Every refinancing wave in commercial real estate runs through the balance sheets of regional and community banks, and how much CRE debt each bank already carries against its capital shapes which of them still have room to lend. As of June 30, 2026, 390 of the 4,313 FDIC insured banks that filed call reports held CRE loans equal to 300% or more of their tier 1 capital plus loan loss reserves, the level federal regulators use to flag a concentration for closer supervisory attention. Among the 165 banks with at least $10 billion in assets, 20 sit at or above that line.
The count keeps falling. On March 31, 2025, 433 banks were at or above 300% and 106 were at or above 400%. Fifteen months later those figures are 390 and 84, and the median bank over $10 billion has eased from 193.4% to 188.2%. Part of the decline is consolidation: the number of banks filing call reports fell from 4,536 to 4,313 over the same stretch.
Apple Bank leads the large bank list at 436.7%, followed by ConnectOne Bank at 430.9% and Provident Bank at 429.2%. Three banks with more than $50 billion in assets cross the threshold: Flagstar Bank, N.A. at 356.6%, Valley National Bank at 326.0% and Columbia Bank at 302.9%. Every figure on this page comes from the quarterly call reports banks file with their regulators, pulled from the FDIC BankFind database and computed the same way for every bank, so any reader can reproduce it.
This ranking is part of the BestCRE Capital coverage, which pairs regulatory data with the lenders borrowers actually call. For the banks most active in each loan type, see the Best CRE Lenders rankings and the construction loan lender rankings; for property sector context, start at the 20 CRE sectors hub.
Twenty Large Banks Sit Above the 300% Line, and Nine of Them Are New York Metro Lenders
The table ranks the 30 most concentrated banks with at least $10 billion in assets by guidance CRE to tier 1 capital plus loan loss reserves. Bold ratios are at or above 300%. The March 31 column shows the same bank one quarter earlier, and the construction column isolates construction and land development loans, which the guidance screens separately at 100% of capital.
| Rank | Bank | State | Assets ($B) | Guidance CRE ($B) | CRE to capital, June 30 | CRE to capital, March 31 | Construction to capital |
|---|---|---|---|---|---|---|---|
| 1 | Apple Bank | NY | 19.9 | 6.82 | 436.7% | 440.7% | 0.0% |
| 2 | ConnectOne Bank | NJ | 14.4 | 7.13 | 430.9% | 426.1% | 51.7% |
| 3 | Provident Bank | NJ | 25.7 | 11.94 | 429.2% | 430.1% | 26.0% |
| 4 | OceanFirst Bank, N.A. | NJ | 23.2 | 8.78 | 381.4% | 427.9% | 32.1% |
| 5 | Dime Commercial Bank | NY | 15.0 | 6.12 | 364.7% | 387.1% | 5.0% |
| 6 | Flagstar Bank, N.A. | NY | 87.7 | 33.20 | 356.6% | 370.9% | 14.7% |
| 7 | Columbia Bank (NJ) | NJ | 12.2 | 4.13 | 354.9% | 345.0% | 43.2% |
| 8 | Simmons Bank | AR | 24.7 | 8.37 | 348.3% | 355.2% | 107.2% |
| 9 | WaFd Bank | WA | 27.6 | 9.34 | 344.1% | 350.3% | 48.9% |
| 10 | Mechanics Bank | CA | 21.2 | 7.08 | 342.2% | 348.0% | 16.9% |
| 11 | Burke & Herbert Bank & Trust Company | VA | 11.0 | 4.35 | 333.7% | 313.5% | 34.7% |
| 12 | Beacon Bank and Trust | MA | 22.2 | 7.81 | 330.0% | 338.7% | 16.0% |
| 13 | Valley National Bank | NJ | 66.2 | 23.20 | 326.0% | 332.3% | 34.9% |
| 14 | Axos Bank | CA | 28.9 | 9.15 | 318.4% | 280.0% | 42.5% |
| 15 | Popular Bank | NY | 15.0 | 5.64 | 311.5% | 309.8% | 74.2% |
| 16 | Banc of California | CA | 34.9 | 10.95 | 309.8% | 289.7% | 52.8% |
| 17 | ServisFirst Bank | AL | 18.3 | 6.74 | 309.2% | 299.8% | 71.8% |
| 18 | United Bank | VA | 33.6 | 12.30 | 308.3% | 310.6% | 83.6% |
| 19 | Columbia Bank (OR) | OR | 65.4 | 20.16 | 302.9% | 303.9% | 30.5% |
| 20 | Merchants Bank of Indiana | IN | 21.2 | 7.20 | 301.1% | 308.6% | 83.5% |
| 21 | Bank OZK | AR | 41.7 | 17.72 | 290.4% | 321.4% | 113.8% |
