Short answer: Federal law caps what a national bank may lend one borrower at 15% of its unimpaired capital and surplus, with an extra 10% allowed for fully secured lending. State limits vary but sit in a similar range. In practice this means only 56.6% of US banks can legally hold a $5 million loan, and just 17.6% can hold a $25 million one. The median bank between $300 million and $1 billion in assets tops out around $8.1 million.
The rule, and what it means in dollars
A bank cannot lend an unlimited amount to any one customer no matter how good the credit is. Under 12 U.S.C. 84, a national bank's loans to a single borrower may not exceed 15% of its unimpaired capital and surplus, with a further 10% available for loans fully secured by readily marketable collateral. State-chartered banks follow state statutes that usually land in the same neighborhood.
The rule exists to stop a single failed credit from taking down an institution. Its practical effect on borrowers is that the size of your loan silently determines which banks can even consider it, before appetite, industry, or credit quality enter the conversation.
Here is what that limit works out to in dollars, using the conservative of 15% of equity or 10% of assets, across every filing bank in the quarter ending June 30, 2026.
| Bank size (total assets) | Banks | Bottom quartile | Median | Top quartile |
|---|---|---|---|---|
| Under $100M | 583 | $0.8M | $1.2M | $1.7M |
| $100M - $300M | 1,224 | $2.2M | $3.1M | $4.0M |
| $300M - $1B | 1,435 | $6.0M | $8.1M | $11.2M |
| $1B - $3B | 629 | $18.4M | $24.8M | $33.8M |
| $3B - $10B | 266 | $59.8M | $79.0M | $110.0M |
| $10B - $100B | 127 | $251.8M | $396.1M | $608.6M |
| Over $100B | 32 | $2.5B | $4.3B | $9.1B |
Source: BankingLens, computed from FFIEC call reports for the quarter ending June 30, 2026. Quartiles are calculated across the full population of filing banks in each size band, not sampled.
How many banks can hold your loan
Turning the same data around gives the number most borrowers actually want: of the 4,296 FDIC-insured banks in the country, how many could legally keep your loan on their own books?
| Loan size | Banks that can hold it | Share of all US banks |
|---|---|---|
| $250,000 | 4,286 | 99.8% |
| $500,000 | 4,241 | 98.7% |
| $1 million | 4,069 | 94.7% |
| $2 million | 3,573 | 83.2% |
| $5 million | 2,430 | 56.6% |
| $10 million | 1,551 | 36.1% |
| $25 million | 757 | 17.6% |
| $50 million | 434 | 10.1% |
Source: BankingLens, computed from FFIEC call reports for the quarter ending June 30, 2026. Quartiles are calculated across the full population of filing banks in each size band, not sampled.
The number below the legal number
The legal limit is a ceiling, not a target. Nearly every bank sets an internal hold limit by policy, often far below what the law allows, because concentrating a quarter of your legal capacity in one relationship is uncomfortable regardless of legality. A bank that could legally lend $20 million may cap its own exposure at $8 million.
This is why the most valuable question in a first conversation with a lender is not about rate. It is whether the bank intends to hold the whole loan or bring in a participant. A participation is not a rejection and often gets the deal done, but it introduces a second institution with its own credit committee, its own timeline, and its own conditions. Learning that in week one is worth more than a few basis points.
What this means for your search
If you are raising under $1 million, capacity is close to irrelevant. Roughly 95% of American banks can hold that loan, so your shortlist should be driven entirely by appetite, industry familiarity, and local relationships.
Above about $5 million, capacity becomes the dominant filter. Nearly half of all banks are simply out, and no amount of a compelling story changes that. The efficient move is to filter on capacity first and then evaluate appetite among the banks that remain, rather than the other way around.
There is also a floor worth knowing about. A $1.5 million request at a $70 billion bank is below the size where a commercial team staffs it properly, so it gets routed to a small-business channel with slower service and less flexibility. Being too small for a lender is a real problem, just a quieter one than being too large.
Frequently asked questions
How much can a bank lend to one borrower?
Under 12 U.S.C. 84, a national bank may lend a single borrower up to 15% of its unimpaired capital and surplus, plus an additional 10% for loans fully secured by readily marketable collateral. State-chartered banks follow their own state limits, which commonly range from 15% to 25% of capital. Banks also set internal hold limits below the legal cap.
How many US banks can fund a $5 million loan?
About 2,430 of 4,296 FDIC-insured banks, or 56.6%, had enough capital to legally hold a $5 million loan to one borrower as of the quarter ending June 30, 2026. At $10 million that falls to 36.1%, and at $25 million to 17.6%.
What is a bank's in-house hold limit?
A hold limit is the maximum exposure a bank is willing to keep on its own books, set by policy well below the legal lending limit. A bank that could legally lend $20 million might cap its own hold at $8 million and sell participations above that. This is why a loan can be legally permissible and still require a second institution.
What happens if a loan exceeds a bank's lending limit?
The bank cannot make the loan alone. It either declines, or it originates the loan and sells participations to other banks so no single institution exceeds its limit. Participations are routine, but they add a second credit committee and typically several weeks to closing.
Does the lending limit apply to related businesses?
Yes. Lending limits apply to a borrower and its related interests combined, so loans to affiliated entities, businesses under common control, and in some cases the owner personally are aggregated. A borrower with several entities can hit the limit sooner than the individual loan sizes suggest.
Where these numbers come from
Every figure on this page is computed from the FFIEC call reports that all 4,296 FDIC-insured banks file each quarter, for the quarter ending June 30, 2026. Nothing here is modeled, estimated, or sampled. You can pull any individual bank behind these distributions on Bank Peer Intel, or, if you are trying to borrow rather than benchmark, see which lenders these numbers point to on Borrower Assist.