Who Holds Commercial Real Estate Risk? Small Banks vs. Large Banks
The share of total assets that U.S. commercial banks hold in commercial real estate loans, comparing the 25 largest domestically chartered banks with all smaller ones, from the Federal Reserve Board's H.8 release. Commercial real estate here covers construction, multifamily, farmland and nonfarm nonresidential loans; H.8 does not report office loans separately.
What does it show?
Commercial real estate loans were 30.5% of small banks' assets in September 2026, against 6.0% at the 25 largest banks; the gap has widened from 21.4 points before the pandemic, mainly because large banks' share fell.
Methodology
Each line divides commercial real estate loans by total assets for one group of U.S. domestically chartered commercial banks, using the Federal Reserve Board's H.8 monthly average levels, seasonally adjusted (series B3219NSMAM / B1151NSMAM for small banks, B3219NLGAM / B1151NLGAM for large banks). Large banks are the 25 largest domestically chartered commercial banks by domestic assets; small banks are all others. The Fed adjusts past levels for banks moving between the two groups, but not for nonbank structure activity: in the week ending December 7, 2022 a thrift's conversion to a commercial bank, with nonbank acquisitions that week, added $88.3 billion of assets, $47.8 billion of them commercial real estate loans, to the small-bank totals (marked), lifting the small-bank share by about 0.4 points. From February 2020 to September 2026 large banks' commercial real estate loans were roughly flat at about $910 billion while their total assets grew by more than a third, so most of the widening gap reflects large banks' growing balance sheets; the small-bank share itself rose by less than a point. Commercial real estate here covers construction and land development, multifamily, farmland and nonfarm nonresidential loans; H.8 does not separate office loans, and the series exclude thrifts, credit unions and nonbank lenders. The 2020-21 dip in both lines is mostly a larger denominator, as deposits swelled bank balance sheets. H.8 data are estimates from a weekly sample benchmarked to quarterly Call Reports and are revised; release prepared 2026-10-30.
Sources
- Federal Reserve Board H.8: Assets and Liabilities of Commercial Banks in the United States ↗
- H.8 full-history data package (XML): series B3219NSMAM, B1151NSMAM, B3219NLGAM, B1151NLGAM ↗
- About the H.8: large and small bank definitions ↗
- H.8 Notes on the Data: structure changes, including the December 2022 thrift conversion ↗