Introduction

Insured domestic financial institutions operating in the United States with total consolidated assets between $10 billion and $100 billion face a complex and multi-layered regulatory reporting landscape. These mid-sized banking organizations occupy a critical position in the financial system—large enough to pose potential systemic risks yet distinct from the very largest global systemically important banks. As a result, federal regulators have established a comprehensive framework of periodic reporting requirements designed to monitor capital adequacy, liquidity positions, credit concentrations, operational risks, and overall financial condition.

This article provides an in-depth examination of the major federal regulatory reports that banks in this asset category must file with the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC). Understanding these reporting obligations is essential for Chief Compliance Officers, Chief Financial Officers, and regulatory reporting teams responsible for producing timely and accurate submissions to federal banking agencies.

The Regulatory Framework

Banks with assets exceeding $10 billion but remaining below $100 billion are subject to enhanced prudential standards under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Section 165 of the Act requires the Federal Reserve Board to establish risk-based capital requirements, leverage limits, liquidity requirements, and stress testing protocols for bank holding companies and savings and loan holding companies with total consolidated assets of $10 billion or more. These enhanced standards are implemented through a series of regular reporting requirements that provide regulators with detailed, timely information about each institution’s financial condition, risk exposures, and capital planning processes.

The regulatory reporting regime serves multiple supervisory purposes. First, it enables regulators to monitor individual institutions’ safety and soundness on an ongoing basis, identifying emerging risks before they threaten financial stability. Second, aggregate data from these reports inform broader systemic risk assessments and macroeconomic policy decisions. Third, the information collected supports the Federal Reserve’s supervisory stress testing framework, including the Dodd-Frank Act Stress Test (DFAST) and Comprehensive Capital Analysis and Review (CCAR) processes. Finally, certain reporting data are used to calculate regulatory capital ratios, liquidity coverage ratios, and other key prudential metrics that determine whether institutions meet minimum regulatory standards. Providing regulators each of those measures are the following reports:

Major Reporting Requirements

1. Consolidated Reports of Condition and Income (Call Report)

The cornerstone of bank regulatory reporting is the quarterly Call Report, formally known as the Consolidated Reports of Condition and Income. Every national bank, state member bank, insured state nonmember bank, and savings association must file a consolidated Call Report as of the close of business on the last calendar day of each calendar quarter.

Purpose and Scope

The Call Report collects comprehensive financial data in the form of a balance sheet, income statement, and supporting schedules that detail a bank’s condition and performance. The information is used by the FDIC, OCC, and Federal Reserve for bank supervision and examination, deposit insurance assessment, monetary policy analysis, and public disclosure. Supervisory agencies use Call Report data to monitor individual bank risk profiles, identify troubled institutions, assess the impact of economic and policy changes on the banking system, and prepare reports to Congress and the public.

Banks between $10 and $100 billion in total consolidated assets file one of two primary Call Report forms depending on their office structure. Banks with any foreign offices—including International Banking Facilities (“IBFs”), foreign branches or subsidiaries, or majority-owned Edge or Agreement subsidiaries—must file the FFIEC 031 form quarterly. Bank’s with only domestic offices file the FFIEC 041 form.

Reporting Frequency and Timing

The Call Report is due quarterly as of March 31, June 30, September 30, and December 31. While the core report is required quarterly, specific schedules have varying frequencies. Schedule RC-T (Fiduciary and Related Services) is filed quarterly only by banks with more than $250 million in fiduciary assets or with fiduciary income exceeding 10% of total revenue; otherwise it is filed annually on December 31. Several memorandum items are reported semiannually on June 30 and December 31, including data on held-to-maturity securities transfers and purchased credit-impaired loans. Other items such as preferred deposits, reverse mortgage data, internet transaction capability, and captive insurance/reinsurance assets are reported only annually on December 31.

2. Complex Institution Liquidity Monitoring Report (FR 2052a)

The FR 2052a is one of the newer but also one of the most detailed and data-intensive regulatory reports in the banking system. It collects granular, transaction-level information on assets, liabilities, funding activities, and contingent liabilities to enable the Federal Reserve to monitor liquidity risks at large, complex banking organizations. Perficient has previously offered a free guide to the 2052a report available here – Breaking Down the FR 2052a Complex Institution Liquidity Monitoring Report, a Guide / Perficient

Purpose and Scope

The Federal Reserve uses the FR 2052a to monitor the overall liquidity profile of supervised institutions, including detailed information on liquidity risks within different business lines such as securities financing, prime brokerage activities, and derivative exposures. These data points as part of the Board’s supervisory surveillance program in liquidity risk management and provide timely information on firm-specific liquidity risks during periods of stress. Analyses of systemic and idiosyncratic liquidity risk issues inform supervisory processes and the preparation of analytical reports detailing funding vulnerabilities.

The report is used to monitor compliance with the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR) requirements established under Basel III and implemented by U.S. banking agencies. The FR 2052a collects data across ten distinct tables covering 115 product types, 14 counterparty types, 72 asset classes, and 75 maturity buckets extending out to five-plus years.

Reporting Frequency and Timing

U.S. banking organizations that are subject to Category III standards with average weighted short-term wholesale funding of $75 billion or more must submit the FR 2052a on each business day. Daily filers must submit reports by 3:00 p.m. ET each business day. U.S. banking organizations subject to Category III standards with average weighted short-term wholesale funding of less than $75 billion, or subject to Category IV standards, must submit the report monthly.

When a banking organization’s required reporting frequency increases from monthly to daily, it may continue to report monthly until the first day of the second calendar quarter after the change in category becomes effective. Conversely, when frequency decreases from daily to monthly, the reduction takes effect immediately on the first day of the first quarter in which the change is effective.

3. Country Exposure Report (FFIEC 009)

The FFIEC 009 Country Exposure Report provides regulators with detailed information on the geographic distribution of U.S. banks’ claims on foreign residents, enabling assessment of country-specific and transfer risks in bank portfolios.

Purpose and Scope

The report is used to monitor country exposures of banks to determine the degree of country risk and transfer risk in their portfolios and assess the potential impact on U.S. banks of adverse developments in particular countries. The International Lending Supervision Act mandates quarterly reporting to obtain more frequent and timely data on changes in the composition and maturity of banks’ loan portfolios subject to transfer risk.

Data collected includes detailed information on claims by country, sector, and maturity, as well as risk transfers through guarantees and other credit enhancements. The Interagency Country Exposure Review Committee (ICERC) uses this information to conduct periodic reviews of country exposures and assign transfer risk ratings to specific countries.

Reporting Frequency and Timing

The FFIEC 009 must be filed quarterly as of the last business day of March, June, September, and December, with submissions due within 45 calendar days after the reporting date (50 calendar days after the December 31 reporting date).

The report is required of every U.S.-chartered commercial bank that holds aggregate foreign claims of $30 million or more and maintains a foreign branch, international banking facility, majority-owned foreign subsidiary, or similar foreign office. Bank holding companies must also file under certain conditions, and Edge and agreement corporations with foreign claims exceeding $30 million must file unless consolidated under a reporting bank.

4. Weekly Report of Selected Assets and Liabilities (FR 2644)

The FR 2644 provides the Federal Reserve with high-frequency data on selected balance sheet items from a sample of commercial banks, serving as the primary source for weekly banking statistics.

