Insider and related-party credit, commercial real estate concentration, and deposit concentration are three bank Call Report clues that can change a diligence decision. The point is not to prove misconduct from one disclosure; it is to decide whether the bank should be cleared, watched, priced differently, or escalated before a sponsor-bank selection, credit memo, board approval, or public comparison.
Quick summary: insider credit means loans or credit extensions to directors, executive officers, principal shareholders, or their related interests. CRE concentration means commercial real estate exposure that is large relative to capital and growth. Deposit concentration means funding that depends heavily on brokered, uninsured, third-party, program, or other less-stable channels.
The most useful schedules are RC-M for insider and related-party credit, RC-C and RC-R for CRE exposure versus capital, RC-E and RC-O for deposit mix, and RC-N, RI-B, and RI-C for credit quality and allowances. The practical takeaway is simple: a clue becomes a decision only when it is tied to a schedule, a trend, a control record, and the next document needed.
Bank Call Report Cheat Sheet
A useful filing review starts with the legal bank, the regulator, and the reporting form. Check the institution in FDIC BankFind[1] or the Federal Reserve National Information Center[2], then pull the bank’s Call Report from the FFIEC Central Data Repository[3]. Once the report is open, translate the schedule codes into plain English before writing the memo.
- RC-M: insider and related-party credit, plus other memoranda.
- RC-C and RC-R: loan categories and the capital denominator used for CRE concentration screens.
- RC-E and RC-O: deposit detail, brokered deposits, assessment data, and uninsured-deposit reporting.
- RC-N, RI-B, and RI-C: past due and nonaccrual loans, charge-offs and recoveries, and allowances.
- NIC, CECL, BaaS, and FBO: the Fed’s institution directory, current expected credit loss accounting, banking-as-a-service, and for-benefit-of account structures.
| Clue | Public source to check | Decision rule |
|---|---|---|
| Insider or related-party credit | Schedule RC-M and Federal Reserve Regulation O[4] | If item 1.b is above zero, or aggregate insider credit is rising, request the board approval record, abstention record, and ordinary-market credit support. |
| CRE concentration | Loan categories, total risk-based capital, and OCC Bulletin 2006-46[5] | If construction and land loans reach 100 percent of total risk-based capital, or total CRE reaches 300 percent with 50 percent growth in 36 months, escalate the file for capital, allowance, and stress-test review. |
| Funding or deposit concentration | Deposit detail, assessment data, and uninsured-deposit reporting expectations[6] | If the bank relies on brokered, high-rate, third-party, or uninsured deposits, tie the funding source to runoff assumptions and contingency liquidity instead of treating deposits as one stable line item. |
| Allowance pressure | Past due loans, nonaccrual loans, net charge-offs, and CECL allowances[8] | If problem loans and net charge-offs are moving faster than the allowance, write down the bridge between management’s reserve story and the reported credit data. |
Action Checklist For Bank Filing Review
Build the review into the workflow before the investment committee, sponsor-bank selection call, or board packet is drafted. Start with the bank search and individual bank profiles at /banks, then move to the public-source checks below so each conclusion can be traced back to a filing, an instruction, or an order.
- Confirm the legal bank name, FDIC certificate, RSSD ID, charter type, and primary federal regulator in BankFind or NIC before comparing banks with similar trade names.
- Pull the latest Call Report from the FFIEC Central Data Repository and note the form type: FFIEC 031, FFIEC 041, or FFIEC 051.
- Read the insider-credit schedule, loan and capital schedules, deposit schedules, and credit-quality schedules before relying on the headline ratio page.
- Search FDIC enforcement decisions and orders[14], OCC enforcement actions[15], and Federal Reserve enforcement actions[16] by legal bank name and holding company name.
- For fintech, payment, banking-as-a-service, middleware, or affiliate programs, map the relationship to the June 2023 third-party guidance stages: planning, due diligence, contract, monitoring, and termination.[7]
- End the memo with one of three calls: clear for ordinary monitoring, watch with named triggers, or escalate before approval. A useful trigger names the schedule, the threshold, and the next document needed.
Read Insider And Related-Party Credit In Call Reports
For insider and related-party credit, the named source is Schedule RC-M, not rumor. Item 1 covers extensions of credit by the reporting bank to executive officers, directors, principal shareholders, and their related interests, using definitions from Federal Reserve Regulation O, 12 CFR Part 215.[4] Regulation O generally treats a principal shareholder as a person or company with power to vote more than 10 percent of a class of voting securities, and item 1.b counts insiders whose related credit equals or exceeds the lesser of $500,000 or 5 percent of total capital.
