Every commercial real estate (CRE) loan rests on a few guesses: the rent a building will collect, how many units will sit empty, what it costs to run, and the cap rate that turns its income into a value. A bank has made each of those guesses before, on similar buildings, and its files record how every one of those loans turned out. Loan comps are that record put to use: the bank's own past loans, read for what it assumed and whether the assumption held up.
This guide is for anyone who underwrites, approves, reviews or pays for commercial real estate loans: CRE credit analysts and underwriters, credit officers and chief credit officers, review appraisers, relationship managers, loan review and credit administration, and the leaders deciding whether to automate the research. No background needed.
Imagine you are a CRE credit analyst at a regional bank in Charlotte, North Carolina. It is October 12, 2026, and credit committee meets on Thursday, October 15. On your desk is Sycamore Yard Apartments, 228 units built in 2021 in Huntersville, being bought for $58.9 million. The buyer wants a $33.5 million loan, five years fixed at 5.95%. The broker's offering memorandum, page 22, underwrites the building at a 5.15% cap rate with 4% vacancy and no reserve for replacements. On those numbers the loan covers its payments 1.27 times, just above your bank's 1.25x minimum.
Your bank has lent on nine garden apartment buildings like this one around Charlotte since 2023. You open their approved credit memos and compare.
Broker's pro forma, p. 22
Cap rate
5.15%
Vacancy
4.0%
Reserves
$0 a unit
Value
$58.9M
The bank's nine closed loans
Cap rate
5.40–6.10%, median 5.75%
Vacancy
median 6.0%
Reserves
$250 a unit
Value
$47.6M
$33.5M requested$30.6M supported at 1.25xon the bank's own numbers; the request fails two policy tests.
The broker's cap rate is below all nine. Only one of the nine was underwritten at 4% vacancy: Juniper Trace in Matthews. After 612 new units opened within a mile, it is 86.4% occupied, its income is 17% below plan and it sits on the watch list.
On the bank's medians the building is worth $47.6 million, and the request fails two of your bank's tests. It covers its payments 1.14 times against the 1.25x minimum, and its debt yield, a year's income as a share of the loan, is 8.2% against an 8.5% minimum. The loan that passes both is $30.6 million.
What the bank's own loans caught: a cap rate lower than any the bank has accepted, a vacancy guess that has already failed once, and a request $2.9 million larger than the building's income supports.
What CRE loan comps are, and why a lender's own loans are the evidence that counts
The five assumptions behind every income-property loan, how a loan is sized, what the rules ask, how appraisals and exceptions fit in, where precedent research goes wrong and what the 2026 market looks like. If you are new to commercial real estate credit, start here.
01 · In plain words
One apartment loan shows what loan comps are for
When a bank lends against an apartment building, an office or a warehouse, it is betting on the building's income. The loan will be repaid from the rent the tenants pay, after the owner pays taxes, insurance, staff and repairs. So before the bank lends, an analyst writes down a forecast of that income.
Five guesses carry almost all the weight: the rent a unit or a square foot will fetch, the share of space that will sit empty or unpaid (vacancy), what the building costs to run (operating expenses), a yearly allowance for roofs and boilers that wear out (replacement reserves), and the capitalization rate, or cap rate, that turns one year's net income into a value.
Those guesses decide the loan. Net operating income (NOI) divided by the yearly loan payments gives the debt service coverage ratio (DSCR); the loan divided by the value gives the loan to value (LTV). Move the vacancy two points or the cap rate half a point, and a loan that fitted the bank's policy no longer does. The borrower's broker has every reason to choose generous guesses. The appraiser estimates what the building would sell for today, from recent sales. Neither of them tells the bank what it has itself been willing to assume, or how those assumptions worked out.
The bank already knows. Every loan it has made on a similar building has an approved credit memo that records the rent, vacancy, expenses, reserves and cap rate it underwrote, an appraisal and a review of that appraisal, and years of operating statements in servicing that show what the building actually earned. Put side by side, those files are the bank's loan comps: comparable loans of its own, each with its assumptions and its outcome.
The trouble is that they sit in separate PDFs and systems, and nobody can search them, so analysts start from the broker's numbers and two loans a mile apart end up underwritten on different assumptions.
This guide is about turning that memory into evidence: finding the bank's comparable loans, reading what it assumed, joining how each loan has done since, and using the result to set the assumptions on the next loan, with a record that a credit officer, a review appraiser and an examiner can follow.
Sycamore Yard's $33.5 million request, from package to servicing
The borrower and broker send a packageOffering memorandum, rent roll, trailing operating statements, purchase contract. For Sycamore Yard: a $33.5 million request on a $58.9 million purchase.
The bank orders an appraisal and reviews itAn independent appraiser values the building; the bank's review appraiser checks the work. Here: $59.4 million at a 5.10% cap.
The analyst sets the assumptions and sizes the loanRent, vacancy, expenses, reserves and cap rate, tested against credit policy. This is where the bank's own comparable loans are read, or skipped.
A credit officer reviews and committee decidesThe memo explains every assumption; exceptions to policy need a written justification and the right approver.
Servicing records how the loan turns outOccupancy, expenses and coverage arrive every year. They are the outcome the next analyst needs, and they rarely get back to the memo.
Step 3 is the subject of this guide. The bank, buildings, people and figures in the example are fictional.
Four surprises about CRE underwriting assumptions and appraisals
Regulators set ceilings, and leave the assumptions to the bank
The federal guidelines cap loan to value at 85% of an improved property's value and tell each bank to set its own limits, including a minimum debt service coverage. They set no coverage number, no vacancy floor and no cap rate.1
Appraisals miss sale prices by about a tenth
Across 7,133 institutional properties sold between 1997 and early 2021, appraised values differed from the later sale price by 11.1% on average, and the gap has not narrowed.2
Optimism runs by lender, and it predicts trouble
In 39,522 loans securitized from 2013 to 2019, 29% overstated the property's income by 5% or more, and the lenders who overstated most saw the most distress later.3,4
Examiners count exceptions, and expect them aged
The OCC tells examiners to read a rising number of policy exceptions as a sign of relaxed underwriting, and expects banks to age them by volume, loan officer and type.5
Loan comps, cap rate, DSCR and policy exception
Loan comps
The bank's own closed loans on similar buildings, with the assumptions it underwrote and how each loan has performed since.
Cap rate
Net operating income divided by value. A lower cap rate means a higher value for the same income.
DSCR
Debt service coverage: NOI divided by a year of loan payments. 1.25x means $1.25 of income for each $1.00 due.
Policy exception
A loan approved outside one of the bank's own standards, with a written reason and a named approver.
Sales comps, lease comps and loan comps: three kinds of evidence a CRE lender can use
In shortSales comps show what similar buildings sold for. Lease comps show what similar space rents for. Loan comps show what the lender itself assumed when it lent on similar buildings, and whether those assumptions held up. Only the third pairs an assumption with an outcome, and only the lender holds it.
"Comps" is short for comparables, and in commercial real estate it usually means market evidence. An appraiser picks recent sales of similar buildings, adjusts them for differences and concludes on a value. A leasing analyst does the same with signed leases to support the rent line. Both are evidence about the market on a given day. The OCC's handbook expects a lender's analysis of a property's income to consider "Comparable rental rates, operating expenses, and sales prices", and says that "Inadequately supported or questionable analysis should be challenged."5
A lender has a third set of comparables that no data vendor sells: its own loans. For each one it knows the rent, vacancy, expenses, reserves and cap rate it accepted, the exceptions it granted and why, and what the building has done since. The credit analyst's official job description already assumes this comparison. O*NET's profile of the occupation lists the task "Compare liquidity, profitability, and credit histories of establishments being evaluated with those of similar establishments in the same industries and geographic locations."6
A bank's loans are also a different population from the market's. Federal Reserve economists found that banks, life insurers and securitization lenders "differ in how they are funded and regulated, and therefore specialize in loans with different characteristics."7 Comparables drawn from the whole market, or from securitized loans, describe somebody else's book.
Only the lender's own loans pair an assumption with what happened next
What each kind of evidence can tell a CRE underwriter
NoPartlyYes
Price or valueRent levelAssumed vacancy and expensesOutcome after closingPage you can citeSales compsYesNoNoNoPartlyLease compsNoYesNoNoPartlyThe appraisalYesYesPartlyNoYesBroker's pro formaYesYesYesNoYesThe bank's own loan compsPartlyYesYesYesYes
Our reading of the sources5,7,8 · An appraisal states the appraiser's own vacancy and expense conclusions; a pro forma states the broker's. Neither says how a similar loan performed.
Show the numbers
Price or value
Rent level
Assumed vacancy and expenses
Outcome after closing
Page you can cite
Sales comps
Yes
No
No
No
Partly
Lease comps
No
Yes
No
No
Partly
The appraisal
Yes
Yes
Partly
No
Yes
Broker's pro forma
Yes
Yes
Yes
No
Yes
The bank's own loan comps
Partly
Yes
Yes
Yes
Yes
When each kind of evidence should lead
Value
Sales comps and the appraisal
What a buyer would pay today. The bank's appraisal regulations and the 2010 interagency guidelines make the appraisal the bank's evidence of value, prepared independently of the people making the loan.8
Rent
Lease comps and the rent roll
What tenants pay for similar space, and what this building collects now. The OCC asks lenders to compare actual lease rates with the pro forma and the appraisal during lease-up.5
Assumptions
The bank's own loan comps
What the bank has accepted for vacancy, expenses, reserves and cap rate on similar buildings, and whether those loans held up. Where the bank has few or none, the honest answer is a count, and market evidence leads.
Independence still applies. The interagency guidelines say "an institution's collateral valuation function should be independent of the loan production process."8 Loan comps inform the bank's own underwriting and its review of an appraisal. They are never sent to an appraiser as the number to hit.
03 · The rules and their dates
The rules behind CRE underwriting assumptions and exception reports, as of October 2026
Status as of October 2026
In shortNo rule tells a bank what cap rate or vacancy to use. The rules require a written, board-approved real estate lending policy with clear and measurable standards, supervisory ceilings on loan to value, monitoring of the local market, documented exceptions, and reports that examiners review. Two texts changed in 2026: the model risk guidance in April and the OCC's lending booklet in July.
The core CRE rules are decades old; the 2026 changes sit around them
Dec 1992Interagency real estate lending guidelines
Written policy, supervisory LTV limits, exception reporting to the board (12 CFR 34 subpart D).
Dec 2006CRE concentration guidance
Underwriting, market analysis, MIS and stress testing for concentrated banks; no lending cap.
