I have calculated the total CRE exposure (CRE nonfarm-nonresidential and multifamily mortgages, CRE construction loans, CRE loans not secured by real estate, and unused CRE commitments) as a percentage of total equity to serve as a broad measure of bank exposure to commercial real estate. A variation of this ratio is used by banking regulators to assess CRE exposures; any ratio over 300% is viewed as excessive exposure to CRE. Data are as of Sep. 30, 2025 (Q3).

Below is a list of the total CRE exposure of the 52 banks with greater than $10B in assets where their exposure exceeds 300% of total equity capital. (52 out of 154 large banks, out of 4,435 banks of any size.) Twenty have exposures greater than 400% and four have exposures greater than 500%.

Most prominent (by asset size) are #6 Flagstar Bank, #25 Valley National Bank, #26 Zion Bancorp, #29 Synovus Bank, #33 Columbia Bank (formerly Umpqua Bank), #44 Comerica Bank, #48 East West Bank, and #49 Old National Bank--each of which has more than $50B in total assets.

Flagstar has $92B in assets, $7.9B in CRE mortgages, $30.7B multifamily, $1.6B in CRE construction loans, and $0.7B in unused CRE commitments, for a total CRE exposure of $41.4B, but has only $8.6B in total equity. Total CRE exposure is 481%of total equity (down from 499% of total equity as of Q2).

Zion has $89B in assets, $16.6B in CRE mortgages, $3.0B in multifamily, $2.2B in CRE construction loans, and $3.5B in unused CRE commitments, for a total CRE exposure of $25.8B, but has only $6.9B in total equity. Total CRE exposure is 376% of total equity. Down from 389% in Q2.

East West Bank has $79B in assets, $15.8B in CRE mortgages, $4.4B multifamily, $0.7B in CRE construction loans, and $1.6B in unused CRE commitments, for a total CRE exposure of $21.2B, but has only $6.6B in total equity. Total CRE exposure is 308% of total equity. Down from 317% in Q2.

Comerica has $77B in assets, $11.6B in CRE mortgages, $3.2B multifamily, $2.9B in CRE construction loans, and $3.4B in unused CRE commitments, for a total CRE exposure of $21.2B, but has only $6.6B in total equity. Total CRE exposure is 309% of total equity. Down from 312% in Q2.

Old National Bank has $71B in assets, $13.7B in CRE mortgages, $5.9B in multifamily, $2.6B in CRE construction loans, and $2.4B in unused CRE commitments, for a total CRE exposure of $24.6B, but has only $8.1B in total equity. Total CRE exposure is 318% of total equity. Up from 312% in Q2.

Columbia Bank (formerly Umpqua) has $67B in assets, $14.9B in CRE mortgages, $10.6B in multifamily, $2.2B in CRE construction loans, and $1.0B in unused CRE commitments, for a total CRE exposure of $30.4B, but has only $8.1B in total equity. Total CRE exposure is 358% of total equity. Down from 359% in Q2.

Valley NB has $63B in assets, $17.8B in CRE mortgages, $8.4B in multifamily, $2.2B in CRE construction loans, and $1.5B in unused CRE commitments, for a total CRE exposure of $29.9B, but has only $8.1B in total equity. Total CRE exposure is 377% of total equity. Up from 373% in Q2.