A commercial real estate loan usually runs five to ten years, with payments set as if it would take twenty-five to repay, so on its last day most of the money is still owed in one large payment. The borrower can pay it only with a new loan, a sale or fresh cash. Maturity management is the lender's work of checking each loan months before that day, at today's rates and values, and deciding whether to refinance it, extend it on new conditions or work it out, with the evidence on file before the date arrives.
This guide is for anyone who carries a maturing CRE loan: portfolio managers, relationship managers, credit officers, special assets officers, chief credit officers, loan review, and the leaders deciding whether to automate the work. No background needed.
Imagine you are the portfolio manager who tracks every commercial real estate loan coming due at a regional bank in Charlotte, North Carolina. It is Monday, October 12, 2026. One of your 512 loans, a $38.5 million loan on Linden Crossing, a four-story suburban office building, was made in February 2019 at a fixed 4.15%. It was written for eight years with payments set on 25, so on February 1, 2027, 112 days from today, the owner owes the bank $30,174,256 in one payment.
Every monthly payment for eight years has arrived on time. The owner, Aldercrest Partners, is backed by its principal, Graham Holloway, who personally guarantees part of the loan.
The appraisal in the 2019 file valued the building at $55.0 million. A new one, effective September 15, 2026, on page 3 of the appraiser's report, says $32,625,000: the building is 78.4% leased instead of 94%, and buyers now pay for offices on an 8% return instead of 6.25%. Your bank lends at most 65% of value on an office refinance today.
What is owed · February 1, 2027
Loan
CRE-19-0412
Original
$38,500,000 (2019)
Balance due
$30,174,256
Payment record
96 of 96 on time
What today's terms lend · appraisal p. 3
Value
$32,625,000 (2026)
Limit
65% of value
New loan
$21,206,250
Short by
$8,968,006
A refinance needs $8.97M of new cashThe guarantor has $11.4Mand must keep $5.0M under his guaranty.
Paying the whole shortfall would leave Holloway $2,431,994 in cash, below the $5.0 million his guaranty requires him to keep, so a clean refinance is off the table. A 24-month extension with $3.0 million paid down, a market rate and a $1.2 million leasing reserve leaves a $27,174,256 loan that the building's income covers 1.12 times. With current financials and a current appraisal in the file, examiners can accept that as a pass, the grade for a sound loan.
Sizing the loan four months early catches the $8.97 million gap while the owner can still close part of it, and shows which answer an examiner will accept.
Balloon payments, refinance gaps and the 2023 workout statement: how a maturing CRE loan is decided
Balloons, the refinance test, the 2023 workout statement, valuations, the 2026 maturity wall, the common mistakes and how lenders run the work today, explained without selling anything. If you are new to commercial real estate lending, start here.
01 · In plain words
What happens when a commercial real estate loan comes due
A home loan is usually paid down each month until nothing is left. A commercial real estate loan is built another way: a bank lends against an office building or an apartment complex for five, seven or ten years, but sets the payment as if the loan would run 25 or 30. When the term ends, most of the money is still owed in one payment, the balloon. Few owners have that much cash, so they pay it with a new loan, the sale of the building or a deal with the bank.
That makes the maturity date a second credit decision. The bank asks the questions it asked when it made the loan, with today's answers: how much income the building earns now, what it is worth now, what interest rate a new loan would carry, and how strong the owner is now. Lenders call the investor behind the borrowing company the sponsor, and often the sponsor's principal personally guarantees the loan.
If a new loan on those facts covers the balloon, the loan can be refinanced. If it falls short, the difference is called the refinance gap, and somebody has to fill it: the owner with fresh cash, the bank with more time, or both with a new structure.
Lenders have three broad answers. They can refinance on today's terms. They can extend the loan for a year or two, usually with conditions such as a paydown, a market interest rate or a reserve for leasing costs. Or they can work it out: restructure the debt, agree to wait while the property is sold, or in the end take the building.
The 2023 federal policy statement on CRE workouts says a lender that does this after a careful review of the borrower will not be criticized for it, even if the loan ends up graded as a problem.1 The careful review is the hard part: the evidence sits in the rent roll and operating statement the owner sends, the appraisal in the credit file, the guarantor's personal financial statement, and the market.
Gathering and reading it takes weeks, so the work has to start months before the date. When it starts late, the bank ends up granting a short extension "while we look at it", which moves the date without fixing anything.
The life of one maturing loan, in five steps
The loan is made2019: $38.5 million on an office building, 4.15% fixed, eight years, payments set on 25 years. 94% leased, worth $55 million.
The years passEvery payment on time. Rates rise, tenants shrink, and buyers start paying less for offices.
The loan is sized again before its dateToday's income, today's value, today's rate. The new loan would be $8.97 million short. This is where the decision is made, early or late.
Refinance, extend or work outThe options are compared, the loan is graded, the decision is approved and written up for examiners.
The balloon is paid or re-datedA refinance pays it; an extension moves it to a later date, which comes round again.
Step 3 is the subject of this guide. The bank, building, people and figures in this example are fictional.
Four surprises about CRE loans that reach their balloon date
A perfect payment record proves little
A loan can pay on time for eight years and still fail on its last day, because the new loan is sized on today's value and rate. The OCC's handbook warns that borrowers able to make their payments "could find it difficult to refinance their balloon payment amount at maturity because of declines in property value".2
A loan worth less than its balance can still be a pass
The 2023 statement's own office example keeps a renewed loan at 102% of the building's value as a pass, because current financials showed the borrower could pay at a market rate.1
The same loan becomes special mention when the file is stale
In the next scenario of that example, a similar renewal with no new valuation and no new financial statements is listed special mention. The examiner cites a falling revenue trend and the lender's "administrative weaknesses".1 The paperwork is the part the lender controls.
Rates rose again in the fall of 2026
Market data: the 5-year Treasury, a common base for refinance pricing, averaged 3.70% in December 2025 and 4.80% in September 2026, and closed at 4.78% on October 29, 2026 (FRED).3 Every maturing loan's coverage test moved with it.
Balloon, refinance gap, debt service coverage, extension
Balloon
The large final payment of a loan whose monthly payments did not pay it down in full during its term.
Refinance gap
The balance due at maturity less the largest new loan the lender's current terms would make. Positive means short.
Debt service coverage
The property's net operating income divided by a year of loan payments. 1.25x means $1.25 of income per $1.00 of payments.
Extension
Keeping the loan for a further term with the same lender, usually with new conditions. Also called a renewal.
Why most CRE loans end with a balloon, and how the refinance gap opens
In shortA short term on a long payment schedule leaves most of the loan unpaid at maturity, so repayment depends on a new loan sized on new facts. When income or value has fallen, or rates have risen, the new loan is smaller than the balloon and a gap opens. Maturity management is finding that gap early enough to close it.
Lenders like short terms on income property because each maturity is a chance to look again. The OCC's handbook calls it "a built-in restructuring trigger, for example, a loan with a five-year tenor and payments based on a 20-year amortization", which lets the bank "periodically review the strength of the primary and secondary repayment sources and re-underwrite the credit".2 Borrowers like long amortization because it keeps the monthly payment low. The price of both is the balloon.
A five-year loan on a 25-year schedule still owes about 90% at maturity
Share of the original loan still owed when the term ends, at a 6% fixed rate
Interest only100%
5-year term, 25-year schedule89.9%
7-year term, 25-year schedule85%
5-year term, 20-year schedule84.9%
10-year term, 30-year schedule83.7%
10-year term, 25-year schedule76.4%
Illustrative · replace with your own numbers · Standard loan arithmetic at a 6% rate; your loans' rates change the figures a little. The guide's example, 8 years on 25 at 4.15%, still owes 78.4%.
Show the numbers
Item
Value
Interest only
100%
5-year term, 25-year schedule
89.9%
7-year term, 25-year schedule
85%
5-year term, 20-year schedule
84.9%
10-year term, 30-year schedule
83.7%
10-year term, 25-year schedule
76.4%
The three questions behind every maturity
Income
What does the building earn now?
Net operating income is rent and other income less operating costs, before loan payments. At maturity the lender rebuilds it from a current rent roll and operating statement, leaving out leases that are not signed.
Value
What is it worth now?
Commercial buildings are valued mostly by dividing income by a capitalization rate, the return buyers demand. When cap rates rise from 6.25% to 8%, the same income is worth 22% less.
Rate
What would a new loan cost?
Refinance rates are usually a spread over a Treasury yield. A higher rate raises the payment, so the same income supports a smaller loan.
How the gap opens on one loan
In the guide's example, all three moved against the loan at once. Net operating income fell from $3,664,000 at origination to $2,610,000 underwritten today, as tenants left and the largest one shrank. The value fell 40.7%, from $55.0 million to $32,625,000, as the cap rate rose and income fell. The rate on a new office loan at the example bank is 7.10% against the 4.15% the borrower pays now. The balloon is $30,174,256; the largest new loan the bank's terms allow is $21,206,250.
Income, value and the loan the bank will make all fell between 2019 and 2026
Linden Crossing, at origination and today, in millions of dollars
At origination, 2019Today, 2026
Net operating income$3.7M$2.6M
Appraised value$55M$32.6M
Loan the bank will make$38.5M$21.2M
Balance owed$38.5M$30.2M
Fictional example from this guide · Fictional. The 2019 loan was 70% of value; today 65% of the new value lends $21.2M against $30.2M owed.
Show the numbers
At origination, 2019
Today, 2026
Net operating income
$3.7M
$2.6M
Appraised value
$55M
$32.6M
Loan the bank will make
$38.5M
$21.2M
Balance owed
$38.5M
$30.2M
The building still pays: coverage on today's 4.15% payment is 1.11x on trailing income. The trouble sits at the date, when the loan has to be replaced on 2026 terms.
03 · The 2026 maturity wall
How big the 2026 CRE maturity wall is, who holds it, and why it keeps moving
Figures as of October 2026
In shortAbout $875 billion of commercial and multifamily mortgages is scheduled to mature in 2026, 17% of everything outstanding. Banks and other depositories service $396 billion of it. The total keeps moving because lenders extend loans into later years: a record $384 billion was pushed into 2025, and the same comparison of the MBA's surveys shows about $212 billion added to 2026.