Dec 2010Appraisal and evaluation guidelines
Valuation independent of loan production; review function.
Mar 2022OCC CRE booklet, Version 2.0
Exceptions aged and stratified; NOI, cap rate and debt yield explained.
Jun–Dec 2023Third-party, workout and concentration letters
Responsibility stays with the bank; workouts; MIS on concentrations.
Apr 17, 2026Model risk guidance replaced
SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026 replace SR 11-7; generative AI and AI that acts on its own fall outside its scope.
Jul 2026OCC lending booklet, Version 1.0
Issued June 25, 2026 and dated July; replaces the 1998 Loan Portfolio Management booklet. Inner targets, exception volume, postmortems.
12 CFR 34 subpart D and Appendix A (same rule at the Fed and FDIC)
A policy "reviewed and approved by the bank's board of directors at least annually", with "Prudent underwriting standards, including loan-to-value limits, that are clear and measurable"; monitor "conditions in the real estate market in its lending area"; consider "Current and projected vacancy, construction, and absorption rates" and "Valuation trends, including discount and direct capitalization rates".1
Current
Exceptions under the same guidelines
Each exception "should be supported by a written justification that clearly sets forth all of the relevant credit factors"; significant ones reported to the board; "Lending policy exception reports will also be reviewed by examiners".1
Current
OCC Commercial Real Estate Lending booklet
Exception reports read for "frequency and nature"; "aging of all exceptions with sufficient stratification to identify trends in volumes, loan officer, and types"; cap rates under "normal, orderly, and sustainable market conditions".5
Version 2.0, March 2022 (reputation-risk references struck March 20, 2025); current
OCC Lending and Loan Portfolio Risk Management
"Policies often include outer limits, with procedures or guidelines including more granular instructions or inner targets"; "the absence of exceptions can indicate that the policy is too liberal or vague"; postmortems on problem loans.15
Version 1.0, dated July 2026; issued June 25, 2026 (Bulletin 2026-29)16
CRE concentration guidance
For concentrated banks: "underwriting, risk assessment and monitoring of CRE loans, portfolio risk management, management information systems, market analysis, and stress testing"; "does not establish a limit".9
December 2006, current
Appraisal and evaluation guidelines
Valuation independent of loan production; a review function with the right depth and qualifications.8
December 2010, current
SR 26-2 / OCC Bulletin 2026-13 / FDIC FIL-15-2026
Model risk guidance; spreadsheet arithmetic and deterministic rules excluded from the model definition; generative AI and AI that acts on its own outside its scope.13,18,14
April 17, 2026
Third-party guidance
"A banking organization's use of third parties does not diminish its responsibility" for the activity.10
June 9, 2023, current
The supervisory loan-to-value ceilings, and a bank's own limit inside them
A bank's own multifamily limit sits well inside the 85% federal ceiling
Maximum loan to value, percent of value
Raw landsupervisory limit65%
Land developmentsupervisory limit75%
Commercial and multifamily constructionsupervisory limit80%
Improved propertysupervisory limit85%
Example bank's multifamily policyfictional example, of the lesser of price and value75%
Source1 · The last bar is the fictional example bank's own policy, shown for comparison.
Show the numbers
Category
Maximum LTV
Raw land
65%
Land development
75%
Commercial and multifamily construction
80%
Improved property
85%
Example bank's multifamily policy
75%
The guidelines say "Institutions should establish their own internal loan-to-value limits for real estate loans", that the supervisory figures "should not be interpreted to mean that loans at these levels will automatically be considered sound", and that a riskier subcategory deserves a lower internal limit.1 For a purchase, value means "the lesser of the actual acquisition cost or the estimate of value."1 Loans above the supervisory limits are capped in total at 100% of capital, and 30% for commercial and multifamily property.1
What did not change in 2026. We searched for 2026 changes to the 2006 concentration guidance, the supervisory LTV limits and the $500,000 commercial appraisal threshold set in 2018 (the 2010 appraisal guidelines still print the older $250,000),19 and found none as of October 30, 2026. The 2026 changes that touch this work are the model risk guidance and the OCC's new lending booklet.13,15
04 · Five assumptions
Rent, vacancy, expenses, reserves and cap rate: how five guesses become a value
In shortNet operating income is the rent the building can collect, less vacancy, plus other income, less operating expenses and reserves. Divide it by a cap rate and you have a value. The same building gives three values in the example below, $47.6 million to $59.4 million, because three parties chose different guesses.
NOI = units × rent × 12 × (1 − vacancy) + other income − operating expenses − replacement reserves · Value = NOI ÷ cap rate
The OCC defines each piece. NOI analysis "may assume market vacancy rates that are above or below actual vacancy rates, and expenses that may not represent an actual or immediate cash expense, such as management fees and reserves for capital replacements". "An important objective of the underwriting process is to develop an NOI that represents a stabilized estimate of income and expenses."5
Fannie Mae's multifamily guide, updated October 26, 2026, sets two floors a bank can borrow for its own policy: vacancy, concessions and bad debt together of at least "5% of GPR" (gross potential rent), and a replacement reserve of at least $200 a unit that "must be included whether the escrow is funded or not".20
One building, three sets of guesses
Line, 228 units
Broker's pro forma
Appraisal
Bank's nine loans (medians)
Rent a unit a month
$1,585
$1,580
$1,561 (in place)
Vacancy and credit loss
4.0%
5.0%
6.0%
Other income
$285,000
$285,000
$285,000
Operating expenses a unit
$6,200
$5,725
$6,600
Reserves a unit
$0
$250
$250
Net operating income
$3,034,498
$3,029,436
$2,737,842
Cap rate
5.15%
5.10%
5.75%
Value
$58.9M
$59.4M
$47.6M
Fictional example. The analyst chose $6,600 of expenses, above the nine-loan median of $6,350, because the three loans closed since March 2025 average $6,617 after insurance renewals.
The same building is worth $11.8 million less on the bank's own numbers than on the appraisal
Sycamore Yard Apartments, value under three sets of assumptions
Broker: 5.15% cap, 4% vacancy, no reservesNOI $3,034,498$58.9M
Bank's nine loans: 5.75% cap, 6% vacancyNOI $2,737,842$47.6M
Fictional example from this guide
Show the numbers
Assumptions
Value
Appraisal: 5.10% cap, 5% vacancy
$59.4M
Broker: 5.15% cap, 4% vacancy, no reserves
$58.9M
Bank's nine loans: 5.75% cap, 6% vacancy
$47.6M
Where the $296,656 of NOI went
The broker's NOI is $296,656 a year higher than the bank's. Two points of vacancy are worth about $85,000; $400 a unit of expenses about $91,000; the missing reserve $57,000; the rest is rent. Capitalized at 5.75%, the reserve alone is worth about $990,000 of value, all of it missing from a pro forma that leaves the line blank.
Higher expenses and vacancy explain three-fifths of the broker's extra $296,656 of NOI
Sycamore Yard, how much higher the broker's yearly NOI is than the bank's, by line
Operating expenses: $6,200 against $6,600 a unit$91.2K
Vacancy: 4% against 6%$85.4K
Rent: $1,585 against $1,561 a unit a month$63K
Reserves: $0 against $250 a unit$57K
Fictional example from this guide · Vacancy is valued at the bank's rent; the rent line is the rent difference after the broker's 4% vacancy. The four add to $296,655, $1 short of the gap from rounding.
Show the numbers
Line
Broker's NOI higher by
Operating expenses: $6,200 against $6,600 a unit
$91.2K
Vacancy: 4% against 6%
$85.4K
Rent: $1,585 against $1,561 a unit a month
$63K
Reserves: $0 against $250 a unit
$57K
Half a point of cap rate is worth millions
Moving from the broker's cap rate to the top of the bank's range takes $8.3 million off the value
Value of Sycamore Yard at the bank's NOI of $2,737,842, by cap rate, $ millions
53.25.15% (broker)
50.75.40% (lowest comp)
47.65.75% (median comp)
44.96.10% (highest comp)
Fictional example from this guide
Show the numbers
Cap rate
Value, $ millions
5.15% (broker)
53.2
5.40% (lowest comp)
50.7
5.75% (median comp)
47.6
6.10% (highest comp)
44.9
Holding the bank's NOI fixed, the value runs from $53.2 million at the broker's cap rate to $44.9 million at the top of the bank's own range. The OCC's warning applies in both directions: "Rising interest rates may lead to higher capitalization rates and lower property values without any change to the actual property's fundamentals."5 A cap rate taken from the cheapest-money years can be supported by many sales and still fail the test of "normal, orderly, and sustainable market conditions".5
05 · Sizing the loan
Coverage, loan to value and debt yield: which test sets the loan amount
In shortA bank sizes an income-property loan three ways and lends the lowest: the loan whose payments the NOI covers at the minimum DSCR, a share of the lesser of price and value, and the loan on which the NOI earns a minimum debt yield. On the bank's own numbers, coverage is the test that sets Sycamore Yard's loan, at $30.6 million.
DSCR = NOI ÷ yearly debt service · LTV = loan ÷ lesser of price and value · Debt yield = NOI ÷ loan
The OCC describes each test. DSCR "measures the borrower's ability to service its debt", and "The determination of an appropriate DSCR should consider the loan amortization period and the expected volatility of the cash flow." Debt yield "provides a measurement of risk that is independent of the interest rate, amortization period, and capitalization rate", and is "especially useful during periods of low interest and capitalization rates".5 The Federal Reserve's stress-test documentation says "lenders generally require a minimum DSCR between 1.2 and 1.5 to qualify for a loan".21
Coverage sets the limit: the bank's own numbers support $30.6 million against $33.5 million requested
Sycamore Yard, the largest loan each policy test allows at the bank's assumptions
1.25x coverage (5.95%, 30-year amortization)sets the loan$30.6M
8.5% debt yield$32.2M
The request1.14x and an 8.2% debt yield$33.5M
75% of the lesser of price and value$35.7M
Fictional example from this guide
Show the numbers
Test
Largest loan
1.25x coverage (5.95%, 30-year amortization)
$30.6M
8.5% debt yield
$32.2M
The request
$33.5M
75% of the lesser of price and value
$35.7M
At the request, payments are $2,397,286 a year. The broker's NOI covers them 1.27 times; the bank's covers them 1.14 times and gives a debt yield of 8.2%, so the request would need two policy exceptions, coverage and debt yield, before anyone discusses price. At $30.6 million coverage is exactly 1.25x and the debt yield is 8.95%. Loan to value is 70.4% at the request, inside the bank's 75% limit: on these numbers, loan to value leaves room to spare.
