Kieler Volksbank eG: Bafin ordnet zusätzliche Eigenmittel an

The measure is institution-specific, but the supervisory signal is broader: weak governance in CRE credit can translate directly into higher capital requirements under §25a KWG. For compliance and risk teams at banks with commercial property exposure, this is a prompt to test whether lending strategy, approval workflows, risk controls, documentation and board oversight are robust enough to withstand supervisory scrutiny. Actionable steps include a targeted §25a gap assessment, review of CRE underwriting and monitoring controls, clear remediation ownership at board level, and early engagement with supervisors where weaknesses are identified.

Firms should also consider internal audit validation and capital planning contingencies if remediation is slower than expected. The order reinforces that organisational shortcomings are not merely conduct or process issues; they can affect capital adequacy and strategic capacity. Lenders with strong CRE governance may gain a relative advantage, while those with unresolved weaknesses face capital, reputational and supervisory risks.