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Finding and managing vulnerabilities in credit portfolios 

Fresh reminders of why it's important to manage credit concentration risk are everywhere. Effective loan review is a key element of managing concentration risk in loan portfolios. 

Key topics covered in this post: 

Credit concentration risk: Navigating the landscape

Whether it’s uncertainty over potential tariff impacts, elevated interest rates, or commercial real estate (CRE) credit health, fresh reminders of the importance of managing credit concentration risk are all around financial institutions.

A recent Federal Reserve newsletter for community banks reiterated guidance and supervisory expectations for prudent concentration risk management practices. It’s a good reminder that in today’s environment, risk managers and credit professionals should reexamine how they identify, assess, and communicate portfolio vulnerabilities.

An effective credit risk review function is a key element of managing concentration risk in credit portfolios. Modern loan review processes can help financial institutions satisfy examiners while accommodating the staffing pressures facing many loan review departments.

Abrigo's experienced credit risk advisors can help you manage concentration risk.

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Regulator comments on overseeing concentration risk

Concentrations often arise naturally for community banks and credit unions due to the types of businesses and industries that they serve in their communities. A bank in an urban corridor might understandably have a CRE credit concentration. A rural credit union might amass numerous agricultural loans.

Concentrations can also develop from over-exposure to specific borrowers, collateral types, or loan products. Concentrated credit exposure may build gradually. But a shift in rates, asset values, or borrower conditions can quickly turn that exposure into vulnerability. “Concentration risk must be managed in conjunction with credit, interest rate and liquidity risks; as a negative event in any category may have significant consequences on the other areas, as well as strategic and reputation risks,” says the NCUA.

The Fed’s June 2024 Community Banking Connections newsletter noted that concentration risk, particularly commercial real estate (CRE) risk, has remained a central supervisory focus since the Great Recession—and recent history has added a new layer of urgency.

Banks’ relative exposures to CRE (as a share of assets) increased in recent years, according to the St. Louis Federal Reserve. In addition, charge-off rates on CRE loans (excluding farmland) have increased from 0.02% in Q4 2022 to 0.26% in Q4 2024, FRED economic data from the St. Louis Fed shows. During a recent Abrigo credit risk webinar, 51% of bank and credit union credit risk professionals responding to a poll reported an increase in problem loans over the last three months, and 42% said their borrowers are seeing declining economic conditions.

The newsletter for community bankers also noted that the 2023 failures of Silicon Valley Bank and other regional institutions highlighted the dangers of unmonitored deposit concentrations, emphasizing that concentration risk isn’t limited to the asset side of the balance sheet.

Indeed, managing asset concentration is among the areas that “have become top priorities for regulators,” wrote Andrew Giltner, Lead Examiner within the Chicago Fed’s Supervision and Regulation Division, in the Community Banking Connections newsletter.  

The regulatory message for financial institutions is clear: Know where you’re concentrated, understand the risk dynamics, and maintain the capital and oversight necessary to weather downturns.

Concentration risk management framework

Credit concentrations “should not necessarily be avoided by bankers because doing so may neglect the banking needs of their community members,” the article said. However, the degree and level of credit concentrations affect a bank’s risk profile. To control concentration risks, bankers need a comprehensive risk management framework.

A strong framework, according to the article, includes:

  • A strategic plan incorporating the institution’s desired asset or funding concentrations and its commensurate policies, procedures, and risk limits.
  • Management information systems that are tailored to appropriately capture concentrations so that management and the board can more easily provide oversight.
  • Capital planning that accounts for concentrations to maintain an acceptable level of capital.
  • Contingency plans to raise capital or reduce concentration levels when predetermined parameters are triggered.

The newsletter points to Supervision and Regulation (SR) letter 07-1, “Interagency Guidance on Concentrations in Commercial Real Estate,” for more details on strong risk management practices related to having a CRE loan concentration. Those practices include conducting portfolio stress testing and sensitivity analysis, market analysis, and having an effective credit risk review function. The National Credit Union Administration, too, has noted the importance of an independent review function in managing concentration risk in credit union loan portfolios.

How credit risk review can help manage concentrations

While some credit teams think of loan review as a compliance mechanism for retrospectively validating individual loan risk ratings and verifying the adequacy of loan documentation, the function of credit risk review has more strategic value tied to handling concentration risk.

