This guide is mainly for fintech founders and operators evaluating a sponsor bank, meaning the regulated bank that will hold customer funds, issue accounts, or sit behind a banking product. Credit analysts, financial journalists, and small-bank directors can use the same public fields, but the main decision here is sponsor-bank diligence: is deposit repricing a manageable earnings headwind, or is the bank replacing relationship balances with rate-sensitive funding?
What To Check First For Deposit Repricing Risk
- Deposit mix: Open Schedule RC-E, the Call Report schedule for deposit liabilities, and compare noninterest-bearing deposits, savings and money market accounts, CDs, brokered deposits, reciprocal deposits, listing-service deposits, and large time deposits.
- Deposit cost: Use Schedule RI for deposit interest expense and Schedule RC-K for average balances to estimate how quickly interest-bearing deposits are repricing.
- Runoff and replacement: A rising deposit cost is most concerning when low-cost deposits are falling, large CDs are rising, or brokered and listing-service deposits appear at the same time.
Decision rule: treat deposit repricing as unresolved funding risk when two consecutive quarters show any three of these signals: noninterest-bearing deposit share falling, time deposits over $250,000 rising, brokered or listing-service deposits rising, annualized interest-bearing deposit cost rising faster than peers, uninsured deposits staying high, or management giving no specific runoff and pricing plan.
Last updated / sources: As of 2026-04-23, this article uses public FFIEC, FDIC, OCC, and Federal Reserve materials. The FFIEC Central Data Repository provides public Call Reports, and the FDIC’s March 2026 Call Report forms and instructions page points to FFIEC 031, 041, and 051 forms with instructions most recently updated December 31, 2025.[1][2] The rate backdrop matters: the Federal Reserve’s open market table shows the FOMC target range moving from 0.25%-0.50% on March 17, 2022 to 5.25%-5.50% on July 27, 2023, a 500 basis point move in both bounds.[3] Verify the latest filings and enforcement updates before citing in a credit memo or investor document.
Which Deposit Fields Matter In Schedule RC-E?
Start with institution identity, then deposit mix. Use FDIC BankFind Suite or NIC Institution Search to confirm the legal bank, primary regulator, FDIC certificate, and RSSD identifier before reading the Call Report.[4][5] That step keeps bank-level deposit liabilities separate from holding-company commentary and from fintech program branding.
In Schedule RC-E, “Deposit Liabilities,” do not stop at total deposits. Split noninterest-bearing transaction accounts from interest-bearing transaction accounts, money market deposit accounts, other savings, time deposits, brokered deposits, reciprocal deposits, and listing-service deposits. Reciprocal deposits are deposits placed through a network so customers can receive broader insurance coverage across banks. Listing-service deposits come from rate-listing platforms where customers often compare yield. A bank with 30% noninterest-bearing deposits has a different repricing profile than one with 5% noninterest-bearing deposits and a fast-growing CD book, even if total deposits are the same.
| Field to check | Public source | Why it matters |
|---|---|---|
| Total deposits and noninterest-bearing versus interest-bearing deposits | Schedule RC-E, Deposit Liabilities | Shows how much of the funding base reprices directly when customers demand higher rates. |
| Money market deposit accounts and other savings deposits | Schedule RC-E Memorandum item 2.a in the FFIEC 051 RC-E instructions[6] | These balances can look stable until competitors raise rates or customers move balances into CDs. |
| Time deposits below $100,000, $100,000 through $250,000, and more than $250,000 | Schedule RC-E Memorandum items 2.b, 2.c, and 2.d | The $250,000 split lines up with the standard FDIC insurance amount and helps separate retail CDs from larger rate-sensitive accounts. |
| Time deposits with remaining maturity or next repricing date of three months or less, over three months through 12 months, over one year through three years, and over three years | Schedule RC-E Memorandum items 3 and 4 | Near-term buckets show how much CD cost can reset inside the next quarter or year. |
| Total brokered deposits, brokered deposits of $250,000 or less, reciprocal deposits, and listing-service deposits | Schedule RC-E Memorandum items 1.b, 1.c, 1.g, and 1.f; Schedule RC-O item 9 for brokered reciprocal deposits | Brokered, reciprocal, and listing-service funding can be useful, but it needs a different stability assumption than local operating accounts. |
| Estimated uninsured deposits | Schedule RC-O Memorandum item 2 and FDIC reporting expectations[7] | Banks with $1 billion or more in total assets report estimated uninsured deposits; this is a confidence and runoff field, not just a deposit-cost field. |
Takeaway: the first risk signal is not “deposits are down.” It is a mix shift from operating balances into balances that can demand a market rate or leave when a better rate appears.
