CRE Risk Overload: Why 2026 Will Be a Reckoning for Mid-Sized Banks

September 12, 2025

Mid-sized banks are carrying CRE risk that regulators can’t ignore.

With CRE exposures exceeding 300% of equity, many banks are now in the spotlight.

A few key pressures we are noticing:

  • Office values still 20–30% below pre-2020
  • Borrower costs outpacing rents, squeezing DSCR
  • $1.5T in CRE maturities due by 2026
  • Insurance costs doubling in high-risk regions

Regulators have made it clear: banks above 300% will face tougher scrutiny in 2026.

But here’s the catch — not all CRE is equal. Sunbelt multifamily isn’t West Coast office. Midwest industrial isn’t Northeast retail.

That’s why ONCI goes beyond national averages. Our metro-level, property type specific models give banks forward-looking, local insights — showing where stress is real, where it’s manageable, and where examiners will focus.

The banks that re-underwrite early will control the narrative. The ones that wait will be forced to react.

Where is CRE stress building in your book?