# FDIC FIL-4-2006: Commercial Real Estate Lending Proposed Interagency Guidance

> Federal · Agency guidance · Superseded

URL: https://www.frixlaw.com/law-library/statutes/FDIC_FIL06004

## Section

- **Citation:** FDIC FIL-4-2006
- **Heading:** Commercial Real Estate Lending Proposed Interagency Guidance
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** Superseded
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** FDIC Financial Institution Letters / Commercial Real Estate Lending Proposed Interagency Guidance

## Text

Financial Institution Letter
FIL-4-2006
January 13, 2006

COMMERCIAL REAL ESTATE LENDING
Proposed Interagency Guidance
Federal Deposit Insurance Corporation
550 17th Street NW, Washington, D.C. 20429-9990

Summary: The federal bank and thrift regulatory agencies are seeking comment on the
attached proposed interagency guidance relating to sound risk-management practices for
concentrations in commercial real estate (CRE) lending. Comments are due by March 14, 2006.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
Chief Lending Officer
Compliance Officer

Related Topics:
Real Estate Lending Standards
Publishing Requirements

Attachment:
Proposed Interagency Guidance
Contacts:
James Leitner, Senior Examination Specialist,
Division of Supervision and Consumer Protection,
on (202) 898-6790 or Benjamin W. McDonough,
Attorney, Legal Division, on (202) 898-7411

Note:
FDIC financial institution letters (FILs) may be
accessed from the FDIC's Web site at
www.fdic.gov/news/news/financial/2006/index.html.

To receive FILs electronically, please visit
http://www.fdic.gov/about/subscriptions/fil.html.

Paper copies of FDIC financial institution letters
may be obtained through the FDIC's Public
Information Center (1-877-275-3342 or 202-416-
6940).

Highlights:

•
The Federal Deposit Insurance Corporation
(FDIC), the Office of the Comptroller of the
Currency, the Board of Governors of the Federal
Reserve System, and the Office of Thrift
Supervision have proposed the attached
guidance addressing sound risk-management
practices for concentrations in CRE lending.

•
Concentrations of CRE loans may expose
institutions to unanticipated earnings and capital
volatility in the event of adverse changes in the
general commercial real estate market
ncy, the Board of Governors of the Federal
Reserve System, and the Office of Thrift
Supervision have proposed the attached
guidance addressing sound risk-management
practices for concentrations in CRE lending.

•
Concentrations of CRE loans may expose
institutions to unanticipated earnings and capital
volatility in the event of adverse changes in the
general commercial real estate market.

•
The proposed guidance reinforces existing
guidelines for real estate lending and provides
criteria for identifying institutions with CRE loan
concentrations that may warrant greater
supervisory scrutiny. Such institutions should
have robust risk-management systems in place
and capital levels higher than the regulatory
minimums and appropriate to the risk associated
with these concentrations.

•
The FDIC encourages institutions to review the
attached Federal Register notice and to comment
on the scope of the definition of CRE and on the
appropriateness of the thresholds for determining
elevated concentration risk.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FDIC_FIL06004. Check the current official text before relying on it. Not legal advice.
