Beyond the banks. 57 mid-size non-bank lenders, and what we can count about them.
Review No. 4 counted 264 banks over the regulators’ commercial property line, because banks file a report that can be counted. The firms that lend next to them file no such report. We listed 165 non-bank lenders in four countries and looked at the 57 of mid-size: who they are, what they lend against, and where the gap to banks is.

Mid-size non-bank lenders are the same kind of business as mid-size banks, a small team holding a large property book, but nobody can count their risk the way a bank’s is counted. Of the are debt funds or agency lenders. For banks we can say how many are past a regulatory line and how many dollars sit there. For these firms we can say how many there are and what they lend against, and nothing about the dollars.
165 non-bank lenders in four countries, and 57 of them are mid-size.
A bank is easy to find: it holds a charter and files a quarterly report. A non-bank lender is not. We built a list from the membership of the agency lending programs (Fannie Mae, Freddie Mac, HUD, CMHC), the commercial mortgage REITs and mortgage investment corporations, known debt funds and bridge lenders, and the insurers that hold commercial mortgages. It has in the US, UK, Canada and Australia.
We then sorted them by estimated staff. have к people, have fewer than и have . are the same size as the banks of Review No. : big enough to lend on property at scale, too small to have a department that reads every loan file. By country they are , in the UK, in Australia and in Canada.
Two cautions. The staff figure is our estimate for the whole firm, not a count, and for insurers and for REITs with an outside manager the size of the property lending team is a different number.
23 of the 37 debt funds on the list are mid-size, the largest group. They lend on transitional, construction and bridge loans, and some on hotels, apartments, medical offices and student housing.
Non-bank CRE lenders with an estimated 100 to 999 staff, US, UK, Canada and Australia; counted by Реалист from its lender list, 25 Oct 2026.
The size is the same as the banks. What differs is what the firms lend against, and that depends on their type.
Debt funds and agency lenders are 38 of the 57, and they lend on different things.
are the largest group, firms. Their loans are mostly transitional: a property that is being built, repositioned or refinanced, where the borrower needs money for a few years and the plan, not today’s rent, supports the loan. The list describes their books as construction, bridge, hotel, apartment and medical office debt.
are firms, of them in the US. They originate apartment loans that are then sold to or guaranteed by a government-backed program. The loan has to fit the program’s standard, which is why their files look alike.
Это private and bridge lenders split into two kinds. One lends to investors on rental homes and small commercial properties, many loans of small size. The other lends short-term for acquisitions and development. Tap a country to see how the divide by type where you work.
The agency programs are US-based, so 14 of the 15 agency lenders are here.
Country of the head office on our list.
These are different books with different risks. One question applies to all of them: is the loan file as strong as the borrower says.
For banks we can count the risk. For these firms we can only count the firms.
Review No. used the quarterly reports banks file. They give employees, equity and four kinds of property loan for each bank, so we could say that mid-size banks hold investor property above of capital, in all.
We found nothing like this for the . The five types have different parties to report to, and we did not look for each firm’s reporting duties, so this is a statement about what we could count from one place, not about what the firms disclose. The list carries a description of each firm’s book and no amounts.
The practical result is a gap in the second look. A bank over the line knows an examiner may ask how it reviews its loans. A mid-size non-bank has no single trigger that we found, so the question of how every loan file is checked is left to each firm. Switch between the two groups below.
| Firms in the group | 1,192 banks with 100 to 999 employees |
|---|---|
| What is reported | Employees, equity, and four kinds of property loan, every quarter |
| A line that triggers a second look | 300 % of capital in commercial real estate loans, set by the regulators in 2006 |
| Over the line | 264 banks, 22 %, holding $283.0 billion of $713.6 billion |
Banks: FDIC call-report fields, 30 June 2026 (Review No. 4). Non-banks: Реалист lender list, 25 Oct 2026.
We do not claim non-banks lend worse. We claim only that the evidence to say so, or to say the opposite, is not collected in one place. Where it is missing, the file in front of the credit committee is the only check, and it is worth reading against the property’s own numbers.
Что с этим делать
If you lend against property in one of these five types, the useful step is to see your own files the way a second reader would: the offering memorandum, rent roll, operating statement and collateral, read against each other.
Реалист reads the credit file of a commercial property loan and returns the issues and the questions for the borrower. It does not replace your underwriters, your appraisal or your legal review. It makes sure the same checks are made on every loan, not only on the large ones.
Источники
Found: from a dated document. Derived: calculated by us from found figures. Estimate: our judgment, with the method.
- НайденоBank call-report fields, 30 June 2026: employees, equity, construction, multifamily and commercial real estate loans. FDIC · BankFind Suite API, financials endpoint · report date 30 Jun 2026 · read 25 Oct 2026 document ↗
- НайденоThe 300 percent criterion for a commercial real estate concentration. Federal banking agencies · Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices · 71 FR 74580 · 12 Dec 2006 (OCC Bulletin 2006-46) document ↗
- Выведено165 non-bank lenders; 57 with an estimated 100 to 999 staff; US 32, UK 10, Australia 8, Canada 7. Calculation by Реалист from its lender list (knowledge item 2026-10-25-icp-lenders-nonbank) · 25 Oct 2026
- ВыведеноThe 57 by type: 23 debt funds, 15 agency lenders, 12 private and bridge lenders, 4 insurer teams, 3 mortgage REITs. Calculation by Реалист from its lender list · 25 Oct 2026
- ВыведеноBanks: 264 of 1,192 over 300 % of equity; $283.0 billion of $713.6 billion. Calculation by Реалист from the call-report fields in card f1 · 30 Jun 2026
- EstimateStaff sizes are estimates; no single report was found for the 57; no dollar book was measured. Реалист judgment on the measure · Nov 2026
Counts are Реалист calculations from its own lender list (25 Oct 2026) and from FDIC call-report fields (30 June 2026). Staff sizes are estimates. The list is not a regulatory register and does not name firms. Реалист’s opinion, not investment or legal advice.