On May 1, the FDIC, Fed and OCC jointly issued updated host state loan-to-deposit ratios under Section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 (the Riegle-Neal Act). The ratios, which use data as of June 30, 2025, replace those issued in May 2025 and, as required by the Riegle-Neal Act, are used to determine whether banks with interstate branches are complying with the statutory prohibition against using interstate branches primarily to take deposits without serving community credit needs. Each ratio “compares the total loans in a state to total deposits in the state for all banks that are legally operating in that state,” excluding banks designated as wholesale or limited purpose under the Community Reinvestment Act, credit card banks, and special purpose banks.

The published ratios range from 52 percent (Virgin Islands) to 96 percent (Massachusetts, New Hampshire and New Jersey). Under the compliance framework, the agencies first compare a bank’s statewide loan-to-deposit ratio to the host state ratio; if the bank’s ratio is at least one-half of the published host state ratio, the bank is deemed compliant. If the bank’s ratio falls below that threshold, or if data is unavailable, the supervising agency must determine whether the bank is reasonably helping to meet the credit needs of its communities. A bank that fails both steps is in violation of Section 109 and may be subject to sanctions.