Why the 1.2 line matters. The Fed's stress model adjusts the projected default probability of income-producing loans that approach maturity with DSCR below 1.2, "a typical minimum underwriting threshold", "upwards by a factor of four, to account for the tendency of the logistic regression model to underpredict PD for such loans".21 It is a correction inside a stress model, and a bank should not copy the factor into its pricing. It does show the shape of the risk: a loan whose coverage slips from 1.27x to 1.14x moves toward the loans the supervisor's own model underpredicted.
Interest-only periods and amortization
Interest-only months raise coverage on paper, because no principal is paid, and leave more debt at maturity. The OCC's booklet expects policy to address "Requirements and limits on interest-only loans for stabilized commercial real estate", and in the April 2026 senior loan officer survey longer interest-only periods were among the most widely reported easings of the past year.5,22 In the example bank's policy, anything over 12 months is an exception.
06 · Finding comparable loans
What makes a past loan comparable, and how 1,284 closed loans become nine
In shortComparability is a set of written criteria: property type and class, market, size, year built and when the loan closed. Each criterion trades sample size for relevance. A good search shows its criteria, says why each loan was left out, and reports how many loans the answer rests on.
Five criteria take 1,284 closed loans down to nine comparables
Example bank, Class A garden apartments near Charlotte
Closed CRE loans since 20141,284
Multifamily loans in the Charlotte metro since January 202331
Garden style, Class A or B+, built 2016 or later, 180–320 units9
Fictional example from this guide · 22 of the 31 were left out as mid-rise, older or under 180 units.
Show the numbers
Stage
Loans
Closed CRE loans since 2014
1,284
Multifamily loans in the Charlotte metro since January 2023
31
Garden style, Class A or B+, built 2016 or later, 180–320 units
9
Criterion
Example setting
What it protects
What it costs
Property type and class
Garden apartments, Class A and B+
Like income, like expenses
Mid-rise and older stock drop out
Market
Same metro area
Same rents, taxes, supply pipeline
Loans 30 miles away count as much as loans next door
Closed since
January 2023
Assumptions set at current rates
Fewer loans; little history to judge
Year built
2016 or later
Like capital needs and amenities
Older comparables in the same submarket
Size band
±40% of the subject's units
Like staffing and expense per unit
Small or large outliers
Loans since paid off
Included, shown to payoff
Against keeping only the loans still on the books
Shorter outcome history for some
Within one property type, class and metro over three years, a community bank may have only a handful of loans; the example bank has nine. That is enough to see a range and an outlier, and too few to estimate a default rate. The answer should always say how many loans it rests on, and when the count is zero it should say so and step aside for market evidence.
Keep the underwriting as it was approved. A comps record that overwrites the NOI the bank underwrote with this year's NOI destroys the comparison it exists to make. Store the approved assumptions unchanged, store performance beside them with its date, and read only memo versions marked approved.
07 · Appraisals and cap rates
Why a lender's cap rate often sits above the appraisal's, and how far appraisals miss
In shortAn appraiser estimates market value on a date, from recent sales. A lender chooses a rate it is willing to lend against for the loan's term. When the sales behind an appraisal date from 2021 and 2022, around the historic low in cap rates that the Federal Reserve dates to 2022,23 a bank that underwrites above them is adjusting for the move. Appraisals also carry their own error, about 11% of value on average.
The Federal Reserve's May 2026 Financial Stability Report says cap rates at purchase "have recovered from historical lows reached in 2022," "rising to a level just below its historical average in the most recent data."23 CBRE's survey for the first half of 2026 found the all-property median roughly flat, with rates up 50 to 100 basis points (0.50 to 1.00 percentage point) in key coastal markets since late 2025.24 An appraisal effective in September 2026 whose comparable sales closed in 2021 and 2022 carries those years' cap rates into the file.
How far appraisals miss the later sale price
Apartment appraisals miss the later sale price least, industrial most
Mean absolute percentage error between appraised value and sale price, NCREIF properties sold 1997 to early 2021
The study's authors write: "We also do not find any evidence that the MAPE has significantly narrowed over the past decade compared to previous years when disregarding the large deviations that occurred during the great financial crisis in 2009."2 On a stabilized apartment at a 5.75% cap rate, an 8.6% value error is about the same as moving the cap rate 49 basis points (our arithmetic). A bank that sits about half a point above its appraisals is allowing for roughly one average appraisal miss.
The example bank against its own appraisals
On all nine comparable loans the bank underwrote a higher cap rate than the appraisal
Example bank, Charlotte garden apartments closed March 2023 to April 2026, cap rate %
Appraisal cap rateBank's underwritten cap rate
Juniper Trace, Mar 20234.9%5.4%
Mallard Bend, Aug 20235.1%5.6%
Cedar Loop Commons, Nov 20235.3%5.75%
Copper Hollow, Feb 20245.15%5.5%
The Mooresville loan, Jun 20245.4%5.9%
Alderwick Row, Oct 20245.2%5.65%
Tern Ridge Flats, Mar 20255.6%6.1%
Pebblewick Park, Sep 20255.35%5.75%
Hartley Mill, Apr 20265.4%5.85%
Fictional example from this guide · Medians: appraisal 5.30%, bank 5.75%, a 45 basis-point gap. The broker's 5.15% on Sycamore Yard is below every rate the bank underwrote.
Show the numbers
Appraisal cap rate
Bank's underwritten cap rate
Juniper Trace, Mar 2023
4.9%
5.4%
Mallard Bend, Aug 2023
5.1%
5.6%
Cedar Loop Commons, Nov 2023
5.3%
5.75%
Copper Hollow, Feb 2024
5.15%
5.5%
The Mooresville loan, Jun 2024
5.4%
5.9%
Alderwick Row, Oct 2024
5.2%
5.65%
Tern Ridge Flats, Mar 2025
5.6%
6.1%
Pebblewick Park, Sep 2025
5.35%
5.75%
Hartley Mill, Apr 2026
5.4%
5.85%
A gap that steady is a practice worth writing down: an analyst who starts from the appraisal's cap rate would be about 45 basis points more aggressive than the bank has been. Juniper Trace is the caution. The bank underwrote it half a point above its 4.90% appraisal and it still missed, because its income rested on 4.0% vacancy. A careful cap rate on an aggressive NOI does not make a careful loan.
What the review appraiser checks. The OCC's appraisal review worksheet asks reviewers whether the appraisal's "comparables [are] truly comparable with respect to property characteristics and location", and "is the capitalization or discount rate supportable, and does it appear reasonable in terms of the class, property type, and market conditions?"5 The bank's own cap-rate history by property type is useful evidence for that review, kept on the bank's side of the independence line.8
08 · Did it hold up?
Judging whether an assumption held up: NOI, vacancy and expenses against plan
In shortCompare what the memo underwrote with what servicing shows now, line by line, with the date of each figure. NOI against plan is the summary; vacancy and expenses explain it. Research on thousands of securitized loans shows that income optimism is persistent by lender and predicts distress, which is why a bank's own record is worth reading.
NOI against plan = (trailing-twelve-month NOI − underwritten NOI) ÷ underwritten NOI
Take the underwritten NOI from the approved memo and the trailing twelve months from the borrower's operating statements, on the same definitions. Then look at vacancy and expenses separately, because a loan can hit its NOI with high rents covering an expense overrun that will not repeat. A simple scale reads well on a map or a table: held up (NOI within 2% of plan or better), close (within 6%), missed (worse). The thresholds are a policy choice; write them down.
Seven of nine loans held up on income, but only four on expenses
Example bank's nine comparable apartment loans, servicing to September 30, 2026
Held upCloseMissed
NOI against plan711
Expenses against plan441
Fictional example from this guide · Held up: NOI no worse than −2%, expenses within 3% of plan. Close: −6% and 6%. The one miss on both is Juniper Trace.
Show the numbers
Measure
Held up
Close
Missed
NOI against plan
7
1
1
Expenses against plan
4
4
1
The expense row tells the sharper story. The five loans closed before mid-2024 run 4 to 9% over their expense plan after insurance renewals; the four underwritten since carry more and are on plan. A median built from all nine would reproduce the older loans' mistake, which is why the analyst in the example underwrote $6,600 a unit, above the $6,350 median. The FDIC's 2026 Risk Review describes the same pressure across the industry: higher operating costs and elevated vacancy squeezing property income.25
Optimism is a habit of lenders, and it shows up later as distress
29 in 100 securitized loans overstated the property's income by at least 5%
29 in 100
of 39,522 loans securitized in CMBS 2013–2019, comparing underwritten income with the first year's actual income
of 39,522 loans securitized in CMBS 2013–2019, comparing underwritten income with the first year's actual income
29 of 100
Griffin and Priest found that income overstatement in these loans "varies widely and persistently across originators, is predictable ex ante" and "is highly predictive of pre- and COVID-period loan distress".4 Their data are securitized loans; a bank's book is a different population. The lesson carries over: habits persist, so a bank whose recent apartment loans ran over on expenses will probably do it again unless someone shows the analyst the record.
Three cautions before you trust a comparison. Survivorship: keep loans that paid off, with performance to payoff. Regime: loans closed when money was cheap performed in a different rate world. Size: nine loans show a range and an outlier; estimating a default rate takes far more loans. Say all three in the note.
09 · Policy exceptions
Policy exceptions: what examiners count, and why each one needs its outcome beside it
In shortExceptions are legitimate when they are justified in writing and approved at the right level. Examiners read their number and trend, and the OCC expects them aged and stratified by type and officer. The column that helps the next approver most is the outcome: how the last loan with the same exception is doing now.
The OCC's CRE booklet warns: "An excessive or significantly increasing number of exceptions to the CRE lending policy could indicate that the bank is unduly relaxing its underwriting practices, needs to revise its loan policy, or that its policies are inconsistent with the board's risk tolerance."5 The 2026 lending booklet adds the other side: "the absence of exceptions can indicate that the policy is too liberal or vague".15 Some banks, it notes, track exceptions by loan officer, broker or dealer.15
Coverage was the most common single type of CRE exception at the example bank
17 exceptions on 158 CRE loans closed since January 2023
17exceptions
Other (lease term, tenant, anchor, pre-leasing, debt yield)5
Debt service coverage4
Interest-only period3
Loan to value3
Vacancy floor2
Fictional example from this guide
Show the numbers
Part
Value
Other (lease term, tenant, anchor, pre-leasing, debt yield)
5
Debt service coverage
4
Interest-only period
3
Loan to value
3
Vacancy floor
2
The example bank, fictional
10.8% of loans carried an exception
Seventeen exceptions on 158 CRE loans since January 2023: ten approved by the chief credit officer, seven by the senior credit officer. Both vacancy exceptions sit on the two weakest multifamily loans in the book. Two of the nine Charlotte apartment comparables carry exceptions that are performing (coverage at 1.24x, 24 months interest-only); the vacancy exception on a third is the one that failed.
