Nearly $1 trillion in commercial real estate debt comes due this year — $936 billion by CRE Daily's count, up 18.6% from 2025 — roughly a fifth of it tied to office buildings where delinquencies are running near 12%. Against that backdrop, the Federal Reserve's July Senior Loan Officer Opinion Survey found banks reporting the easiest CRE lending standards since early 2022.

Read past the headline number and the easing isn't where the risk is.

Per the Fed's SLOOS release and Invesco's read of it, the easing was narrower than the headline suggests. A moderate net share of banks eased standards on nonfarm nonresidential loans, a modest net share eased on multifamily, and construction and land development standards were basically unchanged. The easing concentrated at large banks — the $100-billion-plus institutions — while smaller banks reported basically unchanged standards on multifamily and construction.

Here's the part the headline drops: in the same survey, banks still described their standards as sitting at the tighter end of their entire range since 2005 — a significant net share said so for construction lending, moderate net shares for nonfarm nonresidential and multifamily. "Easiest since 2022" measures the direction of change, not the level. Standards eased from very tight to slightly-less-very-tight, at the subset of banks with the least at stake.

Per CRE Daily's office-loan analysis, the $936 billion maturing this year is up 18.6% from 2025, and projected maturities don't peak until 2029 — at $1.1 trillion. The refinancing math is the real constraint: loans coming due carry an average rate of 4.76%, while new CRE loans are pricing at an average of 6.24%. That gap hits debt service coverage on every refinance regardless of what the standards survey says. Office delinquencies stand at 11.76% per Trepp — a number that doesn't move because a sentiment survey eased.

And volume is returning straight into that wall: CRE originations rose 36% year-over-year in Q3 2025, with office originations up 181%.

Per CRE Daily's Q2 2026 regional-bank tally, nonperforming CRE assets rose at Truist and U.S. Bancorp, Huntington's nonperforming-asset ratio climbed 13 basis points, Fifth Third's rose 11, and KeyCorp posted a double-digit-basis-point increase of its own — all in the same quarter the Fed was calling standards the loosest in years.

The same tally shows what the banks did about it: credit-loss allowances declined at 10 of 11 super-regionals, and net charge-off ratios fell at 8 of 11. Nonperformers rising while reserves fall is a bet that the problem loans resolve rather than spread. The surface numbers look fine — Citizens cut its CRE charge-off rate to 0.36% from 0.64%, PNC trimmed nonperforming CRE balances 10% — but Citizens is carrying a $2.5 billion office book at 12.4% reserve coverage, and Flagstar has cut its office loan-loss allowance by 142 basis points.

Per The Real Deal, private credit funds and mortgage REITs handled 40% of non-agency CRE closings in Q4 2025 — and banks are financing that private-credit growth through back-leverage facilities, effectively outsourcing the risk they won't underwrite directly while still profiting from it.

Note what that does to the survey itself: SLOOS measures bank lending standards. A growing share of the marginal CRE dollar is now originated outside the banking system entirely — funded by banks one step removed, invisible to the very survey generating the "easiest since 2022" headline.

"Easiest lending standards since 2022" is a real, reported number. It's also a description of risk appetite at the banks least exposed to the debt actually coming due this year — measured by a survey that no longer sees where the marginal risk lives.

What to watch from here: S&P Global projects loan-loss provisions rising to 24% of bank net revenue in 2026, from 20.8% in 2025 — that's reserves being forced to catch up with the wall. Watch whether smaller banks follow the large banks' easing, and whether that 12% office delinquency rate bends before the 2029 maturity peak arrives.