It is important to note that no element of the proposed guidance is intended to act as a “trigger” or “hard limit” for immediate cutback or reversal of CRE lending; rather, the guidance is a reminder to institutions that certain risk-management standards are vitally important for banks involved in the business.
I have been following this path from my perch at t he Bundesbanksince 2010 – I started out originally responsible for financial stability and, since 2014, have been in charge of banking and financial supervision. And I, too, have been asking myself time and again: have we taken the right road? Or have we fallen short?