Tells the next approver whether the mitigant worked
Rarely
Link to the approval page
An examiner can read the justification in seconds
Rarely
The OCC's 2026 booklet describes postmortems in the same spirit: comparing "each loan's terms and characteristics with underwriting guidelines", reviewing the borrower's condition "at the time of loan approval and over time", and "Assessing the adequacy and timeliness of collateral valuations".15 An exception report with outcomes beside it is a postmortem that runs before the loss.
10 · What goes wrong
Ten ways precedent research goes wrong, and what catches each
In shortThe errors fall into four groups: starting in the wrong place (the broker's pro forma), reading the wrong document (a draft, or the appraisal for the bank's view), comparing the wrong things (terms instead of assumptions and outcomes), and keeping the wrong loans (survivors only). Each has a simple control.
#
Error
Why it happens
What catches it
Where the analyst starts
1
Anchoring on the broker's pro forma
It arrives first, complete and formatted
Start from the bank's comps; explain every move toward the broker
2
Taking the appraisal's cap rate as the bank's
It is the only cap rate with a signature
Show the bank's underwritten cap rate beside the appraisal's on every comparable
"Economic vacancy" in one year, "vacancy and collection loss" in another
A field map checked by a credit person on old templates
6
A stale outcome shown as current
Servicing figures carry different dates
Every outcome with its as-of date
What gets compared
7
Comparing terms instead of assumptions and outcomes
The loan system holds amount, rate and maturity, and nothing else
Underwritten NOI beside actual NOI, loan by loan
8
A median that repeats the old mistake
Older loans that missed are still in the set
Show the recent trend and each loan's outcome next to the median
Which loans are kept
9
Paid-off loans dropped
They leave the servicing extract
Keep them, with performance to payoff
10
Borrower names visible to everyone who searches
One search across many relationships
Names follow relationship entitlements; others see the loan without the name
Anchoring on the broker and dropping reserves are common and costly: fix them first
How far it moves the loan amount →
Test for it
Fix first
Spot-check
Automate the check
Broker anchorAppraisal cap as bank'sZero reservesDraft memo readStale outcomeSurvivors only
How often it happens →
Illustrative · replace with your own numbers · Positions are our judgment from the worked example; no public data ranks these errors by frequency.
Show the numbers
Item
How often it happens (0–1)
How far it moves the loan amount (0–1)
Broker anchor
0.75
0.78
Appraisal cap as bank's
0.70
0.67
Zero reserves
0.62
0.57
Draft memo read
0.12
0.30
Stale outcome
0.70
0.20
Survivors only
0.20
0.08
11 · The 2026 market
The 2026 CRE lending market in numbers: $3.14 trillion on bank books, $875 billion maturing
In shortUS commercial banks hold $3.14 trillion of CRE loans and the book is growing again. About $875 billion of commercial and multifamily mortgages matures in 2026, each one a re-underwriting. Bank delinquencies are low; securitized multifamily delinquencies jumped in 2026. Standards are easing from a tight level, mostly on loan size, pricing and interest-only periods.
Nonfarm nonresidential loans are three-fifths of bank CRE; multifamily a fifth
CRE loans at all US commercial banks, September 2026, seasonally adjusted, $ billions
Source26 · Total $3,140.2 billion (H.8 of October 30, 2026); growth 5.2% annualized in September and 3.6% in the third quarter. Small domestically chartered banks hold $2,107.7 billion, about two-thirds.
MBA's 2025 survey of loan maturity volumes counts 17%, or $875 billion, of the $5.0 trillion of commercial and multifamily mortgages held by lenders and investors matures in 2026, after $957 billion scheduled for 2025; the figures are balances at December 31, 2025. Depositories face $396 billion, 21% of their balances.27
Each maturity is a new underwriting, done with current assumptions on a building first underwritten with older ones. Extension is part of that work, and a 2026 Federal Reserve study found that after the spring 2023 bank stress, "banks increased income and principal paydown requirements for extensions," which contributed to strong performance of extended loans.28
How CRE loans are performing
Securitized multifamily delinquency rose 1.45 points in a year
Trepp CMBS delinquency rate by property type, September 2025 and September 2026, %
Sep 2025Sep 2026
Office11.1%12.2%
Multifamily6.59%8.04%
All CMBS7.55%8.02%
Retail6.76%6.58%
Industrial0.56%1.14%
Source29 · Trepp data for September 2026, reported by Scotsman Guide on October 6, 2026.
Show the numbers
Sep 2025
Sep 2026
Office
11.1%
12.2%
Multifamily
6.59%
8.04%
All CMBS
7.55%
8.02%
Retail
6.76%
6.58%
Industrial
0.56%
1.14%
Bank CRE delinquency doubled from 2023 and has held near 1.5%
Delinquency rate on CRE loans excluding farmland, all commercial banks, %, first quarter of each year and Q2 2026
At June 30, 2026, 1.10% of insured institutions' multifamily loans, 1.23% of nonfarm nonresidential loans and 0.99% of construction loans were noncurrent, and year-to-date net charge-offs ran at 0.12% to 0.16%.31 Averages that low say little about the next loan; the variation that matters sits inside each bank's book. The OCC's spring 2026 report points to one source of it: "continuing rental rate declines in the Sun Belt, driven by the substantial supply wave of 2022-24", while "demand is steady and multifamily properties remain resilient."32
Standards are loosening from a tight position
Banks went from heavy tightening in 2023 to net easing of CRE standards by mid-2026
Net percentage of domestic banks reporting tighter standards, by survey month (negative = easing)
Construction and landNonfarm nonresidentialMultifamily
Over the year to April 2026, "the most widely reported changes in terms … were higher maximum loan sizes, narrower spreads of loan rates over the bank's cost of funds, and longer interest-only payment periods", modest net shares lowered DSCR requirements for construction and multifamily loans, and the most cited reason was "more aggressive competition from other banks or nonbank lenders".22
In July, "a significant net share of banks reported that lending standards were at the tighter end of their range for CLD loans," with "relatively tight levels of standards for NFNR and multifamily loans".17 The survey panel is mostly large banks (56 domestic banks answered in July), and the largest of them led the easing. A community bank's own exception count is its private version of the survey.
12 · Software and AI
What software can do with a bank's old credit memos, and what the 2026 rules expect
Status as of October 2026
In shortSoftware can find comparable loans from plain-words criteria, read approved memos and appraisals into fields with the page behind each, join servicing with dates, and size the next loan on the result. The April 2026 model guidance leaves generative AI outside its scope, so the controls come from third-party guidance and the bank's own AI policy. The test that matters is whether every figure opens at its page.
The April 2026 interagency guidance, issued as Fed SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026,14 defines a model as "a complex quantitative method, system, or approach that applies statistical, economic, or financial theories to process input data into quantitative estimates" and excludes "simple arithmetic calculations, such as those found within spreadsheets, as well as deterministic rulebased processes".13
A footnote places generative AI, and AI that acts on its own, outside the guidance, and adds that "a banking organization's risk management and governance practices should guide the determination of appropriate governance and controls for any tools, processes, or systems not covered in this document."13
Reading memos sits outside the model guidance and inside the bank's other rules
Which text covers each part of a comps tool you buy
NoYes
Model guidanceThird-party guidanceYour policy and proceduresFinding loans by criteriaNoYesYesReading memos and appraisals into fieldsNoYesYesJoining servicing outcomesNoYesYesSizing arithmetic and policy testsNoYesYesRisk ratings or default forecastsYesYesYesChoosing assumptions and signingNoNoYes
Our reading of the sources13,10,1 · For a tool bought from a vendor. Your counsel and model risk team decide.
Show the numbers
Model guidance
Third-party guidance
Your policy and procedures
Finding loans by criteria
No
Yes
Yes
Reading memos and appraisals into fields
No
Yes
Yes
Joining servicing outcomes
No
Yes
Yes
Sizing arithmetic and policy tests
No
Yes
Yes
Risk ratings or default forecasts
Yes
Yes
Yes
Choosing assumptions and signing
No
No
Yes
The OCC and the Fed on AI that reads credit memos
Use is narrow and supervised. The OCC's spring 2026 report finds banks taking a measured approach to generative AI and AI that acts on its own, "with usage generally limited to specific use cases with guardrails and human-in-the-loop accountability to manage risk."32
Credit decisions are the hard case. The Fed's Vice Chair for Supervision, July 2026: using AI "in a way that has more direct impact on credit decisions affecting individual customers—presents more substantial legal compliance challenges than other AI use cases."34
The Treasury's 2024 report warns that generative AI "can be susceptible to 'AI hallucinations,' producing confidently stated but incorrect output".35 A figure that carries its document and page can be checked in seconds; one that does not cannot be checked at all. The third-party guidance keeps the responsibility with the bank, and NIST's framework names the work: GOVERN, MAP, MEASURE and MANAGE.10,36
The Equal Credit Opportunity Act and Regulation B apply to business credit too.37 A CFPB final rule effective July 21, 2026 states that ECOA does not authorize disparate-impact liability; the ban on disparate treatment is unchanged, and a lawsuit challenging the rule is pending.38 Consistent assumptions across similar loans are part of showing consistent treatment.
How you would know a search works
Replay it on closed loans whose outcomes you know, letting it see only what the bank knew at each committee date. Score three things: did it find the loans a senior officer would cite, do its figures match the pages, and did loans whose assumptions sat outside the comps' range perform worse. Then open citations at random, plant a draft memo beside an approved one, and ask about a property type the bank has never financed. A small clean test proves less than it seems.
Thirty clean citation checks still allow a 9.5% error rate
95% upper bound on the share of wrong figures when every checked figure is right
30 figures checked, none wrong9.5%
60 figures checked, none wrong4.9%
300 figures checked, none wrong1%
Illustrative · replace with your own numbers · Binomial arithmetic: 1 − 0.05^(1/n).
Show the numbers
Test size
Error rate could still be up to
30 figures checked, none wrong
9.5%
60 figures checked, none wrong
4.9%
300 figures checked, none wrong
1%
Choosing each cap rate and approving exceptions stay human
Choosing each assumption, and writing down why it differs from the comps.
Judging a building nobody has lent on, where the honest answer is a count of zero.
Approving exceptions, at the authority the policy names.