| 22 | First United Bank and Trust Company | OK | 16.6 | 4.96 | 284.7% | 276.2% | 89.3% |
| 23 | TowneBank | VA | 22.6 | 6.72 | 283.6% | 304.9% | 55.8% |
| 24 | SouthState Bank, N.A. | FL | 68.8 | 20.49 | 282.6% | 275.8% | 40.4% |
| 25 | First Bank | NC | 13.0 | 4.44 | 281.9% | 279.4% | 53.8% |
| 26 | Citizens Business Bank, N.A. | CA | 21.2 | 6.42 | 281.1% | 238.1% | 9.4% |
| 27 | Rockland Trust Company | MA | 25.0 | 8.23 | 276.8% | 282.3% | 50.2% |
| 28 | Bank of Hope | CA | 19.0 | 5.89 | 276.2% | 275.6% | 10.0% |
| 29 | Atlantic Union Bank | VA | 38.0 | 12.01 | 274.3% | 272.5% | 42.5% |
| 30 | City National Bank of Florida | FL | 29.1 | 9.64 | 273.5% | 275.4% | 46.6% |
Of the 20 large banks above the line, 9 are headquartered in New York or New Jersey, and multifamily loans make up 53.4% of their combined guidance CRE. That is the rent regulated and market rate apartment lending that defines the region, and it explains why these banks look concentrated even though many carry little construction risk: Apple Bank reports a construction ratio of 0.0%. Outside the New York metro, the banks above the line range from Massachusetts and Virginia to Arkansas, Alabama, Indiana and the West Coast.
The 300% Ratio Is a Supervisory Screen, Not a Limit
The measure comes from the 2006 interagency guidance Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices, issued jointly by the OCC, the Federal Reserve and the FDIC. The guidance counts construction and land development loans, multifamily loans, nonfarm nonresidential loans that are not owner occupied, and loans to finance commercial real estate that are not secured by real estate. Owner occupied properties are left out because repayment depends on the operating business rather than on rents.
Examiners look harder at a bank when that total reaches 300% of capital and the CRE portfolio has grown 50% or more in the prior 36 months, or when construction and land development loans alone reach 100% of capital. The agencies stated plainly that they were not setting a cap. A bank above the line is expected to run stronger risk management, stress testing and capital planning, and many lenders operate above it for years. The denominator used here is tier 1 capital plus the allowance for loan and lease losses, the version supervisory reports now apply so that every bank can be measured on the same basis.
Fewer Banks Cross the Line Each Quarter
| Quarter | Banks filing | At or above 300% | At or above 400% | Construction at or above 100% | Large banks at or above 300% | Median large bank |
|---|---|---|---|---|---|---|
| March 31, 2025 | 4,536 | 433 | 106 | 282 | 21 of 163 | 193.4% |
| June 30, 2025 | 4,494 | 428 | 104 | 286 | 20 of 159 | 193.2% |
| Sept. 30, 2025 | 4,452 | 411 | 99 | 271 | 23 of 159 | 189.4% |
| Dec. 31, 2025 | 4,411 | 410 | 98 | 272 | 21 of 159 | 189.1% |
| March 31, 2026 | 4,353 | 407 | 92 | 275 | 19 of 160 | 189.7% |
| June 30, 2026 | 4,313 | 390 | 84 | 276 | 20 of 165 | 188.2% |
The trend is steady rather than dramatic. Banks at or above 400% fell from 106 to 84 over five quarters, while the large bank count above 300% has hovered between 19 and 23. Construction concentrations have barely moved, with 276 banks at or above 100% of capital in the latest quarter against 282 at the start of the series. Across all banks, half sit below 128.6%, which means the typical lender is nowhere near the threshold and the concentration story belongs to a specific group of real estate specialists.
The biggest one quarter declines among large banks came at OceanFirst Bank, N.A., down 46.5 points to 381.4%, and Bank OZK, down 31.0 points to 290.4%, which moved it below the line. Moving the other way, Banc of California rose from 289.7% to 309.8% and Axos Bank rose from 280.0% to 318.4%.