The FDIC states the standard insurance amount as $250,000 per depositor, per insured bank, for each ownership category.[8] That does not mean every balance over $250,000 will leave under stress, but it is the first public threshold to use when reading uninsured deposits and large time deposits.
How To Spot Runoff Versus Normal Repricing
Deposit cost alone is incomplete because it can rise with healthy growth or with defensive funding. Use Schedule RI for interest expense on deposits and Schedule RC-K, the schedule of quarterly average balances. A clean screen is: annualized cost of interest-bearing deposits equals quarterly interest expense on interest-bearing deposits multiplied by 4, divided by Schedule RC-K average interest-bearing deposits.
- Peer compare: For each bank, calculate noninterest-bearing deposits divided by total deposits, time deposits over $250,000 divided by total deposits, brokered deposits divided by total deposits, uninsured deposits divided by total deposits when Schedule RC-O Memorandum item 2 is reported, and annualized interest-bearing deposit cost. Put the candidate next to peers in the same quarter using the bank peer comparison view.
- Movement compare: A 75 basis point increase in deposit cost with flat balances is less concerning than the same 75 basis point increase paired with 10% deposit runoff and a new brokered-deposit balance in Schedule RC-E Memorandum item 1.b.
- Insurance compare: Pair the FDIC $250,000 coverage amount with Schedule RC-O estimated uninsured deposits. For a fintech program, ask whether the bank can identify beneficial owners and reconcile third-party ledger records, because uninsured status and record access are separate issues.
Three red-flag combinations matter more than any single line item. First, noninterest-bearing deposits fall while large time deposits rise. Second, deposit cost rises faster than peers while total deposits still shrink. Third, uninsured deposits remain high while management adds brokered, reciprocal, or listing-service funding. Each combination says the same thing in a different way: customers may no longer be choosing the bank for the relationship.
There are false positives. Rising deposit cost is not automatically a problem when total deposits are stable, noninterest-bearing share is only drifting, loan yields are resetting, and the bank is deliberately matching deposit duration to asset cash flows. Healthy repricing looks planned: the bank pays more where it must, keeps core operating accounts, avoids sudden wholesale replacement, and explains the maturity profile in terms that match the filing.
Mini workflow: take a hypothetical $2.0 billion-deposit bank and compare the current quarter with the same quarter one year earlier.
| Step | Public filing field | Hypothetical reading | Decision signal |
|---|---|---|---|
| 1 | Schedule RC-E total deposits and noninterest-bearing deposits | Total deposits fall from $2.00 billion to $1.85 billion; noninterest-bearing deposits fall from $600 million, or 30%, to $360 million, or 19%. | The bank is not just paying more. It is losing low-cost balances. |
| 2 | Schedule RC-E Memorandum item 2.d and items 4.a through 4.b | Time deposits over $250,000 rise from $100 million, or 5%, to $300 million, or 16%; $200 million reprices or matures within 12 months. | Near-term funding cost pressure is visible in the maturity buckets. |
| 3 | Schedule RC-E Memorandum item 1.b and Schedule RC-O item 9 | Brokered deposits move from $0 to $150 million, with brokered reciprocal deposits reported. | The bank may be replacing relationship funding with purchased or networked funding. |
| 4 | Schedule RI deposit interest expense and Schedule RC-K average interest-bearing deposits | Quarterly deposit interest expense rises from $4 million on $1.40 billion of average interest-bearing deposits to $16 million on $1.49 billion. | Annualized interest-bearing deposit cost moves from 1.14% to 4.30%, or up 316 basis points. |
| 5 | Schedule RC-O Memorandum item 2 | Estimated uninsured deposits fall from $700 million, or 35%, to $600 million, or 32%. | The dollar amount is down, but uninsured concentration remains high enough to ask about depositor composition. |
Takeaway: this is a repricing problem, not a routine mix change, because the bank is paying more after losing low-cost balances and replacing part of the base with funding that can reset or leave quickly.