Keeping valuation independent of loan production.8
The responsibility for the loan, which stays with the bank that signs it.10
13 · How teams do it today
How CRE credit teams research precedent today, and where the hours go
In shortAn analyst asks colleagues, searches the loan system for loan numbers, opens memos one by one, pulls current figures from servicing and lines everything up in a spreadsheet. The finding and reading take most of the time, so the research is done fully for large or unusual loans and from memory for the rest. No public figure measures the hours.
Who looks for precedent: credit analyst, credit officers, review appraiser
CA
CRE credit analyst
Spreads the rent roll and operating statements, sets the assumptions, sizes the loan, writes the memo.
Cares about: finding the memo that answers "have we done this before?"
CO
Senior credit officer
Reviews the memo, approves within a limit, chairs or presents to committee.
Cares about: what was assumed last time, and how it worked out.
CC
Chief credit officer
Owns the policy and its inner targets, approves the larger exceptions, answers the examiner.
Cares about: the same assumptions on similar loans, whoever underwrites them.
RA
Review appraiser
Reviews each appraisal, independent of loan production.8
Cares about: comparable sales from the right rate environment.
RM
Relationship manager
Brings the deal and carries the answer back to the sponsor.
Cares about: a clear reason, quickly, if the loan comes in smaller.
Four places an analyst digs for a past loan before the memo
Precedent research passes through four sources before it reaches the memo
1Ask around
Colleagues and the credit officer recall similar deals.
AnalystHours to days
2Search the loan system
Property codes and towns give loan numbers and terms; the assumptions are in the memos.
AnalystAn hour
3Open the memos and appraisals
Find cap rate, vacancy, expenses, reserves, DSCR and exceptions in 30-page PDFs.
AnalystMost of a day
4Pull outcomes
Occupancy, coverage and rating from servicing or the last annual review.
Analyst, loan servicingHours
5Line up and size
A spreadsheet of comps; the subject sized against them.
AnalystHours
6Review and sign
The memo explains each assumption; the credit officer signs.
Credit officerBy policy
Illustrative · replace with your own numbers · Times are illustrative for one multifamily acquisition at a regional bank.
Show the numbers
Step
What happens
Who
Time
Ask around
Colleagues and the credit officer recall similar deals.
Analyst
Hours to days
Search the loan system
Property codes and towns give loan numbers and terms; the assumptions are in the memos.
Analyst
An hour
Open the memos and appraisals
Find cap rate, vacancy, expenses, reserves, DSCR and exceptions in 30-page PDFs.
Analyst
Most of a day
Pull outcomes
Occupancy, coverage and rating from servicing or the last annual review.
Analyst, loan servicing
Hours
Line up and size
A spreadsheet of comps; the subject sized against them.
Analyst
Hours
Review and sign
The memo explains each assumption; the credit officer signs.
Credit officer
By policy
Nineteen hours, three-fifths spent finding and reading old memos
Finding and reading take about three-fifths of a precedent search done by hand
Hours for one loan's precedent research
Finding past loansReading memos and appraisalsChecking performanceSizing and policy testsWriting it up
By hand, about 19 hours65323
Illustrative · replace with your own numbers · An estimate published with the solution described in Part B; no bank has measured it. Time three of your own.
Show the numbers
Finding past loans
Reading memos and appraisals
Checking performance
Sizing and policy tests
Writing it up
By hand, about 19 hours
6
5
3
2
3
When precedent costs two days, it is consulted for large or unusual loans and skipped for the rest, which is where a bank relies on one officer's memory. That arrangement fails three ways: a new analyst underwrites to the outer limit because the inner target is invisible; a second officer across town applies a different one; and when the officer retires the bank loses the memory of which exceptions went badly.
The OCC's booklet puts the inner targets in procedures and guidelines.15 Written down, they become something an analyst can follow and an examiner can test.
Memo folders, bought market comps or a searchable loan record
In house
Memory, folders and a spreadsheet
A folder of approved memos by borrower, a credit department spreadsheet of key terms, loan review's sample files and the chief credit officer's recall. Cheap, and limited to what someone remembers to look for.
Bought data
Market comps and surveys
Sales and lease databases and broker cap-rate surveys. Good evidence of the market; silent on what the bank assumed or how its loans did.
Software
A searchable record of the bank's own loans
Tools that read approved memos, appraisals and servicing into a searchable record. They differ most on whether every figure opens at its page, whether outcomes carry dates, and who sees which borrower.
Part B · See it working
Botminds CRE Loan Comps Search, from a plain-words question to a signed research note
This part shows how Botminds does it, at a fictional regional bank in Charlotte with 1,284 closed CRE loans since 2014. Every bank, borrower, person, loan and figure in the screens is sample data.
14 · One loan, start to finish
Sycamore Yard Apartments, priced against nine of the bank's own past apartment loans
In shortThis is the example from the top of the page, inside the product. Priya Nandakumar, the CRE credit analyst, asks one question in plain words. Six agents, each a piece of software with one job, find the bank's comparable loans, read 27 documents and join servicing; the loans drop on a map, colored by whether each assumption held up. Priya sizes Sycamore Yard on the bank's own numbers, signs a cited research note, and Marcus Hale, the senior credit officer, reviews and signs it before Thursday's committee.
1
A question bar over a map of the bank's own lending
The first screen is a map of Calder Point Bank's closed CRE loans across North and South Carolina, Georgia and Tennessee: 1,284 loans since 2014, one dot for about five loans. The loan in hand sits in the rail: Sycamore Yard, 228 units in Huntersville, the broker's 5.15% cap rate and 4% vacancy, committee Thursday, October 15.
Three ready questions sit under the bar, and any question can be typed in plain words.
The comps map. The bank's closed CRE loans as dots, a question bar, and the loan in hand with the broker's assumptions.
2
The criteria come back as chips, and every left-out loan has a reason
Priya asks how the bank has underwritten Class A garden apartments around Charlotte since 2023, and how those loans did. The question reader turns it into criteria: multifamily, garden, Class A and B+, Charlotte metro, closed since January 2023, built 2016 or later, 180 to 320 units.
The comparable loan finder searches 1,284 loans, finds 31 multifamily loans in the metro and keeps 9; the other 22 are left out as mid-rise, older or under 180 units. The memo and appraisal reader works through 27 documents and records 486 figures, each with its page.
Finding the loans. The run log beside the map: criteria set, loans searched and left out, documents read, servicing joined, policy checked.
3
Nine pins, each with the cap rate the bank underwrote and how the loan did
Nine numbered pins land around Sycamore Yard, ranked by closeness. Each carries the cap rate the bank underwrote and its income against plan. The verdict bar counts them: seven held up, one came close, one missed.
The answer beside the map cites every sentence: cap rates of 5.40% to 6.10%, median 5.75%, about 45 basis points above the appraisals; vacancy median 6.0%; the broker's 5.15% below all nine; and on the bank's own numbers the loan sizes to $30.6 million at 1.25x, against $33.5 million requested.
Nine comparable loans. Pins colored held up, close or missed; the verdict bar; the cited answer with the sizing.
4
Juniper Trace: what the bank assumed, and what happened
Priya clicks pin 5. The card leads with one line: underwritten at a 5.40% cap, actual NOI 17% below plan. In March 2023 the bank underwrote 4.0% vacancy and $5,940 a unit of expenses at 1.30x. On September 30, 2026 the building is 86.4% occupied, expenses run $6,480 a unit, 9% over plan, coverage is 1.08x and the loan is rated 6, on the watch list.
The reason is in plain words: 612 new units opened within a mile, and concessions reached six weeks free. Credit memo and servicing record are one click away.
Juniper Trace. Underwritten at closing beside today, with the reason and links to the memo page and servicing.
5
Sycamore Yard, sized on the bank's numbers
On the sizing screen the broker's pro forma, the appraisal and the bank's nine comps sit side by side. Priya clicks "Use the comps medians" and sets expenses to $6,600 a unit, above the median, because the three newest loans average $6,617. NOI comes to $2,737,842 and the value to $47.6 million.
The policy checker shows which test sets the loan: $30.6 million at 1.25x coverage, $32.2 million at the 8.5% debt yield, $35.7 million at 75% loan to value. At the request, coverage is 1.14x against 1.25x and the debt yield 8.2% against 8.5%, so two of the six policy tests fail and four pass. The warning on the screen names the coverage exception; the debt yield test in the list below it fails as well.
Sizing on the bank's numbers. Three sets of assumptions, the analyst's own column, and the three policy tests that set the loan.
6
A cited research note, reviewed before committee
Priya signs and saves research note RN-2026-1147: the question, the nine loans, what the bank assumed, how those loans performed, the sizing and her recommendation to size the loan to $30.6 million or present the request with exceptions. She sends it to Marcus Hale.
Marcus reviews and signs: "Assumptions backed by the bank's own deals, ready for Thursday." Only then can the note be inserted into the credit memo, with every source as it stood that day.
The research note, reviewed. Prepared by the analyst, reviewed by the credit officer, each section cited, ready to go into the memo.
The run in these screens finished in 16 seconds on the sample bank's loans, with a source on every sentence of the answer and the note. Time the same question on your own loans.
15 · Every screen
A medical office question, assumption ranges, the bank's cap rate against its appraisals, and every exception with its outcome
In shortOne loan is the story. These screens show the rest: the lens that recolors every pin, the ranked table, a second question about medical office, the full cited answer and its sources, the assumption ranges and comps table, a memo page, one loan's history, ranges by property type, the bank's cap rate against its appraisals by quarter, every policy exception with its outcome, the settings and the library.
The "Did it hold up?" lens. Switched to expenses, the pins recolor: four held up, four close, one missed. The five loans closed before mid-2024 ran 4–9% over plan after insurance renewals.
Ranked by closeness. Mallard Bend 96 down to Tern Ridge Flats 71; underwritten against now for vacancy and coverage; a row finds its pin, the arrow opens the loan.
A second question. Suburban medical office in the Southeast since 2022: eight loans, $93.6 million, cap rate median 6.95%. Wrenfield runs 8% above plan; the answer also says the bank has no medical office loan outside these four metros.
The cited answer. The question as criteria, an answer with a citation on each sentence, and how it was found, agent by agent.
Eleven sources. Memo, appraisal, review, servicing and policy, each at its section and page.
A memo page. A citation opens the approved memo at its page, the cited figures highlighted.
Ranges and the comps table. Where the broker and the appraisal sit against the bank's nine loans, then every loan's terms, exception and rating now.
One comparable loan. Juniper Trace's occupancy month by month against the 96.0% underwritten, and the 612 new units that pulled it down.
Assumption ranges. What the bank has underwritten in the Charlotte metro since January 2023, by property type, kept current from every memo, appraisal and servicing record.
