A UBPR report is the FFIEC’s performance report for a bank: it turns Call Report data into ratios for earnings, capital, liquidity, asset quality, and growth. For a credit analyst, the hard part is not reading the ratio; it is proving that the peer group is real enough for the decision. Real peers are banks with a similar size, business model, loan mix, funding model, and reporting period, not merely banks in the same default UBPR bucket.
The core takeaway is simple: use the default UBPR peer group as a first screen, then test it. If a bank looks strong only because it is being compared with the wrong population, build a custom peer set and tie the conclusion back to the Call Report schedules behind the ratio.
As of 2026-04-23, the schedules, thresholds, and guidance referenced below are summarized from public FFIEC, FDIC, OCC, Federal Reserve, CFPB, and other regulator sources. Verify the latest filings and enforcement updates in the sources before citing this analysis in a credit memo or investor document.
What Is A UBPR Report?
Start with the FFIEC Uniform Bank Performance Report[1] because it was built for supervisory, examination, and management analysis. For most peer questions, trace the ratio back to the Call Report schedules that carry the largest signal: RC for the balance sheet, RI for income, RC-R for capital, RC-C for loans, RC-N for problem loans, and RC-E or RC-O for deposits.
The FDIC Call Report forms page lists current FFIEC 031, 041, and 051 materials[2], and the FFIEC Central Data Repository makes Call Report data available in PDF, semicolon-delimited, and XBRL formats[3]. The practical point is that a UBPR ratio is a calculated view of public filing data, so a reviewer can rebuild the number instead of accepting it as a black box.
Schedule map for workpapers: RC covers the balance sheet; RI covers income; RC-R covers capital; RC-C covers loans; RC-N covers past due and nonaccrual loans; RC-E and RC-O cover deposits; RI-B covers charge-offs and recoveries; RI-C covers allowances; and RC-K covers average balances.
How UBPR Peer Groups Are Built
A UBPR percentile is only as useful as the comparison set behind it. FFIEC explains that UBPR peer averages are trimmed averages: the top 5 percent and bottom 5 percent of ratio values are excluded before the average is calculated, and a double number sign appears when fewer than five valid ratio values are available[1]. Percentile rank is different because it ranks the bank against all banks in the peer group for that ratio.
That matters because a bank can look like an outlier against the wrong population and ordinary against a better one. Asset size, loan mix, deposit model, branch network, regulator, and geography can all change a ratio before management quality enters the discussion. A branch-heavy agricultural lender, a CRE lender, and a bank with a large fintech deposit program should not be treated as interchangeable just because they file a Call Report.
FFIEC made this point in practice in its February 13, 2026 UBPR peer group memorandum[4]. For commercial banks with assets up to $300 million, FFIEC removed office count and headquarters MSA status from the peer group definition effective February 26, 2026, leaving asset size as the main peer-group factor for those smaller banks.
| FFIEC example from the 2026 memo[4] | Bank count for 9/30/2025 | Peer average ROAA | Peer average Tier 1 leverage |
|---|---|---|---|
| Legacy Peer Group 14: less than $50 million average assets, 2 or more offices, headquarters in an MSA | 8 | -1.94 percent | 12.99 percent |
| Revised Peer Group 8: less than $50 million average assets | 159 | 0.74 percent | 16.33 percent |
The lesson is simple: a ratio did not become better because a peer definition changed. The denominator changed. If a board packet, acquisition screen, or credit memo uses a percentile rank, the memo should identify the peer source, report date, bank count, and any custom peer rules.
When The Default Peer Group Fails
The default UBPR peer group is a baseline, not the end of the analysis. FFIEC also provides a Custom Peer Group Bank Report that lets users compare one bank with a user-defined group of banks[5]. You can pair that work with an internal peer comparison view when the business question is narrower than the standard UBPR bucket.
How To Build A Custom Peer Set
Use three filters before you calculate the comparison: business model, report period, and risk driver. The risk driver is the thing most likely to explain the ratio, such as CRE concentration, agricultural credit exposure, deposit mix, branch model, or recent growth. Write the inclusion rule first, then add the banks.
- CRE lender: Build the peer set around RC-C real estate loan mix, not just asset size. The 2006 Interagency CRE Concentration Guidance flags construction, land development, and other land loans at 100 percent or more of total capital, or total CRE loans at 300 percent or more of total capital with CRE growth of 50 percent or more during the prior 36 months[6]. For commercial banks in that guidance, construction and land development came from RC-C item 1a, total capital from RC-R line 21, and total CRE from RC-C items 1a, 1d, 1e, and Memorandum item 3.
- Fintech sponsor-bank overlay: Do not compare a bank with a banking-as-a-service program only against ordinary community banks. Treat fintech activity as an overlay on the UBPR review by adding deposit composition from RC-E and RC-O, enforcement searches, and third-party risk sources such as FDIC FIL-29-2023[7]. If custodial deposit accounts with transactional features are part of the model, add FDIC FIL-64-2024 as a separate control question[8].
