The 25 U.S. Banks With the Highest Commercial Real Estate Exposure in 2026 (Q4 2025 Call Reports)

Updated: April 24, 2026. Data snapshot: Q4 2025 U.S. Call Reports dated 2025-12-31.^[1]

The highest commercial real estate exposure at U.S. banks is usually found by comparing a bank’s CRE book to the capital available to absorb losses. That is the point of this ranking. Using local U.S. Call Report data from that Q4 2025 snapshot, we ranked active U.S. banks by total CRE divided by total capital. In plain English, the higher the ratio, the more heavily a bank is leaning on commercial real estate relative to its capital base.

This matters because CRE concentration can amplify stress when office, retail, multifamily, or construction markets weaken. A bank can still be profitable and well-run with a high ratio, but the ratio tells you where to look first. For investors, lenders, consultants, and bank strategy teams, it is one of the quickest screens for balance-sheet sensitivity.

Key Takeaways

• The ranking is based on the latest local U.S. Call Report date available in the database: Q4 2025, dated 2025-12-31.
• The metric is combined CRE / total capital. It includes construction and land development, multifamily, non-owner-occupied nonfarm nonresidential, and owner-occupied nonfarm nonresidential loans.
• This is a combined concentration screen, not a direct OCC 300% supervisory-threshold table; that supervisory reference is based on non-owner-occupied CRE and a growth test.^[2][3]
• Among 4,340 active U.S. banks with usable data, the average CRE-to-capital ratio was 293.1% and the median was 275.6%.
• On this combined measure, 2,000 banks were above 300%, 721 were above 500%, and 59 were above 800%.
• The highest ratio in the dataset was 1,284.8%, or about 12.85x capital.
• The top-25 median was 929.5%; all 25 banks were above 866.3%, 16 were above 900%, and 6 were above 1,000%.
• The top 25 includes 17 banks under $1 billion in assets and 8 above $1 billion; the median asset size is about $550 million.
• Michigan led this top-25 list with four banks, followed by Minnesota and Pennsylvania with three each.

The 25 U.S. Banks With the Highest Commercial Real Estate Exposure in 2026

The table below ranks active U.S. banks by combined CRE exposure relative to capital using Q4 2025 Call Report data as of 2025-12-31. Dollar figures are shown in approximate U.S. dollars and reflect Call Report convention, where source values are reported in thousands.

Short answer: First Bank of the Lake is the largest outlier at 1,284.8%, followed by Beach Cities Commercial Bank at 1,167.0% and Metropolitan Commercial Bank at 1,110.4%. The top 25 all sit above 866.3%, so the list should be read as a concentration screen: it identifies balance sheets where CRE exposure deserves immediate follow-up, not banks that are automatically distressed.

What This Ranking Shows

A few patterns stand out. First, the tail is steep. The median bank in the top 25 is Capital Bank at 929.5% CRE-to-capital, more than three times the full-dataset median of 275.6%. Six banks are above 1,000%, and 16 are above 900%.

Second, this is not only a small-bank story. Seventeen banks on the list are under $1 billion in assets, but eight are above $1 billion. Metropolitan Commercial Bank and Poppy Bank both show that high CRE concentration can appear in multi-billion-dollar institutions too.

Third, the list is geographically broad but not evenly distributed. Michigan has four banks in the top 25, while Minnesota and Pennsylvania have three each. California, Missouri, New York, and Texas each have two. That does not mean those states are uniformly riskier. It means individual balance-sheet strategy still matters more than geography alone.

Fourth, a high CRE-to-capital ratio is a screening signal, not a final verdict. Two banks can post similar ratios but have very different risk profiles depending on borrower quality, sponsor diversification, construction exposure, office concentration, funding mix, and unrealized securities pressure. That is why a list like this is most useful as a first pass rather than a standalone conclusion.

Why CRE Exposure Still Matters in 2026

Commercial real estate still matters in 2026 less because every CRE loan is weak and more because concentration is widespread. In this dataset, 2,000 of 4,340 active banks are above 300% on the combined measure, 721 are above 500%, and 59 are above 800%. The top-25 threshold alone is 866.3%, so this ranking is showing the far end of an already broad exposure distribution.

The asset-size split is also useful. The top 25 includes very small banks, midsize community banks, and large niche commercial banks. That matters because the same ratio can mean different work: at a small bank, loan-level borrower concentration may dominate; at a multi-billion-dollar bank, property type, funding profile, and geographic footprint often matter more.

Recent research has framed CRE distress as one channel through which tighter monetary policy can pressure bank balance sheets, but this article’s dataset adds the bank-level triage layer: which institutions have the largest CRE books relative to their capital cushion.^[4]

How To Use This List

1. Start with concentration, then break down the loan book

A high CRE-to-capital ratio should push you into the bank’s construction, multifamily, non-owner-occupied, and owner-occupied components. A bank with a construction-heavy CRE book is usually more cyclical than one dominated by stabilized multifamily or seasoned owner-occupied properties.

2. Compare banks against peers, not just the whole industry

A Texas community bank should not be benchmarked the same way as a New York niche commercial bank. Peer context matters. Build the comparison around asset size, geography, business model, loan mix, and funding profile before drawing conclusions.

3. Pair exposure with early-warning signals

CRE concentration becomes more meaningful when it shows up alongside funding stress, weak profitability, brokered deposit dependence, or rising problem assets. Concentration by itself is only one part of the risk picture.

