Commercial Real Estate Lending Headwinds, the 2024 Regulatory Focus on Credit Risk and Liquidity, and What Small- and Medium-size Banks Need to Know.



Commercial Real Estate Loan Portfolios are under increasing pressure. The troubled commercial real estate market is facing a record volume of maturing loans, significantly increasing prospects for a surge in defaults as property owners are forced to refinance at higher rates. Heightened regulatory focus on credit risk and liquidity signal the need for preemptive strategies. Here we present a viable solution for lenders.

Key Takeaways
1. Bank CRE loans totaled $2.972 trillion in January 2024.
2. According to research from Apollo, small banks account for nearly 70% of all CRE loans outstanding.
3. Nearly 1,900 banks with assets less than $100 billion have CRE loans outstanding greater than 300% of total capital. That level of 300% may indicate a lender is exposed to significant risk of CRE concentration, according to the FDIC.
4. CRE loan delinquency rates are increasing monthly and there are substantial CRE loans maturing in the next two to three years.
5. The CRE sector is likely to face a significant challenge as loans mature at higher rates, increasing the difficulty of refinancing and adversely impacting debt service coverage.
6. CRE lenders and portfolio managers need to engage third party professional guidance in order to navigate the headwinds of a potentially stormy horizon.
7. Small- to medium-size banks are the most vulnerable, and the Federal Reserve is willing to allow weak banks to fail.

What brought us to this point?
The pressure on CRE has been created by a convergence of factors, including a sharp increase in interest rates, rising costs and reduced operating margins, income pressure, tighter financing needs and a wall of debt maturing over the next 18 months…The imminent refinancing needs of CRE owners are another source of stress in the sector, with nearly $1.1 trillion worth of commercial mortgage loans expected to mature before the end of 2024, according to Goldman Sachs Global Investment Research. Given the balloon maturities common in commercial mortgages, many borrowers will have to refinance their existing loans at higher rates.

The Fed has hiked interest rates 11 times since January 2022 to curb inflation, making CRE credit tighter. The collapse of Silicon Valley Bank, Signature Bank and First Republic Bank in March 2023 worsened the crisis. Lenders’ caution is reflected in stringent credit policies, with loans originated only to those borrowers who have demonstrated strong creditworthiness.

There are substantial CRE loans maturing in the next two to three years. The CRE sector is likely to face a significant challenge, as, based on current market conditions, low-interest loans mature at higher rates, increasing the difficulty in refinancing. Increasing defaults at maturity would affect the weaker CRE assets, depending on asset quality, type and location.

Where are we now?

Small- and Medium-size Banks: CRE holdings as a proportion of total risk-based capital above 300% may indicate a lender is exposed to significant risk of CRE concentration, according to public guidelines from the Federal Deposit Insurance Corporation (FDIC). In total, nearly 1,900 banks with assets less than $100 billion had CRE loans outstanding greater than 300% of equity, according to Fitch.

Fitch, in a detailed report in December, also said if prices decline by approximately 40% on average, losses in CRE portfolios could result in the failure of a moderate number of predominately smaller banks.

According to S&P Global, “Regulators have reiterated the importance of banks maintaining strong risk management of their CRE portfolios, particularly for institutions with elevated CRE concentrations. The FDIC has also said that it is increasing examination staff in anticipation of more "problem banks" and plans to subject institutions to tougher exams.

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