BankingLENS

Banking benchmarks

How much bank capital is still underwater?

Published September 16, 2026. Every figure computed from FFIEC call reports for the quarter ending June 30, 2026.

Short answer: For the median FDIC-insured bank at June 30, 2026, accumulated other comprehensive income (AOCI) was -4.95% of equity, across 4,237 banks. At the worst quarter in our series, Q3 2023, it was -17.65%. Measured before tax and counting the held-to-maturity bonds that AOCI leaves out, the median unrealized loss on securities is 7.03% of equity, down from 25.30%. Summed across all banks, AOCI is -$156.6 billion against $2,624.8 billion of equity (-5.97%). And 1,327 banks (31.3%) still have AOCI worse than -10% of equity.

Two measures of the same losses

AOCI to equity is the loss that has already reached the balance sheet. AOCI sits in the equity capital section of Schedule RC and is mostly the after-tax gain or loss on available-for-sale securities, which are carried at fair value. We divide it by total equity, so a negative figure is a loss already taken out of GAAP equity.

Unrealized loss to equity, the figure on our scorecard's securities panel, is wider. Schedule RC-B reports amortized cost and fair value side by side for held-to-maturity and available-for-sale securities. We take cost minus fair value across both, before tax, and divide by total equity, so a positive figure is a loss.

The wider measure runs larger for two reasons. Held-to-maturity bonds are carried at amortized cost, so their unrealized losses reach neither AOCI nor equity (Kansas City Fed), apart from losses frozen in AOCI when bonds moved over from available-for-sale. And AOCI is net of tax, so at a C corporation it shows less than the pre-tax loss. A Subchapter S bank, which pays no federal income tax at the bank level, gets little or no tax offset, so the same bonds give it a deeper AOCI ratio. In a peer set that mixes the two, compare the pre-tax figure.

Our numbers and the FDIC's

The population is the 4,238 FDIC-insured banks and savings institutions that filed a call report for June 30, 2026, the same count as in the FDIC's Quarterly Banking Profile for the second quarter. We leave out the 58 non-deposit trust companies among the 4,296 filers, since they take no deposits and make almost no loans. AOCI ratios are available for 4,237 banks.

That report, released August 25, 2026, put unrealized losses on investment securities at $326.7 billion, or 5.5% of amortized cost. It's a pre-tax industry total in which the largest banks weigh most, so it doesn't compare directly with our medians, which count every bank once, or with our after-tax AOCI total of -$156.6 billion.

How many banks are still underwater

Of the 4,237 banks with an AOCI ratio:

By size, the lower quartile moves far more than the median.

Bank size (total assets) Banks Lower quartile Median Upper quartile Aggregate
All banks4,237-13.05%-4.95%-1.05%-5.97%
Under $100M543-10.89%-2.19%-0.01%-6.69%
$100M to $300M1,214-16.11%-5.48%-1.03%-9.34%
$300M to $1B1,433-14.35%-5.69%-1.66%-8.44%
$1B to $3B625-10.85%-4.96%-1.56%-6.71%
$3B to $10B264-8.00%-3.92%-1.14%-5.90%
$10B to $100B126-6.55%-3.90%-1.27%-4.79%
Over $100B32-9.04%-5.31%-2.68%-6.03%

Source: BankingLens, computed from FFIEC call reports for the quarter ending June 30, 2026. Negative figures are losses, so the lower quartile is the deeper end. Aggregate is total AOCI over total equity for the band.

The two bands between $100M and $1B have the deepest medians, -5.48% and -5.69%, and the longest tails: a tenth of banks from $100M to $300M are at -31.62% or worse, against -12.72% for banks from $10B to $100B. Under $100M the median is only -2.19% and the upper quartile is -0.01%, so a quarter of the smallest banks show essentially no AOCI loss.

In every band the aggregate is deeper than the median. In a total, the banks with the largest losses count in full; a median barely notices them.

The path since 2023

Both medians hit their worst point in Q3 2023.

Quarter AOCI to equity (median) Pre-tax unrealized loss to equity (median)
Q1 2023-13.71%19.27%
Q2 2023-15.02%21.05%
Q3 2023-17.65%25.30%
Q4 2023-11.51%16.04%
Q1 2024-11.90%16.63%
Q2 2024-11.45%16.09%
Q3 2024-7.46%10.44%
Q4 2024-9.90%14.03%
Q1 2025-8.16%11.67%
Q2 2025-7.34%10.56%
Q3 2025-5.47%7.81%
Q4 2025-4.56%6.63%
Q1 2026-5.19%7.45%
Q2 2026-4.95%7.03%

Source: BankingLens, computed from FFIEC call reports. Medians across each quarter's FDIC-insured filers; the pre-tax column includes held-to-maturity securities.

The improvement came in steps, and not every quarter helped. The largest setback along the way was Q4 2024, when the AOCI median went from -7.46% to -9.90%; what remains still moves with longer-term market rates. For the last four quarters it has held between -4.56% and -5.47%. The upper quartile of the pre-tax measure has come in from 54.42% of equity at Q3 2023 to 16.77%.