The best-known count of CRE maturities is the Mortgage Bankers Association's annual survey. Its February 2026 release found that 17% of the $5.0 trillion of commercial and multifamily mortgages held by lenders and investors, about $875 billion, was scheduled to mature in 2026, down 9% from the $957 billion scheduled for 2025, with $652 billion scheduled for 2027.4
Two cautions come with the figures. They are unpaid balances at the end of the prior year, so the balloons will generally be smaller.4 And they are schedules, and in recent years a large share has been extended into later years.5,6
The scheduled wall peaked in 2025 and is smaller for 2026
Commercial and multifamily mortgages scheduled to mature in the survey year, and the next year's schedule
$929B2024
$957B2025
$875B2026
$652B2027 (scheduled)
Source7,5,4 · Each year's figure is from the MBA survey released that February; the 2027 figure is the February 2026 schedule and will rise as loans are extended into it.
Show the numbers
Period
Value
2024
$929B
2025
$957B
2026
$875B
2027 (scheduled)
$652B
Who holds the 2026 maturities
Depositories, mostly banks, carry the largest dollar amount: $396 billion of the commercial mortgages they service, 21% of the balance, comes due in 2026, against $452 billion (25%) for 2025 and $441 billion (25%) for 2024.4,5,7 Commercial mortgage securities and similar vehicles face $200 billion, 25% of theirs, and credit companies and warehouse lenders $163 billion, 29%.4 Life insurers face $76 billion (10%), and the multifamily and health care loans held or guaranteed by Fannie Mae, Freddie Mac, FHA and Ginnie Mae $39 billion (4%).4
The bank share is spread across many institutions. The Federal Reserve's H.8 release puts commercial real estate loans at all US commercial banks at about $3.14 trillion in September 2026, seasonally adjusted, and about 70% of the CRE held by domestically chartered banks sits outside the 25 largest.8
The FDIC's 2026 Risk Review puts the median bank's CRE loans at 200% of its capital and allowance, 289% at banks of $10 billion to $100 billion and 311% at banks of $1 billion to $10 billion.9 A bank at three times capital in CRE, a fifth of which matures in a year, re-underwrites well over half its capital's worth of loans every twelve months.
Banks of $1 billion to $100 billion hold the most CRE against their capital
Median CRE loans as a share of tier 1 capital plus the allowance, year-end 2025
Banks of $1–10 billion311%
Banks of $10–100 billion289%
All banks (median)200%
Source9 · FDIC 2026 Risk Review. The higher the ratio, the more of the bank's capital each year's maturities put back on the table.
Show the numbers
Item
Value
Banks of $1–10 billion
311%
Banks of $10–100 billion
289%
All banks (median)
200%
Hotels have the largest share of their loans maturing in 2026
Share of each property type's outstanding mortgage balance scheduled to mature in 2026
Hotel and motel30%
Industrial23%
Office17%
Health care15%
Multifamily13%
Source4 · Share of volume says where the maturities are; the refinance gap, which follows value and income, says where the trouble is. Office carries the largest fall in value.
Show the numbers
Item
Value
Hotel and motel
30%
Industrial
23%
Office
17%
Health care
15%
Multifamily
13%
Why the wall moves: extensions
Each year's wall is made of new maturities plus old ones carried forward. Colliers, comparing the MBA's surveys year over year, counted $384 billion of loans extended from earlier years into 2025, up 42% from $270 billion into 2024 and about 40% of all 2025 maturities. Office owners received $85 billion of those extensions, 45% of the $187 billion of office loans due in 2025.6
The MBA's earlier survey scheduled $663 billion for 2026;10 its February 2026 survey counts $875 billion,4 so the same comparison shows about $212 billion added to 2026, a little over half the 2025 figure. The MBA's chief economist called 2025 "a transition year" in which "lenders were no longer simply extending loan terms".4
Extensions into 2025 set a record; about half as much was added to 2026
CRE loans carried from earlier years into the year shown, measured by comparing one MBA survey's schedule with the next
$270BInto 2024
$384BInto 2025
$212BInto 2026
Source6,10,4 · 2024 and 2025: Colliers on MBA data. 2026: our arithmetic on the same method, $875B (MBA, February 2026) less the $663B the previous survey scheduled for 2026. New short loans that mature within the year also count, so read it as approximate.
Show the numbers
Period
Value
Into 2024
$270B
Into 2025
$384B
Into 2026
$212B
The industry wall is the wrong number for one bank. What matters to a lender is how much of its own book would not refinance at today's terms, in which months and property types, and how many of those loans already have a decision. That number is only available loan by loan.
04 · The rules and their dates
The guidance that governs a maturing CRE loan, and what changed by October 2026
Status as of October 2026
In shortNo regulation tells a bank what to do with a maturing loan. Four texts shape the answer: the 2023 interagency workout statement (how examiners grade extensions and restructurings), the OCC's 2024 refinance-risk bulletin (watch maturities across the portfolio), the appraisal rules (when a renewal needs a new valuation) and ASU 2022-02 (which extensions must be disclosed). The model-risk guidance changed in April 2026.
The workout statement and the refinance-risk bulletin are both still in force
Apr 2018Appraisal threshold rule
Commercial threshold raised to $500,000; renewals of existing loans keep their own exemption.
Jul 6, 2023Workout statement
OCC, Fed, FDIC and NCUA replace the 2009 statement: prudent workouts after a comprehensive review are not criticized.
2023TDR accounting ends
ASU 2022-02 in effect for CECL adopters: modifications to borrowers in difficulty are disclosed instead.
Oct 3, 2024OCC Bulletin 2024-29
Refinance risk to be measured at each loan and across the portfolio, with maturity monitoring and stress tests.
Apr 17, 2026SR 26-2, OCC 2026-13, FIL-15-2026
Joint revised model risk guidance replaces SR 11-7 and OCC 2011-12; spreadsheet arithmetic falls outside the model definition.
Jun 2026Examiners' focus
The Fed reviews CRE underwriting, classifications and reserves at community and regional banks.
Policy Statement on Prudent CRE Loan Accommodations and Workouts (88 FR 43115)
A workout plan on current information; global debt service coverage; a guarantor tested against all the guarantees it has given; an accurate grade, accrual decision and allowance. Renewals to borrowers who can repay on reasonable terms "will not automatically be subject to adverse classification".1
In force since July 2023; Fed SR 23-5 and OCC Bulletin 2023-23 apply it to banks of every size18,19
Evaluate refinance risk at approval, in monitoring, near maturity and when considering extensions; "processes to identify, measure, monitor, and control refinance risk at the portfolio level", including monitoring maturities and stress testing.13
Issued October 3, 2024; no rescission found as of October 2026
OCC Comptroller's Handbook, Commercial Real Estate Lending
Cap rates, interest rates and coverage "should be stress-tested"; lists "rewrites or renewals for the sole purpose of deferring repayment" among weak practices.2
Version 2.0, March 2022; reputation-risk references removed March 20, 2025
Appraisal rules, 12 CFR 34.43 and the FDIC and Fed versions
A renewal needs no new appraisal if no new money is advanced or the market and property have not materially changed, but still needs "an appropriate evaluation".20
Troubled debt restructuring accounting removed; modifications to borrowers experiencing financial difficulty, including term extensions, are disclosed.12
In effect for CECL adopters
SR 26-2 (Fed), OCC Bulletin 2026-13 and FDIC FIL-15-2026
Model risk management. Simple spreadsheet arithmetic is outside the definition of a model, and generative AI is outside the guidance's scope.14,15,16
April 17, 2026, one joint issuance; replaced SR 11-7 and OCC 2011-12
The 2023 statement is supervisory guidance: it explains how examiners will judge a loan. It is the text they carry into a CRE file review, and its appendix of worked examples is the closest thing the industry has to a grading key.
05 · Sizing the refinance
How to size a maturing loan: coverage, loan-to-value and debt yield, worked through
In shortSize the loan three ways at the lender's current terms for its property type and take the smallest result. The test that gives the smallest loan names the problem: value, rate or income. The gap is the balloon less that loan. Rates move the answer, so sizing has to be repeated as the curve moves.
Coverage, loan-to-value and debt yield on a maturing loan
Coverage
Debt service coverage
Income ÷ minimum coverage = the most the property can pay a year. Turn that payment into a loan amount at today's rate and amortization.
NOI ÷ min DSCR → payment → loan
Value
Loan-to-value
The maximum loan-to-value times today's value from a current appraisal or evaluation.
max LTV × value
Income alone
Debt yield
Income ÷ minimum debt yield. The OCC: it "provides a measurement of risk that is independent of the interest rate, amortization period, and capitalization rate".2
NOI ÷ min debt yield
No regulator sets the numbers; each bank's credit policy does, and the OCC's handbook says effective policies set minimum coverage, loan-to-value limits and a minimum debt yield for each type of loan or property.2
The Fed's stress-test documentation notes that lenders "generally require a minimum DSCR between 1.2 and 1.5" to refinance a balloon.21 The fictional example bank's rate sheet, which its screens show, prices office refinances at 7.10% (a 5-year Treasury input of 3.85% plus a 3.25% spread), with 25-year amortization, 1.25x minimum coverage, 65% maximum loan-to-value and a 10% minimum debt yield.
Loan-to-value binds: the bank's terms lend $21.2M against $30.2M owed
Linden Crossing, sized at the example bank's office terms on $2,610,000 of underwritten income
Balance owed at maturity$30.2M
65% of the $32,625,000 value$21.2M
1.25x coverage at 7.10%, 25 years$24.4M
10% debt yield$26.1M
Fictional example from this guide · Fictional. The smallest of the three limits sets the loan; the gap is $30,174,256 − $21,206,250 = $8,968,006, 29.7% of the balance.