Purpose and Scope

The FR 2644 collects sample data that are used to estimate universe levels for the entire commercial banking sector when combined with quarterly Call Report data. Data from the FR 2644, together with other sources, are used to construct weekly estimates of bank credit, balance sheet data for the U.S. banking industry, sources and uses of banks’ funds, and current banking developments.

These weekly statistics are published in the Federal Reserve’s H.8 statistical release “Assets and Liabilities of Commercial Banks in the United States” and are routinely monitored by Federal Reserve staff, included in materials prepared for the Board of Governors and the Federal Open Market Committee, and incorporated into the semiannual Monetary Policy Report to Congress.

Reporting Frequency and Timing

The FR 2644 is submitted weekly as of the close of business each Wednesday by an authorized stratified sample of approximately 850-875 domestically chartered commercial banks and U.S. branches and agencies of foreign banks. This sample accounts for approximately 88% of domestic assets of commercial banks and U.S. branches and agencies of foreign banks. Small banks (those with assets less than $5 billion) have an option to report monthly rather than weekly, helping to reduce burden for community banks while maintaining adequate sample coverage.

5. Single-Counterparty Credit Limits (FR 2590)

The FR 2590 report enables the Federal Reserve to monitor compliance with the Single-Counterparty Credit Limits (SCCL) rule, which prohibits covered companies from having aggregate net credit exposure to any unaffiliated counterparty exceeding 25% of Tier 1 Capital.

Purpose and Scope

The SCCL rule, adopted pursuant to Section 165(e) of the Dodd-Frank Act, is designed to limit the exposure of large banking organizations to single counterparties, thereby reducing the risk that the failure of a counterparty could cause significant losses to a covered bank and threaten financial stability. The FR 2590 reporting form collects comprehensive information on a respondent organization’s credit exposures to its counterparties, including detailed data on gross exposures, securities financing transactions, derivative exposures, risk-shifting arrangements, eligible collateral and mitigants, and the presence of relationships requiring aggregation under economic interdependence or control tests.

Reporting Frequency and Timing

Respondents must file the FR 2590 quarterly as of the close of business on March 31, June 30, September 30, and December 31. Submissions are due 40 calendar days after the first three quarters and 45 calendar days after the December 31 reporting date.

All U.S. bank holding companies, savings and loan holding companies, and foreign banking organizations that are subject to Category I, II, or III standards must file the report. For foreign banking organizations, the requirement applies to those subject to Category II or III standards or those with total global consolidated assets of $250 billion or more. The estimated average hours per response for the FR 2590 is approximately 254 hours per quarterly submission, reflecting the detailed counterparty-level information and complex risk calculations required. The report requires respondents to identify and report data for their top 50 counterparties. Respondents must retain one exact copy of each completed FR 2590 in electronic form for at least three years.

6. Capital Assessments and Stress Testing Report – Annual (FR Y-14A)

The FR Y-14A is the annual component of the Capital Assessments and Stress Testing information collection that supports the Federal Reserve’s supervisory stress testing and capital planning framework.

Purpose and Scope

The FR Y-14A collects detailed quantitative projections of balance sheet assets and liabilities, income, losses, and capital across a range of macroeconomic scenarios, as well as qualitative information on methodologies used to develop internal projections of capital across scenarios. The report comprises Summary, Scenario, Regulatory Capital Instruments, Operational Risk, and Business Plan Changes schedules.

Respondents report projections across supervisory scenarios provided by the Federal Reserve as well as firm-defined scenarios where applicable. The data are used to assess capital adequacy of large firms using forward-looking projections of revenue and losses, to support supervisory stress test models, for continuous monitoring efforts, and to inform the Federal Reserve’s operational decision-making under the Dodd-Frank Act.

Reporting Frequency and Timing

The FR Y-14A is filed annually with an as-of date of December 31. Submissions are due 52 calendar days after the calendar quarter-end (typically early February). The annual submission must be accompanied by an attestation signed by the CFO or equivalent senior officer.

Bank Holding Companies, Intermediate Holding Companies, and Savings and Loan Holding Companies with $100 billion or more in total consolidated assets are required to file. The specific schedules required depend on whether the institution is subject to Category I-III standards or Category IV standards.

The FR Y-14A reporting burden is substantial, reflecting the comprehensive forward-looking projections and detailed scenario analysis required. The current estimated average burden is approximately 1,330 hours per annual response. This includes both the preparation of quantitative projections across multiple scenarios and the development of supporting qualitative documentation describing methodologies and assumptions.

7. Capital Assessments and Stress Testing Report – Quarterly (FR Y-14Q)

The FR Y-14Q collects detailed quarterly data on Bank Holding Companies’, Intermediate Holding Companies’, and Savings and Loan Holding Companies’ various asset classes, capital components, and categories of pre-provision net revenue.

Purpose and Scope

The FR Y-14Q schedules collect firm-specific granular data on positions and exposures used as inputs to supervisory stress test models, to monitor actual versus forecast information on a quarterly basis, and for ongoing supervision. The report comprises Retail, Securities, Regulatory Capital Instruments, Regulatory Capital, Operational Risk, Trading, PPNR, Wholesale, Retail Fair Value Option/Held for Sale, Counterparty, Balances, and Supplemental schedules.

All schedules must be submitted for each reporting period unless materiality thresholds apply. For example, only firms subject to Category I, II, or III standards with aggregate trading assets and liabilities of $50 billion or more, or trading assets and liabilities equal to 10% or more of total consolidated assets, must submit the Trading and Counterparty schedules.

Reporting Frequency and Timing

The FR Y-14Q is filed quarterly as of March 31, June 30, September 30, and December 31. Submissions are due 45 calendar days after the end of the first three quarters and 52 calendar days after the December 31 quarter-end. For the fourth quarter Trading and Counterparty schedules, submissions may be due as early as March 15 if the Board selects an earlier as-of date for the global market shock component.

New reporters receive implementation relief, with the filing deadline extended to 90 days after quarter-end for the first two quarterly submissions. This allows institutions crossing the significant $100 billion asset threshold extra time to build necessary reporting infrastructure and processes.

Table: Federal Reporting Requirements Summary

Additional Considerations

Data Governance and Quality Control

The volume, granularity, and frequency of these reporting requirements demand robust data governance frameworks and quality control processes. Financial institutions must establish clear data lineage documentation, implement automated validation checks, maintain comprehensive data dictionaries, and conduct regular reconciliation across reports.

Many of these reports require data at transaction or contract levels (FR 2052a, FR-2590, FR Y-14Q), necessitating direct integration with core banking systems, loan origination platforms, treasury management systems, and risk management applications. Manual data gathering and spreadsheet-based processes for Inured Depository Institutions with greater than $10 billion of assets are insufficient for sustained compliance with these requirements, particularly for daily or weekly filings. At Perficient, we have seen and helped clients implement AI-enhanced reporting capabilities.

Systems and Technology Infrastructure

Implementing and maintaining compliance with these reporting requirements typically requires significant technology investments. Institutions may need to deploy specialized regulatory reporting platforms, develop custom data extraction and transformation tools, implement automated validation and reconciliation systems, and establish secure data transmission capabilities.

The FR 2052a, in particular, has driven substantial technology modernization at many institutions due to its granular cash flow reporting requirements and daily submission frequency for the largest banks. Similarly, the FR Y-14A and Q reports require sophisticated data aggregation capabilities to assemble loan-level detail from disparate systems across the enterprise.