The gap, by quarter. The bank's underwritten cap rate against the appraisals' on garden apartments since 2023, with the broker's 5.15% below both.
Policy exceptions. Seventeen on 158 loans since January 2023, aged and grouped by type, each with its approver, mitigant and how the loan is doing now.
Your criteria and policy. What counts as comparable and the minimums the loan is tested against, versioned and on the audit trail.
The library. Closed loans, approved memos and reviews, appraisals and servicing, each read as it is filed.
Most screens open full size when selected. The bank, borrowers, people and figures are fictional.
16 · Agents, and who signs
Agents find and read the precedent; the analyst picks the cap rate, vacancy and expenses, and a credit officer signs the note
In shortEach agent has one job and limits it does not cross. None chooses an assumption, sizes a loan for approval or waives a policy. The analyst picks the cap rate, vacancy and expenses and recommends the amount; a named credit officer reviews and signs the note; committee approves the loan.
Six agents, from question reader to answer writer
Question reader
Turns a plain-words question into criteria (property type, class, market, vintage, size and period) and shows them as chips the analyst can change.
Never applies a criterion it does not show; asks when a criterion is unclear.
Comparable loan finder
Searches the bank's closed loans, scores how comparable each is to the loan in hand, and says why each loan is in or left out.
Never includes a loan the user may not see; borrower names follow entitlements.
Memo and appraisal reader
Pulls the underwritten cap rate, rent, vacancy, expenses, reserves, DSCR and exceptions from each approved memo, appraisal and review report.
Never reports a number without its document and page; reads approved versions only.
Performance tracker
Joins occupancy, coverage, risk rating and payment history from servicing, with the date of each figure.
Never presents a stale figure as current.
Policy checker
Tests the assumptions and the sizing against credit policy and the supervisory loan-to-value limits, and reports which test sets the loan amount.
Never waives or reinterprets a policy; it recommends, people decide.
Answer writer
Writes the cited answer, the comps table and the research note, and says where the bank has little or no history.
Never writes a sentence without a source, or chooses an assumption for the analyst.
The analyst picks the cap rate; a credit officer signs
Chooses and recommendsCRE credit analystSets the cap rate, vacancy, expenses and reserves, explains any move away from the comps, recommends the amount and signs the research note.
Reviews and signsSenior credit officerReviews the note and signs it before it can go into the credit memo; committee approves the loan.
Owns policy and exceptionsChief credit officerOwns the comparable criteria and the policy minimums as settings, and approves exceptions at the authority the policy names.
Every question, answer, note and signature is on the audit trail, with the sources as they stood that day. Agent steps and human decisions are recorded apart, settings changes are versioned, and only approved memo versions are searched.
Priya Nandakumar's six loans in underwriting and her reviewers
Fictional, from the sample data
PN
Priya Nandakumar · CRE credit analyst
Writes three or four credit memos a month, with six loans in underwriting.
"I know we've done this deal before. I just can't find the memo."
MH
Marcus Hale · senior credit officer
Approves memos up to $40 million and chairs Thursday's credit committee.
"Show me what we assumed last time and how it worked out."
JP
Joan Pemberton · chief credit officer
Approves policy exceptions, including Juniper Trace's vacancy exception in 2023.
Cares about: how the last exception of the same kind turned out.
GW
Graham Whitlock · chief review appraiser
Reviews every appraisal above $5 million.
"The appraisal's comps are from when money was cheap."
TB
Travis Bramwell · relationship manager
Brought in Sycamore Yard and owes the sponsor an answer by Friday.
"If we can't do $33.5 million, tell me why in one page."
17 · What goes in and out
From the core system and old credit memos to a ranked comps table, assumption ranges and a research note
In shortThe solution reads the records the bank already keeps and leaves them where they are. Out come a cited answer, a ranked comps table, assumption ranges by property type and market, a sizing of the loan in hand on the bank's own numbers, an exception history with outcomes, and a research note ready for the credit memo.
Borrower names follow the relationship; other loans appear with the name hidden.
Your loan review
Gets exception reports with outcomes and every figure linked to its page.
Every sentence sourced, thin evidence said aloud, people decide
1
Every sentence carries its source
Memo, appraisal, review or servicing record, at the page, one click away.
2
Thin evidence is said out loud
The answer says how many loans it rests on, and says "none" when there are none.
3
Agents find; people decide
The analyst chooses, the credit officer signs, committee approves.
Part C · Are you ready to automate?
Your own loan history as evidence: the cost of leaving it unsearched, and the case for software that searches it
You underwrite CRE loans, manage the people who do, or answer for the assumptions behind them. This part is written for you: what guesswork and slow research cost today, what automating the search could return, whether your bank is ready, and what to ask any vendor of comps software, including us.
18 · What guesswork costs
What unsearched loan history costs you: analyst days, loose assumptions and exceptions granted blind
In shortStart from your own costs. No regulator or study publishes how long precedent research takes or how often a bank's assumptions drift from its own history, so the numbers that matter are yours. A few published figures frame them: what an analyst hour costs, how much CRE debt comes up for re-underwriting, and how sharply risk rises when coverage slips.
$57/hr
a credit analyst's median pay, $83,510 a year, loaded for benefits at the 70% wage share of employer costs.39,40
BLS 2025 wages via O*NET, June 2026 compensation costs · our arithmetic
$875B
of commercial and multifamily mortgages matures in 2026, $396 billion of it at depositories. Each maturity is a re-underwriting on today's assumptions.27
MBA, February 2026
4×
the Fed's stress-test adjustment to the default probability of income-producing loans near maturity with coverage below 1.2.21
Federal Reserve, Credit Risk Models, updated January 2026
Most of the hours are in finding and reading, which software can take
Analyst hours of precedent research for one CRE loan
By handWith automation
Finding past loans like this one60.1
Reading memos and appraisals50.5
Checking how those loans performed30.2
Sizing and testing against policy20.5
Writing the research note31
Illustrative · replace with your own numbers · The solution's makers' own estimate; no bank has measured it. Time three of your own loans.
Show the numbers
By hand
With automation
Finding past loans like this one
6
0.1
Reading memos and appraisals
5
0.5
Checking how those loans performed
3
0.2
Sizing and testing against policy
2
0.5
Writing the research note
3
1
What nobody publishes. There is no public figure for hours of precedent research per loan, the share of loans underwritten outside the bank's own range of assumptions, how often an exception is granted without checking the last one like it, or how much NOI a bank's loans miss plan by on average. Vendor figures for these come without a dataset. Measure your own.
Timing precedent research and measuring cap rate drift on your loans
Cost
Where it hides
How to find your number in a week
Analyst research time
Asking around, opening memos, rebuilding a comps spreadsheet
Time the precedent research on three live loans, step by step
Loans with no precedent check
Smaller and routine loans, where nobody looks
Read the last 20 memos: how many cite the bank's own similar loans?
Assumption drift
Two loans a mile apart on different cap rates
List cap rate and vacancy on your last 10 loans of one type in one metro; note the spread
NOI misses
Servicing, never compared back to the memo
For 10 loans two years old, underwritten NOI against trailing twelve months
Exceptions granted blind
An exception report with no outcome column
For each exception since 2023, today's coverage and rating
Exam and loan review comments
Findings on underwriting support or exception tracking
Your last two exam reports and loan review findings on CRE
The repeated vacancy exception and the cap rate nobody can support
The loan sized on someone else's guessesIn the example, $2.9 million more debt on a building worth $11.3 million less than the broker said.
The exception that repeatsA vacancy exception that failed once, granted again because nobody saw the first.
The officer who retiresThe inner targets in one person's head leave with them.
The examiner's question you cannot answer fast"Show me how you supported this cap rate."
The sponsor who hears no too lateA smaller loan explained on Friday after a week of optimism.
19 · Your return
Analyst days back and losses avoided: the return on searching your own closed loans
In shortPut in your own numbers. The calculator starts from a published analyst wage and asks you for the rest: how many loans need precedent research, the hours they take now and after, what the tool and your testing cost a year, and, if you want, one loss you believe better assumptions would avoid. Every default marked illustrative is an assumption to replace.
Analyst hours, precedent on every loan, one set of inner targets
Analyst time
Answers, with the pages
Comparable loans found and read with their pages; the analyst checks and chooses.
loans × hours saved × loaded hourly cost
Coverage
Precedent on every loan
Routine loans get the same check as large ones, because it takes minutes.
share of memos citing the bank's own comps, before and after
Consistency
One set of inner targets
Every analyst starts from the same evidence for the same kind of building.
spread of underwritten cap rate and vacancy within a type and metro
Exceptions
The last one's outcome in view
Approvers see how loans with the same exception are doing now.
exceptions approved with an outcome on file ÷ all exceptions
Credit losses
Fewer loans sized on optimism
Sizing on the bank's own numbers moves loans like Sycamore Yard back inside policy.
loss avoided on a loan you would have sized differently
Exams
Support an examiner can follow
Every assumption with its comparable loans and pages, every exception with its outcome.
hours spent assembling support for exams and loan review
Your analyst hours back from searching your own closed loans
Only the hourly cost is built from published figures: the BLS median wage for credit analysts as O*NET publishes it, $83,510, divided by 2,080 hours and by the 70% wage share of employer costs.39,40 Every input marked illustrative is an assumption.
Your volumeHours per loanYour cost and one loss
Illustrative yearly value
Research time today, valued$0
Analyst time released, valued$0
After your yearly cost, with the avoided loss$0
Analyst hours released a year0
Loans a year to cover your cost on time alone0
Formulas, per year: Research time today = loans × hours today × hourly cost Time released = loans × (hours today − hours with automation) × hourly cost After your cost = time released + avoided loss − yearly cost Break-even loans = yearly cost ÷ (hours saved × hourly cost); a very large number means the hours saved never cover the cost
The 19 and 2.5 hour defaults come from the solution makers' own estimate for a multifamily acquisition; replace them with your own timings. The avoided loss starts at zero on purpose: enter a figure only if you can name the loan. Released hours are value only when you decide what they are for: more loans per analyst, faster answers to sponsors, or deeper review.
The hours saved per loan decide how many loans cover the cost
Loans a year to cover $75,000 of yearly cost on analyst time alone, at $57 an hour
Saves 16.5 hours a loan80 loans
Saves 8 hours a loan164 loans
Saves 4 hours a loan329 loans
Illustrative · replace with your own numbers
Show the numbers
Hours saved
Loans a year
Saves 16.5 hours a loan
80 loans
Saves 8 hours a loan
164 loans
Saves 4 hours a loan
329 loans
A bank that underwrites 60 new CRE loans a year and re-underwrites 60 maturities clears the 80-loan line in the chart. A bank that makes 30 CRE loans a year, all of one kind in one town, may do as well with a well-kept spreadsheet.
