Schedule RC-C, Part I is the Call Report schedule where FDIC-insured banks and savings associations report loans and lease financing receivables by category. It tells a credit analyst what the bank lends against: real estate, commercial and industrial borrowers, agriculture, consumers, leases, and other loans. Read it before judging growth, earnings, allowance coverage, or peer risk.
This guide is written primarily for credit analysts reviewing bank credit risk. Fintech founders, journalists, and board members can use the same checks as secondary readers, but the focus here is category mix and public Call Report evidence.
Methodology: the workflow below starts with public FFIEC and FDIC Call Report forms and instructions[1][2], compares current data with the same quarter one year earlier, and cross-checks loan mix against credit-quality, allowance, income, and capital schedules before drawing a credit conclusion.
Key Takeaways
- RC-C turns total loans into a category map, which is the starting point for any credit review.
- Category growth matters more than headline loan growth when one portfolio is changing the risk profile.
- Real estate, C&I, consumer, agricultural, lease, and other loans should not be benchmarked as if they carry the same cycle risk.
- The next schedules to read are RC-N, RI-B, RI-C, RI, RC-K, and RC-R because they connect exposure to performance, reserves, earnings, and capital.
- Use peer comparison after the category mix is clear, not before.
Start With Loan Categories
Start with the category map, not the growth rate. RC-C separates loans secured by real estate from commercial and industrial loans, agricultural loans, consumer loans, loans to depository institutions, loans to nondepository financial institutions, lease financing receivables, and other loan types. For banks that file FFIEC 041 or FFIEC 031, the FDIC’s instructions also say column A is completed by banks with $300 million or more in total assets, giving analysts more detailed category data for larger filers.[2]
The first cut should answer one question: what credit cycle is this bank tied to? Heavy construction and land development exposure points to local real estate supply, developer liquidity, and project completion risk. Heavy C&I exposure points to borrower cash flow, industry mix, collateral monitoring, and line usage. Heavy consumer exposure points to unemployment, charge-off seasoning, and pricing discipline.
That category check also protects the denominator. Nonperforming assets divided by total loans is less useful if one peer is mostly one-to-four family residential mortgages and another is mostly nonfarm nonresidential commercial real estate. The same reported delinquency rate can point to different underwriting questions depending on the portfolio that carries the exposure.
For institution lookup, confirm the legal bank first in FDIC BankFind Suite[3] or the National Information Center[4]. Then use the bank’s Call Report, not a holding-company presentation, for the category mix.
Watch Growth By Category
Total loan growth can hide the real credit decision. A bank can show modest total growth while a single portfolio grows quickly enough to change the risk profile. The analyst’s job is to find that portfolio, size it against the balance sheet and capital, and then ask whether credit performance is moving in the same direction.
The main workflow is simple and repeatable:
- Pull RC-C, Part I for the current quarter and the same quarter one year earlier from the FFIEC Central Data Repository Public Data Distribution.[5]
- Group loans by major category: real estate, commercial and industrial, agricultural, consumer, leases, and other loans.
- For real estate, split construction and land development, farmland, one-to-four family residential, multifamily, and nonfarm nonresidential when the reporting form provides that detail.
- Calculate category share of total loans for each period.
- Calculate year-over-year category growth, then compare that growth with total loan growth.
- Use the peer comparison view to check whether the bank is an outlier against banks with a similar size, geography, or business model.
A useful decision table is below. It does not decide whether the bank is safe. It tells you which question to ask next.
| RC-C signal | Source to pair with it | Question to ask |
|---|---|---|
| Construction and land development loans are a large share of loans | Schedule RC-R capital and the 2006 interagency CRE guidance | Is the exposure near the supervisory CRE concentration screens? |
| C&I loans are growing faster than total loans | Schedule RI interest income and Schedule RI-B charge-offs and recoveries | Is pricing and loss experience moving with the faster growth? |
| Consumer loans are growing quickly | Schedule RC-N past due loans and Schedule RI-B net charge-offs | Is seasoning showing up in delinquency or charge-off trends? |
| Real estate loans dominate the book | Schedule RC-C real estate detail and Schedule RC-R capital | Is capital concentration risk increasing faster than earnings? |
The most cited numeric screen for commercial real estate comes from the Interagency Guidance on Concentrations in Commercial Real Estate Lending issued in December 2006.[6] The guidance identifies banks that may warrant higher supervisory attention when construction, land development, and other land loans are 100 percent or more of total capital, or when total commercial real estate loans are 300 percent or more of total capital and the CRE portfolio has increased by 50 percent or more during the prior 36 months. Those are not automatic failure lines. They are supervisory screens that tell the analyst to read concentration management, stress testing, capital planning, and board reporting more closely.
