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Major U.S. Bank Regulatory Filings

Filing Filed By Filed To Frequency Purpose
Y-9C (Consolidated Financial Statements) Bank Holding Company (BHC) / SLHC Federal Reserve Quarterly Consolidated financial statements, capital monitoring
Y-9LP (Parent Company Only) Bank Holding Company Federal Reserve Quarterly Parent-only income and condition (double leverage, debt)
Call Report (FFIEC 031/041/051) Banking Subsidiary OCC (national banks), Fed (state members), FDIC (state nonmembers) Quarterly Core balance sheet, income, capital, loan/deposit detail
FR Y-14 (Stress Test Reports) Large BHCs > $100B Federal Reserve Quarterly / Annual Data for CCAR/DFAST stress testing
10-K / 10-Q / 8-K Public Bank Holding Companies SEC 10-K annual, 10-Q quarterly, 8-K event-driven Investor financials, MD&A, risk, material events
Proxy Statement (DEF 14A) Public Bank Holding Companies SEC Annual Solicit shareholder votes (directors, comp, proposals)
FR Y-6 (Annual Report) Bank Holding Company Federal Reserve Annual Corporate structure, ownership, governance
FR Y-10 (Org Structure Changes) Bank Holding Company Federal Reserve Event-driven (30 days) Report acquisitions, divestitures, control changes
FR Y-15 (Systemic Risk Report) Large BHCs / IHCs Federal Reserve Annual Systemic footprint for G-SIB surcharge
FR Y-11 (Nonbank Subsidiaries) Bank Holding Company Federal Reserve Quarterly / Annual Financials of significant nonbank subs
FFIEC 009/009a (Country Exposure) Banks with foreign exposures Federal Reserve Quarterly Break down international exposures by country
CRA Exams & Public File Banking Subsidiary OCC / FDIC / Fed ~Every 2–3 years Evaluate community lending to LMI areas
FR Y-16 (Stress Testing for $10B–$100B) Mid-size BHCs / Banks Federal Reserve Annual (when required) Dodd-Frank stress testing (repealed for many)


DEALER acronym for accounting:

Letter Account Type Increases With Decreases With
D Dividends Debit Credit
E Expenses Debit Credit
A Assets Debit Credit
L Liabilities Credit Debit
E Equity Credit Debit
R Revenue Credit Debit


General overview:

Investment Bank - Banking vs Markets

Investment Banking - Want to raise money Global Markets - Have money and want to invest
Mergers & Acquisitions – Advise on buying and selling companies or segments Sales – Help investors buy or sell stock, bonds, or derivatives
Debt Capital Markets – Raise money in bond markets Trading – Buy and sell stocks, bonds, or derivatives from clients
Leveraged Finance – Help high-debt companies raise bonds and loans Electronic Trading – Connect investors to exchanges and execution platforms
Equity Capital Markets – Raise money in the stock market Financing – Help investors finance their positions
  Research – Provide investment insights through reports and analysis


Sales and Trading Classifications

FICC:

Equities:

Macro Products: - That rely on overall market/economy

Spread Products:

Quant Roles:

Research:



Products that require Balance Sheet Prowess:

Boutique Bank Products Products Requiring Balance Sheet
Mergers and Acquisitions Bank Revolvers
Equity Capital Markets Investment Grade Syndicated Loans
Equity Sales & Trading Trade Finance, Letter of Credit
Leveraged Finance and Private Capital Cash Management
Investment Management Investment Grade Debt Origination
Wealth Management Derivatives (Swaps, Futures, Options)
  Credit Trading

Raising Funds Options:

Cost Level Category Instruments / Options
Lowest Cost Asset Backed Finance Receivables, Trade Finance, Inventory
  Debt Commercial Paper (Short Term), Bonds, Loans
Highest Cost Equity IPO (First Issuance), Follow-On (Additional Issuance), Convertible Bonds

M&A Advisory Work

Invest Grow Exit
Acquisition Bolt-on/Roll-ups Strategic Sale
Minority Stake Fundraising Secondary Sale
  Divestiture IPO

ECM Work:

DCM Work:

Risk Solutions:



