The white-hot commercial real estate market is showing signs of cooling, lenders say.

Lending has become riskier on projects in markets from Atlanta to Las Vegas, they say, citing fears of overbuilding and effects from the Asian economic crises.

"My sense is that the market has peaked. If anything, we're at the top of the curve," said Bill Herrera, regional vice president at Bank of America in charge of commercial real estate lending for the San Francisco Bay area. "We're taking a cautious approach."

No one sees a repeat of the real estate debacle of the late 1980s, which created the worst crisis for the banking system since the Great Depression. But shares of real estate investment trusts, which largely replaced savings and loans as sources of commercial real estate capital, have been sagging since March. And regulators have been increasingly urgent in calling for caution.

"The prospects for the U.S. office market are softening," said Lloyd Lynford, president of Reis Reports, a New York data firm. "The downward slope in vacancy rates that started in 1994 has been arrested, and over the next five years we expect more new construction to put upward pressure on vacancy rates."

A year ago Bank of America would have been willing to finance a vacant office property in Silicon Valley, Mr. Herrera said. Today, he says, he will do such speculative deals only for long-term clients.

Though vacancies and rents remain strong in the Bay Area, where Mr. Herrera lends, other cities are showing signs of an actual slowdown.

The growth rate of quoted rents on new office leases in Dallas has decreased to 10% in the last year, from 16% in 1996, said Greg Willett, a director at M/PF Research Inc. in Dallas.

"Rents have gone nuts in recent years," Mr. Willett said. "They're starting to ease back a bit with so much under construction."

Several bankers cited Las Vegas, where the casino industry has lost tourism dollars because of the Asian economic crisis, as another potentially overheated market. "I'd be very cautious there," said James Fitzgerald, a senior vice president at Credit Lyonnais in New York.

The poor performance of REIT stocks this year indicates that "the equity markets are skeptical," said Robert Mueller, chief credit officer at Bank of New York. REITs "have a difficult time paying reasonable prices."

The backup in REIT shares will make it harder for the trusts to raise capital, dampening their appetite for acquisitions, said Barclay Jones, vice chairman of W.P. Carey, a Manhattan-based real estate investment company.

Another yellow flag: In June the Federal Reserve admonished the nation's banks to tighten their lending standards, singling out loans to REITs.

"It's a good time for lenders to maintain sound underwriting standards," Mr. Mueller said.

But there are also signs that lenders are more cautious than in the 1980s, when overbuilding fueled by competition among lenders sent the national vacancy rates close to 20%.

Mr. Fitzgerald said that borrowers wanting to use "liberal structures" whom he rejected four months ago have been coming back to him with the same deals. That these borrowers were unable to find funding elsewhere suggests that lenders "are fairly disciplined," he said.

Mr. Herrera of Bank of America said commercial office rents in the Bay Area were increasing dramatically until the first quarter, while vacancy rates are around a healthy 5%.

However, the region has seen some setbacks. Silicon Valley has suffered from the Asian crisis and from layoffs at such high-tech companies as Intel of Santa Clara.

Mr. Herrera said the absorption rate for office space in the Bay Area dropped to about one million square feet in the first of half, from between three million and four million in 1997.

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