BANKING RISK & COUNTERPARTY PLANNING · SEPTEMBER 19, 2026
Fed Review Highlights Concentration, Interest-Rate, and Liquidity Risk Lessons
The Federal Reserve’s initial independent-review findings on Silicon Valley Bank cite concentrated uninsured deposits, unrealized securities losses exceeding capital, and insufficient readiness to borrow from the discount window.
What the September 18 review reported
Source publication date: September 18, 2026. Vice Chair for Supervision Michelle W. Bowman announced initial findings from an independent review of the March 2023 failure of Silicon Valley Bank. The remarks state that the Starling Advisory Group’s report is the first in a series and that the views expressed are Bowman’s own. The findings concern one failed institution and the supervisory response; they should not be generalized to every bank.
- 01Deposits were highly concentrated
- 02Securities losses exceeded capital
- 03Liquidity readiness proved inadequate
The review identified a combination of vulnerabilities
Bowman said the review found that SVB had unrealized accounting losses on its securities portfolio that exceeded capital, a deposit base that was 94% uninsured and concentrated in venture-capital-backed technology companies, and inadequate operational readiness to borrow from the Federal Reserve’s discount window when needed. The review also concluded that supervisory staff knew or should have known about material vulnerabilities by March 2022 but did not act promptly enough to require mitigation.
Supervisory escalation is part of the response
The remarks describe supervisory operating principles focused on material safety-and-soundness threats and earlier, proportionate action. Bowman also said examination teams will submit monthly reports that flag uncertainty about potential supervisory action so leadership can clarify standards and escalation. These process changes concern oversight of banks; they do not create a new deposit guarantee, commercial loan entitlement, or prediction about a particular institution.
Practical borrower and investor takeaway
Review operating, payroll, tax, escrow, reserve, and investment cash by legal owner, institution, account type, and insurance category with qualified treasury, legal, and accounting advisers. Understand access rights, sweep arrangements, pledged-account restrictions, transfer limits, backup payment methods, and the time needed to move or replace a banking relationship. Maintain a current bank-contact and liquidity contingency plan. Deposit concentration controls do not replace borrower cash-flow planning, and the review does not imply that all uninsured balances or banks carry the same risk.
Businesses and investors should review where operating cash is held, understand deposit-insurance and counterparty exposure, preserve payment continuity, and avoid treating any bank’s brand or size as a substitute for treasury controls.
Discuss a financing need →This independent summary is based on the cited source and is provided for general educational purposes only. Terms and program requirements may change.