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Examined: Sat, 25 Apr 2026 19:36:10 GMT

TD Bank, National Association

RSSD 497404 · DE · Total assets $346,188M
Composite CAMELS
2
2 — Satisfactory
C
Capital
2
0 findings
A
Asset Quality
2
0 findings
M
Management
2
0 findings
E
Earnings
4
4 findings
L
Liquidity
2
0 findings
S
Sensitivity
2
0 findings
0
Critical
3
High
1
Moderate
0
Low
24
Procedures run

Findings

HIGH · 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 $-1,361M on average assets $376,005M. 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.
HIGH · Earnings Procedure E-03

Efficiency ratio elevated relative to earnings capacity

Citation
FFIEC UBPR User's Guide §IV — Earnings Analysis
Evidence
Efficiency ratio is 100.02%. An elevated efficiency ratio indicates noninterest expense is consuming a high share of operating revenue and may weaken the institution’s ability to absorb credit costs, funding-cost pressure, or revenue disruption.
Recommended action
Provide expense and revenue decomposition by major line item, including compensation, occupancy, technology, professional services, and noninterest income trends. Submit a board-reviewed operating plan with measurable expense controls, revenue initiatives, and quarterly efficiency targets.
HIGH · Earnings Procedure E-04

Year-to-date net income is negative

Citation
OCC Comptroller's Handbook, "Earnings"
Evidence
Year-to-date net income is $-1,361M. Negative earnings reduce internal capital generation and may indicate margin pressure, expense imbalance, elevated credit costs, or nonrecurring losses requiring supervisory attention.
Recommended action
Provide a written earnings-restoration plan identifying the drivers of the loss, expected recurrence, capital impact, and corrective actions. Include quarterly milestones for returning to sustainable profitability and board reporting that tracks actual performance against the plan.
MODERATE · Earnings Procedure E-05

Combined margin compression and elevated operating cost burden

Citation
OCC Comptroller's Handbook, "Earnings"
Evidence
Year-to-date net interest margin is 2.69% while the efficiency ratio is 100.02%. The combination of sub-3% margin and above-70% efficiency ratio indicates weakened recurring earnings capacity from both revenue pressure and operating-cost burden.
Recommended action
Provide an integrated earnings analysis showing whether margin pressure, deposit repricing, asset mix, noninterest expense, or fee-income weakness is the primary driver. Submit a board-approved profitability plan with coordinated pricing, funding, balance-sheet, and expense actions and quarterly monitoring metrics.

Key ratios computed

Tier 1 ratio
16.94%
↑ rank 4 of 16 · global
Tier 1 leverage
9.94%
↑ rank 5 of 16 · global
Total capital
18.19%
↑ rank 4 of 16 · global
NPL ratio
0.94%
ACL coverage
158.90%
CRE concentration
27.83%
Construction conc.
9.85%
ROA (annualized)
-0.36%
↑ rank 16 of 16 · global
NIM
2.69%
↑ rank 9 of 16 · global
Efficiency ratio
100.02%
↓ rank 16 of 16 · global
Loans / Deposits
61.29%
Brokered / Deposits
0.86%
Uninsured / Deposits
34.43%
Liquid asset ratio
8.67%
HTM loss / Tier 1
—
Asset growth YoY
—

Trend — last 8 quarters

Total assets ($M)
$372,778M
23Q03$401,245M 23Q06$374,251M 23Q09$366,252M 23Q12$367,175M 24Q03$369,860M 24Q06$370,332M 24Q09$399,881M 24Q12$372,778M
Tier 1 leverage
9.94%
23Q039.95% 23Q0610.52% 23Q0910.93% 23Q1211.01% 24Q0310.91% 24Q0610.93% 24Q0910.23% 24Q129.94%
Tier 1 RBC ratio
16.94%
23Q0317.59% 23Q0617.89% 23Q0918.04% 23Q1217.78% 24Q0317.53% 24Q0617.70% 24Q0916.95% 24Q1216.94%
ROA (YTD ann.)
-0.36%
23Q030.45% 23Q060.54% 23Q090.67% 23Q120.61% 24Q030.04% 24Q060.35% 24Q09-0.33% 24Q12-0.36%
NIM (YTD ann.)
2.69%
23Q032.60% 23Q062.59% 23Q092.63% 23Q122.65% 24Q032.67% 24Q062.69% 24Q092.67% 24Q122.69%
Efficiency ratio
100.0%
23Q0367.5% 23Q0666.8% 23Q0962.8% 23Q1266.2% 24Q0387.8% 24Q0676.3% 24Q0999.8% 24Q12100.0%

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