Start here20 · Readiness check
How searchable your loan history is: volume, approved memos, servicing data and exception records, scored
In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Volume
How many CRE loans a year need assumptions set, counting new loans, renewals and maturities?
Why it mattersVolume turns hours per loan into analyst capacity, and 2026 maturities add re-underwriting on top of new business.27
A strong answer"About 150, a third of them maturities, mostly multifamily and industrial."
2
Your history
How many years of closed CRE loans, with approved memos and appraisals, does the bank hold electronically?
Why it mattersA search can only read what the bank can give it. Years of paper memos mean a scanning project first.
A strong answer"Ten years in the document system, approved versions marked."
3
Your baseline
Do you know how long precedent research takes, and how often memos cite the bank's own similar loans?
Why it mattersNo public benchmark exists, so your own baseline is the only way to prove an improvement.
A strong answer"About two days on a large loan, skipped on small ones; 6 of our last 20 memos cite our own comps."
4
Policy and inner targets
Are your CRE minimums written by property type, and are the inner targets (typical vacancy, cap-rate practice) written anywhere?
Why it mattersThe OCC expects outer limits in policy and inner targets in procedures; software tests against what is written.15
A strong answer"Minimums by type in policy; inner targets drafted for multifamily and industrial."
5
Exceptions
Does your exception report show how each loan with an exception is doing now?
Why it mattersExaminers read exception volume and trend and expect aging by type and officer; the outcome is what the next approver needs.5
A strong answer"Aged, by type and approver, with today's coverage and rating beside each."
6
Servicing data
Can you get occupancy, coverage and risk rating for each loan, with dates, in one extract?
Why it mattersOutcomes make loan comps worth more than a list of terms.
A strong answer"Monthly from servicing, annual reviews for the rest, as-of dates on each."
7
Owner and entitlements
Is there a named owner for the comps criteria, and a clear rule for who may see which borrower?
Why it mattersComparability is a credit judgment, and one search across many relationships needs entitlements.
A strong answer"The chief credit officer owns the criteria; names follow the relationship."
8
Governance
Do you have a way to approve AI in credit work: vendor due diligence, a view on the 2026 model guidance, human sign-off and an audit trail?
Why it mattersThe April 2026 guidance leaves generative AI to your own framework, and third-party guidance keeps the responsibility with you.13,10
A strong answer"Vendor management and model risk have a path for AI tools, and every note needs a named signer."
9
Vision · for reflection
If an examiner asked tomorrow how you supported the cap rate on your last five apartment loans, what would have to be true to answer in five minutes with pages?
Why it mattersYour answer lists the gaps. Each gap is a candidate job for software: finding, reading, joining or writing up.
A strong answerA short, specific list, for example: "the comparable loans named, their memo pages, the appraisal gap, and how each loan did."
Explore, replay 20 to 30 closed loans, or search the whole book
0–6
Explore
Gather the documents first: find where approved memos, appraisals and servicing live, time three precedent searches, and write down the inner targets for your largest property type.
7–11
Ready to pilot
Replay a search on 20 to 30 closed loans whose outcomes you know, limited to what the bank knew at each committee date. Check figures against pages and keep your analysts choosing every assumption.
12–16
Ready to implement
Plan the full book: every property type and market, entitlements, policy settings, the exception report with outcomes, memo integration and the evidence an examiner will ask for.
21 · Questions for any vendor
How a loan comps tool decides what is comparable, and sixteen more things to ask its vendor
In shortAsk every vendor the same questions, us included. The answers show what the tool reads, how it decides what is comparable, what evidence you keep, who sees what, and how you would test it on your own closed loans.
Ask
A good answer
A warning sign
What it reads
Which documents does it read: memos, annual reviews, appraisals, review reports, servicing?
All of them, approved versions only, with the page of each figure
"We index your PDFs" with no fields
How does it handle templates that changed over the years?
A field map you can inspect, checked by your credit staff on old templates
"The AI figures it out"
How does it tell a draft from the approved memo?
Approval status from your system; drafts never searched
Whatever is in the folder
What counts as comparable
Can we see and change the criteria behind every answer?
Criteria shown with each answer, defaults set by your credit officer
A similarity score with no criteria
Does it say why each loan was left out?
A reason for every exclusion
Only the loans it kept
What does it say when the bank has few or no comparable loans?
The count, including zero, in the answer
Market averages presented as the bank's
Outcomes and evidence
Does every figure and sentence open at its source page?
Document, section and page, for analyst, officer and examiner
A confidence score in place of a page
Does each outcome carry its as-of date, and are paid-off loans kept?
Dated figures; paid-off loans shown to payoff
Current loans only
Can it show exceptions with how each loan is doing now?
Aged, by type and approver, with outcome and approval page
An exception count
Your policy and people
Who chooses the assumptions and who signs?
Your analyst chooses; your credit officer signs; the tool never sizes for approval
Recommended assumptions applied by default
Who sees which borrower's name?
Your relationship entitlements, enforced in every answer
Everyone who can search sees everything
Are criteria, minimums and reviewers versioned settings?
Yes, owned by credit, on the audit trail
Settings any user can change
How does it keep appraisal independence?
Comps stay with underwriting and review; nothing goes to appraisers
"Share the bank's cap rate with your appraiser"
Your data and AI
Which AI models do you use, where do they run, and does our data train them?
Named models, a region you choose, no training on your data, in writing
"Proprietary AI", no more detail
How should we classify it under the 2026 model guidance and our third-party program?
A part-by-part answer for your model risk team
"It's all a model" or "none of it is"
Proof
Can we replay it on our own closed loans before we sign?
Yes, limited to what was known at each committee date
Demo data only
What will you report from the test?
Loans found against a senior officer's list, figures checked against pages, with counts
One accuracy percentage
We found no published independent test of any loan comps tool's accuracy, as of October 2026. A replay on your own closed loans is the fairest comparison, and the same test measures your current process.
22 · How to start
Ten weeks on one property type in one market: replay closed loans, then search beside your analysts
In shortMeasure first, then replay a search on loans whose outcomes you know, then run it beside your analysts on live loans, then decide with four numbers. None of these steps commits you to a vendor.
Time three precedent searches on live loans, step by step, and count how many of your last 20 memos cite the bank's own comparable loans.
Pick one property type and one market where you have at least 20 closed loans, and gather their approved memos, appraisals, reviews and servicing.
Ask a senior officer to list the precedents they would cite for five past loans, before the tool runs.
Replay and run in parallel: the five past loans limited to what was known then, and four weeks of live loans with your analysts choosing every assumption.
Decide with four numbers: precedents found against the officer's list, figures checked against pages, analyst minutes, and memos that now cite the bank's own loans.
A ten-week pilot ends with a decision on four numbers
Your teamVendor
Time three searches; count memo citations
Gather one property type's documents
Load documents, criteria and policy
Senior officer lists precedents for five loans
Replay on five closed loans
Parallel run on live loans
Score the four numbers; decide
Week 0246810
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Time three searches; count memo citations
0
2
Gather one property type's documents
0
3
Load documents, criteria and policy
1
4
Senior officer lists precedents for five loans
2
3
Replay on five closed loans
4
5
Parallel run on live loans
5
9
Score the four numbers; decide
9
10
Precedents found, figures right and an honest count of zero
Measure
How
Why
Precedents found
Loans the tool found ÷ loans on the senior officer's list, plus extra loans the officer agrees with
The test credit officers trust
Figures right
Random figures opened at their pages; 60 with none wrong bounds the error rate below 5%
A misread vacancy travels into a memo unseen
Honest counts
Ask about a property type the bank never financed
A confident answer to that question is a failure
Analyst minutes
Stopwatch from question to signed note
The cost case rests on it
Memos citing own comps
Share of new memos citing the bank's comparable loans
Coverage of routine loans is where the value grows
The full working-session questions: 21 questions in seven groups
Bring CRE credit, the chief credit officer, review appraisal, relationship managers, loan review, model risk, vendor management and IT into one room. Each question says why it matters, what a strong answer looks like, and the warning sign.
A
CRE loans needing assumptions, by property type, market and maturity
A1
How many CRE loans a year need assumptions set, by property type and market?
Why it mattersShows where comparable loans are plentiful and where they are thin.
Strong answer · warning sign
Counts by type and metro.
One number for the whole book.
A2
How many 2026 and 2027 maturities will we re-underwrite?
Why it mattersMaturities are new underwriting on old buildings.27
Strong answer · warning sign
A maturity schedule by type.
"We renew most of them."
A3
Which property types will we leave out at first, and why?
Why it mattersRare types have few comps; say so early.
Strong answer · warning sign
A short exclusion list.
"Everything, day one."
B
Policy and inner targets
B1
Are our minimums written by property type?
Why it mattersThe guidelines ask for LTV limits by property type and minimum standards for debt service coverage; the OCC booklet explains debt yield as a further test.1,5
Strong answer · warning sign
A table by type.
One minimum for all.
B2
Where are our inner targets written today?
Why it mattersUnwritten targets leave with the officer who holds them.
Strong answer · warning sign
In procedures, by type.
"Ask the chief credit officer."
B3
What counts as comparable, and who decides?
Why it mattersCriteria are a credit judgment and become settings.
Strong answer · warning sign
Written criteria with an owner.
Each analyst's own.
C
Exceptions and outcomes
C1
What does our exception report show, and who reads it?
Why it mattersExaminers read it for volume and trend.5
Strong answer · warning sign
Aged, by type and officer, read by the board.
A list nobody reads.
C2
For our last five vacancy or coverage exceptions, how is each loan doing?
Why it mattersThe cheapest test of whether mitigants work.
Strong answer · warning sign
Answered in an hour.
Answered in a week.
C3
Do we run postmortems on weak loans, before they are losses?
Why it mattersThe 2026 booklet names postmortems as part of workout practice.15
Strong answer · warning sign
A short template, used.
Only after charge-off.
D
Approved memos, dated servicing outcomes and paid-off loan files
D1
Where do approved memos, appraisals and reviews live, and how is "approved" marked?
Why it mattersDrafts must never be read as approved.
Strong answer · warning sign
One system, status recorded.
Shared drives.
D2
Can servicing give dated occupancy, coverage and rating per loan?
Why it mattersOutcomes without dates mislead.
Strong answer · warning sign
A monthly extract.
Annual reviews only, on paper.
D3
Do we keep paid-off loans' files and history?
Why it mattersDropping them biases the comps toward survivors.