Staffing and Expertise Requirements

Compliance with these reporting requirements necessitates dedicated teams with specialized expertise spanning regulatory reporting, financial accounting, risk management, data management, and systems analysis. Larger institutions typically maintain separate teams for different reporting families, with subject matter experts for capital, liquidity, credit risk, market risk, and operational risk reporting.

The attestation requirements for several reports—including the FR Y-14Q and FR 14A—place direct accountability on senior financial officers, underscoring the importance of robust internal controls, documentation, and review processes.

Coordination with Business Lines

Successful regulatory reporting requires close coordination between centralized reporting functions and business lines across the organization. Trading desks must provide transaction-level derivatives data, retail lending units must supply detailed loan-level information, treasury teams must furnish liquidity and funding details, and international operations must contribute country exposure data.

Establishing clear roles, responsibilities, and service level agreements between reporting teams and data providers is essential to ensure timely, accurate submissions.

Conclusion

Banks with total consolidated assets between $10 billion and $100 billion face a demanding federal regulatory reporting regime that reflects their significance to the financial system and the potential risks they pose. The seven major reporting requirements discussed in this article—Call Reports, FR 2052a, FFIEC 009, FR 2644, FR 2590, FR Y-14A, and FR Y-14Q—collectively require thousands of hours of effort annually and generate vast amounts of detailed financial, risk, and operational data.

Effective management of these reporting obligations requires substantial investments in data infrastructure, technology systems, specialized expertise, and governance processes. Institutions must balance the compliance imperative with considerations of cost, efficiency, and the need to leverage reporting data for internal management purposes. Those institutions that view regulatory reporting not merely as a compliance burden but as an opportunity to enhance data quality, strengthen risk management, and improve decision-making are best positioned to meet these obligations efficiently while deriving maximum value from their reporting investments.

As the regulatory landscape continues to evolve in response to emerging risks and changing market conditions, banking organizations in this asset range must maintain flexibility, invest in scalable reporting infrastructure, and cultivate deep regulatory expertise to navigate future reporting requirements successfully. The complexity and significance of federal bank reporting requirements underscore the critical role of compliance and regulatory reporting functions in maintaining the safety, soundness, and stability of individual institutions and the broader financial system.

Our financial services experts continuously monitor the regulatory landscape and deliver pragmatic, scalable solutions that meet the mandate and more. Reach out to Perficient’s BFSI team here – Contact Us / Perficient – and discover why we’ve been trusted by 18 of the top 20 banks, 16 of the 20 largest wealth and asset management firms, and are regularly recognized by leading analyst firms.

As we progress through 2025, the banking industry is set for substantial transformation driven by several key trends. Digital transformation will remain a powerful force, with advancements in AI and machine learning enabling unparalleled operational efficiencies and hyper-personalized customer experiences. Banks will look to transform the way they do business by moving beyond their walls with the maturing of open banking and embedded finance.

To stay competitive, banks must adapt and embrace emerging industry trends. This will require being more inquisitive and innovative compared to previous years, as the adoption of AI and cloud technologies continues to expand.

Banking Trend #1: Hyper-Personalization for Customer Satisfaction

Customers increasingly demand personalized banking experiences tailored to their unique needs and preferences. Hyper-personalization transforms the traditional banking model into a customer-centric approach, significantly boosting satisfaction and retention rates. Banks can use advanced data analytics and AI to deliver highly personalized financial services, such as customized savings plans and tailored investment advice. By leveraging data, banks can anticipate customer needs and proactively offer solutions, like recommending mortgage products or providing financial wellness tools based on individual spending patterns. Delivering these tailored experiences will be a crucial differentiator for banks aiming to attract and retain customers.

Recommended Approach: Banks should leverage advanced data analytics, artificial intelligence (AI), and machine learning (ML) to create highly individualized experiences. By understanding customer preferences, behaviors, and financial needs in real-time, banks can offer tailored products, services, and communication, leading to a more seamless and intuitive customer experience. This approach improves engagement and loyalty, increases revenue opportunities, and provides competitive differentiation.

See Also: Transforming Industries, Powering Innovation

Banking Trend #2: Adapting to Regulatory Shifts

As the banking landscape evolves, staying compliant with regulatory requirements becomes increasingly challenging, especially with the rise of open banking, AI, and data privacy concerns. In 2025, banks will face a more complex regulatory environment, with new rules focused on data privacy, cybersecurity, and sustainability. The rise of digital banking, cryptocurrency, blockchain, and AI adoption across banking operations will prompt regulatory bodies to implement clearer frameworks and guidelines to ensure stability and consumer protection.

Recommended Approach: Navigating constant changes in risk and regulatory environments is crucial for banks in 2025. By ensuring compliance with regulations, banks mitigate risks and maintain trust with customers and regulatory authorities. To stay ahead, banks should adopt compliance technologies that automate regulatory reporting and help them stay agile in a rapidly changing landscape. Investing in advanced technologies like AI and machine learning can help identify potential risks and streamline compliance efforts. By adopting these strategies, banks can better manage the dynamic risk and regulatory environment, ensuring compliance while maintaining competitiveness and customer trust.

Related: Strategies + Solutions to Ensure Regulatory and Compliance Excellence

Banking Trend #3: Embedded Finance Enables Industry Crossover

Embedded finance integrates financial services into non-financial platforms, allowing users to access banking services within applications they already use. By embedding payment, lending, and insurance services into apps and websites, non-financial companies are able to offer financial products directly to their customers. For example, ride-sharing apps like Uber and Lyft offer in-app payment options, and e-commerce platforms provide financing options at checkout. By integrating financial services into non-financial platforms, banks can tap into new markets and customer bases, generating additional revenue.

Recommended Approach: Banks looking to start or deepen their embedded finance solutions should take several key steps. These steps include identifying strategic partnerships and collaborating with fintech companies and non-financial platforms that align with their goals. These partnerships provide the necessary technology and customer reach to implement embedded finance solutions effectively. Next, invest in technology by upgrading IT infrastructure to support embedded finance, including adopting cloud-based solutions and modern technologies that offer the agility and scalability needed for seamless integration. Create robust APIs that allow third-party platforms to integrate your financial services. Ensure these APIs are secure, reliable, and easy to use. Leverage advanced data analytics to understand customer behavior and preferences, helping you offer personalized financial services that meet the specific needs of your customers.

You May Enjoy: 6 Digital Payment Trends Set to Transform 2025

Banking Trend #4: Leveraging AI for Insights and Automation

AI and automation have evolved from buzzwords to essential components of banking operations. In 2025, AI will play a pivotal role in customer service, fraud detection, risk management, and personalized financial advice. AI-powered chatbots will handle routine customer inquiries, freeing human agents to tackle more complex issues. Additionally, AI-driven algorithms will enhance banks’ ability to detect emerging fraud patterns and mitigate risks more effectively. Automation will streamline internal processes, leading to cost reductions and improved operational efficiency.

Recommended Approach: To fully utilize AI, banks need to prioritize improving their data strategy, recognizing that high-quality, reliable, and trustworthy data is essential for AI to deliver significant outcomes. They need to align AI initiatives with the bank’s overall business goals. Then identify areas where AI can add the most value, such as customer service, fraud detection, and risk management and focus on value-driven AI use cases. They also need to invest in modern technology and infrastructure for agility and scalability.