Functional Types of IB Work



Bank Metrics:



Some example Things to do:

Capital Roll Forward:

Benchmarking Banks:

Comparison Dimensions:

Selecting Peer Group:

Finding Peer Groups:

Risk Management Page:



Past Due, Classified, and Non-Performing Loans – What They Mean


1. Past Due Loans

Aspect Explanation
Definition Loans where scheduled payments are late — typically 30 days or more past due, but still accruing interest if the borrower is expected to catch up.
Purpose Serves as an early warning signal of repayment issues.
Example A borrower misses a payment due on Sept 1 and hasn’t paid by Oct 1 → 30–59 days past due.
Typical Thresholds Banks break this down into 30–59 days, 60–89 days, and 90+ days past due.
Accounting Impact Still accrues interest income unless moved to nonaccrual status.

2. Classified Loans

Aspect Explanation
Definition Loans internally or regulatorily flagged as having potential or well-defined weaknesses, even if not yet delinquent.
Purpose Tracks credit deterioration before default — key internal risk-management tool.
Categories (per U.S. regulatory guidance) Special Mention: Potential weakness.
Substandard: Well-defined weakness jeopardizing repayment.
Doubtful: Collection highly questionable.
Loss: Considered uncollectible (to be charged off).
Basis for Classification Borrower financials, collateral value, covenant compliance, or repayment trends — not limited to missed payments.
Accounting Impact Often still accruing but with heightened allowance for possible loss.

3. Non-Performing Loans (NPLs)

Aspect Explanation
Definition Loans that no longer accrue interest because collection is doubtful or they are 90 + days past due.
Purpose Reflects confirmed impairment within the loan portfolio.
Criteria (typical U.S. bank) • ≥ 90 days past due and unpaid, or
• Placed on nonaccrual status because full repayment is unlikely.
Accounting Impact Interest recognition stops; typically covered by specific loan-loss allowance or partial charge-off.

Relationship Between Categories

Stage Description Category
Payment 30 days late Borrower behind on payments Past Due
Borrower shows strain or covenant breach Early deterioration but may still be current Classified (Special Mention / Substandard)
Borrower stops paying ≥ 90 days Default, repayment uncertain Non-Performing Loan (NPL)

In short, a single loan can progress from Past Due → Classified → Non-Performing as conditions worsen.


How These Are Defined

Source Description
Internal Bank Policy Each bank sets thresholds (e.g., 30 days = past due; 90 days = nonaccrual).
Regulatory Guidance Defined by the OCC, FDIC, and Federal Reserve under the Uniform Retail Credit Classification and Account Management Policy and Interagency Guidelines for Credit Risk Review.
Judgment-Based Classification may depend on borrower cash flows, collateral strength, or covenant performance — not just delinquency days.

Example – Multi-Family Loan at OBK

Stage Scenario Category
Borrower 40 days late on payment but expected to cure Slight delinquency Past Due (0.36%)
Borrower current but DSCR falling below covenants Heightened risk Classified (Substandard)
Borrower 90 + days unpaid, collateral < loan balance Default Non-Performing (0.36%)

Why These Metrics Matter



Understanding AOCI in Banks


** What is AOCI (Accumulated Other Comprehensive Income/Loss)?**

AOCI is a component of shareholders’ equity that captures unrealized gains or losses not yet reflected in the income statement.
For banks, this mainly comes from changes in fair value of securities, but can include other items as well.


** Major Sources of AOCI in Banks**

Source Description Typical Impact
Available-for-Sale (AFS) Securities Unrealized gains/losses from changes in market value of bond portfolios marked to fair value under ASC 320. Usually largest driver of AOCI (negative when rates rise).
Derivative / Hedging Adjustments Effective portion of cash-flow hedges under ASC 815. Moderate impact, depending on hedge book.
Pension Adjustments Actuarial gains/losses from defined-benefit plans. Minor for most regional banks.
Foreign Currency Translation Exchange-rate changes on foreign subsidiaries. Minimal for domestic banks.

