credit losses... Roughly 31 percent of all banks (1,374 banks) were CRE-concentrated at year-end 2024, resembling year-end 2023."
• "30 percent of community banks were CRE-concentrated as of fourth quarter 2024."
• Median CRE concentration ratio by size cohort at year-end 2024: community banks 195%; noncommunity banks under $100B, 258%; regional banks ($10B-$100B) specifically, 289%; banks $1B-$10B, 314% (the single highest median of any cohort); banks under $1B, 163%; banks over $100B, only 69%.

This confirms two things independently found in the AskAmerica query: (1) the magnitude — roughly 1,200-1,400 banks nationally clear the 300%-of-capital screen, matching this run's 1,267-1,291 for 2023-2024 on the narrower <$100B/single-threshold proxy; and (2) that CRE concentration is a small/mid-bank phenomenon specifically — the largest banks (>$100B) are barely exposed (69% median) while the $1B-$10B cohort is the most concentrated of any size class (314% median).

Has the number been growing?

Two different but both-true answers, depending on which number is asked for: the raw count of concentrated banks fell substantially from 2013 (1,512, when the post-financial-crisis banking population was much larger) to a low near 1,212 in 2021, then rose back to roughly 1,267-1,291 in 2022-2024, and has been essentially flat (1,229-1,267) since. The share of small/mid banks that are concentrated, however, has climbed steadily and specifically since 2019 — from about 24.4% (2019) to about 28.0-28.2% every year-end from 2023 through 2025, and remains at 28.1% as of the most recent available quarter (Q2 2026). The share rise reflects two forces moving together: real growth in CRE lending relative to capital at surviving community and regional banks, compounded by the shrinking total population of small/mid banks (down from 6,853 to 4,264 institutions under $100B over the same window) through mergers and failures, which mechanically raises the concentrated share even where the raw numerator is flat. FDIC's own characterization — that 2024 "resembled" 2023 — is consistent with the recent plateau seen here, but masks the longer 2019-2024 climb in share terms.

Every query behind this report

4 warehouse calls ran in this session, in order. Each is reproducible against the same snapshot.

SELECT EXTRACT(YEAR FROM repdte) AS yr,
  COUNT(*) FILTER (WHERE total_assets_thousands < 100000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0
    AND (COALESCE(cre_nonfarm_nonresidential_thousands,0)+COALESCE(cre_construction_land_dev_thousands,0)+COALESCE(cre_multifamily_thousands,0))
        / (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 3.0
  ) AS n_high_cre,
  COUNT(*) FILTER (WHERE total_assets_thousands < 100000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0) AS n_total_small_mid
FROM banking.financials
WHERE EXTRACT(MONTH FROM repdte)=12 AND EXTRACT(DAY FROM repdte)=31
GROUP BY EXTRACT(YEAR FROM repdte)
ORDER BY yr

SELECT MAX(repdte) AS max_date FROM banking.financials

SELECT
  COUNT(*) FILTER (WHERE total_assets_thousands < 100000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0
    AND (COALESCE(cre_nonfarm_nonresidential_thousands,0)+COALESCE(cre_construction_land_dev_thousands,0)+COALESCE(cre_multifamily_thousands,0))
        / (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 3.0
  ) AS n_high_cre,
  COUNT(*) FILTER (WHERE total_assets_thousands < 100000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0) AS n_total
FROM banking.financials
WHERE repdte = DATE '2026-06-30'

SELECT EXTRACT(YEAR FROM repdte) AS yr,
  COUNT(*) FILTER (WHERE total_assets_thousands < 10000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0
    AND (COALESCE(cre_nonfarm_nonresidential_thousands,0)+COALESCE(cre_construction_land_dev_thousands,0)+COALESCE(cre_multifamily_thousands,0))
        / (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 3.0
  ) AS n_high_cre,
  COUNT(*) FILTER (WHERE total_assets_thousands < 10000000
    AND (COALESCE(NULLIF(total_risk_based_capital_thousands,0), total_tier1_capital_thousands)) > 0) AS n_total
FROM banking.financials
WHERE EXTRACT(MONTH FROM repdte)=12 AND EXTRACT(DAY FROM repdte)=31
GROUP BY EXTRACT(YEAR FROM repdte)
ORDER BY yr