by Calculated Risk on 1/04/2010 08:42:00 PM

Commentary from surferdude808:

Since August 7, 2009, each week an Unofficial Problem Bank List has been posted to Calculated Risk. The Unofficial Problem Bank List is an attempt to mirror the number of problem banks the FDIC reports each quarter.

The FDIC does not disclose the institutions on its Problem Bank List and CAMELS ratings are confidential. For the most part, institutions on the FDIC Problem Bank List have a CAMELS rating of 4 or 5. Normally, problem institutions or those with a CAMELS rating of 4 or 5 are subject to a safety & soundness formal enforcement action by their respective primary federal supervisor (Federal Reserve, FDIC, OCC, or OTS).

Since the last crisis, much to the consternation of the federal supervisory agencies, they are required to make all formal enforcement actions public. Historically, there is a high positive correlation between a safety & soundness formal enforcement action and a CAMELS rating of 4 or 5. This relationship is the basis for the Unofficial Problem Bank List, which is comprised of institutions operating under a safety & soundness formal enforcement action, and some institutions that have made public announcements that lead us to believe a formal enforcement action is likely.

With the passage of the year, we thought it would be of interest to analyze how the Unofficial Problem Bank List has changed since it was first published. The list had 389 institutions on August 7, 2009 and it finished the year at 575. During the past five months, there have been 277 additions and 91 deletions.

There are four ways to be removed from the list – failure, voluntary dissolution, merger with another institution (without FDIC assistance), or improvement in condition whereby the action is terminated. Of the 91 deletions, 74 are from failure, 9 are from termination of the enforcement action, and 8 are from an unassisted merger.

Of the 389 institutions on the August 7, 2009 list, 325 are still on the January 1, 2010 list as 64 were removed because of failure (48), action termination (9), and unassisted merger (7). Interestingly, 26 institutions that were added after August 7, 2009 failed before January 1, 2010.

So far, only 74 or 11.1 percent of the 666 institutions that have been on the list have failed. However, failure is the cause for 81.3 percent of all deletions. While failures only represent 11.1 percent of institutions that have appeared on the list, failed bank assets (quarter before failure) of $135.8 billion represent 30 percent of the $450.2 billion of assets that have been on the list. Moreover, failure is responsible for 98 percent of the $138.6 billion of assets of institutions deleted from the list. Thus, for the second half of 2009, failure was the primary way institutions and assets were removed from the list.

Unofficial Problem Bank List Change Summary
		Number of Institutions	Assets ($Thousands)
Start	(8/7/2009)	389	276,313,429
Additions		277	173,919,123
Subtractions
	Action Terminated	9	1,605,652
	Unassisted Merger	8	1,141,008
	Failures	74	135,814,823
	Asset Change		8,453,550
End	(1/01/2010)	575	303,217,519