** Why AOCI Matters**

Impact Area Explanation
Tangible Book Value (TBV) Unrealized losses in AOCI reduce TBV, lowering P/TBV multiples and equity strength.
Regulatory Capital Under Basel III:
• Large banks include AOCI in CET1.
• Community banks can elect to opt out.
Investor Valuation Analysts adjust TBV for AOCI to reflect true economic equity.
Earnings Volatility AOCI shields unrealized mark-to-market swings from hitting EPS until securities are sold.

** Example – Origin Bancorp (OBK) Q3 2025**

Metric Value Comment
AOCI Balance −$61.2 million Unrealized bond losses from AFS portfolio.
Securities Yield 3.62% Up from 3.16% in Q2 after repositioning.
Portfolio Duration 4.31 years Moderate rate sensitivity.
Portfolio Mix 42% MBS, 26% Municipals, 26% CMOs, 6% Corporate MBS drives rate sensitivity.

Why Analysts Adjust TBV for AOCI

  1. Reflect Economic Equity:
    TBV should represent real shareholder value — unrealized losses in AOCI are real market hits even if not realized.

  2. Purchase Accounting Alignment:
    In M&A, all assets and liabilities are marked to fair value. AOCI therefore becomes economically realized at closing.

  3. Peer Comparability:
    Banks differ in AFS vs. HTM mix. Adjusting for AOCI ensures all are evaluated on the same marked basis.


AOCI Treatment in M&A

Step Description Impact on Deal Math
1️⃣ Target’s AFS portfolio holds unrealized losses in AOCI. TBV already reduced by AOCI.
**2️⃣    
** Acquirer revalues securities to fair value at closing. AOCI is wiped out; replaced by fair-value “mark.”
3️⃣ Mark is amortized (GAAP term) / accreted (economic term) into income over time. Reduces Day-1 TBV dilution; boosts NII over time.
4️⃣ Analysts explicitly include this in merger models. Captures both capital and earnings effects.

Example – TowneBank Deal Disclosure

AOCI Securities Mark-Down: ~$2.7 million amortized over 4 years (straight-line method)

Interpretation:


Modeling Implications

Metric View Meaning
Including AOCI Reflects economic TBV (accounts for unrealized losses).
Excluding AOCI Reflects accounting TBV (ignores market value).
Day-1 TBV Impact Mark reduces tangible equity at closing.
Future Earnings Impact Mark reverses (accretes) into income over amortization period.

Amortization vs. Accretion – Terminology Clarified


Why the Word “Amortization” Is Used

Even when income increases over time (as discounts reverse), GAAP still calls the process “amortization” because the effective-yield or straight-line method is used to allocate the fair-value adjustment.

In other words:

“Amortization” describes the method, not the direction.


Economic vs. Accounting View

Perspective Term Used Direction Effect on Income
GAAP / Accounting Amortization Applies to both premiums and discounts on assets Can increase or decrease income
Analyst / Economic Accretion Used when a discount increases income over time Income rises as discount unwinds

Example

Item Fair-Value Mark Accounting Disclosure Economic Description Effect
AFS Securities −$4.0m “Amortized over 4 years” “Accretes back into NII” +$1.0m income per year
Fixed Assets −$1.0m “Amortized over 30 years” Reversal increases noninterest income Gradual income accretion

Amortization vs. Accretion by Balance Sheet Category

Category GAAP Term Direction of Impact Effect on Income Why
Assets (Loans, Securities, Fixed Assets) Amortization Mark-down (discount) → income rises as discount unwinds Increases NII ASC 310-20 & ASC 805 define effective-yield amortization for assets.
    Mark-up (premium) → income falls as premium amortizes Decreases NII Same method, opposite sign.
Liabilities (Deposits, Borrowings, CDs, FHLB) Accretion Mark-down (discount) → liability value grows → cost rises Reduces NII GAAP uses “accretion of discount” for liabilities approaching par.
    Mark-up (premium) → liability amortizes down → cost falls Increases NII “Accretion” applies in both cases.

Shortcut Rule

Item Type Term Always Used Economic Effect
Assets “Amortized” Income may increase (discount) or decrease (premium).
Liabilities “Accreted” Cost may increase (discount) or decrease (premium).