Show the numbers
Item
Value
Balance owed at maturity
$30.2M
65% of the $32,625,000 value
$21.2M
1.25x coverage at 7.10%, 25 years
$24.4M
10% debt yield
$26.1M
Which limit binds, and the fix it points to
When this binds
The problem is
Typical fixes
Loan-to-value
Value has fallen faster than income, as on offices whose cap rates have risen
Equity in, time for value to recover, a restructure that recognizes the loss
Coverage
The rate: floating-rate bridge loans, hotels, loans written at the bottom of the cycle
A longer amortization, a rate cap, more income, a paydown
Debt yield
The property earns too little for the debt, whatever the rate or value
A smaller loan; only income growth helps
Rates rose again in 2026, and every coverage test moved with them
Refinance rates are built on Treasury yields, and the 5-year Treasury has moved a long way since the loans now maturing were written. Market data from FRED: it averaged 2.49% in February 2019, 0.27% in August 2020, 4.77% in October 2023 and 3.70% in December 2025, then 4.80% in September 2026; it closed at 4.78% on October 29, 2026.3
Loans written in 2019 to 2021 were priced off a 5-year Treasury averaging under 2%; in 2026 it has averaged 4.21%
5-year Treasury yield, average for each year, percent
0%2%4%6%4.21%
20192020202120222023202420252026
Source3 · Market data: yearly averages of the daily series DGS5 on FRED, read October 30, 2026; 2026 is January 2 to October 29. October 2026 alone averaged 4.94%.
Show the numbers
5-year Treasury
2019
1.95%
2020
0.53%
2021
0.86%
2022
3%
2023
4.06%
2024
4.13%
2025
3.92%
2026
4.21%
The guide's example follows its own fictional rate sheet, a 3.85% Treasury input plus the office spread, because that is what its screens show. A lender working the same file would rerun it at the day's Treasury. On any loan, a higher rate shrinks the loan the coverage test allows and thins the coverage of an extended loan; it moves the gap only when coverage becomes the binding test. Rate assumptions are policy settings, and they go stale. Refresh them with the curve.
Size on underwritten income, at today's terms, every time. Sizing on the note rate, on trailing income, or with a lease that is not yet signed gives a flattering answer. OCC Bulletin 2024-29 asks banks to test whether a borrower could refinance if its finances or the market worsen, and calls multivariable stress testing "one common method" to assess it.13
06 · How examiners grade it
How the 2023 workout statement grades an extension: the office example, scenario by scenario
In shortExaminers grade a renewed loan by the borrower's ability to pay on reasonable terms, shown with current evidence. The statement's office example renews the same 1.12x loan twice: with a new appraisal and new financials it stays a pass; with an estimate and old statements it becomes special mention. Below-market, interest-only terms to a slow payer make it substandard.
The statement reaffirms two principles from 2009. Lenders "that implement prudent CRE loan accommodation and workout arrangements after performing a comprehensive review of a borrower's financial condition will not be subject to criticism for engaging in these efforts, even if these arrangements result in modified loans that have weaknesses that result in adverse classification". And loans to borrowers "who have the ability to repay their debts according to reasonable terms will not be subject to adverse classification" solely because the collateral is worth less than the loan.1 Both protections depend on the file.
The office example, three renewals of one loan
The example starts with a $15 million office loan, amortized over 20 years, with a $13.6 million balloon after five years, made at 75% of a $20 million value and 1.30x coverage. Hybrid work cuts the building's income. At maturity the lender renews it three different ways.1
The same office loan ends pass, special mention or substandard depending on terms and evidence
Office example, Scenarios 1 to 3, in the 2023 interagency workout statement: what each renewal had, and the grade it got
Weak or missingPartlyIn place
Market rateCurrent valuationCurrent financialsPayment record1 · PassIn placeIn placeIn placeIn place2 · Special mentionIn placeWeak or missingWeak or missingIn place3 · SubstandardWeak or missingIn placePartlyWeak or missing
Our reading of the sources1 · Scenario 1: renewed one year at a market rate, 1.12x, recent appraisal at 102% LTV, pass. Scenario 2: renewed at a market rate, lender's own estimate at 94% LTV, no current financials, special mention. Scenario 3: 12 months interest-only at a below-market rate, sporadic delinquency, 1.10x, substandard and nonaccrual.
Show the numbers
Market rate
Current valuation
Current financials
Payment record
1 · Pass
In place
In place
In place
In place
2 · Special mention
In place
Weak or missing
Weak or missing
In place
3 · Substandard
Weak or missing
In place
Partly
Weak or missing
Scenario 1 has the worse loan-to-value, 102% against 94%, and keeps its pass. Scenario 2's lower figure came from the lender's own estimate, and the examiner noted that the lender "failed to request current financial information and to obtain an updated collateral valuation, representing administrative weaknesses".1 Scenario 2 also had real weaknesses, a falling revenue trend and slowing leasing, so documentation was one problem among several. It was the one the lender fully controlled.
What examiners need to see in the file
The statement expects
Evidence that satisfies it
How it usually fails at maturity
A "well-conceived and prudent workout plan" on current information1
Current rent roll, operating statement and guarantor statements, with dates
Whatever the borrower last sent, a year or more old
Global debt service coverage with realistic projections1
Property income plus the borrower's and guarantors' other income and debts
Property coverage alone
A guarantor able to cover "the total number and amount of guarantees currently extended"1
Liquidity and net worth against every contingent liability
Liquidity counted against this loan only
A current valuation where conditions have changed1,22
New appraisal or evaluation, reviewed before the decision
Term extension to a borrower in difficulty disclosed as a modification
Extension booked as a routine renewal
Three accounting rules that bite at maturity
Accrual
Six months to come back
A restructured loan put on nonaccrual returns to accrual only after "sustained repayment performance", which "generally would be a minimum of six months".1
Collateral-dependent
The excess is loss
As a general principle, for a problem loan that depends on selling the property and has no other reliable source of repayment, such as a capable guarantor, the part above fair value less costs to sell is classified loss.1
Disclosure
Term extensions are reported
Since ASU 2022-02, modifications to borrowers experiencing financial difficulty, including term extensions, are disclosed. A disclosed extension can still be a pass.12
Extensions can hide a weak loan. The statement warns that being current on payments can mislead when "the liberal use of extensions and renewals masks credit weaknesses and obscures a borrower's inability to meet reasonable repayment terms".1 An extension is acceptable when the file shows why the borrower can pay; it is a problem when it only moves the date.
07 · The five paths
Refinance, extend, restructure, forbear or exit: the five paths a maturing loan can take
In shortEvery maturing loan ends on one of five paths. The size of the gap and the sponsor's ability to fill it decide which are open. Starting early keeps more of them open; starting late usually leaves a short extension or a forced sale.
Five paths, from the cleanest to the most expensive
1Refinance
A new loan on today's terms pays off the balloon. Needs the gap to be zero or covered by the borrower's cash.
Same lender or anotherCleanest
2Extend with conditions
More time at a market rate, usually with a paydown, a reserve, a cash sweep and a reaffirmed guarantee.
Same lenderMost common
3Restructure
A formal change in terms, such as an A note the property supports and a B note charged off.
Same lenderLoss recognized
4Forbear
The lender agrees not to enforce for a set period while a sale, lease or refinance completes.
Same lenderBuys time only
5Exit
Payoff from a sale, a discounted payoff, a note sale, foreclosure or a deed in lieu.
A new loan on today's terms pays off the balloon. Needs the gap to be zero or covered by the borrower's cash.
Same lender or another
Cleanest
Extend with conditions
More time at a market rate, usually with a paydown, a reserve, a cash sweep and a reaffirmed guarantee.
Same lender
Most common
Restructure
A formal change in terms, such as an A note the property supports and a B note charged off.
Same lender
Loss recognized
Forbear
The lender agrees not to enforce for a set period while a sale, lease or refinance completes.
Same lender
Buys time only
Exit
Payoff from a sale, a discounted payoff, a note sale, foreclosure or a deed in lieu.
Lender and borrower part
Most costly
How the A note and B note work
A restructuring is "a formal, legally enforceable modification in the loan's terms", in the statement's words.1
The best-known form at maturity splits the debt in two. Note A is sized to what the property supports today and keeps paying. Note B is the rest; the lender charges it off but keeps it as a claim, which bankers call a hope note. The statement says that when a collateral-dependent loan is split this way, Note A should be sized using the fair value of the collateral, that a properly structured and performing Note A generally would not be adversely classified, and that Note B is classified loss.1
The statement's shopping-mall example shows how differently two restructurings of the same $10 million loan are graded.1
What the lender did
What the examiner concluded
Kept one note, interest-only for a year at a below-market rate
The $1 million above the $9 million value classified loss and charged off; the rest substandard; the loan on nonaccrual1
Split it into a $7 million Note A at a market rate, covered 1.20 times, and a $3 million Note B charged off; the borrower then paid for more than six months
The gap and the sponsor's cash together point to the path
Sponsor's ability to put money in →
Refinance
Extend, paydown
Extend on terms
Restructure or exit
Small gap, strongLarge gap, strongSmall gap, weakLarge gap, weakLinden Crossing
Size of the refinance gap →
Our reading of the sources1 · A reading of the statement's examples. Positions are illustrative; the example loan has a 29.7% gap and a guarantor who can fund $3.0M of it.
Show the numbers
Item
Size of the refinance gap (0–1)
Sponsor's ability to put money in (0–1)
Small gap, strong
0.20
0.62
Large gap, strong
0.78
0.74
Small gap, weak
0.15
0.22
Large gap, weak
0.78
0.10
Linden Crossing
0.60
0.55
One simple way to sort maturing loans is by thresholds on the gap as a share of the balance. The example bank's: refinance when the loan passes or a paydown under 5% closes the gap; extend with conditions for gaps of 5% to 32%; work out above 32% or when the loan is already with special assets. Treat such lanes as a first sort for the officer.
08 · Values and appraisals
When a CRE renewal needs a new appraisal, and how far values have fallen
In shortA renewal of a loan the bank already holds needs no new appraisal by rule unless new money is advanced and conditions have materially changed, but it always needs a valid evaluation. Office values are still about a third below their 2022 peak, so most office files need a fresh number, ordered early enough to be read before the decision.
The appraisal rules exempt a renewal of an existing loan if "there has been no obvious and material change in market conditions or physical aspects of the property that threatens the adequacy of the institution's real estate collateral protection", or if "there is no advancement of new monies, other than funds necessary to cover reasonable closing costs". Either way, the bank "shall obtain an appropriate evaluation".20
The agencies' FAQs add two points people misremember: "there is no provision in the agencies' appraisal regulations specifying the useful life of an appraisal or evaluation", and "a final credit decision or action should only occur after the financial institution receives, reviews, and accepts the appraisal or evaluation".22
Six signs a new valuation is due
For a renewal that is part of a workout, the 2023 statement lists material deterioration in six things that should make a lender consider a new appraisal or evaluation: project performance; conditions in the market and for the property type; the difference between actual conditions and the original appraisal's assumptions; changes to the project's specifications; loss of a significant lease or take-out commitment; and increases in pre-sale fallout.1
In the guide's example, two fired at once: a 20.5% tenant gave back a quarter of its space, and office cap rates had moved from 6.25% to about 8%.