- Agricultural or rural lender: Include banks with similar RC-C farmland and agricultural production exposure, then check RC-N past due and nonaccrual trends and RI-B charge-offs. A bank with seasonal farm credit exposure can have a different quarterly pattern than an urban C&I lender.
- Branch-light or high-growth bank: Pair UBPR ratios with FDIC BankFind or NIC structure data before comparing efficiency, deposit growth, and liquidity[9][10]. A bank with few branches and a national deposit strategy can produce a very different RC-E funding profile than a local branch-funded bank.
Document the inclusion rule before you calculate the comparison. A defensible peer note says why each bank was included: same regulator, similar asset band, similar Call Report form, similar loan mix, similar geography, similar deposit model, or a stated reason for an exception.
A short example: a $900 million bank with heavy real estate loans and wholesale-funded growth may rank well on ROAA against its default asset peer group. If the custom peer set includes only banks in the same asset band with similar CRE concentration and noncore funding, the same result may look ordinary. The conclusion changes from ‘management is outperforming’ to ‘performance is consistent with the risk model.’
Common UBPR Peer Mistakes
- Treating a percentile as a verdict instead of a question for follow-up.
- Mixing report periods when one bank has a newer Call Report than the rest of the peer set.
- Ignoring deposit model when comparing efficiency, liquidity, or growth.
- Building the custom peer set after seeing the answer, instead of writing the inclusion rule first.
Review Trends And Rank Movement
A single UBPR percentile can be a weak signal. Trend direction, rank movement, and source-schedule confirmation are stronger. If a bank moves 20 percentile points or more over four consecutive quarters, treat that as a review trigger and reconcile it against the underlying Call Report schedules before writing a conclusion.
Use this seven-step workflow when a UBPR percentile could affect a credit memo, sponsor-bank decision, board package, or public article.
| Step | What to do | Primary source |
|---|---|---|
| 1 | Confirm the exact institution, charter, regulator, RSSD ID, and FDIC certificate. | FDIC BankFind[9] and NIC[10] |
| 2 | Pull the same report period for every bank in the peer set. | FFIEC CDR[3] and FDIC Call Report instructions[2] |
| 3 | Record the default UBPR peer group, bank count, and percentile. | FFIEC UBPR[1] |
| 4 | Build a custom peer set when strategy, geography, or deposit model differs from the default peer. | FFIEC Custom Peer Group Bank Report[5] and peer comparison view |
| 5 | Map each ratio to RC, RI, RC-R, RC-C, RC-N, RC-E, RC-O, RI-B, RI-C, or RC-K. | FFIEC 031, 041, or 051 instructions[2] |
| 6 | Apply issue-specific screens: CRE concentration, fintech third-party risk, allowance coverage, past due loans, deposit mix, and enforcement status. | Interagency guidance and regulator databases |
| 7 | Write the conclusion as a question for follow-up, not as a verdict from one percentile. | Memo workpapers |
The schedule check prevents false stories. A rising return on assets should be reconciled against RI income, RC-K average assets, provision expense, and unusual noninterest income. A falling allowance ratio should be checked against RI-C allowances, RC-N nonaccrual loans, and CECL context. The point is to explain what changed, not just report that the percentile moved.
Rank movement also needs a time rule. Compare the current quarter, the same quarter one year earlier, and at least three year-end points when they are available. If the peer rank moves but the bank’s RC-C loan mix, RC-E deposit mix, or RC-R capital ratios did not move in the same direction, check for merger activity, accounting changes, nonrecurring income, or a peer group definition change.
Connect UBPR Data To Decisions
UBPR-style analysis can support credit review, acquisition screening, board reporting, competitor tracking, sponsor-bank diligence, and risk monitoring. It should not be the whole decision. The useful output is a short list of specific follow-up questions tied to schedules, guidance, or enforcement records.
Use named public sources first. For identity, structure, and filings, start with FFIEC UBPR, the FFIEC Central Data Repository, FDIC BankFind, and NIC[1][3][9][10]. For enforcement context, check FDIC Orders, OCC Enforcement Actions, and Federal Reserve Enforcement Actions[11][12][13]. Do not describe a bank as weak, safe, troubled, or clean unless the statement is tied to a schedule, a dated order, or another primary source.
Edge-Case Overlay: Sponsor-Bank Diligence
For fintech founders, the UBPR page is only a starting screen. The peer question is whether a bank is comparable for the activity you need, not whether it has an attractive percentile. Synapse Financial Technologies, Inc. filed for chapter 11 bankruptcy protection on April 22, 2024, according to the Consumer Financial Protection Bureau[14], and FDIC FIL-64-2024 cites Synapse when discussing risks in custodial deposit accounts with transactional features[8]. Under the FDIC proposal, covered insured depository institutions would need controls including reconciliations no less frequently than close of business daily.