Strong answer · warning sign
Kept, marked paid off.
Purged after payoff.
E
Systems and access
E1
Who may see which borrower's name?
Why it mattersOne search crosses many relationships.
Strong answer · warning sign
Entitlements by relationship.
"Everyone in credit."
E2
Where must the research note go, and in what form?
Why it mattersSets the memo integration work.
Strong answer · warning sign
The memo section, named.
Unknown.
E3
Which market data do we license, and where will it sit beside our own comps?
Why it mattersMarket comps lead where the bank's history is thin.
Strong answer · warning sign
Known sources and terms.
Copied from broker packages.
F
SR 26-2, vendor review and keeping comps away from appraisers
F1
Has our model risk policy moved from SR 11-7 to the April 2026 guidance?
Why it mattersThe old letter was replaced on April 17, 2026.13
Strong answer · warning sign
Updated, with a view on AI tools.
Still cites SR 11-7.
F2
What does vendor management need before a pilot sees real borrower data?
Cap rates above the appraisal, apartment vacancy, debt yield and exception reports: CRE loan comps questions
In shortThe questions CRE credit teams and buyers search for most, each answered on its own.
What are CRE loan comps?
CRE loan comps are a lender's own past loans on buildings similar to the one it is underwriting, with the rent, vacancy, expenses, reserves and cap rate it assumed on each and how each loan has performed since. Sales and lease comps show what buildings sold or rented for; loan comps show what the lender accepted and whether that judgment held up. They come from the bank's approved credit memos, appraisals and servicing records.
How is a loan comp different from a sales comp?
A sales comp reports a transaction: price, date, size and an implied cap rate. A loan comp reports the lender's underwriting of a similar building and its outcome: the vacancy and expenses assumed, the coverage at closing, and the occupancy, coverage and risk rating today. Use sales comps for value and loan comps for the assumptions the bank is willing to lend against.
How do you determine a cap rate for a commercial real estate loan?
Divide stabilized net operating income by value or price, and choose the rate for underwriting from evidence: the appraisal's comparable sales, market surveys and the cap rates the bank itself has underwritten on similar buildings. The OCC says cap rates should reflect returns required "under normal, orderly, and sustainable market conditions". Where the bank's own rate differs from the appraisal's, the memo should say why.
Why do banks underwrite cap rates above the appraisal?
An appraiser estimates market value on a date from recent sales, and an appraisal whose comparable sales closed in 2021 or 2022 carries cap rates from near the historic low the Federal Reserve dates to 2022. A lender chooses a rate it can lend against for the loan's term, and appraisals themselves miss later sale prices by about 11% on average. Underwriting somewhat above the appraisal allows for both.
What vacancy rate should a lender underwrite for apartments?
No regulation sets one. Fannie Mae's multifamily guide requires vacancy, concessions and bad debt together of at least 5% of gross potential rent, and a bank can write a similar floor into its own policy. The better evidence is the bank's own comparable loans and how their occupancy held up, together with the local supply pipeline.
How do you size a commercial real estate loan?
Compute the largest loan each policy test allows and lend the lowest: the loan whose payments the NOI covers at the minimum DSCR, a percentage of the lesser of price and appraised value, and the loan on which NOI earns the minimum debt yield. In the fictional example, a 1.25x coverage minimum sets the loan at $30.6 million while loan to value would allow $35.7 million.
What DSCR do banks require for commercial real estate?
Commonly 1.20x to 1.50x, depending on property type, amortization and how stable the income is; the Federal Reserve's stress-test documentation says lenders generally require between 1.2 and 1.5. Each bank sets its own minimum in policy.
What is debt yield and why do lenders use it?
Debt yield is NOI divided by the loan amount, expressed as a percent. The OCC notes it measures risk independently of the interest rate, amortization period and cap rate, which makes it useful when rates and cap rates are low. A minimum debt yield caps the loan even when coverage and loan to value look comfortable.
What is a CRE policy exception report?
It lists every loan approved outside one of the bank's own standards, with the type, approver, date and written justification. Examiners review it for the number and trend of exceptions, and the OCC expects exceptions aged and stratified by volume, loan officer and type. A useful report also shows how each loan is doing now.
How many comparable loans does a bank need?
There is no threshold. Within one property type, class and metro over three years a community bank may have only a handful, which is enough to see a range and an outlier but too few to estimate a default rate. The answer should always state how many loans it rests on, including zero.
Can AI search old credit memos accurately?
It can find and read approved memos, appraisals and servicing records, provided every figure carries its document and page so a person can check it. Test it by replaying past loans limited to what the bank knew at each committee date, opening citations at random, and asking about a property type the bank never financed. The analyst should still choose the assumptions and a credit officer sign.
Is a loan comps search tool a model under SR 26-2?
Mostly no. The April 2026 interagency guidance, issued as Fed SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026, excludes spreadsheet arithmetic and deterministic rule-based software from its definition of a model and places generative AI and AI that acts on its own outside its scope, while telling banks to govern such tools under their own risk management. A tool that also forecasts defaults or sets risk ratings can fall inside it; the bank's third-party program covers the rest.
Are CRE lending standards tightening in 2026?
No, on balance they are easing from a tight level. In the Federal Reserve's July 2026 senior loan officer survey, banks on net eased standards for nonfarm nonresidential and multifamily loans and left construction standards basically unchanged, with the largest banks easing most. In April, banks reported higher loan sizes, narrower spreads and longer interest-only periods over the past year, mainly because of competition. Even so, in July a significant net share placed construction standards at the tighter end of their range since 2005.
Should a lender share its own cap rates with the appraiser?
No. The interagency appraisal guidelines require the collateral valuation function to be independent of loan production. The bank's own cap-rate history belongs in its underwriting and in the review appraiser's assessment of the report. It stays out of the instructions to the appraiser.
24 · One-page summary
Loan comps on one screen: written criteria, approved memos, outcomes beside assumptions, a cited note
Print this page
In shortThe whole guide on one screen: the method, the rules as of October 2026, the readiness bands and the terms.
Find the bank's loans; say why each one is in or out, and how many remain.
Read the approved memo, appraisal and review for each; keep the page.
Join servicing with dates; judge NOI, vacancy and expenses against plan.
Set the assumptions from the comps; explain every move toward the broker.
Size on coverage, loan to value and debt yield; lend the lowest; note the exceptions.
Sign the research note; a credit officer reviews it before committee.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026 replaced SR 11-7 on April 17, 2026 · OCC Lending and Loan Portfolio Risk Management, Version 1.0, dated July 2026 (Bulletin 2026-29) · supervisory LTV limits, the 2006 concentration guidance and the $500,000 appraisal threshold unchanged · $875 billion of CRE mortgages maturing in 2026.
13 terms
Loan comps
The bank's own similar loans, with what it assumed and how each did.
NOI
Net operating income: collected rent and other income less operating expenses and reserves.
Cap rate
NOI ÷ value; lower cap rate, higher value.
Vacancy and credit loss
Share of potential rent not collected; Fannie Mae's floor is 5%.
Replacement reserves
Yearly allowance for roofs, boilers and paving; at least $200 a unit at Fannie Mae.
DSCR
NOI ÷ yearly debt service.
LTV
Loan ÷ the lesser of price and appraised value.
Debt yield
NOI ÷ loan amount.
Pro forma
The broker's or borrower's forecast of income and expenses.
NOI against plan
Actual trailing NOI against the NOI the memo underwrote.
Policy exception
A loan approved outside a bank standard, with written justification.
Inner target
A typical figure inside the policy's outer limit, written in procedures.
Review appraiser
Checks each appraisal, independent of the people making the loan.
25 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
12 CFR part 34, subpart D and Appendix A, Interagency Guidelines for Real Estate Lending (57 FR 62889, December 31, 1992), Code of Federal Regulations, January 1, 2026 edition. govinfo.gov
J. Deppner, B. von Ahlefeldt-Dehn, E. Beracha and W. Schäfers, "Boosting the Accuracy of Commercial Real Estate Appraisals: An Interpretable Machine Learning Approach", Journal of Real Estate Finance and Economics, 2023. doi.org
UT Austin McCombs School of Business, "Underwriting Fraud Imperils Commercial Mortgage Bonds", October 25, 2023. news.mccombs.utexas.edu
J. M. Griffin and A. Priest, "Is COVID Revealing a Virus in CMBS 2.0?", Journal of Finance 78(4), 2233–2276 (2023). doi.org
OCC, Comptroller's Handbook, Commercial Real Estate Lending, Version 2.0, March 2022 (OCC Bulletin 2022-7); reputation-risk references struck as of March 20, 2025 (OCC Bulletin 2025-4). occ.gov
Federal Reserve, H.8 Assets and Liabilities of Commercial Banks in the United States, released October 30, 2026 (September 2026 data, Tables 1, 2 and 8). federalreserve.gov
MBA NewsLink (Mortgage Bankers Association), "MBA: 17% of Commercial and Multifamily Mortgage Balances to Mature in 2026", February 9, 2026 (MBA 2025 Commercial Real Estate Survey of Loan Maturity Volumes; balances at December 31, 2025). newslink.mba.org
D. Glancy, "Pretend or Amend? On Evergreening in CRE", FEDS 2026-025, May 2026. federalreserve.gov
Scotsman Guide (R. Kingsley), "CMBS delinquencies reach highest level since 2020", October 6, 2026 (Trepp CMBS delinquency rates for September 2026, with August 2026 and September 2025). scotsmanguide.com
FRED, Delinquency Rate on Commercial Real Estate Loans (Excluding Farmland), All Commercial Banks (DRCRELEXFACBS), and charge-off rate (CORCREXFACBS), through Q2 2026. fred.stlouisfed.org
FDIC, Quarterly Banking Profile, Second Quarter 2026, Table V-A. fdic.gov
OCC, Semiannual Risk Perspective, Spring 2026. occ.gov
FRED, SLOOS net percentage of banks tightening standards for CRE loans (SUBLPDRCSC, SUBLPDRCSN, SUBLPDRCSM), through July 2026. fred.stlouisfed.org
CFPB, Equal Credit Opportunity Act (Regulation B) final rule, 91 FR 21620, April 22, 2026, effective July 21, 2026. consumerfinance.gov
O*NET OnLine (U.S. Department of Labor), 13-2041.00 Credit Analysts, Wages & Employment: median $83,510 a year (BLS 2025 wage data). onetonline.org
BLS, Employer Costs for Employee Compensation, June 2026 (USDL-26-1494, September 9, 2026): wages 70.0% of private industry employer costs; release text archived by FRASER. fraser.stlouisfed.org
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