Office values remain 34% below their 2022 peak, the deepest fall of any major type
Commercial property values in June 2026, percent below the 2022 peak, Green Street index
Office34%
Self-storage22%
Apartments19%
Net lease18%
All property14%
Industrial11%
Health care11%
Lodging9%
Data centers7%
Strip retail2%
Malls1%
Source23 · Reported by CRE Daily (July 9, 2026) from Green Street's Commercial Property Price Index for June 2026.
Show the numbers
Item
Value
Office
34%
Self-storage
22%
Apartments
19%
Net lease
18%
All property
14%
Industrial
11%
Health care
11%
Lodging
9%
Data centers
7%
Strip retail
2%
Malls
1%
As is or as stabilized
Commercial appraisals often carry more than one value: "as is" today, and "as complete" or "as stabilized" once leasing is finished. The statement says lenders typically use "the market value conclusion (and not the fair value) that corresponds to the workout plan objective and the loan commitment".1 A maturity sized on an as-stabilized value for a building that is losing tenants overstates the loan the bank can make.
When the agencies raised the commercial threshold in 2018 they estimated that "an evaluation takes approximately 30 minutes less to review than an appraisal", a reminder that the time saved by skipping an appraisal is small next to the risk of a stale value.11
Write the valuation rule as a test. The rules leave the threshold to the bank. A rule such as "a new appraisal when value may have fallen 20%, or a lease over 15% of the space is lost" can be applied to every maturing loan from the rent roll and market data, months before the date.
09 · The common mistakes
Eight ways maturity decisions go wrong, and the evidence that prevents each
In shortMost maturity mistakes come from starting late, sizing on old numbers, or testing the guarantor against one loan. The Fed's own stress-test model has to multiply its default estimate by four for loans approaching maturity with thin coverage, which says how sharply risk rises in the last stretch.
×4
The Fed's supervisory stress test adjusts the default probability "upwards by a factor of four" for income-producing loans that approach maturity with coverage below 1.2x, because its statistical model under-predicts their defaults.21
Federal Reserve, credit risk model documentation, 2026 test
64%
of office loans, and 43% of all CRE loans, "may face cash flow and refinancing issues", in one loan-level study after rates rose.24
NBER Working Paper 31970
4 of 5
large loans behind September 2026's rise in securitized loan delinquency had "missed maturity payoff dates earlier in the year".25
Trepp, reported October 6, 2026
Mistake
Why it happens
What prevents it
Starting at 60 days
Nobody sizes the loan until the borrower asks
Documents requested about 180 days out; a decision file at about 120
The "while we look at it" extension
The date arrives without a decision
A decision before the date; the OCC lists renewals "for the sole purpose of deferring repayment" as weak practice2
Sizing on the note rate
The servicing system holds the old terms
Current refinance terms by property type, refreshed with the curve
Counting unsigned leases
Letters of intent read like leases
Underwritten income from signed leases only; renewals at market
office loans in negative equity after the 2022–23 rate rise, in a loan-level study (14 in 100 across all CRE loans)
44 of 100
Federal Reserve staff research on bank loans adds that "higher LTVs, larger property sizes, and greater local remote work tendencies are all associated with increased delinquency risk, particularly for office loans".26 A bank's own share, measured on its own loans at its own terms, is usually smaller and far more useful.
10 · The risk in 2026
Where CRE refinance risk sits in October 2026: banks, securities, and the extend-and-pretend debate
Figures as of October 2026
In shortBank CRE loans look healthy on the surface: 1.23% of banks' nonfarm nonresidential loans were noncurrent at June 30, 2026. The stress shows in commercial mortgage securities, where Trepp counts 8.02% of loans delinquent and office over 12%. Regulators call refinance risk the thing to watch, and two Federal Reserve studies disagree about whether bank extensions were prudent.
Bank CRE loans are about 1% noncurrent while securitized office loans run over 12% delinquent
Bank noncurrent rates at June 30, 2026 (FDIC) and Trepp's CMBS delinquency rates for September 2026, percent
CMBS office12.2%
CMBS multifamily8.04%
CMBS, all loans8.02%
CMBS lodging6.18%
Bank nonfarm nonresidential1.23%
Bank multifamily1.1%
Bank construction0.99%
Source27,25 · Two different measures: the FDIC counts bank loans 90 or more days past due or on nonaccrual; Trepp publishes its own CMBS delinquency series, reported by Scotsman Guide. Read them as two levels; the definitions differ.
Show the numbers
Item
Value
CMBS office
12.2%
CMBS multifamily
8.04%
CMBS, all loans
8.02%
CMBS lodging
6.18%
Bank nonfarm nonresidential
1.23%
Bank multifamily
1.1%
Bank construction
0.99%
At June 30, 2026, 1.23% of banks' nonfarm nonresidential loans, $1,943.2 billion in all, were noncurrent, with 1.10% of multifamily and 0.99% of construction loans.27 Past-due and nonaccrual nonfarm nonresidential loans fell 14 basis points in the quarter to 1.52%.27 Part of the reason is modification: the FDIC counts $11.6 billion of modified CRE loans in 2025, 0.38% of the CRE-secured portfolio, 82% of them performing.9
Commercial mortgage securities show the stress more plainly. Trepp's delinquency rate rose to 8.02% in September 2026, the highest since 2020; office was 12.16%, multifamily 8.04%, lodging 6.18%, retail 6.58% and industrial 1.14%.25
The OCC and the Fed on CRE refinance risk in 2026
OCC · Spring 2026
"Refinance risk merits continued attention. A substantial volume of CRE loans originated in a lower-interest environment will mature in the next several years and will need to be refinanced at prevailing rates."28
Federal Reserve · May 2026
"Lenders' willingness to extend or modify maturing loans has helped to limit this risk to date." Bank standards that tightened through 2024 "have eased over the second half of 2025".29
Federal Reserve · June 2026
At community and regional banking organizations ("CBO and RBO" in the report), examiners are "reviewing CBO and RBO underwriting practices, classifications, and credit loss reserve methodologies and levels".17
Senior loan officers · July 2026
Over the second quarter, a moderate net share of banks eased standards on nonfarm nonresidential loans and a modest net share on multifamily loans; construction standards were "basically unchanged".30
Extend and pretend, or a sound extension: two Federal Reserve studies disagree
Critics call it "extend and pretend" when a lender extends a loan the borrower cannot repay, to put off recognizing a loss. Two Federal Reserve studies read the bank extensions made since the pandemic differently.
Earlier Fed research found that "banks modify more CRE loans than CMBS, contributing to better loan performance when property incomes decline".33 For one bank the useful part of the debate is the test it implies. An extension with a paydown, a market rate and current evidence is the kind the Board paper describes. An extension at the old rate to a borrower who cannot pay is the kind the New York Fed paper warns about. A bank can sort its own extensions by those features and see which kind it grants.
11 · How teams do it today
Who works a maturing CRE loan today, step by step, and where the weeks go
In shortFive or six people touch every maturing loan, and most of the elapsed time is spent gathering and rebuilding numbers. No regulator or study publishes how long the work takes. The typical split below is an estimate to replace with your own.
Five roles on one maturity, from portfolio manager to chief credit officer
The roles, with the example's fictional people
PR
CRE portfolio manager · Priya Ranganath
Owns the maturity list for 512 loans and $4.2 billion; decides which loans to start on.
"I find out a loan can't refinance when the borrower tells me, six weeks out."
OP
Relationship manager · Owen Pratt
Asks the sponsor for the rent roll and personal statement, and negotiates the paydown.
"He will put money in. He needs to know how much."
LW
Senior credit officer · Lena Whitford
Confirms the risk grade and approves up to her limit.
"Show me the cash flow. That is what decides the grade."
MD
Special assets officer · Marcus Delgado
Takes the loans that need a workout.
"Hand them to me at 120 days, while there is still room to negotiate."
RA
Chief credit officer · Ruth Abernathy
Approves the large accommodations and answers to examiners.
"If we extend it, show me why it's still a pass, on paper, before the date."
Seven steps from the maturity report to a term sheet
Seven steps and four hand-offs between the maturity report and the term sheet
1Maturity report
A list from the servicing system, often copied into a spreadsheet.
Portfolio managerMonthly
2Document request
Rent roll, operating statement, leases, guarantor statement and returns.
Relationship managerWeeks of chasing
3Income rebuilt
Trailing to underwritten net operating income.
Credit analystDays
4Value
Appraisal, evaluation or the valid value on file, reviewed.
Appraisal reviewWeeks if ordered
5Guarantor
Liquidity and every contingent liability; global coverage.
Credit analystDays
6Size and options
The three limits, the gap, refinance against extend against restructure.
Credit officerDays
7Grade, memo, approval
Grade, accrual, disclosure, memo, signatures by limit, term sheet.
A list from the servicing system, often copied into a spreadsheet.
Portfolio manager
Monthly
Document request
Rent roll, operating statement, leases, guarantor statement and returns.
Relationship manager
Weeks of chasing
Income rebuilt
Trailing to underwritten net operating income.
Credit analyst
Days
Value
Appraisal, evaluation or the valid value on file, reviewed.
Appraisal review
Weeks if ordered
Guarantor
Liquidity and every contingent liability; global coverage.
Credit analyst
Days
Size and options
The three limits, the gap, refinance against extend against restructure.
Credit officer
Days
Grade, memo, approval
Grade, accrual, disclosure, memo, signatures by limit, term sheet.
Credit officer and approvers
A week or more
Twenty-three working days, ten of them chasing documents
In a typical hand-run maturity, chasing documents is the largest block of days
Working days on one maturing CRE loan handled by hand, a typical split
Chasing documentsRebuilding incomeValue and marketGuarantor and global cash flowSizing, options, memo and signatures
One maturing loan, about 23 working days10 days3 days6 days
Illustrative · replace with your own numbers · An illustrative estimate, since no public figure exists. Time your own last ten maturities from document request to signed decision.
