HIGH · Liquidity
Procedure L-01
Loans-to-deposits ratio elevated — wholesale-funding reliance
Citation
Interagency Policy Statement on Funding and Liquidity Risk Management (March 2010); FFIEC Liquidity and Funds Management Handbook
Evidence
Gross loans and leases $159,200M against total deposits $149,994M. A loans/deposits ratio above 100% indicates the institution funds loan growth with non-deposit (wholesale, brokered, or borrowed) funding sources, increasing liquidity and funding-cost sensitivity.
Recommended action
Provide an updated Contingency Funding Plan with specific playbook triggers (deposit-runoff thresholds, asset-sale order). Quantify uninsured-deposit runoff under stress scenarios. Document back-up borrowing capacity at FHLB, the discount window, and any standing facilities; pre-position collateral.