Read More: Transform Your Business With Cutting-Edge AI and Automation Solutions

Banking Trend #5: Responsive Resilience

Responsive Resilience continues to be a key banking trend in 2025, emphasizing the ability of financial institutions to adapt swiftly and effectively to changing conditions. Banks must be prepared to respond to economic fluctuations, market changes, and unexpected events. This requires robust risk management frameworks and the ability to pivot strategies quickly. A compounding factor, the shift to digital has caused increased exposure to financial fraud and cyber threats.

Recommended Approach: Invest in advanced technologies such as AI, machine learning, and cloud computing to enhance operational efficiency and adaptability. These technologies can automate processes, improve decision-making, and provide real-time insights. Utilize data analytics to gain deeper insights into customer behavior, market trends, and potential risks. This data-driven approach allows banks to make informed decisions and respond swiftly to changes in the banking landscape.

Explore More: Reimagine Business for the Digital Age

Banking Trend #6: Embracing Open Banking and Connected Ecosystems

Although many institutions have deprioritized open banking in recent years, establishing an open banking strategy now offers significant benefits. Open banking continues to revolutionize the financial industry by enabling secure data sharing between banks and third-party providers through APIs. It unlocks a wealth of third-party financial data, enabling banks to better-tailor products and services, enhance customer loyalty, improve operational efficiencies, and open new revenue streams. This trend will change how banks engage with third-party financial service providers, fostering the development of innovative financial products and services. Open banking will drive greater competition, promote collaboration, and empower consumers with more choices and personalized banking experiences. Examples include budgeting apps that aggregate data from multiple bank accounts, personalized financial advice based on spending patterns and streamlined loan application processes by accessing a customer’s financial data to provide a more accurate and personalized credit score.

Recommended Approach: Banks must establish a clear vision for open banking that aligns with their overall business goals. They should determine specific objectives, such as driving innovation, improving customer experience, or expanding market reach. Additionally, banks need to update their IT infrastructure to support open banking. This includes developing secure and reliable APIs for data sharing and ensuring systems are resilient and scalable.

See Also: 1033 Open Banking Mandate Blueprint for Success

Unlocking New Opportunities in 2025

Our end-to-end digital solutions drive business outcomes, enhance experiences, and ensure robust risk and compliance management to improve operational efficiency and business resilience.

• Business Transformation: Align the business with an actionable roadmap to optimize operations, improve service, and enhance profitability.
• Modernization: Advance technologies to enhance digital capabilities and customer engagement.
• Data + Analytics: Proactively leverage integrated data and AI to refine banking product portfolios and mitigate risks.
• Risk + Compliance: Strengthen risk management frameworks, ensure adherence to banking regulations, and enhance operational stability.
• Consumer Experience: Improve customer satisfaction with hyper-personalized banking services and intuitive digital experiences.

Discover why we have been trusted by 18 of the 20 largest commercial banks. Explore our financial services expertise and contact us to learn more.

The Consumer Financial Protection Bureau (CFPB) recently issued a final rule § 1033.121(c) supporting open banking and personal financial data rights. Under this ruling, banks, credit unions, credit card issuers, and other financial service providers must enhance consumer access to personal financial data.

The first compliance deadline of April 1, 2026, impacts the largest organizations.

• The ruling demands action from all non-depository firms (e.g., institutions that issue credit cards, hold transaction accounts, issue devices to access an account, or provide other types of payment facilitation products or services). The compliance deadline, however, depends on the firm’s total receipts from calendar years 2023 and 2024.
  • April 1, 2026: $10B+ total receipts in either calendar year
  • April 1, 2027: <$10B total receipts in both calendar years
• The ruling also impacts depository institutions that hold at least $850 million in total assets. Compliance deadlines follow a staggered rollout based on total assets.
  • April 1, 2026: $250B+ total assets
  • April 1, 2027: $10B to <$250B total assets 
  • April 1, 2028: $3B to <$10B total assets
  • April 1, 2029: $1.5B to <$3B total assets
  • April 1, 2030: $850M to <$1.5B total assets

Accelerating the shift to open banking with 1033 

Open banking changes how financial data is shared and accessed, giving customers more control of their information. The 1033 Personal Financial Data Rights rule ensures that:

• Personal financial data is made available to consumers and agents at no charge
• Data is exchanged through a safe, secure, and reliable digital interface
• Consumers aren’t surprised with hidden or unexpected charges when accessing their personal financial data
• Consumers can walk away from bad financial services and products
• Safeguards protect consumers and financial firms from surveillance, data misuse, and risky data practices

Open banking is going to do for the banking industry what the introduction of the Apple smart phone did for cell phones.

CFPB 1033 open banking requires financial firms to ease personal financial data access for consumers 

CFPB first proposed the rule in the Federal Register on October 31, 2023, accepted public comments on the regulation though December 29, 2023, then issued its final rule November 18, 2024. This effort carries out the personal financial data rights established by the Consumer Financial Protection Act of 2010 (CFPA).

The final rule § 1033.121(c) “requires banks, credit unions, and other financial service providers to make consumers’ data available upon request to consumers and authorized third parties in a secure and reliable manner; defines obligations for third parties accessing consumers’ data, including important privacy protections; and promotes fair, open, and inclusive industry standards.”  

The implications of the CFPB’s regulation on open banking will be enormous for consumers, banks, and data providers.

Impact on consumers 

Without open banking, consumers struggle to switch between bank deposit and lending offerings. For example, switching checking accounts to one with a better interest rate involves resetting direct deposits and recurring bill-paying, printing new checks, and obtaining a new ATM card. Mistakes resulting in overdrafts are costly, both financially and to one’s credit score and reputation.   

As a result, larger banks have a much smaller net interest margin, as shown in the chart below:

In addition, the stickiness of deposits causes a considerable lag between when a bank raises deposit rates and when deposit balances increase proportionately. 

As open banking, mandated by Rule 1033, takes effect, consumers will be able to:

• Switch credit cards within seconds while retaining terms and rewards of their current account
• Transfer deposits and multiple years of transaction history into a new checking account  

Impact on data providers 

Data providers, including digital wallet providers, will be able to move on from “screen scraping” and instead provide API-driven real-time balances, transaction history, and reward balances to their retail customers. Of course, providing this “new and improved” service will require re-writing front ends and processing engines to provide the necessary data in a timely manner. 

Impact on banks 

Banks and their affiliates must look toward building an open, larger ecosystem as part of continued digital transformation efforts.

While challenging, this work is necessary for banks that aim to grow revenue through collaboration and cooperation. Ultimately, banks that don’t satisfy their borrowers or lenders will be hard-pressed to compete in the ever-challenging financial landscape.

Navigate 1033 open banking compliance deadlines with confidence 

We encourage leaders to identify mandates’ silver lining opportunities. After all, to remain competitive and compliant, financial services firms must innovate in ways that add business value, meet consumers’ evolving expectations, and build trust. Achieving transformative outcomes and experiences requires a digital strategy that not only satisfies mandates but also aligns the enterprise around a shared vision and actionable KPIs, ultimately keeping customers at the heart of progress.