Connect RC-C To Credit Quality
RC-C tells you where the exposure sits. The credit schedules tell you whether stress is appearing. Read it with Schedule RC-N for past due and nonaccrual loans, Schedule RI-B for charge-offs and recoveries, Schedule RI-C for allowance data, Schedule RI for interest income, Schedule RC-K for average balances, and Schedule RC-R for regulatory capital. The point is to connect the loan category to the credit outcome, not to quote one ratio in isolation.
For example, assume a $2 billion community bank reports total loan growth of 6 percent year over year, but construction and land development loans rise from $160 million to $221 million. That is roughly 38 percent growth in one category. If total capital is $200 million, the construction and land development exposure is now about 110 percent of capital, which brings the CRE concentration screen into the memo.
The next checks are specific. Look at RC-N to see whether past dues or nonaccruals are appearing in the same portfolio. Look at RI-B for charge-offs and recoveries. Look at RI-C for allowance support and RC-R for capital. If losses have not appeared yet but capital support is tightening, the conclusion should say that the current issue is concentration and seasoning risk, not proven credit deterioration.
Allowance analysis also changed after CECL. FASB’s Accounting Standards Update 2016-13, Topic 326 introduced the current expected credit loss model, so an allowance comparison should be tied to portfolio mix, expected life, historical loss data, reasonable and supportable forecasts, and qualitative factors.[7] RC-C does not show all of that. It tells you which portfolio assumptions should be challenged first.
A small problem in a large category can matter more than a high percentage problem in a tiny category. If a bank’s largest exposure is nonfarm nonresidential real estate, a modest rise in nonaccruals there can deserve more attention than a sharper percentage increase in a small consumer portfolio. Scale comes first; percentage change comes second.
Use The Schedule For Better Questions
RC-C does not prove underwriting quality. It shows where to ask about borrower type, collateral, geography, maturity, rate structure, renewals, policy exceptions, sponsor strength, and concentration limits. A good review turns the public category total into a sharper follow-up question for management or for a credit memo.
The practical rule is this: if a category is large, growing faster than total loans, or close to a named supervisory concentration screen, do not stop at the total-loans number. Pull the related Call Report schedules, compare peers, and write the question in category terms: which portfolio is growing, what loss signal has appeared, what capital supports it, and what public source confirms the answer?
FAQ
Is Schedule RC-C the same as a loan tape?
No. RC-C is a regulatory schedule in the Call Report. It gives public category totals and selected detail, but it does not show borrower-level balances, collateral values, FICO scores, debt-service coverage, renewal dates, or internal risk ratings.
Which Call Report schedules should I read with it?
Use RC-N for past due and nonaccrual status, RI-B for charge-offs and recoveries, RI-C for allowance data, RI for income, RC-K for average balances, and RC-R for capital. RC-C shows exposure; the other schedules show performance, earnings, reserves, and capital support.
Do the 100 percent and 300 percent CRE screens mean a bank is unsafe?
No. The December 2006 interagency CRE guidance describes supervisory screens, not automatic violation lines. Crossing a screen means the analyst should look harder at concentration management, stress testing, risk limits, and capital planning.
Where can I get the data?
Use the FFIEC Central Data Repository for Call Report downloads.[5] Confirm the legal bank first with FDIC BankFind Suite or the National Information Center, then use a peer tool such as the DDV bank comparison view to benchmark the category mix.
Sources
- FFIEC 041 reporting forms: current Call Report forms and related reporting materials, https://www.ffiec.gov/resources/reporting-forms/ffiec041.
- FDIC Schedule RC-C instructions: FFIEC 031 and FFIEC 041 loans and lease financing receivables instructions, https://www.fdic.gov/bank-financial-reports/ffiec-031-and-041-schedule-rc-c-loans-and-lease-financing-receivables.
- FDIC BankFind Suite: institution lookup and bank identity confirmation, https://banks.data.fdic.gov/bankfind-suite/bankfind.
- National Information Center: bank and holding-company identity lookup, https://www.ffiec.gov/npw.
- FFIEC Central Data Repository Public Data Distribution: Call Report data downloads, https://cdr.ffiec.gov/public/.
- OCC Bulletin 2006-46: interagency guidance on concentrations in commercial real estate lending, https://www.occ.gov/news-issuances/bulletins/2006/bulletin-2006-46.html.
- FASB ASU 2016-13, Topic 326: current expected credit loss accounting standard reference, https://fasb.org/page/PageContent?pageId=/standards/accounting-standards-updates-issued.html&bcpath=tff.