Fed report shows declining supervisory ratings for banks

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The Federal Reserve Board said in its semiannual Supervision and Regulation report Friday that banks of all sizes have faced supervisory downgrades in the last year due to liquidity and interest rate risk problems, but noted that the banking industry is well-capitalized as a whole.
Bloomberg News

WASHINGTON — Banks of all sizes — but particularly big banks — have received declining supervisory ratings in part due to lagging interest rate and liquidity risk-management practices, according to the Federal Reserve's most recent Supervision and Regulation report released Friday.

The number of outstanding supervisory findings at large financial institutions — those with total assets of $100 billion or more — continued to increase in the second half of 2023, the report found. Part of the increase was driven by findings related to weaknesses in liquidity and interest rate risk management, but governance and risk control shortcomings continued to constitute the majority — roughly two-thirds — of outstanding issues at large banks. 

The report noted that by the end of the year, only about a third of large banks received satisfactory ratings across all three components of the Large Financial Institution, or LFI, rating system, which considers capital planning, liquidity management and governance for the largest banks. 

"Supervisors have found weaknesses in interest rate risk and liquidity risk-management practices," read the report. "Some large financial institutions [also] continued to show weaknesses in governance and controls related to operational resilience, cybersecurity, and BSA/AML compliance."

The number of large banks with satisfactory ratings has been on a steady decline since 2019, according to the report, with 2023 marking a five-year low for big bank's supervisory report cards. 

Despite lagging governance and liquidity management, the Fed noted the banking industry appears resilient at the moment, with the majority of firms operating with capital and liquidity levels above regulatory minimums. Overall, large banks' Common Equity Tier 1 capital ratios increased to 12.7% as of the close of 2023, up from 12.3% on June 30, 2023. The Fed also noted an increase in deposits since the last report. Offsetting this strong equity capital funding, however, are declines in fair values of securities held by banks, which decreases their tangible equity.

The majority of small and medium-sized banks continued to have satisfactory ratings and were found to have effective risk management practices. However, the agency notes supervisory ratings downgrades among those tiers of banks have seen a slight uptick also due to interest rate and liquidity risk-management practices.

Among the smallest banks, the predominant supervisory concerns centered around cybersecurity and credit risk. For medium-sized regional banks, the primary supervisory findings cited were market and liquidity risks, as well as cybersecurity.

The report comes at a time when the Fed is mulling various regulations and the banking industry is facing headwinds in the form of distressed commercial real estate property values. 

Bank regulatory agencies have been looking at declining performance of CRE loans as a source of risk for some time. While the Fed's recent financial stability report noted that industry professionals are less concerned about CRE chargeoffs, Friday's report also indicated delinquency rates for some CRE loans and consumer loans have increased above pre-pandemic levels.

Just before the report's release, Fed Governor Michelle W. Bowman noted while the Fed continues to monitor CRE stress closely — especially given increases in delinquencies in certain banks — saying that overall, delinquency rates are low, but that an increasing rate of work-from-home or hybrid work arrangements could give CRE performance more room to fall. Despite efforts by some to promote return-to-work policies, statistics show over a third of workers who can work remotely do so full time. 

"As we know, one of the factors that has led to CRE stress in certain property types, like office, is the post-pandemic changes in the demand for, and use of, these CRE properties," Bowman said. "Should this trend continue, we could see declines in property values, reduced rental income cash flows, or other conditions that could lead to impairment of some banks' CRE loans or portfolios, especially if those loans mature and are refinanced at higher interest rates."

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