A holistic approach could include:

• Strategy + Transformation: current-state assessment, future-state roadmap, change management
• Platforms + Technology: pragmatically scalable, composable architecture and automations to accelerate progress
• Data + Intelligence: well-governed “golden source of truth” data and secure integrations/orchestration
• Innovation + Product Development: engineering and design for what’s now, new, and next
• Customer Experience + Digital Marketing: human-centered, journey-based engagement
• Optimized Delivery: Agile methodologies, deep domain expertise, and scalable global teams

Our financial services experts continuously monitor the regulatory landscape and deliver pragmatic, scalable solutions that meet the mandate and more. Discover why we’ve been trusted by 18 of the top 20 banks, 16 of the 20 largest wealth and asset management firms, and are regularly recognized by leading analyst firms.

Ready to explore your firm’s compliance with Rule 1033? Contact us to discuss your specific risk and regulatory challenges.  

Introduction

A quick summary of the new official digital sign requirement of the FDIC is that effective January 1, 2025, this logo:

must be replaced by this logo:

For readers who missed part 1 of this series or want to reread the original blog can find it here.

However, the new lengthy regulation raised many questions by the industry, and Perficient’s Financial Services Risk and Regulatory consultants have been researching answers and questioning regulators to provide in order to provide our current and future clients the answers to the following questions that have been raised.

Detailed Q&A:

#1. Are IDIs’ websites considered deposit taking channels for purposes of the digital signage requirements?

Answer: Under part 328, the FDIC official digital sign must be displayed on “digital deposit taking channels,” which includes IDIs’ “websites and web-based or mobile applications that offer the ability to make deposits electronically and provide access to deposits at insured depository institutions.” 12 CFR § 328.5(a). If an IDI’s website is purely informational, with no ability to make deposits or access deposits, it would not be a digital deposit-taking channel.

#2. Can the official digital sign appear only on the IDI’s “home page” and not on the other web pages that make up the website?

Answer: No. Under part 328, the FDIC official digital sign must be displayed on the (1) initial or homepage of the IDI’s website or application, (2) landing or login pages, and (3) pages where a customer may transact with deposits. For example, the FDIC official digital sign should be displayed where a mobile application allows customers to deposit checks remotely, because this electronic space is in effect a digital teller window. 12 CFR § 328.5(d).

#3. Where are we required to place the official digital sign on a bank webpage or app to ensure compliance with the “clear,” “continuous,” and “conspicuous” placement of the digital sign?

Answer: The final rule requires IDIs to display the official digital sign in a clear, continuous, and conspicuous manner. In general, the FDIC would expect to see official digital signs displayed on the applicable pages in a manner that is clearly legible to all consumers to ensure they can read it easily. The official digital sign could be displayed above the IDI’s name, to the right of the IDI’s name or below the IDI’s name, but under all circumstances, the official digital sign continuously displayed near the top of the relevant page or screen and in close proximity to the IDI’s name would meet the clear and conspicuous standard under the rule.

#4. Can the official digital sign be dismissed once a customer logs in?

Answer: No. The final rule requires that the official digital sign be displayed “in a continuous manner,” which means it must remain visible on the (1) initial page or homepage of the website or application, (2) landing or login pages, and (3) pages where the customer may transact with deposits. 12 CFR § 328.5(d). The final rule, however, does not require the official digital sign to continue to follow the user as they scroll up or down the screen.

#5. How should IDIs display the FDIC official digital sign on mobile devices with screen resolutions that do not support the ability to display the entirety of the digital sign on one line?

Answer: If the image does not fit a particular device or screen, the official digital sign can be scaled, “wrapped,” or “stacked” to fit the relevant screen and may satisfy the “clear and conspicuous” requirement.

#6. If an IDI’s name appears at the top of its website, and it also appears in the website’s footer, does the new FDIC official digital sign need to be displayed at the top of the page and also in the footer?

Answer: Under the final rule, IDIs are required to display the FDIC official digital sign “clearly and conspicuously” in a continuous manner; the official digital sign continuously displayed near the top of the relevant page or screen and in close proximity to the IDI’s name would meet the clear and conspicuous standard under the rule. 12 CFR § 328.5(f). IDIs are not required to display the FDIC official digital sign every time the IDI’s name appears, such as in the footer of the website.

#7. To satisfy the final rule’s official digital sign requirements, can the official digital sign be placed in the footer of the webpage?

Answer: No. For purposes of satisfying the final rule, IDIs are required to display the official digital sign in a clear, continuous, and conspicuous manner. The official digital sign continuously displayed near the top of the relevant page or screen and in close proximity to the IDI’s name would meet the clear and conspicuous standard under the rule. 12 CFR § 328.5(f). Therefore, placing the official digital sign in a footer of an IDI’s webpage would not meet the clear, conspicuous, and continuous display requirement.

#8. If an IDI displays the FDIC official digital sign on its mobile app’s homepage and alongside the IDI’s logo within the app, is it also necessary to include this signage on the transaction portal before a customer completes a transaction?

Answer: It depends in part on what type of transaction is being completed. The FDIC official digital sign must be displayed on the (1) initial or homepage of the bank’s website or application, (2) landing or login pages, and (3) pages where a customer may transact with deposits. 12 CFR § 328.5(d). For example, the FDIC official digital sign should be displayed where an IDI’s mobile application allows customers to deposit checks remotely, because this is an electronic space where a customer is transacting with deposits.

However, if a consumer is completing a transaction by using an embedded third-party payment platform that consumers: (a) access after logging into their IDI’s website; and (b) utilize to initiate payments/move funds out of the IDI, then the official digital sign should not be posted on those pages.

#9. What are examples of “pages where the customer may transact with deposits” that require the display of the FDIC official digital sign?

Answer: Examples of “pages where the customer may transact with deposits” that require the display of the FDIC official digital sign include, but are not limited to: mobile application pages that allow customers to deposit checks remotely; and, pages where customers may transfer deposits between deposit accounts held within the same IDI (e.g., checking to savings or vice versa). On the other hand, the FDIC would not expect an IDI to display the FDIC official digital sign on pages where a customer is transferring money from a deposit account to a non-deposit account.

#10. What is the definition of “landing or login page”?

Answer: For purposes of the final rule, a “landing or login page” generally refers to an insured depository institution’s (IDI’s) webpage or screen from which a customer is able to log into the IDI’s digital deposit taking channel. Specifically, the terms include pages where customers enter their credentials (e.g., username and password) or use other authentication methods (e.g., face identification) to access an IDI’s website or banking application. The terms are intended to cover various types of logins, whether with usernames and passwords, face IDs, thumbprints, etc.

#11. Where should the official digital sign be placed if the IDI’s app or website does not currently display the IDI’s full name; it only displays the IDI’s logo or a partial name?

Answer: The final rule provides that an official digital sign be continuously displayed near the top of the relevant page or screen and in close proximity to the IDI’s name would be considered clear and conspicuous. 12 CFR § 328.5(f)

If an IDI displays its full name, a partial name of the IDI, or the logo of the IDI (or any similar symbol used to identify the IDI) near the top of the page or screen, and continuously displays the official digital sign in close proximity to it, this approach would be considered clear and conspicuous.

#12. Do the FDIC official digital sign requirements apply to downloadable content such as terms and conditions or other digital collateral available via an IDI’s online channels?

Answer: Part 328 requires IDIs to display the official digital sign on their digital deposit-taking channels on the following pages or screens: initial or homepage of the website or application, landing or login pages, and pages where the customer may transact with deposits. Downloadable content that is available from an IDI’s website would not likely be viewed as a page or screen where the official digital sign would be required.

