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Even experts have a hard time getting a handle on how bad losses might get as the commercial real estate market implodes.

NEW YORK (Fortune) — The banks have taken some lumps since the economy went bad. But some believe their biggest headaches are yet to come.

The pace at which U.S. commercial banks are adding to their loan loss reserves has slowed this year, while loans continue to go bad at a brisk pace.

Despite the optimism of lenders like Wells Fargo (WFC, Fortune 500), some observers warn that banks aren’t socking away enough for a rainier day.

The disconnect is particularly acute in commercial real estate, where lenders are facing a surge of defaults on commercial mortgages and construction loans made when prices were much higher and demand for space much stronger.

Banks have been recognizing commercial real estate losses slowly, even though the high season for defaults isn’t expected to arrive until next year.

That’s not the only problem. Ill-defined or inconsistently applied rules for valuing securities and handling loan modifications can make it hard to say how healthy banks really are, from Citigroup (C, Fortune 500) and Bank of America (BAC, Fortune 500) on down.

The risk is that this year’s recovery could turn out to be a false dawn, delivering another blow to investor trust — not to mention people’s 401(k)s.

“The credibility of the banking system could take another step back,” said Paul Miller, an analyst at FBR Capital Markets. “Everyone is expecting we’ve seen the peak in losses, but it’s impossible to know for sure because you can’t get an apples-to-apples comparison.”

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