That disclosure is not an accusation. It is a prompt. If insider credit is present, ask whether the bank can document board approval, abstention by the interested party, ordinary-market terms, and normal underwriting. If insider credit rises while nonaccrual loans or charge-offs worsen, the follow-up moves from governance hygiene to credit quality.
Review CRE And Deposit Concentration In Context
A bank can be concentrated by borrower, sponsor, industry, geography, collateral, deposit channel, service provider, affiliate, or fintech program. The question is whether the concentration is measured, limited, stress-tested, and tied to capital, liquidity, reserves, and board reporting. A rural agriculture lender, a warehouse lender, or a sponsor bank may be concentrated by design; the reviewer still needs proof that management understands the exposure.
The best-known public screen is the 2006 interagency CRE concentration guidance. OCC Bulletin 2006-46 says regulators may identify a bank for further review when construction, land development, and other land loans are 100 percent or more of total risk-based capital, or when total CRE loans are 300 percent or more of total risk-based capital and CRE has grown 50 percent or more during the prior 36 months.[5] The same guidance says those numbers are supervisory criteria, not hard lending limits.
Deposit concentration deserves the same discipline as loan concentration. FDIC guidance on estimated uninsured deposits reporting notes that the uninsured-deposit memorandum item is completed by banks with $1 billion or more in total assets.[6] For sponsor-bank diligence, brokered-deposit memoranda and uninsured-deposit data are starting points, not the finish line. The follow-up is ledger reconciliation, program-owner controls, pass-through insurance records, and exit planning.
For third-party and fintech programs, pair the schedules with the June 2023 Interagency Guidance on Third-Party Relationships: Risk Management.[7] That guidance covers planning, due diligence, contract negotiation, ongoing monitoring, and termination. It also says a bank’s use of a third party does not reduce the bank’s responsibility to operate safely and comply with law.
Connect Filing Clues To Credit Quality
Related-party and concentration clues matter most when they connect to credit deterioration, rapid balance-sheet growth, weak liquidity, or unusual transactions. A fintech founder may care first about operational continuity. A credit analyst may care first about capital and loss absorption. A journalist may care first about whether public claims match public filings. The same source trail serves all three.
Do not isolate the narrative footnote from the credit schedules. If a bank has a CRE concentration, compare loan categories with capital, past due and nonaccrual amounts, net charge-offs, and allowances. The FDIC’s CECL materials state that FASB issued ASU 2016-13, Topic 326, on June 16, 2016, introducing the current expected credit losses method.[8] That matters because the allowance should reflect expected credit losses, not just losses already charged off.
Recent bank events show why a filing clue must be tied to a source, a date, and a schedule. The FDIC says Silicon Valley Bank was closed on March 10, 2023,[9] Signature Bank was closed on March 12, 2023,[10] and First Republic Bank was closed on May 1, 2023.[11] Those dates do not make every concentrated bank unsafe. They remind the reviewer to connect customer, depositor, asset, and funding concentration before a stress event forces the connection.
Short case study: third-party-program clue. In sponsor-bank review, Evolve Bank & Trust and Synapse are useful because the public materials tie a program-risk clue to controls, reconciliation, and customer records, not because they prove anything about another sponsor bank. The Federal Reserve issued a June 14, 2024 enforcement action against Evolve Bancorp, Inc. and Evolve Bank & Trust for deficiencies in anti-money-laundering, risk management, and consumer compliance programs.[12] The CFPB’s Synapse matter says Synapse filed for chapter 11 bankruptcy protection on April 22, 2024 and describes an alleged shortfall between $60 million and $90 million between consumer funds reflected in Synapse records and funds held by partner banks.[13] The practical question for another bank is whether reconciliations, program ledgers, customer records, and termination plans are strong enough to prove who owns what.
Separate disclosure from interpretation. A related-party loan, a high CRE ratio, or a large third-party deposit program is a fact. The interpretation depends on trend, controls, loss history, liquidity, capital, and enforcement history. If the facts do not line up, the memo should say unresolved rather than stretch into a conclusion.