Show the numbers
Chasing documents
Rebuilding income
Value and market
Guarantor and global cash flow
Sizing, options, memo and signatures
One maturing loan, about 23 working days
10 days
3 days
2 days
2 days
6 days
The 180-day and 120-day clock
A decision 112 days early leaves time to negotiate, value and approve
Aug 5, 2026180 days out
The example bank's clock asks the sponsor for the rent roll, statements and personal financial statement.
Sep 15, 2026New appraisal effective
Ordered when the largest tenant gave back space; read and reviewed before the decision.
Oct 4, 2026120 days out
Decision file due with the credit officer.
Oct 12, 2026Decided
Extension recommended, graded and approved, 112 days before maturity.
Feb 1, 2027Maturity
The balloon is re-dated to February 1, 2029 on the new terms.
Fictional example from this guide · Fictional example. The 180 and 120 days are the example bank's settings.
Show the numbers
When
What
Aug 5, 2026
180 days out
Sep 15, 2026
New appraisal effective
Oct 4, 2026
120 days out
Oct 12, 2026
Decided
Feb 1, 2027
Maturity
Four ways lenders run maturities today
1 · In house, by hand
Spreadsheet and servicing reports
A portfolio manager keeps the maturity list; credit analysts size each loan when its turn comes.
Strength
People who know the borrowers and the buildings
Strain
Sizing starts late and is redone by hand when rates move
2 · Portfolio software
Stress-testing and monitoring tools
Portfolio-level stress tests and watch lists from loan-system data.
Strength
The whole book under scenarios, for the board
Watch for
Whether it reads current rent rolls and appraisals, or only stored fields
3 · Outsourced
Third-party underwriting or loan review
An outside firm re-underwrites selected maturities or reviews grades.
Strength
Capacity and an independent view
Watch for
Turnaround, and whether the bank's own terms are applied
4 · Document-reading software
Reading and sizing on arrival
Tools that read the documents, size every loan at current terms and draft the decision file.
Strength
Every loan sized every night, each figure traced to its page
Watch for
Who grades and approves; whether rate settings stay current
Part B · See it working
Botminds CRE Loan Maturity Management, from the maturity wall to a signed decision
Part A described the work without naming a product. This part shows how Botminds does it, at a fictional regional bank in Charlotte with 512 CRE loans and $4.2 billion outstanding. Every bank, sponsor, tenant, appraiser, person and figure on these screens is sample data.
12 · One loan, start to finish
Linden Crossing's maturity: 41 documents, three options side by side and a 24-month extension approved 112 days early
In shortThis is the example from the top of the page, inside the product. Every night six agents re-size every loan maturing in the next 18 months at the bank's current terms. When Linden Crossing's 41 documents are in, its decision pack is built in under two minutes. Priya Ranganath, the portfolio manager, recommends a 24-month extension; Lena Whitford confirms the grade and Ruth Abernathy, the chief credit officer, approves it 112 days before maturity.
1
The maturity wall, re-sized overnight
Priya's home screen is a calendar of every month for two years. Each cell shows the dollars maturing and the number of loans, and its shade is the dollars that would not refinance at today's terms. The summary underneath reads: 138 loans and $1.06 billion maturing in 18 months, $83.6 million of it across 50 loans that would not refinance, 31 decision packs due within 120 days, 30 ready and 12 decided.
The overnight run beside the calendar lists what changed: two loans moved into a gap after new documents arrived, a 2021 value is too old to rely on, and Linden Crossing has all 41 documents in.
The CRE maturity wall. Two years of maturities, each month shaded by the dollars that would not refinance at today's terms. March 2027 is the darkest month.
2
March 2027, fanned into three lanes
One click opens a month. March 2027 holds 10 loans and $84 million, of which $19.0 million would not refinance. Its loans fall into three lanes: refinance (four loans that pass, or where a paydown under 5% closes the gap), extend with conditions (four, $5.7 million short) and work out (two, $13.3 million short). Each card shows what today's terms would lend against what is owed.
Brantlow Commerce Tower, an office loan in Durham, is $8.4 million short, 38.9% of its balance. It belongs with the special assets officer now, five months before its date.
One month in three lanes. March 2027's ten loans, sorted by the size of each refinance gap.
3
Linden Crossing's decision pack, built from 41 documents
Priya opens Linden Crossing and builds the pack. The agents read the rent roll, 13 leases, three operating statements, two appraisals, the guarantor's statement and his 2025 return, and show each step on screen as they work: 1 minute 37 seconds in all.
The refinance test shows the three limits side by side. At the bank's office terms, 65% of the new $32,625,000 value lends $21,206,250; coverage would allow $24.4 million and debt yield $26.1 million, so loan-to-value binds. The pack reads: "Fails by $8,968,006."
The decision pack. Balance, what today's terms lend, the gap and the days left, with each agent's step and the three limits.
4
Refinance, extend or restructure, side by side
The options page puts the three answers next to each other with the numbers a credit officer grades on. Refinancing needs an $8,968,006 paydown that would leave the guarantor $2,431,994, below his $5.0 million covenant. Restructuring into a $24.0 million A note and a $6.2 million B note means a charge-off, a substandard grade and nonaccrual.
Extending 24 months with $3.0 million down, a 7.10% market rate, a $1.2 million leasing reserve and a cash sweep below 1.20x leaves $27,174,256 at 1.12x coverage, 83.3% loan-to-value and a 9.6% debt yield. The page proposes pass, on the watch list, and marks the extension as a disclosed modification.
Three options. Each with its balance, coverage, loan-to-value, debt yield, proposed grade, accrual and disclosure.
5
Recommended, confirmed and approved, 112 days early
Priya recommends option B and signs with her password and the meaning of her signature, "Evidence reviewed, extend as written". The exposure is above $25 million, so Lena Whitford confirms the grade and Ruth Abernathy approves.
The accommodation memo carries 12 cited sources. The term sheet to the sponsor (paydown, rate, reserve, sweep and the reaffirmed $7.5 million partial guarantee) goes out only after the last approval, and the decision goes into the log examiners read.
Memo and approval. The cited memo, three signatures and the term sheet that is sent only after approval.
The solution's design targets are a decision pack for every maturing loan 120 days before its date, and every maturing loan re-sized each night at today's terms. They are targets, to be measured on your own book.
13 · Every screen
The whole book under a cap-rate what-if, the wall by quarter, a guarantor's other guarantees and the decision log
In shortOne loan is the story. These screens show the rest: the whole book re-sized under a what-if, the wall by quarter and property type, the ranked list, the rent roll rebuilt to underwritten income, the value and the sizing calculator, the guarantor's other guarantees, the signature, a source page, the decision log and the bank's own credit policy as settings.
Cap-rate what-if. Cap rates up 50 basis points: every month re-sizes at once, and $109.2 million across 71 loans would not refinance, $25.6 million and 21 loans more than today.
A loan at a glance. Any card opens the loan's numbers and a button to ask for documents now.
Every figure opens its page. The value in the pack opens page 3 of the appraisal, with the conclusion highlighted.
The wall by quarter. 81 loans pass, 31 have gaps under 10%, 19 have gaps of 10% or more and 7 are in workout; office holds 7 of the 19.
Maturing loans, ranked by gap. Every loan with coverage, loan-to-value and debt yield at today's terms, which test binds, and the next step.
Rent roll and underwritten income. Thirteen tenants, the rollover by year, and each step from $2,742,000 trailing to $2,610,000 underwritten.
Value and the sizing calculator. $55.0 million in 2019, $32,625,000 today; move the rate, cap rate or income and the gap follows. Three comparable sales support the value.
The guarantor's other guarantees. $142.0 million on nine other loans, and whether each paydown leaves him above his $5.0 million covenant.
Signing the recommendation. The option, the grade, who must approve next, and what the signature means.
What the pack found. Five findings with their sources, and the loan then and now.
The decision log for examiners. Every maturity decision with its option, grade, disclosure, approver and days ahead of the date, exportable.
Your credit policy as settings. Refinance terms by property type and the clock. Changes are versioned and re-size the wall that night.
The rates on these screens come from the fictional bank's sample rate sheet: a 3.85% 5-year Treasury input plus a spread for each property type. The example follows them exactly. Real market rates appear only in Part A, section 05, with their source and date; a bank using the solution keeps its own rate sheet current.
14 · Agents, and who signs
Agents re-size every maturity nightly; a credit officer confirms the grade and approves up to $25 million
In shortEach agent has one job and limits it does not cross. None of them changes a loan's terms, sets a value, grades a loan or sends terms to a borrower. The credit officer confirms the grade and approves up to $25 million; above that, or for any downgrade to substandard, the chief credit officer approves. Every figure carries its source.
Six agents, from maturity watcher to options and memo writer
Maturity watcher
Reads the loan system every night, puts each loan maturing in the next 18 months on the wall and runs its clock: documents requested at 180 days, the decision pack due at 120.
Never changes a loan's terms or dates; it reads the loan system and writes nothing back.
Rent roll and cash flow analyst
Reads rent rolls, leases, tenant letters and operating statements; rebuilds trailing and underwritten income and maps lease rollover by year.
Never counts a lease that is not signed.
Valuation and market reader
Reads the appraisal or evaluation on file, comparable sales, cap rates and market rents, compares them with the value at origination, and applies the bank's rule for when a new appraisal is needed.
Never sets or adjusts a value; the appraiser does.
Sponsor and guarantor analyst
Reads the guarantor's personal financial statement, contingent liabilities and returns, and the bank's other exposure; builds liquidity, net worth and global coverage, and tests any paydown against the liquidity covenant.
Never counts a guarantee without demonstrated liquidity behind it.
Refinance sizer
Sizes every maturing loan at the bank's refinance terms for its property type (rate, amortization, minimum coverage, maximum loan-to-value, minimum debt yield) and ranks the wall by gap.
Never uses terms other than the bank's current policy settings.
Options and memo writer
Compares refinance, extend with conditions and restructure on balance, coverage, loan-to-value, debt yield, grade, accrual, disclosure and allowance; drafts the accommodation memo and the term sheet.
Never grades, approves or sends terms; it proposes.
The portfolio manager recommends; credit confirms the grade and approves
Prepares and recommendsCRE portfolio managerBuilds the pack, chooses the option to recommend and signs the recommendation with its meaning.