For credit analysts, the peer question is whether the comparison explains credit risk. A CRE-heavy bank should be reviewed against the 100 percent construction and land development screen, the 300 percent total CRE plus 50 percent growth screen, RC-N past due and nonaccrual trends, RI-B charge-offs, and RC-R capital. A low credit-cost quarter is not enough if nonaccrual loans or concentration ratios are moving the other way.
For financial journalists, the peer question is whether the public claim can be checked. A sentence such as ‘the bank is in the 90th percentile for a UBPR ratio’ is incomplete without the ratio name, report date, peer group, bank count, and schedule basis. If the story involves fintech deposits, AML/CFT, or third-party activity, add FDIC FIL-42-2024 on the AML/CFT program NPR and the relevant enforcement databases before drawing conclusions[15].
For directors, the peer question is whether management is using a flattering benchmark or a useful one. A good board package should show the default UBPR peer, one custom peer set, the reason each peer was included, the report dates used, and the schedule-level source for every ratio that drives a recommendation.
| Decision rule | Use it when | Next action |
|---|---|---|
| Accept the peer set | Same Call Report period, similar business model, clear inclusion rule, and no unexplained rank movement. | Use the peer ratios as context, not as a final answer. |
| Challenge the peer set | The UBPR peer average is based on a small group, the bank changed strategy, or the ratio moved 20 percentile points or more without a schedule-level explanation. | Build a custom peer group and rerun the comparison. |
| Escalate the review | CRE thresholds, fintech deposit controls, enforcement history, allowance trends, or past due loans point to a risk that the peer chart does not explain. | Pull the relevant Call Report schedules and regulator records before citing the result. |
The practical test is whether another analyst could rebuild the peer set tomorrow from the same public sources and reach the same starting point. If not, the UBPR result is a lead for more work, not support for a decision.
FAQ
What is a UBPR report? The UBPR is an FFIEC analytical report for bank supervisory, examination, and management use. It summarizes performance, balance-sheet composition, earnings, liquidity, capital, asset quality, and growth in a format that can be compared against peer data.
Is the default UBPR peer group enough? Sometimes. It is a good first view when asset size and business model are close. It is not enough when a bank has a distinct CRE concentration, agricultural loan book, fintech deposit program, unusual branch model, recent merger activity, or fast balance-sheet growth.
Which Call Report schedules matter most for peer analysis? Start with RC for the balance sheet, RI for income, RC-R for capital, RC-C for loan categories, RC-N for past due and nonaccrual loans, RC-E and RC-O for deposits, RI-B for charge-offs and recoveries, RI-C for allowances, and RC-K for average balances. The right schedule depends on the ratio being challenged.
How should a fintech founder use UBPR when choosing a sponsor bank? Use UBPR to spot questions about capital, liquidity, earnings, credit quality, and deposit mix. Then check FDIC BankFind, NIC, regulator enforcement databases, third-party risk guidance, and any public order that relates to the activity you need the bank to perform.
Is a high UBPR percentile good or bad? Not by itself. A high percentile is a rank inside a peer group. It can be favorable, unfavorable, or neutral depending on the ratio. A high capital ratio is not interpreted the same way as a high past-due loan ratio.
Sources
- FFIEC Uniform Bank Performance Report: https://www.ffiec.gov/data/ubpr
- FDIC current Call Report forms, instructions, and related materials: https://www.fdic.gov/bank-financial-reports/current-quarter-call-report-forms-instructions-and-related-materials
- FFIEC Central Data Repository download help: https://cdr.ffiec.gov/public/HelpFiles/DownloadHelp.htm
- FFIEC February 13, 2026 UBPR peer group memorandum: https://www.ffiec.gov/sites/default/files/media/ubpr/FFIEC-Changes-to-UBPR-Peer_Group-Memorandum.pdf
- FFIEC Custom Peer Group Bank Report: https://www.ffiec.gov/data/ubpr/custom-peer-group-bank-report
- Interagency CRE Concentration Guidance: https://www.federalreserve.gov/frrs/guidance/interagency-guidance-on-concentrations-in-commercial-real-estate-lending-sound-risk-management-practices.htm
- FDIC FIL-29-2023 on interagency guidance for third-party relationships: https://www.fdic.gov/news/financial-institution-letters/2023/fil23029.html
- FDIC FIL-64-2024 on proposed custodial deposit account recordkeeping: https://www.fdic.gov/news/financial-institution-letters/2024/requirements-custodial-deposit-accounts-transactional
- FDIC BankFind: https://banks.data.fdic.gov/bankfind-suite/bankfind
- FFIEC National Information Center: https://www.ffiec.gov/NPW
- FDIC Orders: https://orders.fdic.gov/s/
- 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
- CFPB Synapse Financial Technologies, Inc. action page: https://www.consumerfinance.gov/enforcement/actions/synapse-financial-technologies-inc/
- FDIC FIL-42-2024 on AML/CFT program NPR: https://www.fdic.gov/news/financial-institution-letters/2024/issuance-anti-money-launderingcountering-financing