4. Export and monitor your watchlist

If you are screening banks for investment, sales targeting, M&A research, or credit work, the goal is not to read one article and stop. The goal is to build a repeatable monitor that can track concentration, capital, asset quality, and funding pressure over time.

Screen the full market: For bank-by-bank work, Banking Intelligence lets you search institutions, inspect CRE mix in loan analysis, check early-warning signals, and export results for peer work or pipeline building.

Methodology

This ranking uses the local Banking Intelligence database built from U.S. bank Call Report detail and institution master records.^[1]

• Population: active U.S. banks only, using the institution master flag for active status.
• As-of date: 2025-12-31. No fresher Call Report date is implied in this article.
• Total CRE: combined construction and land development, multifamily, non-owner-occupied nonfarm nonresidential, and owner-occupied nonfarm nonresidential real estate lending; in the local database this is LNRENRES + LNRECONS + LNREMULT + LNRENROW.
• Capital: CBTOT when available, otherwise RBCT1J from call_report_detail.
• Ranking metric: total combined CRE divided by total capital.
• Supervisory threshold note: the OCC/Interagency 300% criterion is based on non-owner-occupied CRE as defined in guidance, plus a 50% three-year growth test; this table does not claim a bank meets or avoids that supervisory test.^[2][3]
• Table sorting: descending by CRE / capital ratio.
• Asset figures: financials.total_assets for the same report date when available, otherwise institution asset size as a fallback.
• Units: source values follow Call Report convention and are stored in thousands of U.S. dollars; display values above are rounded for readability.

This methodology is intentionally simple and transparent. It does not adjust for asset quality, collateral values, sponsor strength, hedging, or 36-month CRE growth. It is a concentration screen, not a loss forecast or a supervisory finding.

Owner-occupied vs. non-owner-occupied CRE: the distinction behind the OCC threshold

The OCC’s Interagency Guidance does not use the exact same combined ratio shown in this ranking. The 300% supervisory criterion is for total non-owner-occupied CRE, as defined in the guidance, and it is paired with a 50% growth test over the prior 36 months; construction and land development also has a separate 100% of capital criterion.^[2][3]

That distinction matters because this table combines owner-occupied and non-owner-occupied real estate loans. Owner-occupied loans are generally repaid from the borrower’s operating business, while non-owner-occupied loans depend more directly on rents, sale proceeds, refinancing, and property-market liquidity. The top bank’s combined ratio is 1,284.8%, but that number should not be read as its OCC-defined non-owner-occupied CRE ratio.

The cleaner way to use this article is to treat the combined ratio as the first screen, then break out non-owner-occupied CRE, construction exposure, multifamily exposure, asset quality, borrower concentration, and funding pressure before making a supervisory or credit-risk conclusion.

The most exposed U.S. banks on this combined measure are carrying CRE books that are many multiples of capital. As of 2025-12-31, the top names range from $71.4 million to $8.25 billion in assets, and the list does not fall neatly into one state, one size band, or one business model.

The practical takeaway is straightforward: start with concentration, then validate with deeper bank-level work. Combined CRE-to-capital is fast enough to rank the whole market, but it is not a final credit judgment.

FAQ

What is a high CRE-to-capital ratio for a bank?

In this article, high means high relative to other active banks using the combined CRE-to-capital screen. The population median was 275.6%, and every bank in the top 25 was above 866.3%. The OCC 300% reference is not a direct pass/fail benchmark for this table because it applies to non-owner-occupied CRE as defined in guidance and is paired with a growth test.^[2][3]

Why use total CRE divided by capital instead of CRE divided by assets?

CRE divided by assets shows balance-sheet mix. CRE divided by capital shows how large the exposure is relative to the bank’s loss-absorbing cushion. For stress screening, that second view is often more revealing.

Does a high ratio mean a bank is in trouble?

No. It means the bank deserves closer review. Underwriting quality, geographic footprint, borrower mix, funding structure, profitability, and nonperforming asset trends all matter.

Why is the article titled 2026 if the data date is 2025-12-31?

Because the article is a 2026 ranking based on the latest local U.S. Call Report snapshot currently available in the database, which is Q4 2025, dated 2025-12-31. Bank Call Report reporting is backward-looking by design.

How can I screen more than just the top 25?

Use the same combined CRE-to-capital screen across all covered banks, then filter by state, asset size, non-owner-occupied exposure, construction exposure, asset quality, capital, profitability, and funding signals.

Sources

1. FFIEC 031 and FFIEC 041 Call Report Instructions, updated December 2025 – Schedule RC-C real estate lending categories and owner-occupied/non-owner-occupied definitions. URL: https://www.ffiec.gov/sites/default/files/data/reporting-forms/FFIEC031_FFIEC041_202512_i.pdf
2. OCC, Commercial Real Estate Lending, Comptroller’s Handbook, Version 2.0 – supervisory CRE concentration criteria and owner-occupied treatment. URL: https://www.occ.gov/publications-and-resources/publications/comptrollers-handbook/files/commercial-real-estate-lending/pub-ch-commercial-real-estate.pdf
3. OCC Bulletin 2006-46, Interagency Guidance on CRE Concentration Risk Management – original interagency concentration guidance. URL: https://www.occ.gov/news-issuances/bulletins/2006/bulletin-2006-46.html
4. NBER, Monetary Tightening, Commercial Real Estate Distress, and U.S. Bank Fragility – research background on CRE distress and bank balance-sheet fragility. URL: https://www.nber.org/papers/w31970

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