#13. Is an IDI required to display the FDIC official digital sign in the app store where the IDI’s app is available for download?

Answer: No. An IDI is not required to post the official digital sign in the app store where its app is available for download.

Contact us to discuss your specific risk and regulatory challenges. Our financial services expertise, blended with our digital leadership across platforms and business needs, equips the largest organizations to solve complex challenges and compliantly drive growth.

FDIC Digital Sign Requirement

Just before Christmas on December 23, 2023, to be precise, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors gave a Christmas gift that was the equivalent of coal in their stocking. Since the 1930s, when the FDIC was founded as part of the New Deal, the black and gold official sign (shown below) displayed at bank branch teller windows has given bank customers confidence that their deposited funds are safe.

Upon opening their stocking, bankers learned that the FDIC Board had adopted a final rule to amend part 328 of its regulations to modernize the rules governing the use of the official FDIC signs and advertising statements, and to clarify the FDIC’s regulations regarding false advertising, misrepresentations of deposit insurance coverage, and misuse of the FDIC’s name or logo.

Driven by the fact that depositors and consumers today have a variety of options for where they can deposit their money and how they can access banking products and services, the new rule is seeking to extend the certainty and confidence associated with the FDIC official sign to digital channels, such as banking websites and mobile apps, through which depositors are increasingly accessing their deposit funds and banking needs.

New Rule Established

However, rather than the same sign to be put online, the December 2023 rule established a new black and navy blue official digital sign shown below:

Beginning on New Year’s Day 2025, banks will be required to display the FDIC official digital sign near the name of the bank on all bank websites and mobile applications. Banks will also be required to display the FDIC official digital sign on certain automated teller machines.

Under the final rule, Insured Depository Institutions (“IDIs”) are required to display the FDIC official digital sign “clearly and conspicuously” in a continuous manner; the official digital sign continuously displayed at the top of the relevant page or screen and in close proximity to the IDI’s name would meet the clear and conspicuous requirement standard.

What Perficient has been seeing in the industry is that since an IDI’s mobile apps and websites must be altered for the new FDIC signage, bank executives are taking the opportunity to kill two birds with one stone and revamp their website and mobile apps to improve the user experience and enhance security while meeting the new FDIC signage requirements.

Contact us to discuss your specific risk and regulatory challenges. Our financial services expertise, blended with our digital leadership across platforms and business needs, equips the largest organizations to solve complex challenges and compliantly drive growth.

A top-leading bank, grappling with business and regulatory challenges, faced scrutiny after failing the Federal Reserve’s annual stress test. Addressing these deficiencies required a comprehensive approach, leading to the establishment of critical programs like the US Bank Holding Company (BHC) regulatory and comprehensive capital analysis and review (CCAR) program.

To bolster its capabilities and ensure compliance, the bank sought assistance from Perficient in delivering exceptional project and program management services to tackle its significant hurdles.

Perficient’s Project and Program Initiatives

Our involvement encompassed various facets of project and program management, including:

• Establishing foundational capabilities to foster smart, effective, and compliant business practices.
• Supporting the change management team in building a robust governance structure for program PMO activities.
• Partnering with stakeholders across risk, finance, technology, and operations, Perficient ensured seamless execution of capital and risk transformation (CART) PMO governance and oversight.

Another key initiative was implementing the OCC Heightened Standards guidelines, which our team utilized as a means to strengthen the bank’s governance and risk management practices.

Perficient provided invaluable support toward:

• Managing plan development and execution through to completion
• Aligning and prioritizing internal initiatives with OCC guidelines for enhanced governance across the three lines of defense (Management, Risk and Regulatory Compliance, Internal/External Audit)

Perficient was also pivotal in coordinating and supporting oversight of the CCAR process by:

• Conducting review and challenge sessions
• Developing forecasting models
• Facilitating process improvements to enhance execution efficiency

In addition to regulatory compliance efforts, Perficient spearheaded initiatives to address operational risks, enhance fraud risk management, and optimize software development life cycle processes. By conducting gap assessments, prioritizing remediation actions, and implementing comprehensive project plans, Perficient ensured the bank was well-equipped to mitigate risks effectively going forward.

Tangible Outcomes

The success of Perficient’s engagements is evident in the tangible outcomes achieved. Following our work, the bank was able to reap the benefits of:

• Improved risk measurement
• Enhanced capital allocation
• Effective responses to regulatory requirements

Ultimately, our team’s diligent project oversight and subject matter expertise enabled the bank to anticipate, evaluate, and mitigate risks proactively, thereby safeguarding its reputation and ensuring long-term resilience.

Interested in how Perficient can transform your business? 

Contact us today to learn more or visit our Financial Services page to discover other ways we provide our expertise. 

This blog post was co-authored by: Carl Aridas

In a recent blog post, Perficient’s Financial Services Risk and Regulatory Center of Excellence (CoE) highlighted the Federal Deposit Insurance Corporation (FDIC) plan to implement a “Robin Hood-like” deposit insurance premium on the nation’s largest banks to recapitalize the agency’s Deposit Insurance Fund.

Since that blog was published, the FDIC has issued an update on its Restoration Plan for the Deposit Insurance Fund (DIF). The Federal Deposit Insurance Act (FDI Act) requires the FDIC Board to adopt a restoration plan when the DIF’s reserve ratio—the ratio of the fund balance relative to insured deposits—falls below 1.35 percent.

READ MORE: Decoding SVB’s Failure & FDIC’s Special Assessment

In a focused review of the last few years, on September 15, 2020, the FDIC established the Restoration Plan to restore the DIF reserve ratio to at least 1.35 percent by the statutory deadline of September 30, 2028. This action became necessary due to extraordinary deposit growth during the first half of 2020, causing the DIF’s reserve ratio to dip below 1.35 percent. The Plan retained the assessment rate schedules in place at the time.

On June 21, 2022, based on projections indicating that the reserve ratio was at risk of not reaching the required minimum by the statutory deadline, the FDIC Board amended the Restoration Plan. However, a year later, the FDIC projected that the DIF reserve is likely to reach 1.35 percent by September 30, 2028.

In conjunction with the Amended Restoration Plan, the FDIC Board increased deposit insurance assessment rates by 2 basis points for all insured depository institutions, effective in the first quarterly assessment period of 2023.

DIF Balances in 2023

However, despite the increase in insurance premiums, the failures of Silicon Value Bank and other banks led to a decline in the DIF balance. As of June 30, 2023, the DIF balance stood at $117B. Increased loss provisions, including those for the bank failures, combined with robust insured deposit growth, resulted in the reserve ratio from 1.25 percent as of December 31, 2022, to 1.10 percent as of June 30, 2023.

LEARN MORE: Regulatory Risk & Compliance in Financial Services

Despite this decline, the FDIC projects that the reserve ratio is likely to reach the statutory minimum of 1.35 percent by the statutory deadline of September 30, 2028. It’s important to note that these projections don’t assume interest rates will remain as high compared to 2023. This also doesn’t account for the concentration of deposits for some of the largest banks dissipated via restructuring, spin-offs, or competing with smaller banks’ interest rates.

Your Financial Services Partner

For more trusted insight and knowledge expertise, we invite you to view our wide array of Financial Services digital solutions.

Our services expertise, blended with our digital leadership across platforms and business needs, equips the largest organizations to solve complex challenges and compliantly drive growth.

Contact us today!

