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Financial Institution Letters

Section 109 Host State Loan-to-Deposit Ratios

On July 7, 2005, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) announced the host state loan-to-deposit ratios1 that the agencies will use to determine compliance with section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 (Interstate Act). In general, section 109 prohibits a bank from establishing or acquiring a branch or branches outside of its home state primarily for the purpose of deposit production. Section 106 of the Gramm-Leach-Bliley Act of 1999 amended coverage of section 109 of the Interstate Act to include any branch of a bank controlled by an out-of-state bank holding company. These ratios update data released on August 26, 2005.

To determine compliance with section 109, the appropriate agency first compares a bank’s statewide loan-to-deposit ratio to the host state loan-to-deposit ratio2 for a particular state. If the bank’s statewide loan-to-deposit ratio is at least one-half of the published host state loan-to-deposit ratio, the bank has complied with section 109. A second step is conducted if a bank’s statewide loan-to-deposit ratio is less than one-half of the published ratio for that state or if data are not available at the bank to conduct the first step. The second step requires the appropriate banking agency to determine whether the bank is reasonably helping to meet the credit needs of the communities served by the bank’s interstate branches. A bank that fails both steps is in violation of section 109 and subject to sanctions by the appropriate agency.

Section 109 of the Interstate Banking and Branching Efficiency Act

2005 Host State Loan-to-Deposit Ratios Using Data as of June 30, 2004

(Excludes wholesale or limited purpose CRA-designated banks, credit card banks, and special purpose banks)

State or U.S. Territory

Host State Loan-to-Deposit Ratio

Alabama

95%

Alaska

75%

Arizona

92%

Arkansas

78%

California

79%

Colorado

72%

Connecticut

88%

Delaware

109%

District of Columbia

77%

Florida

83%

Georgia

93%

Hawaii

70%

Idaho

83%

Illinois

84%

Indiana

149%

Iowa

83%

Kansas

80%

Kentucky

90%

Louisiana

78%

Maine

99%

Maryland

88%

Massachusetts

75%

Michigan

99%

Minnesota

91%

Mississippi

80%

Missouri

86%

Montana

87%

Nebraska

84%

Nevada

61%

New Hampshire

83%

New Jersey

56%

New Mexico

71%

New York

82%

North Carolina

79%

North Dakota

124%

Ohio

131%

Oklahoma

79%

Oregon

90%

Pennsylvania

75%

Rhode Island

79%

South Carolina

92%

South Dakota

85%

Tennessee

92%

Texas

71%

Utah

83%

Vermont

78%

Virginia

76%

Washington

97%

West Virginia

85%

Wisconsin

99%

Wyoming

76%

American Samoa

94%

Federated States of M icronesia

19%

Guam

59%

Puerto Rico

71%

Virgin Islands

44%


Due to the legislative intent against imposing regulatory burden, no additional data were collected from institutions to implement section 109. However, since insufficient lending data were available on a geographic basis to calculate the host state loan-to-deposit ratios directly, the agencies used a proxy to estimate the ratios. Accordingly, the agencies calculated the host state loan-to-deposit ratios using data obtained from the call reports and summary of deposits reports, as of June 30, 2004. For each home state bank, the agencies calculated the percentage of the bank’s total deposits attributable to branches located in its home state (determined from the summary of deposits), and applied this percentage to the bank’s total domestic loans (determined from the call reports) to estimate the amount of loans attributable to the home state. The host state loan-to-deposit ratio was then calculated by separately totaling the loans and deposits for the home state banks, and then dividing the sum of the loans by the sum of the deposits.

Section 109 of the Interstate Act directs the agencies to determine, from relevant sources, the host state loan-to-deposit ratios. As discussed in the preamble to the joint final rule, Prohibition Against Use of Interstate Branches Primarily for Deposit Production (62 FR 47728, 47731, September 10, 1997), implementing section 109, banks designated as limited purpose or wholesale banks under the Community Reinvestment Act (CRA) were excluded from the host state loan-to-deposit calculation, recognizing that these banks could have very large loan portfolios, but few, if any, deposits. Likewise, credit card banks, which typically have large loan portfolios but few deposits, were also excluded, regardless of whether they had a limited purpose designation for CRA purposes. Beginning in 2001, special purpose banks, including bankers’ banks, were excluded because these banks do not engage in traditional deposit taking or lending.

The host state loan-to-deposit ratios, and any changes in the way the ratios are calculated, will be publicized on an annual basis.


1 The host state loan-to-deposit ratio is the ratio of total loans in a state to total deposits from the state for all banks that have that state as their home state. For state-chartered banks and FDIC-supervised savings banks, the home state is the state where the bank was chartered. For national banks, the home state is the state where the bank’s main office is located. The home state of a foreign bank is determined by 12 USC 3103(c) and applicable agency regulations at 12 CFR 28.11(o) (OCC), 12 CFR 211.22 (Board), and 12 CFR 346.1(j) (FDIC).

2 The statewide loan-to-deposit ratio relates to an individual bank and is the ratio of a bank’s loans to its deposits in a particular state where the bank has interstate branches.


Last Updated 10/31/2011 communications@fdic.gov