On April 3rd, the OCC published a white paper that presents findings from a study of bank performance in the context of the 2006 interagency guidance, "Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices." The guidance established supervisory criteria for banks that exceeded 100 percent of capital in construction lending and 300 percent of capital in total commercial real estate ("CRE") lending. The study covered national- and state-chartered commercial banks but did not include savings associations. Among other things, the white paper found that banks with high concentrations of construction and total CRE lending that exceeded supervisory criteria failed at higher rates than banks with lower concentrations. OCC Press Release.