The simple deposit beta on interest-bearing deposits is about 63% if the benchmark move is the 500 basis point FOMC target-range change cited above. Deposit beta means the share of a market-rate move that shows up in a bank’s deposit costs. The next question is whether peers show the same pattern or whether this bank is paying up faster because its funding franchise is weaker.
Compare Deposit Repricing To Asset Yields
Repricing risk affects margin through both sides of the balance sheet. Compare Schedule RI interest income and interest expense with Schedule RC-K average earning assets and average interest-bearing liabilities. Then use Schedule RC-C for loans and Schedule RC-B for securities to see whether earning assets can reset fast enough to offset deposit cost.
If interest-bearing deposit cost rises 316 basis points while loan yield rises only 90 basis points, the margin problem is not solved by saying rates are higher. The bank needs enough floating-rate loans, new loan production, securities cash flow, or fee income to absorb the funding cost. If those offsets are not visible, the deposit trend should flow into the net interest margin forecast.
Do not let a clean deposit table hide asset-side limits. For a community bank with heavy commercial real estate exposure, compare Schedule RC-C real estate loan balances with Schedule RC-R capital. The December 2006 Interagency CRE Concentration Guidance names two supervisory screens: construction, land development, and other land loans at 100% or more of total capital; or total CRE loans at 300% or more of total capital with CRE growth of 50% or more during the prior 36 months.[9] Those are not deposit thresholds. They matter here only because a bank under funding pressure has less room to solve a margin squeeze by stretching for new asset yield.
Credit quality also changes the deposit call. Schedule RC-N past due and nonaccrual loans, Schedule RI-B charge-offs and recoveries, and Schedule RI-C allowances help answer whether the bank can wait for assets to reprice or whether rising credit cost will eat the same margin dollars that higher deposit costs are already taking.
Read Management’s Deposit Repricing Response
Management response should match the filing data. If management says relationship deposits are stable while Schedule RC-E shows an 11 percentage point drop in noninterest-bearing deposit share, a tripling of time deposits over $250,000, and new brokered balances, ask for the customer, product, and maturity explanation. Promotional CDs, branch campaigns, reciprocal programs, brokered funding, Federal Home Loan Bank advances, and relationship pricing each carry a different runoff and cost assumption.
For sponsor-bank diligence, third-party deposit programs need their own read because program deposits can move differently from local operating accounts. The June 2023 Interagency Guidance on Third-Party Relationships says a banking organization’s use of third parties does not remove its responsibility to operate safely and comply with law.[10] The July 25, 2024 Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services, issued through FDIC FIL-45-2024 and parallel OCC and Federal Reserve releases, names liquidity and concentration risk among the risks that can be elevated in these arrangements.[11] For repricing analysis, that means program deposits should not be treated as sticky just because the customer interface is strong.
Synapse Financial Technologies is the example most fintech readers will recognize. The CFPB’s Synapse enforcement action page states that Synapse filed for chapter 11 bankruptcy protection on April 22, 2024 and alleges a shortfall between Synapse records and partner-bank records of $60 million to $90 million.[12] That is not a Call Report field, but it changes how to read deposit stability: cost, legal ownership records, pass-through insurance assumptions, and operational access to funds are separate questions.
Before relying on management commentary, check public enforcement sources. Search the FDIC enforcement orders database, the OCC enforcement actions page, and the Federal Reserve’s enforcement actions database.[13][14][15] If an order discusses liquidity, brokered deposits, capital, concentration risk, third-party risk, or board oversight, cite the order date and regulator rather than summarizing from memory. An order does not prove deposit repricing risk by itself, but it can explain why the same deposit mix is riskier at one bank than at a cleaner peer.
