by Calculated Risk on 11/01/2020 08:12:00 AM

The FDIC's official problem bank list is comprised of banks with a CAMELS rating of 4 or 5, and the list is not made public (just the number of banks and assets every quarter). Note: Bank CAMELS ratings are also not made public.

CAMELS is the FDIC rating system, and stands for Capital adequacy, Asset quality, Management, Earnings, Liquidity and Sensitivity to market risk. The scale is from 1 to 5, with 1 being the strongest.

As a substitute for the CAMELS ratings, surferdude808 is using publicly announced formal enforcement actions, and also media reports and company announcements that suggest to us an enforcement action is likely, to compile a list of possible problem banks in the public interest.

DISCLAIMER: This is an unofficial list, the information is from public sources only, and while deemed to be reliable is not guaranteed. No warranty or representation, expressed or implied, is made as to the accuracy of the information contained herein and same is subject to errors and omissions. This is not intended as investment advice. Please contact CR with any errors.

Here is the unofficial problem bank list for October 2020.

Here are the monthly changes and a few comments from surferdude808:

Update on the Unofficial Problem Bank List for October 2020. During the month, the list decreased by one to 64 banks after a removal. A year ago, the list held 71 institutions with assets of $53.4 billion. First City Bank of Florida, Fort Walton Beach, FL ($135 million) exited the list through failure on October 16, 2020.

On October 7, 2020, the OCC issued a couple of formal actions against Citibank, National Association, Sioux Falls, SD (FDIC Cert#7213, 2q2020 assets -- $1.633 trillion). The formal actions included a Consent Orderand a Civil Money Penalty Order. The Consent Order states that “the OCC intends to intends to initiate cease and desist proceedings against the Bank pursuant to 12 U.S.C. § 1818(b), through the issuance of a Notice of Charges, for deficiencies in its data governance, risk management, and internal controls that constitute unsafe or unsound practices and that contributed to violations of law or regulation” Because of the deficiencies specified in the Consent Order, the OCC issued a $400 million Civil Money Penalty against Citibank. Separately, the Federal Reserve issued a formal enforcement action against the parent bank holding company, Citigroup Inc., that states “… Citigroup has not adequately remediated the longstanding enterprise-wide risk management and control deficiencies …” The substance and nature of these enforcement actions would land most banks on the problem bank list, but our guess is that the FDIC will not designate Citibank as a problem bank. As some observers say, size does have its privileges.