--- title: "Bank Holding Company Analysis for Community Banks" description: "Bank holding company Y-9C filings reveal what the Call Report hides: benchmarks, examiner priorities, and guidance for community bank CFOs and treasurers." canonical_url: https://www.bankregreports.com/blog/bank-holding-company-data-python/ source: BankRegReports published: "2026-08-31" updated: "2026-10-19" --- Most community bank CFOs can quote their [Call Report](/blog/what-is-a-bank-call-report/) capital ratios from memory. Fewer can say, without checking, whether those ratios match what the Fed sees when it opens the holding company's Y-9C. For most simple one-bank structures, the gap is negligible. It widens for institutions with parent-level debt, non-bank subsidiaries, or meaningful AOCI exposure. There, the difference between what management tracks and what regulators measure can be 50 to 150 basis points on a capital ratio. That is enough to change the tenor of an exam conversation. ## The Y-9C Filing: What It Is and Who Has to File It The Federal Reserve's [FR Y-9C](/blog/what-is-the-fr-y-9c/) (Consolidated Financial Statements for Holding Companies) is the holding company counterpart to the bank-level Call Report. It measures capital, earnings, and asset quality at the consolidated entity level. - **Who files:** any bank holding company or intermediate holding company with $3 billion or more in total consolidated assets. - **How many:** roughly 350 institutions file quarterly (the Federal Reserve estimated 352 respondents in 2024). - **Smaller BHCs:** those below that threshold file the FR Y-9SP, a simplified version. ### What the consolidated perimeter includes That distinction matters. The consolidated perimeter in a Y-9C includes the lead bank plus any non-bank subsidiaries: - insurance operations; - mortgage companies; - premium finance subsidiaries; - REIT holding structures; - investment management affiliates. Assets, income, and risk-weighted exposures across all of those entities roll up into the consolidated filing. That filing is what the Federal Reserve evaluates when forming a supervisory view of the organization. State supervisors increasingly do the same through coordination agreements. ### When the Y-9C and the Call Report agree For the large majority of community BHCs, the Y-9C and the Call Report tell nearly the same story. The holding company holds stock in the bank. It may carry a small amount of cash and a line of credit at the parent, and it has no meaningful non-bank operations. In that structure, the consolidated ratios and the bank-level ratios are nearly identical. The Y-9C still matters, because it is the document examiners use to formalize that assessment. Any deviation from it, even a small one, needs to be understood and explained. ### When the gap opens up The gap opens up when the holding company has done any of the following: - issued subordinated debt; - made investments in non-bank affiliates; - built up goodwill and intangibles from acquisition activity. Each of those items flows through the consolidated balance sheet on Schedule HC. Each affects the capital ratios on Schedule HC-R differently than it appears in the bank-level filing.
Histogram of Common Equity Tier 1 ([CET1](/blog/cet1-capital-ratio-explained/)) capital ratios across U.S. banks that report CET1
Where community bank holding companies actually stand on capital: CET1 ratios across every bank that reports them, the benchmark the Y-9C capital schedules roll up to. BankRegReports analysis.
## The Schedules That Drive ALCO and Exam Conversations The Y-9C runs across roughly 2,400 individual data items. The schedules that appear most often in ALCO packages, board presentations, and examiner requests are a shorter list. ### Schedule HC: consolidated balance sheet Schedule HC is the consolidated balance sheet: total assets, gross loans, allowance, securities, deposits (domestic and foreign), long-term borrowings, and equity. This is the reference point for any holding company peer comparison. It is also the starting point for most capital adequacy analysis. ### Schedule HI: consolidated income statement Schedule HI is the consolidated income statement, covering net interest income, noninterest income, provision expense, noninterest expense, and net income. This schedule drives the earnings quality analysis that flows into CAMELS component ratings for management and earnings. ### Schedule HC-K: quarterly averages Schedule HC-K contains quarterly average balances for interest-earning assets and interest-bearing liabilities. This matters for NIM calculations. Some analysts use end-of-period balances from Schedule HC instead of HC-K averages. For a bank with a growing balance sheet, that can shift the net interest margin calculation by 20 to 30 basis points. That is a meaningful distortion when you benchmark NIM against a peer group that uses the correct average-balance method. Examiners know the difference, and sometimes management teams do not. ### Schedule HC-R: regulatory capital Schedule HC-R is the regulatory capital schedule. CET1, Tier 1, Total Capital, and risk-weighted assets are all reported here. This schedule is where: - the prompt corrective action ratios are calculated; - stress test capital projections are anchored; - the distance to well-capitalized minimums is measured. ### Schedule HC-N: past-due and nonaccrual loans Schedule HC-N breaks out past-due and nonaccrual loans by category and delinquency bucket. This is typically the first schedule an examiner reviews when preliminary credit concerns surface before