HIGH · Liquidity
Procedure L-03
Uninsured deposit concentration elevated
Citation
Federal Reserve, Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank (April 28, 2023); Joint Agency Statement on Liquidity Risk Management (July 28, 2023); FDIC FIL-84-2008, Liquidity Risk Management
Evidence
Total deposits $1,324,835M and insured deposits $240,681M indicate material uninsured-deposit exposure. Uninsured deposits are calculated as total deposits less insured deposits and can be more prone to rapid runoff under stress. Threshold calibration: post-SVB community-bank median uninsured share is 40-55%; this rule fires above 55% because that level requires explicit liquidity contingency planning.
Recommended action
Provide deposit segmentation by customer type, size, relationship tenure, and operational dependency. Update liquidity stress assumptions for uninsured runoff, identify high-confidence contingent funding sources (FHLB, discount window, BTFP collateral pre-positioning), and document board-approved concentration limits and trigger-based escalation.