Four Large Banks Meet Both Guidance Tests
The full screen pairs the 300% level with growth of 50% or more over 36 months. Comparing guidance CRE balances at June 30, 2026 with June 30, 2023, 4 banks over $10 billion meet both conditions.
| Bank | State | CRE to capital | Guidance CRE growth since June 30, 2023 |
|---|---|---|---|
| Provident Bank | NJ | 429.2% | +77.1% |
| OceanFirst Bank, N.A. | NJ | 381.4% | +61.1% |
| Burke & Herbert Bank & Trust Company | VA | 333.7% | +236.9% |
| Beacon Bank and Trust | MA | 330.0% | +179.1% |
Growth figures include loans a bank acquired through mergers, so a large jump can reflect a completed deal rather than aggressive new lending. That distinction matters to examiners, who weigh how the portfolio was built and how it is managed. By contrast, Flagstar Bank, N.A. has reduced its guidance CRE balance 32.1% since June 30, 2023 and Valley National Bank has reduced its balance 15.0%, yet both remain above the line because capital has not grown as fast as the loan book shrank.
The Largest Banks Sit Far Below the Threshold
Size and concentration run in opposite directions. Of the 49 banks with at least $50 billion in assets, 3 are at or above 300% and 26 are below 100%. JPMorgan Chase Bank, N.A. is at 61.5%, Wells Fargo Bank, N.A. at 81.8% and Bank of America, N.A. at 45.7%. Just below the line among the super regionals are SouthState Bank, N.A. at 282.6%, Webster Bank, N.A. at 273.3% and Old National Bank at 254.8%.
| Bank | State | Assets ($B) | CRE to capital | Broad CRE to equity |
|---|---|---|---|---|
| Flagstar Bank, N.A. | NY | 87.7 | 356.6% | 464.6% |
| Valley National Bank | NJ | 66.2 | 326.0% | 395.2% |
| Columbia Bank (OR) | OR | 65.4 | 302.9% | 368.8% |
| SouthState Bank, N.A. | FL | 68.8 | 282.6% | 340.7% |
| Webster Bank, N.A. | CT | 85.9 | 273.3% | 262.8% |
| Old National Bank | IN | 73.9 | 254.8% | 316.2% |
| Pinnacle Bank | TN | 128.8 | 245.7% | 310.1% |
| East West Bank | CA | 84.3 | 233.1% | 318.5% |
| Associated Bank, N.A. | WI | 51.8 | 227.8% | 280.3% |
| Western Alliance Bank | AZ | 98.6 | 200.1% | 285.3% |
| UMB Bank, N.A. | MO | 71.9 | 182.3% | 256.2% |
| CIBC Bank USA | IL | 66.5 | 181.1% | 236.5% |
The broad column adds owner occupied loans and unused CRE commitments and divides by total equity. It is not the regulatory measure, but it captures the full real estate footprint a bank has signed up for, including construction draws it is obligated to fund.
California, Texas and New York Hold the Most Concentrated Banks
Counting banks of every size at or above 300%, the leading states are CA (43), TX (33), NY (24), IL (23), WI (22), NJ (17). The large bank list is dominated by the New York metro, but the long tail is community banks: 191 of the 390 banks at or above 300% have less than $1 billion in assets. State by state lender rankings are live for California, Texas, New York and New Jersey.
For Borrowers, Concentration Is a Signal About Appetite
A bank well above 300% can keep lending, but it usually does so selectively: renewing existing relationships, favoring deposit rich borrowers and pricing new CRE requests to protect capital. A bank well below the line with a growing CRE book often has both the capacity and the intent to win new loans. That is the practical use of this data for a sponsor shopping a refinance or a construction loan. Pair the ratio with growth, and a short list of banks with room and momentum appears.
BestCRE tracks that second half of the picture in the fastest growing CRE bank lenders ranking and the multifamily bank lender ranking. A bank that shows up high on growth and in the middle of this concentration table is often the most receptive call. A bank at the top of this table may still be the right lender for an existing customer, but a new borrower should expect tighter terms or a longer conversation about deposits.
A Broader Measure: CRE Exposure Including Commitments
Some analysts publish a wider ratio that adds owner occupied loans and undrawn CRE commitments and divides by total equity. On that basis the picture shifts for lenders with large owner occupied or construction pipelines. ServisFirst Bank is at 309.2% on the guidance measure and 536.9% on the broad measure; ConnectOne Bank moves from 430.9% to 524.9%. Broad figures published elsewhere can differ from bank to bank by hundreds of millions of dollars depending on which commitment lines are counted, so we list ours by component in the method section and publish both ratios side by side.