an exam. The data in it feeds directly into the CAMELS asset quality rating. ## Capital Benchmarks: Where Community BHCs Actually Stand Holding companies under $3 billion file the FR Y-9SP, which carries no consolidated capital ratios, so the community benchmark comes from their subsidiary banks' Call Reports: the median bank-level CET1 ratio for $300M–$3B community banks was 13.7% at March 31, 2025. The well-capitalized minimum under prompt corrective action is 6.5%, a regulatory floor, not a target. Most community bank boards operate with internal minimums 200 to 400 basis points above that floor. That places practical targets in the 11 to 14% range, depending on the institution's risk profile, loan growth expectations, and dividend policy. ### Below 10% and above 16% Institutions running CET1 below 10% should expect examiner scrutiny on three things: capital planning, dividend capacity, and the adequacy of the internal capital adequacy assessment process. Institutions above 16 or 17% are often one of the following: - recently converted mutual savings banks; - recently recapitalized institutions; - S-corps with limited ability to deploy retained earnings externally. Overcapitalization at that level carries its own strategic questions about earnings efficiency. ### Leverage ratio vs. risk-based ratios Tier 1 leverage ratios for the community BHC peer group median around 10%, with the well-capitalized minimum at 5%. The leverage ratio and the risk-based ratios can diverge meaningfully depending on how an institution grew. Growth through CRE or construction lending carries elevated risk weights. Growth through agency MBS or SBA-guaranteed loans carries lower ones. An institution with a 13% CET1 and an 8% leverage ratio has a different risk profile than one with matching ratios, and examiners evaluate both. ### AOCI pressure from the 2022 to 2024 rate cycle The 2022 to 2024 rate cycle created concentrated pressure on BHC capital through the AOCI channel. Many banks built large securities portfolios during 2020 and 2021. Deposit growth was outpacing loan demand then, and short-term rates were near zero. Those banks absorbed significant unrealized losses as the Fed moved 525 basis points between March 2022 and July 2023. Some institutions did not make the AOCI opt-out election (it was unavailable only to advanced approaches institutions, and most community banks took it). For them, unrealized losses on available-for-sale securities ran through [accumulated other comprehensive income](/blog/unrealized-losses-on-bank-securities/) and into regulatory capital ratios. For every institution, opt-out or not, those losses reduced tangible book value. By early 2025, much of that pressure had begun to reverse. For some institutions, though, the tail on longer-duration securities held in available-for-sale portfolios was still working through. ![Holding Company Tangible Equity Ratio Distribution, Q2 2026](figures/bank-holding-company-data-python-2.svg) ## What Do Examiners Focus On at the BHC Level? The Federal Reserve examines a bank holding company under the RFI/C(D) rating framework, not CAMELS. The framework covers Risk management, Financial condition, and Impact on the subsidiary bank, with a separate component for Depository Institution. The differences from CAMELS reflect what the Fed is actually evaluating. It judges the quality of the holding company as a source of strength to the bank, not as a standalone operating entity. For community institutions, three things generate the most examiner attention at the BHC level: 1. the adequacy and reliability of dividend flows from the bank to the holding company to service parent-level obligations; 2. the quality of consolidated capital planning, including stress scenarios and the link between capital projections and strategic plan assumptions; 3. the management of non-bank subsidiaries or off-balance-sheet activities that affect the consolidated risk profile without appearing on the bank Call Report. ### Dividend flows to the parent Some holding companies depend on bank dividends to service parent-level debt (sub-debt issued to investors or a holding company line of credit used for acquisitions). They face a structural vulnerability when the bank's earnings decline. The bank's ability to pay dividends upstream is limited by its own retained earnings and surplus position under state law and Fed guidance. Those limits tighten precisely when the parent most needs the cash. Examiners evaluate whether management has stress-tested the dividend waterfall and whether the holding company has adequate standalone liquidity. ### Capital planning and CRE concentrations The interagency guidance on CRE concentrations applies at the consolidated BHC level. Its two screens are: - construction loans at 100% or more of total risk-based capital; or - total CRE at 300% or more after growth of 50% or more over the prior 36 months. Routing CRE loans through a non-bank subsidiary to manage the bank-level concentration ratio gets no examination benefit while the consolidated ratio remains elevated. Meeting either screen is not a breach of a limit. It does bring enhanced expectations for risk management, stress testing, and board oversight, regardless of how the loans are legally held within the organization. ## Earnings Quality at the Consolidated Level Net interest margin for $300M–$3B community banks (bank-level Call Report data) ran approximately 3.3 to 3.5% in early 2025, after a period of compression. The compression reflects the asymmetry in deposit repricing. ### Why deposit betas