Commercial Real Estate Lending

Commercial real estate (CRE) lending includes acquisition, development, and construction (ADC) financing and the financing of income-producing real estate. Income-producing real estate includes real estate held for lease to third parties and nonresidential real estate that is occupied by its owner or a related party.

• Credit
• Commercial & Industrial Lending
• Consumer Lending
• Commercial Real Estate Lending
• Residential Real Estate
• Agricultural Lending
• Specialty Credit Risks

Laws and Regulations

Key laws and regulations that pertain to FDIC-supervised institutions; note that other laws and regulations also may apply.

• Appendix A to Part 364 — Interagency Guidelines Establishing Standards for Safety and Soundness provides operational and managerial standards for safety and soundness to include asset quality and asset growth
• Part 365 — Real Estate Lending Standards provides standards for real estate lending and addresses the adoption and maintenance of written policies for extensions of credit that are secured by real estate, or that are made for the purpose of financing permanent improvements to real estate
• Part 323 — Appraisals discusses requirements for a written appraisal for certain real estate-related transactions
• Section 337.2 — Standby Letters of Credit discusses the calculation of legal lending limitations, including loans to any one borrower, loans to affiliates of the bank, or aggregate loans
• Section 337.3 and Federal Reserve Board Regulation O address extensions of credit from an institution to its executive officers, directors, and principal shareholders
• Part 347 — International Banking discusses requirements for institutions to engage in foreign financial activities
• Federal Reserve Board Regulation W restricts certain transactions between banks and their affiliates

Supervisory Resources

Frequently asked questions, advisories, statements of policy, and other information issued by the FDIC alone, or on an interagency basis, provided to promote safe-and-sound operations.

• Risk Management Manual of Examination Policies
  • Section 3.1 — Asset Quality describes areas of consideration for assigning the asset quality rating and defines each rating
  • Section 3.2 — Loans describes the review process for evaluating lending policies and credit administration practices, as well as their effectiveness to maintain loan quality and minimize loss
  • Section 3.8 — Off-balance Sheet Activities describes the review process for items such as loan commitments, letters of credit, and revolving facilities
  • Interagency Statement on Meeting the Needs of Creditworthy Borrowers provides a supervisory perspective on providing credit to businesses, consumers, and other creditworthy borrowers
  • Guidance Addressing Certain Issues Related to Troubled Debt Restructurings provides insight into the accounting treatment and regulatory credit risk grade or classification of commercial and residential real estate loans that have undergone troubled debt restructurings
  • Interagency Policy Statement on Documentation for Loans to Small- and Medium-Sized Businesses and Farms outlines steps taken to correct potential misunderstanding of regulatory requirements for lending to creditworthy small- and medium-sized businesses and farms

  Other Resources

  Supplemental information related to safe-and-sound banking operations.

  • FDIC's Supervisory Insights — Summer 2022 article "Commercial Real Estate: An Update on Bank Lending Amid the Evolving Pandemic Backdrop"
    
  • FDIC's Supervisory Insights — Fall 2019 article, “Commercial Real Estate Loan Concentration Risk Management”
  • FDIC's Supervisory Insights — Winter 2011 article, “Navigating the Real Estate Valuation Process”

  Last Updated: August 3, 2024