Deception And Truth Analysis of S&P 500 Banks

The center of gravity of the business press has been centered on global banks for the last several weeks. Attention was, of course, diverted here due to the seizure by regulators of Silicon Valley Bank on 10 March 2023. Investors are rightly concerned with the capital quality of banks given the twin pressures of rising interest rates and inflation. It seems an appropriate time then for a Deception And Truth Analysis of S&P 500 Banks.

Before presenting our insights, several points about why our work matters. At Deception And Truth Analysis we have found that our analyses tend to be predictive of future business outcomes, whether that is outperformance/ underperformance and sometimes, sadly, scandal. Our theory about that is that numbers are outcomes driven by management choices, and in turn those choices are driven by the behavior of company management. In other words, behaviors drive outcomes.

Next, as demonstrated in our Case Study: Silicon Valley Bank we found that going back at least six quarters that the most deceptive fragments of the company’s 10(q)s and 10(k)s were about their: net interest income, their loan portfolio, and the inputs into their risk model. Because these were the most deceptive fragments, and the most deceptive fragments had consistent themes dating for many quarters, it is unambiguous evidence that Deception And Truth Analysis is able to provide you with difference making insights before the market fully appreciates issues.

Here are the details of our analysis:

1. Currently, there are sixteen banks in the S&P.
2. At the time of this writing, three of the banks have yet to issue their 2022 10(k). Those companies are: Bank of America, PNC Financial Services Group, and Zions Bancorporation.
3. Deception And Truth Analysis (D.A.T.A.) Scores range between -100% and +100% with any negative score indicating a level of deceptiveness and any positive score indicating a level of truthfulness. D.A.T.A. Scores are roughly normally distributed with a mean of 4.9% and a standard deviation of 13.2%.
4. In terms of the distribution, 61.6% of documents score in the aggregate as truthful, with 38.4% scoring in the aggregate as deceptive. This comports well with independent research that finds a similar proportion of problematic company reports.
5. Our double-blind, scientifically tested accuracy at assessing deception and truth in written texts is 88.4% with a Type I error rate of 11.3% and a Type II error rate of 14.3%.
6. Our method for assessing deception looks at howlanguage is used, not what language is used. The advantage of this method is that we believe our algorithm is a general deception detection algorithm and is performant in many different settings. The disadvantage is that we need an adequate sample size to ensure statistical significance of our D.A.T.A. Scores. Thus, in our discussion below where we share the themes present in the S&P 500 bank’s most deceptive document fragments, we are not saying that each theme is deceptive. Instead, we are saying that each of these themes is present within the sample that was assessed by us as deceptive.
7. For the sixteen banks below the average D.A.T.A. Score for their documents is 1.80%, with 8 scoring as truthful in the aggregate and with an average D.A.T.A. Score of those documents of 10.59%; and 8 documents score as deceptive in the aggregate with an average D.A.T.A. Score of -6.99%.

In alphabetical order here are the S&P 500 banks’ D.A.T.A. Scores and our disclosure about each bank’s most deceptive fragment, and the contents of those fragments [Note: if you would like access to the deceptive fragments let us know and we are happy to provide you with those details.]. As you can see below some of the themes transcend individual documents and companies and seem to be industry-level issues.

Bank of America

Document: 10/28/22 10(q)

D.A.T.A. Score: -25.08%

Most deceptive document fragment:

D.A.T.A. Score: -78.44%

Themes: Net interest income, non-interest income, provisions for credit losses, non-interest expense, return on average allocated capital, deposits’ performance indicators, consumer investment assets, and net income from consumer lending.

Citigroup

Document: 2/27/2023 10(k)

D.A.T.A. Score: -3.91%

Most deceptive document fragment:

D.A.T.A. Score: -73.56%

Themes: Net credit losses, reclassification of loans, capital ratio, supplementary leverage ratio, ICG net income, ICG revenues, services revenues, markets revenues, banking revenues, PBWM net income, PBWM revenues, and US personal banking.

Citizens Financial Group

Document: 2/16/2023 10(k)

D.A.T.A. Score: +6.20%

Most deceptive document fragment:

D.A.T.A. Score: -59.02%

Themes: Non-interest expense, net charge-offs, securities portfolio, the fair value of the debt securities portfolio, amortized cost basis of the HTM portfolio, the securities portfolio’s duration and convexity risk, total loans and leases, allowance for credit losses, the NCO ratio, commercial portfolio, commercial criticized balances, commercial and industrial criticized balances, and commercial real estate criticized balances.

Comerica

Document: 2/14/2023 10(k)

D.A.T.A. Score: -3.71%

Most deceptive document fragment:

D.A.T.A. Score: -60.65%

Themes: Management accounting system, net interest income, the Funds Transfer Pricing (FTP) methodology, FTP crediting rates, FTP charge rates, business segment performance, loan portfolio, and deposits.

Fifth Third Bancorp

Document: 2/24/2023 10(k)

D.A.T.A. Score: -4.75%

Most deceptive document fragment:

D.A.T.A. Score: -70.04%

Themes: Effective risk management, Enterprise Risk Management Framework, how their risk appetite is determined, risk appetite principles, risk categorization, process for managing risk, and its Three Lines of Defense structure.