Two things shrink these figures even when rates hold still. Bonds pull toward par as they near maturity, and a bank that sells an underwater available-for-sale bond realizes the loss, moving it out of AOCI and into retained earnings. The count of banks also fell from 4,660 to 4,237, so some of the change may reflect who is counted.

Unrealized losses by FFIEC peer group

FFIEC peer groups 1 to 8 are insured commercial banks sorted by size, so savings institutions aren't in the table. The figures are pre-tax, held-to-maturity bonds included.

Peer group Total assets Banks Lower quartile Median Upper quartile
1Over $100B296.11%10.09%15.54%
2$10B to $100B1143.06%6.87%12.34%
3$3B to $10B2272.33%6.82%14.68%
4$1B to $3B5292.47%7.19%15.61%
5$300M to $1B1,2732.52%7.87%18.44%
6$100M to $300M1,0802.24%7.83%19.78%
7$50M to $100M3201.12%6.28%15.73%
8Under $50M1330.31%1.46%10.06%

Source: BankingLens, computed from FFIEC call reports for the quarter ending June 30, 2026, on the FFIEC's current peer groups. Pre-tax unrealized loss to equity; higher is a bigger loss.

From group 2 through group 6 the median barely moves, 6.82% to 7.87% of equity, but each group is wide: in group 6 the lower quartile is 2.24% and the upper quartile 19.78%, so the quartiles, not the median, show where your bank stands.

Two groups stand apart. Commercial banks over $100 billion have the highest median, 10.09%, though the AOCI median for banks that size is -5.31%, close to the all-bank figure; the pre-tax measure counts held-to-maturity losses, which AOCI leaves out, before any tax offset. Banks under $50 million sit at 1.46%. Our data doesn't show why, but a bank that holds its liquidity in cash rather than bonds has little to mark.

What the capital opt-out covers, and what it doesn't

Banks that don't use the advanced approaches could make a one-time, permanent election to leave most AOCI out of regulatory capital; existing banks made it on Schedule RC-R of the March 31, 2015 call report (FDIC letter). For a bank that made it, most AOCI stays out of the capital ratios, and held-to-maturity losses were never in them.

For Category III and IV firms, $100 billion and up, that separation is under review. Proposals released March 19, 2026 would require them to recognize most AOCI in common equity tier 1, phased in over five years. Comments closed June 18, 2026, with no final rule as of this writing (Federal Reserve release).

Outside the ratios, the loss still shows up in four places.

None of it is hidden. Call reports for every bank are free on the FFIEC's Central Data Repository, so any analyst or large depositor can run the same RC-B arithmetic we do.

Frost Bank's AOCI

Frost Bank of San Antonio, the bank on our public sample scorecard, reported AOCI of -18.28% of equity, much deeper than the all-bank median of -4.95% and the -3.90% median for banks from $10B to $100B. Its loan-to-deposit ratio was 51.96%, and a bank that holds more of its balance sheet in securities carries more of this exposure. The scorecard's securities panel shows Frost's pre-tax measure, held-to-maturity included, ranked against its FFIEC peer group.

Frequently asked questions

What is AOCI for a bank?

Accumulated other comprehensive income is the part of a bank's equity capital that holds gains and losses that haven't gone through net income, mostly the after-tax unrealized gain or loss on available-for-sale securities. At June 30, 2026, the median FDIC-insured bank's AOCI was -4.95% of equity.

Do unrealized losses count against bank capital?

Available-for-sale losses reduce GAAP equity through AOCI; held-to-maturity losses generally don't. Banks not using the advanced approaches could make a one-time, permanent election to exclude most AOCI from regulatory capital. A March 2026 proposal would require Category III and IV firms ($100 billion and up) to recognize most AOCI in common equity tier 1, phased in over five years.

How much in unrealized losses do US banks have in 2026?

The FDIC put unrealized losses on investment securities at $326.7 billion in the second quarter of 2026, 5.5% of amortized cost, a pre-tax industry total. AOCI, which is after tax, came to -$156.6 billion across 4,237 banks. The median bank's pre-tax unrealized loss on all securities was 7.03% of equity.

What is the difference between AFS and HTM losses?

Available-for-sale (AFS) securities are carried at fair value, so their unrealized losses flow through AOCI after tax and reduce GAAP equity. Held-to-maturity (HTM) securities are carried at amortized cost, so their losses reach neither AOCI nor equity, apart from losses frozen when bonds were transferred from AFS. Schedule RC-B shows amortized cost and fair value for both.

Have bank unrealized losses gone away?

No, though they're far smaller than at their worst. The median bank's AOCI went from -17.65% of equity in Q3 2023 to -4.95% at June 30, 2026, and has held between -4.56% and -5.47% for four quarters. Still, 1,327 banks (31.3%) have AOCI worse than -10% of equity.

Where these numbers come from

Every BankingLens figure here is computed from FFIEC call reports for the quarter ending June 30, 2026, or the earlier quarters in the trend table; the FDIC total is quoted from its report. You can see these securities figures for a real bank, ranked against its FFIEC peer group, on the sample scorecard for Frost Bank. Plans that cover your state or every bank start at $29 a month (pricing).

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