Confirms the gradeSenior credit officerConfirms the risk grade on every decision and approves up to $25 million of exposure.
Approves above the limitChief credit officerApproves above $25 million and any downgrade to substandard; the loan committee above $50 million.
The recommendation, each approval, the option, the grade and the memo as drafted are written to the decision log and cannot be changed afterward. The term sheet is sent only after the last approval. Settings changes are versioned on the audit trail.
15 · What goes in and out
A wall re-sized every night, a cited decision pack for each loan and a log an examiner can read
In shortIt reads the loan system's maturity schedule, the documents borrowers and appraisers already send, market data and the bank's own credit policy. It leaves behind a wall re-sized every night, a cited decision pack and memo for each loan, approvals by limit, and a decision log. Your systems of record stay where they are.
From the borrower and the file
Rent rolls, leases and tenant letters
Operating statements, trailing and annual
Appraisals and evaluations on file
Guarantor's personal financial statement, contingent liabilities and returns
The sponsor's letters and offers
From the bank
The loan and maturity schedule from the loan system
Refinance terms by property type
The clock: when to ask for documents and when the pack is due
Valuation rule, extension rules, approval limits
Market rents, cap rates and the rate curve
Agents read, size, compare and draftEvery maturing loan, every night, at your current terms
Credit officers grade and approve
Every figure linked to its page
Outputs
A 24-month maturity wall shaded by the dollars that would not refinance, with a rate and cap-rate what-if
A refinance test for every loan: coverage, loan-to-value, debt yield and the binding limit
Refinance, extend and restructure compared, with the grade each would carry
A cited accommodation memo and a term sheet
A decision log for examiners
What changes for the team
Loans found 18 months before their dates
An assembled pack to review for every loan
Workouts handed to special assets at 120 days
The example book: 138 maturing loans, 50 that would not refinance, 19 short by 10% or more
Of 138 maturing loans, 50 would not refinance and 19 are short by 10% or more
The example bank's loans maturing in the next 18 months, by refinance result at today's terms
Maturing in 18 months138
With a refinance gap50
Gap of 10% or more19
Fictional example from this guide · Fictional sample book: $1.06 billion maturing, $83.6 million short across the 50 loans with a gap. Another 7 loans are already in workout and are counted separately on the screen.
Show the numbers
Stage
Count
Maturing in 18 months
138
With a refinance gap
50
Gap of 10% or more
19
March 2027's $19.0M shortfall is mostly in two workout loans
The darkest month's dollars that would not refinance, by lane
$19.0Mshort
Work out: 2 loans$13.3M
Extend with conditions: 4 loans$5.7M
Fictional example from this guide · Fictional. The four loans in the refinance lane pass, or a paydown under 5% closes their gap.
Show the numbers
Part
Value
Work out: 2 loans
$13.3M
Extend with conditions: 4 loans
$5.7M
Loan system, appraisals and market data the nightly re-size reads
Loan or core systemThe maturity schedule, balances, rates, grades
Allowance and reportingGrades, accrual, modification disclosure
Identity and accessRoles, approval limits, separation of duties
For each, check whether it has an API, a file feed or only screens, and who owns it.
Sized at today's terms, cited to the page, approved by limit
1
Sized at today's terms
Every loan, every night, at the bank's current settings for its property type, on underwritten income and a dated value.
2
Every figure carries its page
Rent roll line, appraisal page, guarantor statement line: one click from the pack, the memo and the log.
3
Agents propose; people decide
Agents read, size, compare and draft. Named credit officers grade and approve by limit, and terms go out only after approval.
Part C · Are you ready to automate?
Late maturity decisions have a price: measuring yours, and judging maturity software against it
You run a CRE book, or credit for one, or answer to examiners for the decisions made on it. This part is written for you: what late maturity decisions cost, what automating could return, a readiness check, the questions to ask any vendor, and a pilot plan.
16 · What late decisions cost
What a maturity decided late costs you in interest, grades and staff weeks
In shortStart from your own book. Nobody publishes the hours a maturity takes or what a late decision costs, so the figures that matter are yours. A few published facts frame them: how much of a bank book matures each year, how long a restructured loan stays off accrual, and how much modification work banks already do.
21%
of the commercial mortgage balances serviced by depositories, $396 billion, is scheduled to mature in 2026.4
MBA, February 2026
6 months
of sustained payments, as a general minimum, before a restructured loan on nonaccrual can return to accrual.1
2023 interagency workout statement
$11.6B
of CRE loans at banks were modified in 2025, 0.38% of the CRE-secured portfolio: workout files banks already build every year.9
FDIC 2026 Risk Review
Six months on nonaccrual would leave $626,116 of the example loan's interest unrecognized, the largest of three costs
The fictional $30.2 million maturing loan at its 4.15% note rate against the example bank's 7.10% office rate
Six months of interest not recognized on nonaccrual$626.1K
A 90-day extension at the old rate instead of market$222.5K
Increase in the allowance on the extended loan (example)$386K
Fictional example from this guide · Our arithmetic on the guide's fictional loan: $30,174,256 × 4.15% × 6/12; $30,174,256 × (7.10% − 4.15%) × 3/12. The allowance figure is the example bank's screen. Replace with your own loans.
Show the numbers
Item
Value
Six months of interest not recognized on nonaccrual
$626.1K
A 90-day extension at the old rate instead of market
$222.5K
Increase in the allowance on the extended loan (example)
$386K
What nobody publishes. There is no public figure for hours per maturing loan, days from first document request to decision, the share of extensions granted without current financials, or the share of maturities decided before the date. Measure your own, starting with last year's maturities.
Counting staff hours and days decided before each maturity
Cost
Where it hides
How to find your number in a week
Staff time per maturity
Chasing rent rolls, rebuilding income, sizing and memo writing across four people
Ask the analysts, officers and RMs on five recent maturities to reconstruct their hours
Days decided before maturity
Approval dates in the credit file, maturity dates in the loan system
Subtract one from the other for every maturity in the last twelve months
Short extensions
90- and 180-day renewals booked as routine
Count extensions of a year or less, and how many were extended again
Stale evidence
Values and statements older than your policy allows
For last year's extensions, the age of the value and the statements on the decision date
Interest and grades
Loans that slid to nonaccrual or were downgraded around their date
List them with the months on nonaccrual and the interest not recognized
Exam findings
Comments on CRE renewals, valuations and classification
Your last two exam reports and loan review findings on CRE
The lost paydown, the repeat short extension, the grade that never moved
The paydown you never asked forA sponsor who would have put in $3 million at 120 days has committed the cash elsewhere by week two.
The extension you will inherit againA short renewal at the old rate comes back in three months, with less time and fewer options.
The guarantor others are callingOther lenders with maturities on the same guarantor ask for the same liquidity first.
The grade that should have movedA weakening loan kept as a pass because nobody sized it until the date.
Your officers' best weeksSpent assembling files when they should be negotiating with sponsors.
17 · Your return
Staff hours released and interest kept from nonaccrual: the return on deciding maturities early
In shortPut in your own numbers. The calculator values two things: the staff hours released when files arrive assembled and sized, and the interest kept when a loan is decided before it can slide to nonaccrual. Every default is an assumption to replace.
Staff hours, decisions months ahead and interest kept accruing
Staff time
A pack ready to review
Documents read, income rebuilt, loan sized and options drafted before the officer opens the loan.
maturities × hours saved × loaded hourly cost
Earlier decisions
Decisions months ahead
Every loan sized every night, so the gap is known 18 months out and the paydown conversation starts early.
days decided before maturity, before and after
Interest
Fewer loans drifting to nonaccrual
A loan decided before its date on reasonable terms keeps accruing; one that drifts can lose six months of income.
loans avoided × balance × rate × 6/12
Grades
The evidence behind every pass
Current financials, a current value and the guarantor test in every file, as the 2023 statement's examples reward.
extensions with complete evidence ÷ all extensions
Portfolio view
The whole wall under a what-if
Rates or cap rates moved for every loan at once, for the board and for the refinance-risk limits OCC 2024-29 expects.
hours spent building stress reports
Exams
A log ready for every exam
Option, grade, disclosure, approvers and days ahead for every maturity, exportable.
hours spent assembling exam requests
Your staff hours and accruing interest from early maturity decisions
Every input marked illustrative is an assumption. For scale, O*NET, using BLS 2025 wage data, puts the median loan officer wage at $76,690, $36.87 an hour before benefits.34
Your bookHours per maturity decisionLoans that driftYour cost
Illustrative yearly value
Maturity work today, valued$0
Staff time released, valued$0
Interest kept on loans decided in time$0
After your yearly cost$0
Staff hours released a year0
Formulas, per year: Work today = maturities × hours today × hourly cost Time released = maturities × (hours today − hours with automation) × hourly cost Interest kept = drifting loans × share decided in time × balance × rate × 6/12, using the six-month return-to-accrual rule as the time lost After your cost = time released + interest kept − yearly cost
Not counted: better grades, paydowns negotiated earlier, allowance effects and exam findings avoided. Interest kept assumes the loan would otherwise spend six months on nonaccrual; set the drifting loans to zero to see the time lever alone.
The hours saved per maturity decide how many loans cover the cost
Maturing loans a year needed to cover $150,000 of yearly cost from staff time alone, at $55 an hour
Saves 30 hours a maturity91 loans
Saves 20 hours a maturity136 loans
Saves 10 hours a maturity273 loans
Illustrative · replace with your own numbers · Break-even = yearly cost ÷ (hours saved × hourly cost). Interest kept on loans that would have drifted lowers these numbers.
Show the numbers
Item
Value
Saves 30 hours a maturity
91 loans
Saves 20 hours a maturity
136 loans
Saves 10 hours a maturity
273 loans
At the calculator's defaults, 90 maturities saving 30 hours each release $148,500 of staff time, just short of the $150,000 cost; the interest kept on two drifting loans carries the case. A bank with fewer, simpler maturities should weigh the earlier decisions and the evidence in each file as well.
Start here18 · Readiness check
Maturities a year, written refinance terms and past findings: a readiness score for your maturity desk
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 mature in your book each year, including extensions coming round again?
Why it mattersVolume turns hours per decision into staff capacity. Re-extended loans count twice.