Huntington Bancshares

Document: 2/17/2023 10(k)

D.A.T.A. Score: +2.99%

Most deceptive document fragment:

D.A.T.A. Score: -46.61%

Themes: Board Committees, including the Audit Committee, Risk Oversight Committee, Technology Committee, and Human Resources and Compensation Committee; Enterprise Risk Management and Risk Appetite Framework; key risk indicators; executive level committees to manage risk; and three lines of defense with regard to risk management.

JP Morgan Chase

Document: 2/21/23 10(k)

D.A.T.A. Score: -4.32%

Most deceptive document fragment:

D.A.T.A. Score: -59.74%

Themes: Changes in Basel III capital, changes in the components of RWA under Basel III, model & data changes, movement in portfolio levels, components of the firm’s SLR, off-balance sheet exposures, how business segments are allocated capital, dividend payouts, and suspension of share repurchases.

Keycorp

Document: 2/22/2023 10(k)

D.A.T.A. Score: +6.57%

Most deceptive document fragment:

D.A.T.A. Score: -53.86%

Themes: Regulatory capital requirements, how capital instruments are assigned to tiers under Basel Committee, market risk capital framework, narrative around Basel III and why it was created, how the additional capital requirements under Basel III for large banking organizations do not apply to the company, Stress Capital buffer, the federal prompt corrective action framework established under the FDIA groups FDIC-insured depository institutions, and the five different capital categories.

M&T Bank

Document: 2/22/2023 10(k)

D.A.T.A. Score: -2.91%

Most deceptive document fragment:

D.A.T.A. Score: -62.25%

Themes: Costs associated with data processing, risk management, and other support services; the Discretionary Portfolio segment and its assets; reasons for the decline in net income; net interest income; Residential Mortgage Banking segment; and the Retail Banking segment. 

PNC Financial Services Group

Document: 11/2/2022 10(q)

D.A.T.A. Score: -0.70%

Most deceptive document fragment:

D.A.T.A. Score: -52.29%

Themes: Real Estate segment, Commercial Banking segment, the deposit strategy of Corporate & Institutional Banking, average total deposits, the 2021 BBVA acquisitions, revenues and expenses of newly acquired companies, Treasury Management business, Commercial mortgage banking, capital markets related products, and the Asset Management Group along with its two primary businesses of PNC Private Bank and Institutional Asset Management. 

Regions Financial Corp.

Document: 2/24/2023 10(k)

D.A.T.A. Score: +8.97%

Most deceptive document fragment:

D.A.T.A. Score: -51.50%

Themes: The markets in which Regions competes, deposits, non-interest bearing demand deposits, savings accounts, certificates of deposit, the estimated uninsured deposits, long-term borrowings, and “Credit Ratings” of the bank.

SVB Financial Group

Document: 2/24/2023 10(k)

D.A.T.A. Score: +11.83%

Most deceptive document fragment:

D.A.T.A. Score: -49.77%

Themes: Investment products, client investment fees, wealth management and trust fees, foreign exchange fees, credit card fees, deposit service charges, lending related fees, investment banking revenues, commissions, other noninterest income, and employee compensation.

[Note: In SIVB’s second and third most deceptive fragments in this 10(k) and in its many previous years documents, the most deceptive fragments were unambiguously about their net interest income, their asset portfolio, and the assumptions baked into their risk management model. See our full writeup Case Study: Silicon Valley Bank for details.]

Truist Financial Corp

Document: 2/28/2023 10(k)

D.A.T.A. Score: +1.57%

Most deceptive document fragment:

D.A.T.A. Score: -64.63%

Themes: Risk-taking, compensation plans, the company’s purpose-mission-values as the basis for their risk management, risk management oversight, its three lines of defense in managing risk, the executive level committees that weigh in on risk management, types of risks the bank faces, effective management of market risk, risk management objectives, and interest rate risk.

US Bancorp

Document: 2/27/2023 10(k)

D.A.T.A. Score: +18.66%

Most deceptive document fragment:

D.A.T.A. Score: -29.02%

Themes: Minimum effective [Basel III] ratios, discussion around the calculation of risk-weighted assets, the effect of proposed new Basel standards on the bank and USBNA, current expected credit loss accounting standards, the 2022 stress test cycle, Comprehensive Capital Analysis and Review rules, and stress-testing under CCAR and Dodd-Frank.

Wells Fargo & Company

Document: 2/21/2023 10(k)

D.A.T.A. Score: +27.91%

Most deceptive document fragment:

D.A.T.A. Score: -6.80% [Note: Wells Fargo & Company uses “hereby incorporated by reference” language through much of its 10(k) filing. Thus, its document as evaluated in our DATAbase product is less comprehensive.]

Themes: Capital requirements, subsidiaries insured by the FDIC, the FDIC and its Deposit Insurance Fund, the effect of termination of the FDIC’s DIF on the company, disclosures by banks about consumers’ information, Sarbanes-Oxley Act, the USA Patriot Act, and a discussion about the increase in the amount legislation and regulation in the United States.

Zions Bancoporation

Document: 11/3/22 10(q)

D.A.T.A. Score: -10.57%

Most deceptive document fragment:

D.A.T.A. Score: -53.27%

Themes: A transfer of $9.0 billion of amortized cost of pass-through mortgage-backed AFS securities to the HTM category, their products sold to state and local governments, investments in municipalities, the collateral backing their municipal portfolio, internal risk grades assigned to the municipal portfolio, the ratio of loans and leases to total assets, the loan and lease portfolio, non-interest bearing securities, changes in premises-equipment-software, a project to replace their core loan and deposit banking systems, deposits, and risk-management policies.