Method and Sources
All data come from Consolidated Reports of Condition and Income (call reports) as published in the FDIC BankFind Suite. Guidance CRE is construction and land development loans (LNRECONS), multifamily loans (LNREMULT), nonfarm nonresidential loans not owner occupied (LNRENROT) and loans to finance commercial real estate not secured by real estate (LNCOMRE). The denominator is tier 1 capital (RBCT1) plus the allowance for loan and lease losses (LNATRES). The broad measure adds owner occupied nonfarm nonresidential loans (LNRENROW) and unused commitments to fund commercial real estate, construction and land development loans (UCCOMRE), divided by total equity capital (EQ). Growth compares guidance CRE at June 30, 2026 with June 30, 2023 for the same FDIC certificate. Large banks are those with total assets of $10 billion or more. The page is rebuilt each quarter when the FDIC posts new call report data, and figures are restated if a bank amends its filing.
This page reports regulatory data. A ratio at or above 300% is a supervisory review trigger, not a limit, a rating or a measure of loan quality, and nothing here is investment advice.
About BestCRE
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Frequently Asked Questions
What is a bank’s CRE concentration ratio?
It is the bank’s commercial real estate loans, as defined in the 2006 interagency guidance, divided by its capital. The numerator counts construction and land development loans, multifamily loans, nonfarm nonresidential loans that are not owner occupied and loans to finance CRE that are not secured by real estate. The denominator used on this page is tier 1 capital plus the allowance for loan and lease losses. A bank with $1 of guidance CRE for every $1 of capital is at 100%. Regulators pay closer attention at 300%, especially when the portfolio has grown 50% or more in 36 months. As of June 30, 2026, the median bank over $10 billion in assets was at 188.2%, and half of all banks were below 128.6%. The ratio describes how much real estate risk a bank holds relative to its loss absorbing capital, not the quality of the individual loans.
Does a ratio above 300% stop a bank from making CRE loans?
No. The guidance explicitly does not set a limit. A bank above 300% is expected to show stronger board oversight, portfolio stress testing, market analysis and capital planning, and examiners review those practices more closely. In practice, many banks operate above the line for years. What changes is behavior at the margin: concentrated banks often prioritize existing borrowers, ask for deposit relationships and price new CRE requests to protect capital. At June 30, 2026, 390 banks were at or above 300%, and 84 were at or above 400%. Borrowers working with one of these lenders can usually still get a loan, but should expect more questions about deposits, sponsorship and the specific property than they would face at a bank with ample room.
Which large banks have the highest CRE exposure in 2026?
On June 30, 2026 call report data, the most concentrated banks with at least $10 billion in assets were Apple Bank at 436.7%, ConnectOne Bank at 430.9% and Provident Bank at 429.2%, followed by OceanFirst Bank, N.A. at 381.4%. Among banks with more than $50 billion in assets, Flagstar Bank, N.A. at 356.6%, Valley National Bank at 326.0% and Columbia Bank at 302.9% were at or above 300%. In total, 20 of the 165 large banks crossed the threshold. The national money center banks sit far lower, with JPMorgan Chase Bank, N.A. at 61.5% and Bank of America, N.A. at 45.7%. The full ranking above lists the 30 most concentrated large banks with their prior quarter ratio and their construction ratio.
Are bank CRE concentrations rising or falling?
Falling, gradually. The number of banks at or above 300% declined from 433 on March 31, 2025 to 390 on June 30, 2026, and banks at or above 400% fell from 106 to 84. The median large bank eased from 193.4% to 188.2%. Some of the decline reflects mergers, since the number of banks filing call reports fell from 4,536 to 4,313, and some reflects banks shrinking CRE books while capital grows. Construction concentrations have been flat, with 276 banks at or above 100% of capital in the latest quarter. The next update arrives when the FDIC posts September 30 call report data, and this page will be rebuilt on the same method.
How can borrowers use CRE concentration data when choosing a lender?
Use it as a capacity screen before making calls. A bank far above 300% may still lend, especially to existing customers, but a new borrower should expect tighter terms. A bank comfortably below the line with a growing CRE portfolio is more likely to compete for new business. Start with your state, since most CRE lending is local: the states with the most concentrated banks are CA (43), TX (33), NY (24), IL (23), WI (22), NJ (17). Then cross check this table against the fastest growing CRE bank lenders and the Best CRE Lenders rankings to find banks with both room and momentum. Bring deposit relationships to the conversation, because concentrated and unconcentrated banks alike reward borrowers who bring deposits.
Related: Best CRE Lenders 2026 · Fastest Growing CRE Bank Lenders · Best Construction Loan Lenders