Sample Watch-Memo Decision
Assume two banks both report a similar headline capital ratio. Bank A has total CRE near the 300 percent screen, but growth is below 50 percent over 36 months, nonaccrual loans are flat, and deposit funding is mostly core customer deposits. The watch memo can say: ordinary monitoring, with a trigger to escalate if CRE growth crosses the guidance screen or problem loans move faster than the allowance.
Bank B reports total CRE above 300 percent of total risk-based capital, CRE growth above 50 percent, rising nonaccrual loans, and a larger share of brokered or uninsured deposits. Even before any conclusion about misconduct, the decision should change: request the CRE stress test, board concentration limits, allowance support, uninsured-deposit runoff assumptions, and any active enforcement or remediation materials before approval. The difference is not the ratio by itself. It is the stack of clues pointing in the same direction.
A tight decision rule is better than a long generic paragraph: if a concentration crosses a published supervisory screen, if insider credit is material to capital, if uninsured or third-party deposits drive funding, or if enforcement orders name the same control weakness you are relying on, do not treat the bank as a peer just because its headline capital ratio looks similar.
FAQ
Does Call Report insider credit mean the bank did something wrong?
No. Insider credit is a disclosure point. It becomes a diligence issue when the amount is large relative to capital, the count of larger insider credits changes, the bank cannot document Regulation O process, or the same period shows worsening past due, charge-off, or allowance trends.
Are the 100 percent and 300 percent CRE concentration numbers hard limits?
No. OCC Bulletin 2006-46 describes them as supervisory criteria for further analysis. They are not safe harbors and they are not automatic violations. They are strong triggers for questions about capital, underwriting, market analysis, and stress testing.
What if the bank has no SEC filing?
Use the Call Report, FDIC BankFind, NIC, and the enforcement databases. Private banks still file Call Reports, and those schedules often give enough public data to identify insider credit, CRE concentration, deposit mix, past due loans, charge-offs, and allowances.
What should a fintech founder ask a potential sponsor bank?
Ask which public schedules best explain the bank’s funding mix and credit risk, whether any FDIC, OCC, or Federal Reserve order is active, who owns third-party risk at the board level, how FBO or custodial ledgers reconcile to the core, and what happens if the program or middleware provider must be terminated.
Sources
- FDIC BankFind, bank identity and certificate lookup: https://banks.data.fdic.gov/bankfind-suite/
- Federal Reserve National Information Center, institution and RSSD lookup: https://www.ffiec.gov/NPW
- FFIEC Central Data Repository, public Call Report retrieval: https://cdr.ffiec.gov/public/
- Federal Reserve Regulation O, insider-lending definitions and related interests: https://www.federalreserve.gov/frrs/regulations/regulation-o-loans-to-executive-officers-directors-and-principal-shareholders-of-member-banks.htm
- OCC Bulletin 2006-46, interagency CRE concentration guidance: https://www.occ.gov/news-issuances/bulletins/2006/bulletin-2006-46.html
- FDIC estimated uninsured deposits reporting expectations: https://www.fdic.gov/news/financial-institution-letters/2023/estimated-uninsured-deposits-reporting-expectations
- FDIC FIL-29-2023, Interagency Guidance on Third-Party Relationships: Risk Management: https://www.fdic.gov/news/financial-institution-letters/2023/fil23029.html
- FDIC accounting and CECL resources, including ASU 2016-13 context: https://www.fdic.gov/accounting
- FDIC failed-bank page for Silicon Valley Bank: https://www.fdic.gov/resources/resolutions/bank-failures/failed-bank-list/silicon-valley.html
- FDIC failed-bank page for Signature Bank: https://www.fdic.gov/resources/resolutions/bank-failures/failed-bank-list/signature-ny.html
- FDIC First Republic Bank press release: https://www.fdic.gov/news/press-releases/2023/pr23034.html
- Federal Reserve enforcement action for Evolve Bancorp, Inc. and Evolve Bank & Trust: https://www.federalreserve.gov/newsevents/pressreleases/enforcement20240614a.htm
- CFPB Synapse Financial Technologies enforcement matter: https://www.consumerfinance.gov/enforcement/actions/synapse-financial-technologies-inc/
- FDIC enforcement decisions and orders: https://orders.fdic.gov/
- OCC enforcement actions: https://www.occ.gov/topics/laws-and-regulations/enforcement-actions/index-enforcement-actions.html
- Federal Reserve enforcement actions: https://www.federalreserve.gov/supervisionreg/enforcementactions.htm