There's been growing talk of ESG regulation — particularly the environmental part — that would begin to have an impact on CRE, but it had seemed like a conversation that kept getting put off. Like the Securities and Exchange Commission interest in significant disclosure requirements: noise but action getting delayed.

The general quiet period is coming to an end, according to credit and risk management firm Moody's Analytics. If they're correct, the commercial real estate industry will feel the impact.

"While the US has been slower to integrate climate risk into financial supervision compared to the EU, the last two years saw many US agencies launching climate risk work streams, which are now beginning the process of actively integrating climate risk into the supervisory and regulatory activities," the firm wrote. "Some of these developments relate directly to real estate assets, while many more have indirect implications through their impact on investors, lenders and publicly traded companies."