In a Bank Merger Model

Item Mark Direction GAAP Term Economic Effect
Securities / Loans Down (discount) Amortized Increases income (accretes).
Core Deposits Up (premium) Accreted Reduces income (expense amortizes).
Time Deposits / Borrowings Down (discount) Accreted Increases income (lower funding cost).

Summary

Concept GAAP Word Economic Word Net Effect on Earnings
Asset write-down (discount) Amortization Accretion Increases NII
Asset write-up (premium) Amortization Amortization Decreases NII
Liability discount Accretion Accretion Decreases NII
Liability premium Accretion Amortization Increases NII

Bottom Line:



Understanding Bank Deposit Types and Characteristics


1️⃣ Overview

Deposits are the primary funding source for a bank.
From the bank’s perspective, deposits are liabilities — funds owed to customers — and thus are often shown as negative numbers in presentations.

[ \text{Assets} = \text{Liabilities} + \text{Equity} ]

Deposits = Funding Source (Liability)
Loans/Securities = Uses of Funds (Asset)


2️⃣ Key Deposit Categories


A. FDIC Insured Deposits

Feature Description
Definition Balances fully covered by FDIC insurance (up to $250,000 per depositor, per ownership category).
Typical Source Retail customers and small businesses.
Behavioral Profile Very stable – core deposit base.
Cost of Funds Low – often noninterest-bearing or low-rate checking/savings.
Regulatory View Strongest funding quality.
Accounting Treatment Liability; shown as a negative number.

B. FDIC Insured Reciprocal Deposits

Feature Description
Definition Large customer deposits placed via reciprocal networks (e.g., IntraFi ICS / CDARS) that are split into smaller insured chunks across participating banks.
Mechanism Bank places excess funds with the network and receives an equal amount of reciprocal deposits back from other banks.
Purpose Allows customers to maintain full FDIC coverage while keeping the relationship with one bank.
Regulatory Treatment Not brokered if the bank is well-capitalized and within limits (post-2018 FDIC rule).
Behavioral Profile Stable / core-like, relationship-based.
Cost of Funds Slightly higher than retail deposits but cheaper than brokered CDs.

C. FDIC Insured Brokered Deposits

Feature Description
Definition Deposits obtained through third-party brokers or online listing services.
Purpose Used to quickly raise liquidity when loan growth exceeds local deposit base.
Regulatory View Considered non-core / volatile funding.
Behavioral Profile Rate-sensitive and flight-prone.
Cost of Funds Higher – requires competitive rates.
Usage Example Common in liquidity-stressed banks or rapid balance sheet expansion.

D. Public Funds Deposits

Feature Description
Definition Deposits from state and local governments, school districts, and other public entities.
Examples City payroll accounts, school district operating funds, or tax receipts.
Legal Requirement Must be fully insured or collateralized above FDIC limit.
Collateralization Pledged securities or FHLB letters of credit.
Behavioral Profile Moderately stable, but often seasonal (tax and budget cycles).
Cost of Funds Moderate; priced competitively to attract municipalities.
Liquidity Impact Stable but collateralized → reduces balance sheet flexibility.

E. Collateralized Deposits

Feature Description
Definition Deposits backed by pledged assets (U.S. Treasuries, municipal bonds, or FHLB LOCs).
Who Uses Them Primarily for public deposits above FDIC insurance limits.
Purpose Protects depositor in case of bank failure.
Accounting Treatment Deposit liability offset by pledged collateral (encumbered asset).
Behavioral Profile Stable but reduces available liquidity (pledged assets cannot be reused).
Risk Trade-off Safer for depositor, costlier for bank liquidity management.

F. Uninsured / Uncollateralized Deposits

Feature Description
Definition Deposits exceeding the $250,000 FDIC insurance limit and not backed by pledged collateral.
Typical Source Large corporate, commercial, or wealth-management clients.
Behavioral Profile Rate-sensitive and volatile – most likely to move in stress events.
Risk Flight risk during market uncertainty or confidence shocks.
Cost of Funds Higher – must offer competitive yields to retain balances.
Analyst Focus Tracked closely to gauge potential run-off risk and liquidity exposure.

