Commercial real estate Some banks - mostly those that would not be subject to the A-IRB capital requirements unless they chose to become so - oppose the higher capital charges that A-IRB banks would generally face on their commercial real estate loans.
These banks argue that bank lenders have learned from the losses of the 1980s and early 1990s and now do much better underwriting by insisting on more borrower equity and better appraisal procedures for commercial real estate.