The Federal Financial Institutions Examination Council (FFIEC) continues to refine one of its most critical supervisory tools — the Uniform Bank Performance Report (UBPR). Through its Task Force on Surveillance Systems, the FFIEC has rolled out meaningful enhancements in 2025 and 2026 that give banks and examiners greater insights into liquidity risk, funding profiles, and peer comparisons.
These changes are part of an ongoing multi-year content review designed to keep the UBPR relevant amid evolving risks and regulatory priorities. Here’s what community and regional banks need to know.
Why These Updates Matter Now
Liquidity and interest rate risk remain top supervisory concerns following the 2023 regional bank stresses. The FFIEC is responding by expanding the analytical depth of the UBPR — particularly on the liquidity pages — but hopefully without imposing new reporting burdens on banks.
The UBPR remains a derived report based on existing Call Report data. Banks do not need to submit anything new. However, the way performance and risk are measured and benchmarked is becoming more granular.
Key Updates Banks Should Know
1. Major Expansion of Liquidity Pages (Effective February 17, 2026)
This is the most significant recent change. The FFIEC substantially enhanced Liquidity & Funding (Page 10) and Liquidity & Investment Portfolio (Page 10A).
- Added approximately 58 new concepts and ratios (bringing the total liquidity-related items on these pages to 102).
- New visibility into liquid assets at fair value, uninsured deposit estimates, maturity bucketing of borrowings and brokered deposits, wholesale funding growth trends (1-, 2-, and 3-year), securities portfolio composition relative to Tier 1 capital, and more.
- Greater ability to analyze net liquidity positions after subtracting wholesale funding and to assess funding stability over time.
Bottom line: Examiners now have significantly more detailed tools to evaluate liquidity risk. Banks that proactively monitor these new metrics will be better positioned heading into exams.
2. New Wholesale Funding + Public Funds Ratio (Effective ~August 10, 2026)
On the Liquidity & Funding page, the FFIEC introduced a new ratio: “Wholesale Funding + Public Funds to Total Assets.”
This broader measure combines traditional wholesale funding sources with deposits from states and political subdivisions. It provides a more comprehensive view of funding that may be less stable or more rate-sensitive than core retail deposits.
3. Simplified Peer Groups for Smaller Banks (Effective February 26, 2026)
For commercial banks with average assets up to $300 million, peer groups are now based solely on asset size. The FFIEC removed the previous criteria around number of banking offices and metropolitan statistical area (MSA) location.
Why this matters: Many smaller peer groups had become too small to produce reliable averages. The change should result in more meaningful and statistically sound peer comparisons for community banks.
4. Ongoing Title Cleanups and Formatting Improvements
The July 2026 update also aligned loan category titles across multiple UBPR pages with current Call Report terminology. While cosmetic, these changes reduce potential confusion when comparing reports over time.
What These Changes Do NOT Mean
- No new Call Report or regulatory reporting requirements
- No direct change to capital, liquidity (LCR/NSFR), or interest rate risk regulatory standards
- Limited immediate operational impact for most banks.
Recommended Actions for Banks
Banks should consider taking the following steps in the coming months:
- Review the updated liquidity pages in detail once the new ratios populate.
- Discuss the new metrics in ALCO meetings — particularly the expanded wholesale funding and uninsured deposit analysis.
- Update internal liquidity monitoring dashboards or reports to incorporate relevant new UBPR ratios where they add value.
- Revisit peer group comparisons, especially for banks under $300 million in assets, to understand how your positioning may shift.
- Use the enhanced data as part of board-level risk reporting and exam preparation.
The Bigger Picture
These UBPR enhancements reflect the FFIEC’s continued focus on giving both supervisors and bank management better tools to identify emerging risks early. While the changes are evolutionary rather than revolutionary, the increased granularity around liquidity and funding is meaningful in the current environment.
For the latest details, visit the official FFIEC UBPR Latest Updates page. Institutions that want help interpreting the new ratios or integrating them into their risk management framework should reach out to their compliance or risk management advisors.
