Monday, the FDIC issued a new FIL directive targeting institutions with high concentrations in Commercial Real Estate (CRE). Their guidance outlines specific criteria triggering heightened regulatory monitoring, signaling increased scrutiny during the next examination, or possibly sooner. These criteria include the current 100/300 rule and cases where the outstanding balance of the CRE loan portfolio has surged by 50 percent or more in the preceding 36 months. Given the aggressive approach in exams to this point, this is an early warning of even more examination focus and direction in risk, liquidity, credit admin, reserve and capital adequacy. The announcement also unequivocally attributes past asset quality issues and bank failures to CRE lending concentrations coupled with inadequate risk management practices. In previous crises, "a lack of effective management in CRE lending concentrations led to elevated credit losses". Additionally, failed banks relied on funding sources beyond stable deposits and maintained lower levels of capital.
Our view is that banks are on relatively solid footing regarding LTV's. The customary LTV's were 100%+ during the 80's leading up to 1986, and 75-85% LTV's leading up to the Liquidity Crisis of 2008. Post-crisis, LTV's were 60-70%, and in some cases as the cycle got longer, banks pulled back to very conservative 50-60 LTV's. The Fed action of 400+ bps in rate increases has surprised even the savviest bank economists due to the pandemic black swan event of 2020 and the governments' inflationary spending and lockdowns. The spending and supply-chain disruptions along with lockdowns caused much of the inflationary pressure, while the lockdowns produced/helped propel the work-from-home phenomenon and the occupancy deterioration of the office sector. The increase in short-term rates, declines in occupancy and thus revenue, have crushed the DSCR's of otherwise prudent CRE loans. The climb out of some of this distress will be challenging in many cases and flat-out impossible in some cases. Identifying and categorized these loans and the underlying collateral is a critical exercise leading into 2024, with the assistance of a strong advisory team.
FDIC announcement reminds institutions of the critical importance of credit risk, stress testing, liquidity and robust credit management practices. These management practices, in addition to workout preparedness, loan file management, and proactive credit evaluations, should be a top priority at banks with high CRE exposure. As we've seen in the past with bank failures and/or CRE loan workouts/sales, the loan files are often incomplete; the relationship managers haven't enforced timely borrower and property financials, rent rolls, tax returns, and borrower liquidity or even properly monitored these even in good times. When CRE loan portfolio risk increases, as in the present cycle, banks and their portfolio teams and advisors can get ahead of the game by becoming intimately involved in daily performance of the collateral with the intent of reducing exposure and preventing unforeseen deterioration in collateral positions. The FDIC's comment in their announcement is spot on, 'In these crises, when CRE markets deteriorated, poor management of CRE lending concentrations led to increased credit losses.' In cycles like the present there is often an overreaction to construction loan exposure, when the reality, in the case of apartments specifically, is they will always stabilize, it's just a matter of time. It will be less about the market and more about where interest rates are in 12-18 months. When unemployment ticks up, or disruption spreads, our bank clients should be vigilant with their portfolio management and capital and avoid the panic.
Our firm has the skills and capacity to help institutions face these challenges. We have deep expertise in Commercial Real Estate and Banking, and can help with strategy, risk management, liquidity management and workouts. Given the breadth of our activity in the industry, we understand what is needed by the regulators now, and in the future, as the environment evolves.
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