G. Total Estimated FDIC-Insured Deposits

Feature Description
Definition Combined total of FDIC-insured, reciprocal, and brokered deposits that carry explicit insurance.
Purpose Indicates the insured portion of total deposit base.
Interpretation A higher share = lower liquidity risk.
Typical Ratio Healthy regional banks show 40–60% insured deposits.

3️⃣ Collateralization Explained

Concept Meaning
Collateral Requirement Public deposits above FDIC limits must be secured by pledged assets.
Common Collateral Types U.S. Treasuries, Agency bonds, Municipals, FHLB letters of credit.
Impact on Liquidity Collateral is encumbered – cannot be sold or repo’d.
Trade-Off Safer for depositor but limits bank’s flexibility.

4️⃣ Deposit Composition Example (OBK – Q3 2025)

Category Balance ($000) QoQ % Key Insight
FDIC Insured 3,407,017 +1.0% Core retail and business deposits.
FDIC Insured Reciprocal 1,056,176 +6.4% Full-insurance relationships via ICS/CDARS.
FDIC Brokered 0 (–100%) Fully eliminated.
Collateralized 690,933 –16.8% Secured public funds using pledged assets.
Public Funds 865,637 (flat) Government entities – seasonal.
Uninsured / Uncollateralized 3,177,704 +9.5% Large corporate balances – more volatile.

5️⃣ Deposit Type Comparison Summary

Deposit Type FDIC-Insured? Collateral Required? Relationship Depth Funding Stability Liquidity Impact
Retail / Consumer ✅ Yes ❌ No High Very Stable None
Commercial Partially ❌ No High Stable None
Public Funds ✅ Yes ✅ Yes (above limit) Medium Moderately Stable Encumbers collateral
Reciprocal ✅ Fully ❌ No High Stable None
Brokered ✅ Fully ❌ No Low Volatile None
Collateralized ✅/Secured ✅ Yes Medium Stable Reduces liquidity
Uninsured / Uncollateralized ❌ No ❌ No Medium Volatile / Flighty None

6️ Key Takeaways


Analyst Insight:
When evaluating a bank’s funding profile, focus on:



Coverage Ratio – Liquidity Strength Metric (Origin Bancorp Example)


Formula

[ \text{Coverage Ratio} = \frac{(a + b)}{c} ]

Where:

Symbol Description Value ($000)
a Total Additional Liquidity Sources (FHLB lines + Unpledged AFS + Fed window) 4,449,913
b Cash & Cash Equivalents 626,909
c Uninsured, Non-Collateralized Deposits 3,177,704
d = (a + b)/c Coverage Ratio 1.60×

What It Measures

It measures how much available liquidity a bank has relative to its uninsured, non-collateralized deposits — i.e., the most flight-prone funding source.

Interpretation:
For every $1 of uninsured, non-collateralized deposits, the bank holds $1.60 of available liquidity.


Why It Matters

Aspect Explanation
Post-SVB Focus After 2023’s banking turmoil, investors track uninsured deposit exposure closely.
Liquidity Stress Test Proxy Tests whether the bank could cover a rapid outflow of uninsured deposits.
Regulatory Lens A non-LCR ratio used by community/regional banks to signal resilience.
Investor Comfort Ratios >1.0× suggest enough coverage for high-stress withdrawal scenarios.

Components Explained

Component Nature Liquidity Speed
Cash & Cash Equivalents (b) Immediate funds held on balance sheet. Same-day
Unpledged AFS Securities Securities available for sale or repo. Within 1–2 days
FHLB Borrowing Availability Secured funding line from Federal Home Loan Bank. Within hours
Fed Funds Lines & Discount Window Emergency access to Federal Reserve liquidity. Same-day
Uninsured, Non-Collateralized Deposits (c) Deposits above FDIC insurance cap, unpledged. Can leave quickly

Typical Ranges

Coverage Ratio Interpretation
>1.5× Very strong liquidity; ample cushion.
1.0–1.5× Adequate coverage; manageable stress scenario.
<1.0× Tight liquidity; would require asset sales or external funding.

OBK’s 1.60× ratio indicates a strong liquidity position.


