MODERATE · Earnings
Procedure E-01
Return on assets below typical peer range
Citation
OCC Comptroller's Handbook, "Earnings"; FFIEC UBPR User's Guide §IV — Earnings Analysis
Evidence
YTD net income $132M on average assets $185,554M. Typical community-bank peer ROA is 0.9–1.1%; sustained sub-0.5% ROA can indicate margin compression, asset-quality deterioration, or expense growth out of pace with revenue. Negative ROA triggers heightened supervisory attention.
Recommended action
Provide written analysis of the drivers (margin compression, noninterest expense growth, credit costs, fee compression). If ROA is negative, submit an earnings-restoration plan to the primary regulator with quarterly milestones and a path back to peer-range earnings within four to eight quarters.