The Consumer Financial Protection Bureau (CFPB) has narrowed its focus on what it terms “junk fees” targeting financial industry practices.

Understanding the CFPB’s recurrent theme and deciphering its message from the recent press releases provides insights into potential enforcement actions over the next 12-24 months and how banks can reassess their current fee structures.

Failure to understand the prevailing wind risks running counter to the CFPB’s current focus.

The CFPB’s Problem with Junk Fees

Recently, a regional bank headquartered in Richmond, VA faced a hefty $6.2 million fine for alleged illegal overdraft fee harvesting. CFPB Director Rohit Chopra stated, “Americans are fed up with junk fee scams and the CFPB will continue its work to ensure families are treated fairly”.

The term “junk fee” has appeared in no fewer than 10 press releases in 2023 alone, signaling a broader concern for the CFPB.

In January 2022, the CFPB launched a press release soliciting public feedback on four specific concerns:

• Fees for things people believed were covered by the baseline price.
• Unexpected fees for a product or service.
• Fees that seemed too high for the purported service.
• Fees where it was unclear why they were charged.

Starting in June 2023, the CFPB released several other press releases further criticizing practices they deemed inappropriate. These culminated in an advisory opinion paper where the CFPB illuminated the fact that “…many large banks erect obstacle courses and impose junk fees to answer basic questions.”
A cursory reading elicits the obvious question: Is this a genuine attempt to protect consumers, or is it a strategic move to redefine industry norms?

Guidance to Halt Large Banks

The CFPB’s issuance of guidance to curb large banks from charging illegal junk fees for basic customer service points to a regulatory stance that goes beyond isolated incidents. The choice of words implies a proactive measure, suggesting that the CFPB is steering the industry away from what it considers questionable practices.

Examining Illegal Junk Fees Across Industries

In their October 11th press release, the CFPB shared that examinations have resulted in the return of $140 million to consumers affected by illegal junk fees in banking, auto loans, and remittances. This significant sum underscores that junk fees are not isolated incidents but a systemic concern that requires industry-wide attention.

Questionable Practices – Looking Ahead

The regulatory spotlight has uncovered potentially illegal junk fees in various financial products. While the CFPB positions itself as a consumer protector, the exposed practices raise questions about whether the financial industry is genuinely plagued by issues or if it’s becoming a target for regulatory reform from a partisan agency, not under congressional oversight.

Regardless of the motivation, the CFPB’s recent actions serve as a warning to banks to proactively scrutinize their fee structures.

Junk fees are a central theme, and financial institutions should note it as a leading indicator of regulatory scrutiny. Now is the time for banks to evaluate and eliminate fees that may attract the CFPB’s attention in the evolving financial landscape.

Perficient’s Deep Expertise Can Help

In navigating these uncharted waters, Perficient has experts with decades of experience working for the most successful and compliant banks in the world. We specialize in not only thought leadership but also practical experience helping regional banks and credit unions seeking to understand and rectify potential “junk fees” in their fee structures. With profound expertise in the financial services sector, we can assist banks in identifying and addressing these areas of concern, ensuring compliance, and bolstering customer trust.

Learn More: Perficient’s Financial Services Solutions

As the CFPB intensifies its focus on “junk fees,” the financial industry must adapt and respond. This isn’t just a call for compliance; it’s an opportunity for banks to redefine their practices, fostering transparency and fairness.

Collaborating with Perficient enables financial institutions to take a proactive approach to tackling the issue of “junk fees” and other regulatory challenges. This partnership not only helps avoid regulatory scrutiny but also positions them as advocates for customer well-being in the continually changing financial landscape.

Connect with Perficient today to elevate your business practices.

In recent years, the Consumer Financial Protection Bureau (CFPB) has significantly broadened its oversight, extending beyond major banks to address concerns in various industries, such as payday loan providers, credit reporting agencies, and most recently, the medical debt collection sector.

The CFPB’s Dynamic Approach

The CFPB’s modus operandi often involves proactively addressing potential issues through press releases ahead of engaging in enforcement actions. Often when the CFPB issues press releases, the agency has already issued non-public information requests or consent orders in the space. Given that they don’t have enough staff to engage at all eligible institutions, their unique approach serves as a proverbial “shot over the bow” for the industries they are investigating. This prompts the companies involved in that industry to reevaluate and rectify their practices. If the CFPB sees a larger institution engaging in the practice, it often exemplifies them. The objective is clear: encouraging compliance with consumer protection regulations they deem important before punitive measures are implemented broadly.

The Impact on the Medical Collections Sphere

The recent CFPB press release is poised to send ripples throughout the entire medical collections industry. Whether managing medical debt collections in-house or outsourcing to third-party agencies, companies need to exercise vigilance. This focused scrutiny serves as a wake-up call, signaling that industry practices are under intense scrutiny.

Why Companies Need to Review Their Practices

• Legal Compliance: The rapidly evolving landscape of consumer protection laws demands constant vigilance. Understanding current regulations is crucial to avoid legal repercussions and enforcement actions.
• Reputation Management: With increased public awareness and scrutiny, maintaining a positive reputation is crucial. Unfair or aggressive debt collection practices can lead to severe reputational damage, impacting trust and customer relationships.
• Operational Efficiency: An internal review of debt collection practices can uncover significant opportunities for operational improvements. Like “robo-signing” created an enormous regulatory headache for banks in the last decade, similar practices or “robo-billing” and lack of debt validation plague the medical collections space. The CFPB’s article demonstrates that they have observed, designed, and executed operational practices that led to debts being collected that had already been paid, were not owed by the patient or family, were for inaccurate amounts and collections of medical bills began long after services were provided.

Success In Action

Use Case: Regulatory Engagement Success

Perficient staff recently delivered a presentation to various federal bank regulators, leading to a substantial reduction of over 80% in margin requirements for the client. This regulatory success allowed the client to take on more business, thanks to significantly lowered mandatory margin requirements.

Use Case: Optimized Processing Time

In a recent collections engagement, Perficient successfully implemented a Full-Time Equivalent (FTE) reduction initiative, identifying opportunities, streamlining processes, enhancing compliance, and mitigating risks across various business units. These efforts resulted in a significant achievement of $50 million in savings through the reduction of average processing time.

Related: Healthcare Consulting Services

The Perficient Advantage

In the evolving regulatory landscape, companies in the medical collections industry require a steady hand to navigate complexities. At Perficient, we offer a wealth of experience in both first- and third-party collections from complex banks and credit unions globally. Our team of financial services experts positions us as a trusted partner to assist firms in ensuring compliance while effectively managing delinquency and losses.

While supporting the need for compliance, it’s essential to acknowledge the potential challenges of the CFPB’s approach. The regulatory landscape is nuanced, and companies must adapt strategically. We understand the industry’s concerns and aims to provide guidance that ensures compliance while minimizing disruptions.

As the CFPB emphasizes consumer protection in medical debt collection, companies in the industry must take proactive measures. Contact us today to find out how Perficient can provide the necessary guidance and edge to your business practices!

In various press releases, the Federal Deposit Insurance Corporation (FDIC) has highlighted that an estimated $16.3 billion of the total cost incurred from the failures of Silicon Valley Bank (SVB) and Signature Bank was designated for safeguarding uninsured depositors. This financial strain emphasizes the critical need for effective regulatory oversight.

