Bank Door — what the local bank sector could absorbSee it on every loan’s exit read →
$18M of CMBS matures here within two years.
The 10 regional and local banks that gather deposits here could write roughly
$577M more CRE before the 300% supervisory line, so the maturing balance is
0.03× that room.
The median metro sits at 0.12×.
After Committed Draws
$357M / −38%
Banks In Footprint
10 / 1 at the line
The room above is already part-sold. Construction lending is a promise drawn
down over two or three years, and the undrawn part is an obligation the bank cannot decline while the borrower performs
— every one of those dollars lands in the same CRE book the 300% line governs. These banks
have $259M of construction committed and not yet
advanced, of which $220M
comes out of the room above, leaving $357M,
with 3 banks
whose entire remaining room is spoken for.
A bank with no room contributes zero here, never a negative one — capacity does not net
across balance sheets — so $39M of what has
been promised is not deducted at all, because there is nothing left to deduct it from. On today’s
capital that is funding already contracted which would cross the line as it draws.
SR 06-26 draws a second line at 100% of capital for construction and land:
2 more cross it
once their own commitments fund.
Counted — 10 regional & local CRE lenders
| Bank | Deposit share | CRE / Capital* | Room contributed | Noncurrent CRE |
| Arrow Bank National Association NY |
21.7% |
142% total 195%
|
🔒 |
0.44% |
| Pioneer Bank, National Association NY |
97.2% |
236% total 274%
|
🔒 |
0.30% |
| First National Bank Of Scotia NY |
100.0% |
125% total 183%
|
🔒 |
2.85% |
| The Adirondack Trust Company NY |
93.7% |
261% total 337%
|
🔒 |
0.57% |
| Ballston Spa National Bank NY |
100.0% |
272% total 334%
|
🔒 |
0.11% |
| Community Bank, National Association NY |
1.6% |
201% total 260%
|
🔒 |
0.17% |
| Wayne Bank PA |
4.5% |
201% total 359%
|
🔒 |
2.24% |
| The Bank Of Greene County NY |
10.2% |
295% total 338%
|
🔒 |
0.04% |
| Chemung Canal Trust Company NY |
19.6% |
375% total 428%
|
🔒 |
0.14% |
| Rhinebeck Bank NY |
0.0% |
250% total 337%
|
🔒 |
0.23% |
Not counted — 9 banks with deposits here
These hold deposits in this metro but are left out of the capacity above, because for them deposit location stops indicating where they lend — or they do not lend CRE at all. Real money that could refinance here is deliberately not counted.
no CRE book — CRE under 100% of capital — not a CRE lender
Keybank National Association OH · Trustco Bank NY · Bank Of America, National Association NC · Citizens Bank, National Association RI · Td Bank, National Association DE · Jpmorgan Chase Bank, National Association OH · Bank Of Richmondville NY
national — operates in more than 5 states, so deposits stop indicating where it lends
Manufacturers And Traders Trust Company NY · Nbt Bank, National Association NY
* Two ratios, two perimeters.
The large figure is supervisory CRE over total risk-based capital —
construction, multifamily and non-owner-occupied nonfarm nonresidential. That is the book SR 06-26 draws its
300% line against, and it is what the red coloring and the room contributed are both measured on.
Total beneath it adds owner-occupied CRE — lending to a business on
its own premises — which the guidance deliberately leaves out. A bank can sit well above 300% on total CRE and
still be inside the line, with real room to lend; both are shown so the gap is visible rather than surprising.
How to read this. It is not whether any particular loan can refinance — a borrower also reaches
national banks, life companies, agencies and debt funds. It is how much of this metro’s maturing volume the local
bank sector could absorb if it were the only door.
Banks are placed by deposit share (FDIC Summary of Deposits, June 2025) — a proxy for
where they lend, not a measurement; call reports carry no collateral geography. Room = 3× total risk-based capital less CRE held
(SR 06-26, the capital base the rule names — not book equity), from Q2 2026 call reports, apportioned by that share.
Committed construction comes from FFIEC Schedule RC-L as filed at 2026-06-30 —
the undrawn half of loans already written, which the balance sheet above does not show.
Banks in more than 5 states, single-branch bookers and banks that do not lend CRE are excluded —
313 banks holding $268.2B of national capacity not counted here.
Local Lenders — banks headquartered here, worst CRE noncurrent firstUnlock each bank’s early-warning flag →
| Bank | Total CRE | CRE / Capital* | Noncurrent CRE | Early Warning |
| Ballston Spa National Bank |
$490M |
272% total 334%
|
0.11% |
🔒 |
| First National Bank Of Scotia |
$132M |
125% total 183%
|
2.85% |
🔒 |
| Trustco Bank |
$234M |
28% total 39%
|
0.73% |
🔒 |
| The Adirondack Trust Company |
$646M |
261% total 337%
|
0.57% |
🔒 |
| Pioneer Bank, National Association |
$671M |
236% total 274%
|
0.30% |
🔒 |
* Two ratios, two perimeters.
The large figure is supervisory CRE over total risk-based capital —
construction, multifamily and non-owner-occupied nonfarm nonresidential. That is the book SR 06-26 draws its
300% line against, and it is what the red coloring and the room contributed are both measured on.
Total beneath it adds owner-occupied CRE — lending to a business on
its own premises — which the guidance deliberately leaves out. A bank can sit well above 300% on total CRE and
still be inside the line, with real room to lend; both are shown so the gap is visible rather than surprising.
Banks are matched to their HQ metro (a proxy for footprint). Noncurrent CRE = CRE-balance-weighted blend of multifamily / nonresidential / construction noncurrent (distress already arrived).
Early Warning is a validated
leading signal — the bank’s 30-89 early-delinquency rank among all CRE lenders this quarter, which has predicted ~2.3× forward CRE distress. Per-bank flags are on a
plan.