Ongoing, independent analysis by loan reviewers represents a critical link in an institution’s defense against concentration risk. Continuous monitoring in loan review helps determine whether large or correlated loan concentrations align with the financial institution’s risk appetite and lending policies. It can provide context to detect emerging vulnerabilities that might lead to elevated losses if adverse conditions impact the concentrated segments.

A modern, data-informed loan review framework helps financial institutions connect the dots between individual loan file findings and systemic portfolio risks. It identifies patterns across loans that share similar characteristics, whether those be:

  • industry
  • geography
  • collateral type
  • borrower structure, or
  • funding source.

Overcoming barriers to concentration risk insight

As noted earlier, one challenge with keeping an eye on any concentration of credit risk is that credit accumulations tied to a characteristic can build quietly. Loan review cycles that are segmented or siloed by lending team or product type can make it difficult for decision-makers to fully recognize how that exposure is aggregating—or deteriorating—until it’s too late.

Time-consuming, manual processes and turnover in loan review staff or constrained staff can also hamper the institution’s ability to recognize increasing loan exposure or deteriorating trends in a particular category. And it’s clear that many loan review departments are facing such challenges in their day-to-day work.

A recent Abrigo loan review webinar found that 56% of respondents consider time-consuming manual processes their biggest challenge in the loan review process. Another 24% said the top challenge is limited staff resources, and 12% said it’s identifying emerging credit risk.

That’s where standardized, software-enabled loan review processes become critical. Most institutions have a firm grasp on their largest credit relationships. But understanding aggregate exposure across similar loans—especially when loans span business lines, geographies, or periods—requires the ability to extract structured insights from the credit data already being collected.

Centralizing review data and applying consistent risk rating methodology across the portfolio helps credit risk teams:

  • Tag and analyze loans by concentration categories (e.g., NAICS codes, property types, geographic zones)
  • Identify sector-specific risk trends in risk ratings, exceptions, or performance metrics
  • Compare actual exposure to risk tolerances set by policy or board-level limits
  • Detect participation layering or overexposure in sectors that have experienced recent stress
  • Surface actionable insights for management and the board before concentrations create systemic vulnerability

Using some loan review software, users can leverage concentration tracking dashboards and reporting features to drill down into high-risk segments and flag others for investigation. They can evaluate risk rating consistency and assess borrower performance within those concentrations. Abrigo’s DiCOM Loan Review Software has these features.

Abrigo Senior Consultant Kent Kirby, a retired banker with experience in all aspects of commercial lending, loan review, and portfolio management, has said that one reason identifying emerging trends can be difficult is that loan review analysis is resource-intensive, even when it’s automated.

Kent Kirby

Kent Kirby

Many loan reviewers, he said, are “so tired just doing the analysis, you never get around to doing the root causes and patterns.”

The newest feature available with DiCOM is aimed at addressing that. An AI-powered loan review assistant analyzes loan data and automatically generates insights. It uses generative AI to build narratives to quickly inform credit risk decisions aligned with an institution’s policies.

“Artificial intelligence allows you to do that initial analysis, to cut that time down so you can focus on root causes and patterns,” Kirby said.

 

Asking the right questions before the regulators do

Risk reviewers equipped with data-driven tools can provide insights beyond file-level observations. They provide strategic intelligence that can inform loan policy, underwriting standards, and capital planning.

Notably, such tools also allow loan review officers and credit analysts to communicate quantified risk trends clearly across the organization. Highlighting to leaders insights tailored to the institution’s unique risk profile will make it easier for senior management to make timely, well-informed decisions about credit concentration limits, capital buffers, and loan participation strategies.

That’s especially important in an environment where CRE vacancy rates are shifting, farmland values are responding to commodity volatility, and interest rates and the economy are placing pressure on debt service coverage ratios.

About the Author

Mary Ellen Biery

Senior Strategist & Content Manager
Mary Ellen Biery is Senior Strategist & Content Manager at Abrigo, where she works with advisors and other experts to develop whitepapers, original research, and other resources that help financial institutions drive growth and manage risk. A former equities reporter for Dow Jones Newswires whose work has been published in

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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