Immediately following the Silicon Valley Bank (SVB) failure, Perficient’s Financial Services Risk Management and Regulatory Capabilities Center of Excellence (CoE) swiftly analyzed publicly available documents, providing readers with a comprehensive breakdown of the bank’s failure. Despite this proactive approach, federal banking regulators either neglected to review the same documents or did so without taking necessary action before the bank failed.

Explore our detailed analysis in Perficient’s article on the causes of the failures: 7 Possible Causes of SVB Failure and Predicting the Impact on Regulatory Reporting

Assessment Base for the Special Assessment

Turning to the FDIC’s response, they have recently announced a Robin Hood-style special assessment, targeting large banks to contribute a premium for an Insured Depository Institution’s (IDI) estimated uninsured deposits as of December 31, 2022. This initiative aims to exempt the first $5 billion of IDI’s uninsured deposits, presumably shielding smaller bankers, especially in an election year.

The secondary special assessment will be levied at an annual rate of approximately 13.4 basis points over eight quarterly assessment periods. Commencing with the first quarterly assessment period of 2024 (i.e., January 1 through March 31, 2024), larger banks will be expected to remit payments by June 28, 2024.

SEE ALSO: Risk Management in Financial Services

Covered Entities

Covering 114 banking organizations, the FDIC’s estimate includes 48 with total assets exceeding $50 billion and 66 with assets ranging between $5 and $50 billion. Notably, these entities will bear more than half of the special assessment burden, underscoring the consequences of regulatory lapses in properly supervising the banks under their purview.

Certain large banks have publicly announced the estimated impact of the special assessment which the CoE has provided in the table below:

Together these banks would be paying more than half of the special assessment, which was caused by the regulator’s failure to properly supervise the banks they were supervising.

Unlock Perficient’s Financial Expertise

As your expert partner, Perficient invites you to engage in discussions addressing your specific risk and regulatory challenges.

Our unparalleled financial services expertise, combined with digital leadership across platforms and business needs, empowers the largest organizations to overcome complex challenges and foster compliant growth.

Contact us today to navigate the evolving landscape of risk and regulation successfully.

On May 31, the Federal Deposit Insurance Corporation (FDIC) reported to the public what many banks already knew and had been experiencing for the past year – that deposits are declining in the American banking sector.

There has almost been $1.2 Trillion removed from the banking system over the past year. In addition, the recent banking stress, which resulted in several large bank failures, has amplified the outflow of deposits from the banking system, causing total deposits to decline for the fourth consecutive quarter at a faster rate than in prior quarters. Although not substantiated by published figures in their report, the FDIC did state that deposit outflows have moderated since the end of the quarter.

Of course, one reason that deposits have left the banking system is that while the Federal Reserve raised rates throughout the four quarters shown above, banks have lagged in raising deposit rates. However, the difference began to wane in the first quarter of 2023. As interest rates that banks earned on their loans increased, the interest rates they paid on deposits increased by a larger amount in the first quarter of 2023, which contributed to lower quarterly net interest margins for the industry as shown below:

Note that while Net Margin shrank by only 1 basis point for the largest financial institutions, mid-sized and smaller banks had their margins whittled away in the first quarter by far larger amounts.

Positives (Or Less Negative Than Before)

Unrealized losses on held-to-maturity securities totaled $284.0 billion in the first quarter. Unrealized losses on available-for-sale securities totaled $231.6 billion in the first quarter. While more than $.5 Trillion of unrealized losses lurking on the bank industry’s balance sheet is certainly bad news (except for in the eyes of analysts who have been kept busy trying to determine which institutions are at-risk) the positive spin is that the amount of unrealized losses actually declined by $102.2 billion (16.5%) in the first quarter of 2023.

Perficient’s Response

At the request and urging of several significant bank clients, Perficient is now offering a cross-functional Banking Crisis Service Offering, combining financial analysis, social media monitoring, and IT changes including artificial intelligence offerings that:

1. Automates the orchestration of data mining, reporting, and generation of actionable insights to replace labor-intensive, manual reporting and analysis using discrete data from multiple sources.
2. Uses social media and market sentiment analytics to assess market sentiment and generate prescriptive insights on threats to brand reputation.
3. Conducts continuous assessments of key customers for deposit outflow risks and 360° customer value to direct targeted campaigns to those customers and/or specific market segments.
4. Coordinates multi-channel campaigns with personalized, targeted messaging for social media influencers, analysts, key customers, and employees.
5. Enables automated and on-demand reporting to provide more timely and granular information to investors such as deposit details, customer concentrations, liquidity immediately available vs contingent liquidity sources, and loans by collateral and CRE segment to better evaluate risk and boost institution responsiveness.

Contact Perficient’s financial services team today to learn more about this product offering.

The Landscape

According to Forbes Advisor: 2022 Digital Banking Survey, as of 2022, 78% of adults in the U.S. prefer to bank via a mobile app or website.

That’s a whole lot of consumers, all of whom come with unique expectations, needs, and data. And those consumers desire digital experiences that are personalized and meaningful.  In fact, Gartner shares that brands risk losing 38 percent of customers from poor personalization efforts.

Tectonic Shifts Demand Value-Adding, Strategic Steps

This shift in digital banking preferences confronts institutions with technology and business challenges that are more convoluted than ever, and a plethora of platform and technology advances have risen in response to consumers’ expectations for more personalized, meaningful experiences with their banking institutions. However, it’s not always obvious which of the many potential technology vendors and implementation partners will best drive an organization’s desired business goals. Not to mention, institutions face new, more sophisticated threats every day that defy the ways in which they’ve traditionally conducted business (i.e.., blockchain​, digital wallets​, money center banks​, emerging payment solutions, digital lending​, economic turmoil​, and fintech disintermediation).

Choosing the Right Strategic Partner

Banks seek partners who understand the headwinds, will empower them to navigate these challenges with confidence and enable them to create tailored experiences that engage customers in new ways. They want to have meaningful relationships with technology partners who will bring innovative ideas and proven experience to the table.

As financial services leaders research personalization technology partners, we recommend the following value-add checklist. The right partner will help you to:

• Get ahead of your competition
• Balance incumbency and innovation​
• Expand your franchise to grow and increase profitability​
• Create unique combinations of products and functionality that solve customer problems​
• Scale new product propositions quickly and efficiently​
• Avoid over-investing in capabilities that do not drive strategic value
• Improve organizational flexibility and modular approaches to service design and product development​
• Remain in compliance

Propelling Success With Omnichannel Marketing

All these efforts, to be successful, must coincide with omnichannel marketing. Marketers often turn to technology vendors to help them define robust and compliant digital marketing strategies. The right technologies can give marketers the reliable and digestible data needed to enable them to make strategic decisions and deliver streamlined, personalized communications across channels in the locations where consumers are engaging most.

Bankers that have a defined digital marketing strategy are seeing greater lead generation and client acquisition. However, according to research, sixty-five percent of advisors who generate leads through a website still find it ineffective at meeting growth targets. This indicates an opportunity for further optimization of video, digital advertising, webinars, search engine marketing, social media, and more, which reinforces the importance of having the right technology in place to drive these initiatives effectively.

How Perficient Can Help

Perficient enables banks to deliver end-to-end personalized, omnichannel marketing initiatives and products. We partner with leading technology vendors, such as Salesforce and Adobe, to match our clients with the right platforms for their unique needs.

Interested in learning more? Explore our expertise in financial services, and contact us today.