A strong answer"About 90 a year, a fifth of them loans we extended once already."
2
Shape of the book
How much of your maturing CRE is balloon loans on office, hotel, retail or loans written in 2019–2022?
Why it mattersThose are the loans most likely to carry a gap; a book of fully amortizing owner-occupied loans gains less.
A strong answer"Most of it: five- and seven-year balloons, a quarter office."
3
Your baseline
Do you know how many days before maturity your decisions are made, and how many hours they take?
Why it mattersNo public benchmark exists, so your own numbers are the only way to show an improvement.
A strong answer"Median 35 days before the date last year; about 40 staff hours a loan."
4
Terms and policy
Are your refinance terms by property type, your valuation rule and your extension rules written down?
Why it mattersSoftware sizes against your settings. Terms that live in officers' heads have to be written first.
A strong answer"Rate spread, amortization, coverage, loan-to-value and debt yield by type, revised each quarter."
5
Findings
Have examiners or loan review commented on CRE renewals, valuations or classifications in the last two years?
Why it mattersFindings bring deadlines and budgets, and the Fed says examiners are reviewing CRE classifications now.17
A strong answer"Loan review found three extensions on values over two years old."
6
Files and systems
Can software reach your loan system's maturity data and the credit files where rent rolls and appraisals live?
Why it mattersReading documents from one place with an API is faster to set up than email attachments.
A strong answer"A nightly loan file, and a document system with an API."
7
Owner and budget
Is there a named owner of maturity management with a budget to change how it is done?
Why it mattersThe work crosses portfolio management, relationship managers, credit, appraisal review and special assets. Without one owner it stalls.
A strong answer"The chief credit officer sponsors it; the head of CRE portfolio management owns it."
8
Governance
Do you have a path to approve AI in credit work: vendor due diligence, a view under the 2026 model risk guidance (SR 26-2, OCC Bulletin 2026-13, FDIC FIL-15-2026), named signers and an audit trail?
Why it mattersThe 2026 model guidance leaves generative and agentic AI out of its scope, so your own framework has to cover it.15,14,16
A strong answer"Vendor management and model risk have a route for AI tools, and every decision needs a named signer."
9
Vision · for reflection
If rates rose another half point tomorrow, how long would it take you to tell the board which of next year's maturities would no longer refinance, and by how much?
Why it mattersYour answer shows where the work is manual: the data, the sizing or the reading of documents.
A strong answerA specific list, for example: "two weeks, because underwritten income lives in each analyst's spreadsheet."
Explore, replay 20 to 30 maturities, or size the whole wall
0–6
Explore
Measure first: days before maturity and hours per decision on last year's loans. Write your refinance terms and valuation rule down, and name an owner. Start narrow, for example with nightly sizing of the next 18 months.
7–11
Ready to pilot
Run a measured pilot on 20 to 30 of last year's maturities, where you know the answer, and on this quarter's live loans. Compare sizing, options and staff hours with your own process.
12–16
Ready to implement
Plan the whole book: your terms and clock as settings, approval limits, the loan-system feed, document sources, the decision log for examiners, and how special assets receives workouts.
19 · Questions for any vendor
Sizing at your current terms, cited evidence and who decides: sixteen questions for refinance-risk software vendors
In shortAsk every vendor the same questions, us included. The answers show how a loan is sized, what is read, whose terms apply, what evidence you keep and who decides, and how you would test it on loans you already decided.
Ask
A good answer
A warning sign
Sizing
Does it size every maturing loan at our current terms by property type, with all three limits?
Coverage, loan-to-value and debt yield, the binding one named
A single coverage ratio on the note rate
On what income does it size: trailing, underwritten, signed leases only?
Underwritten from the rent roll, unsigned leases left out, each step shown
Whatever figure is stored in the loan system
How often does it re-size, and what triggers it?
Nightly, and whenever a rent roll, value or rate changes
A quarterly batch
Can we move rates and cap rates across the whole book at once?
Yes, with every loan and month re-sized and the change shown
Scenarios run by the vendor on request
Reading
Which documents does it read: rent rolls, leases, operating statements, appraisals, personal financial statements, returns?
All of them, with the page and line of each value
Only structured data you key in
Does it test the guarantor against every contingent liability?
Liquidity and net worth against all guarantees, with the covenant
This loan's guarantee only
How does it apply our valuation rule?
Flags each loan that needs a new appraisal or evaluation, early enough to order it
Uses the value on file whatever its age
Decisions and evidence
How does it compare options, and against what?
Refinance, extend and restructure on coverage, loan-to-value, grade, accrual and disclosure, reasoned against the 2023 statement
A recommendation with no comparison
Can every figure in the memo be opened at its source?
Document, page and line, for officers, loan review and examiners
A confidence score in place of a page
Who grades, approves and sends terms?
Named officers by limit; terms only after approval
Terms sent automatically
What is logged for examiners?
Option, grade, disclosure, signers and days before maturity, unchangeable, exportable
An activity feed
Your policy and data
Who can change terms, the clock and limits, and is it versioned?
The policy owner; versioned; applied to the next nightly run
Settings any user can change
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 our model risk team classify each part under the April 2026 model risk guidance?
A component-by-component answer
"It's all a model" or "none of it is"
Proof
Can we test it on last year's maturities, with the documents we had then?
Yes, blind, compared with our committee's sizing line by line
Demo loans only
What will you report from the test?
Sizing differences by limit, options matched, staff minutes
One accuracy percentage
We found no published independent test of any maturity or refinance-risk vendor, as of October 2026. Re-sizing loans you already decided is the fairest comparison you can run.
20 · How to start
Last year's maturities first, this quarter's beside your team: a twelve-week trial decided on three numbers
In shortMeasure first, then test on last year's maturities where you know the outcome, then run beside your team on this quarter's live loans. Decide with three numbers. None of these steps commits you to a vendor.
Measure last year: for every maturity, days decided before the date, staff hours on five of them, and the age of the value and statements used.
Write your terms down: refinance terms by property type, the valuation rule, extension rules and approval limits.
Pick 25 past maturities across property types, with the documents in the file at the time, and the committee's own sizing.
Run live beside your team for five weeks on the next six months of maturities, with your officers grading and approving every decision.
Decide with three numbers: sizing agreement with your committee, days decided before maturity, and staff hours per decision.
A twelve-week pilot ends with a decision on three numbers
Your teamVendor
Measure last year's maturities
Write terms, clock and limits as settings
Connect the loan file and documents
Re-size 25 past maturities blind
Compare with committee sizing
Run live on the next six months
Officers grade and approve live loans
Decide on three numbers
Week 04812
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Measure last year's maturities
0
2
Write terms, clock and limits as settings
1
3
Connect the loan file and documents
1
4
Re-size 25 past maturities blind
3
6
Compare with committee sizing
5
7
Run live on the next six months
6
11
Officers grade and approve live loans
6
11
Decide on three numbers
11
12
Sizing agreement, days decided early and staff hours per maturity
Measure
How
Why
Sizing agreement
Loan amount and binding limit against your committee's, on the past loans
The decision rests on the size
Days decided before maturity
Approval date against maturity date, before and during the pilot
Early decisions keep options open
Staff hours per decision
Logged by each role, from first request to approval
The cost case rests on it
Evidence complete
Share of decisions with current financials, a current value and the guarantor test
What the 2023 statement's examples reward
Citations that check out
100 random figures opened at their source
Trust in the pack depends on it
The working-session questions: 15 questions in five groups
Bring portfolio management, relationship managers, credit, appraisal review, special assets, finance, model risk and IT into one room. Each answer becomes a setting, a data feed or a decision about scope.
A
Loans maturing in the next 18 months, and which to leave out
A1
How many loans mature in the next 18 months, by property type and month?
Why it mattersSets the size of the wall and where to start.
Strong answer · warning sign
A list from the loan system.
"We'd have to ask each officer."
A2
Which loans would we keep out: owner-occupied, fully amortizing, construction?
Why it mattersConstruction loans follow a different clock.
Strong answer · warning sign
A clear exclusion list.
"Everything, day one."
A3
How many of this year's maturities were extended before?
Why it mattersRepeat extensions are where the risk hides.
Strong answer · warning sign
A count with the dates.
Not tracked.
B
Your refinance terms, rate base and appraisal-at-renewal rule
B1
What are our refinance terms by property type, and who updates the rate base?
Why it mattersStale rates give stale gaps.
Strong answer · warning sign
A spread over a named Treasury, refreshed.
A rate set last year.
B2
When do we require a new appraisal at renewal?
Why it mattersThe rules leave the threshold to the bank.22
Strong answer · warning sign
A written test.
"When it feels old."
B3
What must an extension carry: market rate, paydown, sweep, reaffirmed guarantee?
Why it mattersBelow-market terms change the grade.1
Strong answer · warning sign
Extension rules in policy.
Negotiated case by case.
C
Renewal findings, guarantor tests and modification disclosure
C1
What did examiners and loan review say about CRE renewals in the last two years?
Why it mattersFindings show where the process breaks.
Strong answer · warning sign
A list by type.
Nobody tracks them.
C2
How do we test a guarantor's other guarantees?
Why it mattersThe statement asks for all of them.1
Strong answer · warning sign
Contingent liabilities schedule, verified.
This loan only.
C3
Who decides whether an extended borrower is in financial difficulty for disclosure?
Why it mattersTerm extensions to such borrowers are disclosed.12
Strong answer · warning sign
A named owner and rule.
Finance finds out at quarter end.
D
A nightly maturity file, credit documents and market data
D1
Can we send a nightly maturity file from the loan system?
Why it mattersIt drives the wall.
Strong answer · warning sign
A scheduled extract exists.
Screens only.
D2
Where do rent rolls, appraisals and personal statements live?
Why it mattersSets the integration work.
Strong answer · warning sign
One document system.
Officers' inboxes.
D3
Which market data do we license for rents and cap rates?
Why it mattersValues and what-ifs depend on it.
Strong answer · warning sign
Known source and terms.
Copied from old appraisals.
E
SR 26-2, vendor review and who sponsors the maturity desk change
E1
Has our model risk policy moved from SR 11-7 to the April 2026 guidance?
Why it mattersSR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026 replaced it on April 17, 2026.14,15,16
Strong answer · warning sign
Updated, with a view on AI tools.
Still cites SR 11-7.