The FDIC Failed Bank List records Silicon Valley Bank on March 10, 2023, Signature Bank on March 12, 2023, and First Republic Bank on May 1, 2023.[16] Those dates are not a shortcut for judging any other bank. They are a reason to avoid loose language about “sticky deposits.” In a memo, “sticky” should mean the filing history shows stable balances, manageable repricing, limited uninsured concentration, and no sudden replacement with brokered or high-cost time deposits.
FAQ
Which schedule should I open first? Start with Schedule RC-E for deposit mix, then Schedule RI and Schedule RC-K for cost. Add Schedule RC-O when uninsured deposits, brokered reciprocal deposits, or deposit insurance assessment fields matter to the question.
Is brokered deposit growth always bad? No. Brokered funding can be planned and well managed. It becomes a warning sign when it appears at the same time as noninterest-bearing runoff, high uninsured concentration, rising deposit cost, weak liquidity commentary, or an enforcement order that names funding or liquidity controls.
When is rising deposit cost not a problem? It is less concerning when the bank keeps its core deposit base, peers show a similar increase, asset yields are resetting fast enough, and management can explain the pricing plan without leaning on vague claims about loyal customers.
How should a fintech founder use this before choosing a sponsor bank? Confirm the legal bank in BankFind or NIC, read five quarters of Schedule RC-E and RC-O, compare the bank with peers, and then check whether public third-party-risk guidance or enforcement actions point to deposit program weaknesses. Do not treat a brand name or API capability as a substitute for the bank-level funding record.
Can I use net interest margin by itself? No. NIM is the result, not the diagnosis. A bank can show acceptable NIM for one quarter while replacing cheap deposits with CDs, brokered deposits, or borrowings that will reprice the next quarter.
Sources
- FFIEC Central Data Repository, public Call Reports: https://cdr.ffiec.gov/public/
- FDIC current quarter Call Report forms, instructions, and related materials: https://www.fdic.gov/bank-financial-reports/current-quarter-call-report-forms-instructions-and-related-materials
- Federal Reserve Open Market Operations table, FOMC target ranges: https://www.federalreserve.gov/monetarypolicy/openmarket.htm
- FDIC BankFind Suite, bank identity and certificate lookup: https://banks.data.fdic.gov/bankfind-suite/
- FFIEC National Information Center Institution Search: https://www.ffiec.gov/NPW
- FFIEC 051 Schedule RC-E Deposit Liabilities instructions, December 2025: https://www.fdic.gov/bank-financial-reports/ffiec-051-schedule-rc-e-deposit-liabilities-december-2025.pdf
- FDIC FIL-37-2023, estimated uninsured deposits reporting expectations: https://www.fdic.gov/news/financial-institution-letters/2023/estimated-uninsured-deposits-reporting-expectations
- FDIC Deposit Insurance At A Glance, standard deposit insurance amount: https://www.fdic.gov/resources/deposit-insurance/brochures/deposits-at-a-glance/
- Federal Reserve, Interagency Guidance on CRE Concentrations, December 2006: https://www.federalreserve.gov/frrs/guidance/interagency-guidance-on-concentrations-in-commercial-real-estate-lending-sound-risk-management-practices.htm
- FDIC FIL-29-2023, Interagency Guidance on Third-Party Relationships: https://www.fdic.gov/news/financial-institution-letters/2023/fil23029.html
- FDIC FIL-45-2024, Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services: https://www.fdic.gov/news/financial-institution-letters/2024/agencies-issue-statement-bank-arrangements-third-parties
- CFPB Synapse Financial Technologies enforcement action page: https://www.consumerfinance.gov/enforcement/actions/synapse-financial-technologies-inc/
- FDIC enforcement orders database: https://orders.fdic.gov/
- OCC enforcement actions page: https://www.occ.gov/topics/laws-and-regulations/enforcement-actions/index-enforcement-actions.html
- Federal Reserve enforcement actions database: https://www.federalreserve.gov/supervisionreg/enforcementactions.htm
- FDIC Failed Bank List: https://www.fdic.gov/bank-failures/failed-bank-list