According to Mike Restuccia, an independent member of Institutional Real Estate, Inc’s board of directors who also happens to audit banks for a living, the Federal Deposit Insurance Corp and Office of the Comptroller of the Currency here in the United States jointly conduct an ongoing survey series in their effort to create an early warning system to detect potential changes in, among other things, bank underwriting practices.

The conclusion from one of the latest of these surveys is that underwriting has definitely loosened up. (Even more concerning, notes Restuccia, banks seldom admit to regulators that they’re loosening up as much as they really are.)

He also noted that in reviewing the loan portfolios among some of his customers — mostly local community banking institutions — he’s starting to see covenant-light loans, and the kind of no- or low-qualification loans that we saw heading into the last credit market crisis. He’s also seeing some higher loan-