compressed NIM Deposit betas (the fraction of each rate increase passed through to depositors) were lower than many expected. Measured from March 31, 2022 to the September 30, 2024 peak in deposit costs, the median $1B–$10B bank's cumulative deposit beta was about 42% on total deposits and about 53% on interest-bearing deposits (BankRegReports analysis of Call Report data). But the repricing lagged asset yields by roughly two quarters. Loan yields and investment portfolio yields began repricing upward as soon as the Fed started moving. CD and MMDA costs, by contrast, continued rising well after the Fed paused. Many asset-liability models assumed faster pass-through. Betas came in lower in the early hiking phase, which supported NIM. Then the lagged repricing caught up, which drove compression in 2023 and 2024. ### ROA and efficiency ratio benchmarks Return on assets for the peer group typically runs 0.95 to 1.10%. - **Above 1.20%:** reflects some combination of above-peer earning asset yields, a diversified fee income base, or an efficiency structure below 60%. - **Below 0.80%:** gets examiner attention, particularly when the cause is elevated provision expense rather than intentional investment in technology or market expansion. The efficiency ratio for the peer group sits in the 60 to 65% range. An institution running above 70% consistently needs a clear narrative for the board. Organic branch expansion into a new market is a different story than structural overhead that has outpaced revenue for three years. ## The NIC Database and Organizational Structure The Federal Reserve's National Information Center (the NIC database) maintains the legal ownership structure for every bank holding company: - parent-child relationships; - percentage ownership; - changes in control; - the list of controlled non-depository subsidiaries. This is the data source that links your holding company entity to your lead bank and to any affiliates. ### Why NIC structure matters in M&A For merger and acquisition analysis, the NIC structure matters in ways that Call Report data alone cannot address. When you evaluate a target, three things can surface risks that do not appear in the bank-level filing: - the consolidated BHC capital ratios; - the organizational chart of non-bank subsidiaries; - the history of inter-company transactions at the holding company level. Examples of what can hide there: - a mortgage company subsidiary with off-balance-sheet repurchase exposure; - a trust company with discretionary asset management liability; - a premium finance affiliate with concentrated credit risk. These items live in the Y-9C consolidated filing and the NIC organizational data, not in the Call Report. ## Pulling BHC Peer Data Without Building a Data Pipeline The Federal Reserve publishes Y-9C bulk data quarterly, and the official source is the [Federal Reserve](https://www.federalreserve.gov). The raw files, however, come as caret-delimited (^) flat files with BHCK-prefixed MDRM codes as column headers. Three things make systematic peer analysis across multiple quarters a genuine data management project: schema changes between periods, MDRM code redefinitions, and amended filing handling. That project is well outside the scope of most community bank finance departments. The [BankRegReports platform](https://www.bankregreports.com) normalizes Y-9C data alongside Call Report, FDIC, NCUA, and SEC EDGAR filings into a single interface. You can: - search any holding company by name; - filter to a peer group by asset size and geography; - pull consolidated capital and earnings metrics across as many quarters as you need; - on the Pro plan, export to Excel. The NIC parent-child relationships are maintained in the platform. The bridge between your holding company consolidated metrics and your lead bank Call Report data is already built. The community banks with the most defensible positions in an examination cycle share one trait. Their CFO and treasurer understand the consolidated holding company picture as clearly as the bank-level Call Report. That means knowing where the Y-9C ratios differ from the bank-only ratios, why they differ, and what the trend looks like relative to peers. Examiners have that view before they arrive. Management should have it first. --- The benchmarks and peer data referenced in this post are available through the [BankRegReports platform](https://www.bankregreports.com), no data engineering required. Search any FDIC-insured bank, pull peer group comparisons, and, on the Pro plan, export to Excel for your ALCO package or board presentation. ## About this document This is the markdown twin of the page named in `canonical_url` above. Source filings are public record; the cleaning, normalization, cross-source linkage, and derived metrics are BankRegReports' own. Attribute with a link to the canonical URL. Markdown twins are published for editorial content only. Institution data pages do not have them. For data at scale use the API, which is documented at https://www.bankregreports.com/api/ and specified at https://www.bankregreports.com/openapi.json. It returns typed JSON with explicit units and periods, and one call replaces hundreds of page fetches. ## Sitemap - [Glossary](https://www.bankregreports.com/glossary/): every metric, with formula and thresholds - [Blog](https://www.bankregreports.com/blog/): analysis and explainers - [API documentation](https://www.bankregreports.com/api/): the programmatic way to get this data - [XML sitemap](https://www.bankregreports.com/sitemap.xml): the complete crawlable index