Summary Table

Metric Definition Formula 3Q25 Value Meaning
Coverage Ratio Available liquidity vs. uninsured deposits (FHLB + Unpledged AFS + Fed Lines + Cash) ÷ Uninsured deposits 1.60× OBK holds $1.60 of accessible liquidity for every $1 of uninsured deposits.

Analyst Tip

Rule of Thumb: Coverage Ratio ≥ 1.25× is considered healthy.
Below 1× means the bank could not fully cover its uninsured outflows without outside funding.
The higher the ratio, the greater the liquidity resiliency and regulatory comfort.



Understanding the Statement of Comprehensive Income vs. Income Statement (Using Origin Bancorp Example)


Core Difference

Statement What It Shows Scope
Income Statement (Statement of Income) Performance from operating activities — revenues, expenses, provisions, and taxes. Net Income (bottom line of core profitability).
Statement of Comprehensive Income Includes Net Income + Other Comprehensive Income (OCI) — changes in equity from non-owner sources. Comprehensive Income (total change in equity excluding capital actions).

[ \text{Comprehensive Income} = \text{Net Income} + \text{Other Comprehensive Income (OCI)} ]


Why Banks Need a Separate “Comprehensive” Statement

Banks hold large portfolios of Available-for-Sale (AFS) securities, derivatives, and hedges, which are marked to market.
Changes in their fair value affect shareholders’ equity, but not net income — unless the securities are sold.

Therefore, GAAP requires these unrealized gains/losses to be reported in Other Comprehensive Income (OCI).


How the Two Statements Flow Together

Category Appears in Income Statement? Appears in OCI (Comprehensive Statement)? Example (OBK 3Q25)
Interest income / expense ✅ Yes ❌ No $100.8M Net interest income
Provision for credit losses ✅ Yes ❌ No $36.8M provision
Operating expenses ✅ Yes ❌ No Salaries, occupancy, etc.
Unrealized gain/loss on AFS securities ❌ No ✅ Yes $15.8M gain in OCI
Cash flow hedge gains/losses ❌ No ✅ Yes $(70)k adjustment
Tax effects on above items ❌ No ✅ Yes $3.3M tax expense on AFS gain
Net income (bottom line) ✅ Yes ✅ Used as starting point  
Comprehensive income (final line) ❌ No ✅ Yes (Net Income + OCI) $21.0M total comprehensive income

Typical Components of OCI for a Bank

OCI Item Source Why It’s in OCI (not Net Income)
Unrealized gains/losses on AFS securities Mark-to-market changes in AFS portfolio Not realized through sale yet
Unrealized gains/losses on cash flow hedges Derivatives used to hedge interest rate risk Hedge accounting rules defer recognition
Foreign currency translation adjustments For foreign operations (not relevant for OBK) Non-cash, unrealized impact
Pension plan adjustments Actuarial changes in defined-benefit plans Long-term, not core earnings

Everything reported under Other Comprehensive Income (OCI) accumulates into
AOCI (Accumulated Other Comprehensive Income) within Shareholders’ Equity on the balance sheet.

[ \text{Ending AOCI (Balance Sheet)} = \text{Beginning AOCI} + \text{Current Period OCI (Statement of Comprehensive Income)} ]

OCI affects equity (and thus Tangible Common Equity and TBVPS) — even though it doesn’t affect earnings.


Summary Table

Aspect Income Statement Comprehensive Income Statement
Purpose Measure profitability from operations. Measure total change in equity from all sources except capital actions.
Includes Revenues, expenses, provision, taxes. Net income + OCI (AFS, hedges, etc.).
Output Net Income. Comprehensive Income.
Impacts Earnings (EPS, ROAA). Equity (AOCI, TBVPS).
Used for Valuation & P/E analysis. Capital strength & TBV analysis.
OBK Example (3Q25) Net income $8.6M OCI $12.4M → Comprehensive income $21.0M.

Analyst Tip

The Income Statement tells you what the bank earned.
The Comprehensive Income Statement tells you what the bank is worth more or less by — even before those gains/losses are realized.

That’s why analysts often adjust TBV for AOCI, but not EPS, because AOCI changes capital, not earnings.