E2
What does vendor management need before a pilot sees real loan data?
Why it mattersDue diligence is the bank's.
Strong answer · warning sign
A known path and timeline.
First time anyone has asked.
E3
Who sponsors the change, and what can move in the budget?
Why it mattersA pilot without a sponsor ends as a demo.
Strong answer · warning sign
A named executive.
No sponsor.
21 · Frequently asked questions
The maturity wall, refinance gaps, extensions and new appraisals: questions CRE lenders ask
In shortThe questions lenders and buyers search for most, each answered on its own.
What is CRE loan maturity management?
CRE loan maturity management is a lender's work of tracking every commercial real estate loan coming due, sizing each one again at today's income, value and rates, and deciding before the date whether to refinance, extend with conditions or work it out. It ends with a graded, approved and documented decision for each loan.
What is the CRE maturity wall?
The CRE maturity wall is the large amount of commercial real estate debt scheduled to come due in the next few years. The Mortgage Bankers Association puts 2026 maturities at about $875 billion, 17% of the $5.0 trillion of commercial and multifamily mortgages outstanding, with $652 billion scheduled for 2027.
What is a refinance gap?
A refinance gap is the balance due at maturity minus the largest new loan the lender's current terms would make against the property. If it is positive, the borrower has to put in that amount, the lender has to extend or restructure, or the loan cannot be repaid as it stands.
How do you calculate how much a maturing CRE loan can be refinanced for?
Size it three ways at current terms and take the smallest: income divided by the minimum coverage ratio, turned into a loan at today's rate and amortization; the maximum loan-to-value times today's value; and income divided by the minimum debt yield. The smallest result is the loan, and the test that produces it shows the problem.
What happens when a commercial real estate loan matures and cannot be refinanced?
The whole balance is due, so the lender and borrower choose between an extension with conditions, a restructuring such as an A note and B note, a forbearance while a sale or lease completes, or an exit by sale, note sale or foreclosure. If nothing is agreed and the balloon is unpaid, the loan is in maturity default.
Is a renewed or extended CRE loan automatically classified?
Not automatically. The 2023 interagency workout statement says renewals of maturing loans to borrowers who can repay on reasonable terms will not automatically be adversely classified, though they should be identified in the bank's grading system. Its office example keeps a renewed loan at 102% loan-to-value as a pass because current financials and a recent appraisal supported it.
Does a CRE loan extension need a new appraisal?
Not always. Under the federal appraisal rules a renewal of an existing loan needs no new appraisal if no new money is advanced beyond reasonable closing costs, or if the market and property have not materially changed, but the bank must still have an appropriate evaluation. A bank may always order a new appraisal, and its own valuation policy sets when it must.
Is a loan extension a disclosed modification?
A term extension granted to a borrower experiencing financial difficulty is a modification that banks disclose under ASU 2022-02, which replaced troubled debt restructuring accounting. Extensions on market terms to borrowers outside financial difficulty fall outside the disclosure. A disclosed extension can still be graded pass.
What does the OCC expect for refinance risk?
OCC Bulletin 2024-29, issued October 3, 2024, asks banks with commercial loans to evaluate refinance risk when approving loans, in monitoring, near maturity and when considering extensions, and to identify, measure, monitor and control it across the portfolio, including by monitoring maturities and stress testing.
What is a good debt yield for a commercial real estate loan?
No regulator sets one. The OCC says debt yield measures risk independently of the interest rate, amortization and cap rate, and lists a minimum debt yield among the items an effective CRE lending policy sets for each type of loan or property. Each bank chooses its own; the fictional bank in this guide's example uses 10% for office and 12% for hotels.
How far ahead should a bank start work on a maturing CRE loan?
Early enough to get current documents, order and review a valuation, negotiate a paydown and take the decision to committee before the date. The fictional bank in this guide's example watches 18 months ahead, requests documents 180 days out and wants a decision file 120 days out; the appraisal FAQs add that a final credit decision should come only after the valuation is received, reviewed and accepted.
Can AI analyze a CRE loan extension?
AI can read rent rolls, leases, appraisals and guarantor statements, rebuild income, size the loan and compare options, provided every figure is traced to its source. The grade, the terms and the approval should stay with credit officers. The April 2026 model risk guidance, SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026, leaves generative and agentic AI outside its scope, so each bank's own controls apply.
22 · One-page summary
Maturity management on one page: an 18-to-24-month window, re-sized loans, five paths and a graded decision
Print this page
In shortThe whole guide on one screen: the method, the rules as of October 2026, the readiness bands and the terms.
The method
Keep a rolling 18 to 24 months of maturities from the loan system.
Ask for rent roll, statements and guarantor financials about 180 days out.
Rebuild underwritten income; apply your valuation rule; order values early.
Size at current terms: coverage, loan-to-value, debt yield; take the smallest.
Test the guarantor against every guarantee; compare refinance, extend and restructure.
Grade, decide accrual and disclosure, approve by limit, log the decision before the date.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: the 2023 workout statement and OCC Bulletin 2024-29 in force · SR 26-2 / OCC 2026-13 / FDIC FIL-15-2026 replaced SR 11-7 on April 17, 2026 · appraisal thresholds unchanged since 2018 · market data: the 5-year Treasury averaged 4.94% in October 2026 through the 29th (FRED).
14 terms
Balloon
The large final payment left when a loan's term is shorter than its amortization.
Maturity wall
The debt scheduled to come due over the next few years, by month or year.
Refinance gap
Balance due at maturity less the largest loan today's terms allow.
NOI
Net operating income: rent and other income less operating costs, before debt.
Underwritten NOI
The lender's view of income: signed leases, market renewals, vacancy and reserves.
DSCR
Debt service coverage: NOI ÷ a year of loan payments.
LTV
Loan-to-value: the loan ÷ the property's current value.
Debt yield
NOI ÷ the loan amount, independent of rate and cap rate.
Cap rate
The return buyers demand; value ≈ NOI ÷ cap rate.
Extension
More time with the same lender, usually on new conditions.
A/B note
A restructure into a note the property supports and a charged-off remainder.
Forbearance
A lender's agreement not to enforce for a set period.
Special mention
A grade for potential weaknesses that deserve close attention.
Evaluation
A simpler valuation than an appraisal, allowed in some renewals.
23 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
OCC, Federal Reserve, FDIC, NCUA, “Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts”, 88 FR 43115, July 6, 2023. federalregister.gov
OCC, Comptroller's Handbook, Commercial Real Estate Lending, Version 2.0, March 2022 (reputation-risk references removed March 20, 2025). occ.gov
Federal Reserve Bank of St. Louis, FRED, DGS5 (5-Year Treasury Constant Maturity), accessed October 30, 2026. fred.stlouisfed.org
MBA, “MBA: 17% of Commercial and Multifamily Mortgage Balances to Mature in 2026” (2025 Commercial Real Estate Survey of Loan Maturity Volumes), MBA NewsLink, February 9, 2026. newslink.mba.org
MBA, “MBA: 20% of Commercial and Multifamily Mortgage Balances Mature in 2025” (2024 Commercial Real Estate Survey of Loan Maturity Volumes), MBA NewsLink, February 11, 2025 (released February 10). newslink.mba.org
Bisnow (C. Long), “Colliers: Loan Extensions Hit New High Of $384B”, March 21, 2025. bisnow.com
MortgagePoint (D. C. Lester), “Billions of Commercial/Multifamily Mortgages to Mature in 2024”, reporting the MBA's 2023 Commercial Real Estate Survey of Loan Maturity Volumes, February 19, 2024. themortgagepoint.com
Federal Reserve, H.8 Assets and Liabilities of Commercial Banks in the United States, release of October 30, 2026 (Tables 1, 4 and 8, seasonally adjusted). federalreserve.gov
OCC Bulletin 2023-23, “Credit Administration: Final Interagency Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts”, June 29, 2023. occ.gov
12 CFR 34.43, Appraisals required; transactions requiring a State certified or licensed appraiser. ecfr.gov
Federal Reserve, Supervisory Stress Test Model Documentation: Credit Risk Models, October 2025, updated January 2026. federalreserve.gov
Interagency FAQs on the Appraisal Regulations and the Interagency Appraisal and Evaluation Guidelines, 2018. federalreserve.gov
CRE Daily, “Green Street Index Reveals Sector-Based CRE Pricing Gains”, reporting Green Street's Commercial Property Price Index (June 2026 data), July 9, 2026. credaily.com
E. Jiang, G. Matvos, T. Piskorski, A. Seru, “Monetary Tightening, Commercial Real Estate Distress, and US Bank Fragility”, NBER WP 31970, revised December 2024. nber.org
Scotsman Guide, “CMBS delinquencies reach highest level since 2020” (Trepp data), October 6, 2026. scotsmanguide.com
D. Glancy and R. Kurtzman, “Determinants of Recent CRE Distress: Implications for the Banking Sector”, FEDS 2024-072. doi.org
FDIC, Quarterly Banking Profile, Second Quarter 2026, August 25, 2026. fdic.gov
OCC, Semiannual Risk Perspective, Spring 2026. occ.treas.gov
Federal Reserve, Financial Stability Report, May 2026, Asset valuations. federalreserve.gov
Federal Reserve, Senior Loan Officer Opinion Survey, July 2026. federalreserve.gov
M. Crosignani and S. Prazad, “Extend-and-Pretend in the U.S. CRE Market”, FRBNY Staff Report 1130, October 2024, revised June 2026. newyorkfed.org
D. Glancy, “Pretend or Amend? On Evergreening in CRE”, FEDS 2026-025, Federal Reserve Board, May 2026 (page updated August 21, 2026). federalreserve.gov
D. Glancy, R. Kurtzman, L. Loewenstein, “Loan Modifications and the Commercial Real Estate Market”, FEDS 2022-050, August 2022. doi.org
O*NET OnLine (US Department of Labor), “Loan Officers, 13-2072.00”, with BLS 2025 wage data, accessed October 30, 2026. onetonline.org
Next step
See it on your own maturing loans.
Explore the solution, or bring a sample of your own maturing loans and your refinance terms, and we will size them with you, every figure linked to its page.
We use essential cookies to make this site work, and cookieless, anonymised analytics to understand how it's used. "Accept all" also turns on Google Analytics, which sets cookies. Privacy policy