FoFi Risk Intelligence — $100M–$250M Early-Warning Read (Q4 2025)
NCUA Call Report Early-Warning Series

Where Growth Is Outrunning Credit Discipline in Smaller Credit Unions

An early-warning read on the $100M–$250M asset band, three to four quarters out, as of the Q4 2025 call report.

This note reads the deterioration signal building in the peer cohort of federally insured credit unions holding $100M to $250M in assets — 678 institutions, measured against the December 31, 2025 call report. It is a directional analysis: we do not name individual credit unions, but describe where the cohort is leaning three to four quarters ahead.

The read covers the specific, directional risk themes the early-warning system tracks for this cohort — growth, asset quality, portfolio, earnings, liquidity, and efficiency — where the forward signal is most separable and the raw-metric corroboration is strongest. Every theme below carries strong raw-metric evidence: the modeled risk direction is confirmed by the institutions’ own reported NCUA metrics for roughly four-fifths or more of flagged cases. One target under validation review is excluded.

A note on reading the figures: the theme shares are independent, overlapping signals, not a breakdown of a whole. A single credit union can screen elevated on more than one theme, so the percentages are not mutually exclusive and do not sum to the cohort.


01 What we are observing now

This band leans differently from larger community credit unions. The clear lead is growth / expansion stress, elevated for roughly 25% of the cohort as of Q4 2025 — followed closely by asset quality (≈17%) and portfolio deterioration (≈17%), then earnings (≈16%). Liquidity sits lower here (≈13%) than in larger bands — smaller balance sheets carry less wholesale-funding sensitivity, so funding is not the lead risk.

The read is one of growth quality: in smaller institutions the forward signal concentrates where expansion is running ahead of underwriting and reserve build, and where credit-quality and portfolio metrics are already beginning to confirm it. This is a credit-cycle posture, not a funding-structure posture.

Theme prevalence
Figure 1. Share of the $100M–$250M cohort screening elevated by risk theme, Q4 2025. Growth/expansion stress leads, with asset quality and portfolio close behind. Shares are independent and overlapping; they do not sum to the cohort.

02 Why it matters for balance sheet and P&L

Growth quality. The lead signal pairs rapid member-, asset-, and loan-growth with rising charge-off and delinquency context. Fast growth is not itself a problem; growth that outruns underwriting standards and reserve build is. For a $100M–$250M institution, a single fast-growing segment can shift the credit profile of the whole book within a few quarters.

Asset quality and portfolio. The near-tied second-tier themes reflect credit deterioration already surfacing — net charge-off and delinquency rates, allowance coverage, and segment-level delinquency moving off-peer. On the income statement the proximate drag appears through operating-expense-to-assets, provisioning, and ROA.


03 What near-term risk this points to

At the T3/T4 horizon (three to four quarters from the Q4 2025 cycle) the cohort’s lean points to a sequence:

  1. Growth quality first — the lead theme; expansion outrunning underwriting and reserve build is the earliest-firing pattern in this band.
  2. Asset-quality and portfolio confirmation second — net charge-off, delinquency, and segment-level credit metrics begin to surface the deterioration, already visible in this cohort.
  3. Earnings drag third — provisioning and efficiency pressure convert credit deterioration into thinner margins.

This is a credit-cycle vulnerability read, not a distress call: a meaningful slice of the band is expanding in a way that a normal credit cycle would test more than peer-median institutions.


04 Historical validation and model evidence

The signals come from gradient-boosted and glass-box models selected through a governed champion-selection process. Across the themes in scope, held-out discrimination is strong: validation AUC runs from the high-0.70s to low-0.90s (median ≈0.82), KS in the 0.4–0.7 range (median ≈0.50), and top-decile lift between 2.6× and 4.5× (median ≈3.5×), with score-population stability (PSI) green on every model.

AUC versus lift scatter
Figure 2. Each marker is one early-warning model (11 models across 7 themes): held-out AUC against top-decile lift, colored by model confidence tier, sized by KS. All sit right of the 0.75 strong-discrimination line.
What “strong evidence” means here, and its limit. The strong-evidence designation reflects raw-metric corroboration: across these themes, the institutions’ own reported NCUA metrics confirm the modeled risk direction — through deteriorating trends, off-peer position, and supportive macro context — for roughly 81–89% of flagged cases. Separately, multi-window out-of-time backtesting is still accruing; for most themes there are too few out-of-time quarters yet for a stability verdict, and the development sample spans a comparatively benign macro period. We treat the validation metrics as evidence of discrimination and the corroboration rates as evidence of raw-metric support — not as calibrated probabilities of loss.
Table 1. Model card by theme — held-out discrimination for the early-warning models, T3/T4 horizon (range shown where a theme has more than one model).
Risk themeHorizonValidation AUCKSTop-decile liftModel confidence
Growth / expansion stressT40.810.45–0.463.4×High
Asset qualityT40.860.554.4×High
Portfolio deteriorationT40.770.403.0×Strong
Earnings stressT40.80–0.890.47–0.623.2–3.8×High
Liquidity pressureT3–T40.76–0.850.38–0.542.6–3.6×Strong High
Management efficiencyT40.82–0.920.50–0.693.5–4.5×High
Composite risk signalT40.910.674.0×High

05 Current-cycle screen

Against the December 31, 2025 call report, across the 678-institution band, growth/expansion stress is the dominant theme, followed by asset quality and portfolio deterioration in a near tie. Unlike the larger asset bands, liquidity is not the lead risk here — it screens elevated for only about an eighth of the cohort. Raw-metric corroboration is high across themes — between roughly 81% and 89% of flagged cases confirmed — which supports the strong-evidence designation for this cycle.

The macro overlay reinforces the read: across the state-quarters in scope, labor-market pressure is the modal macro context (the majority of state-quarters), with a minority showing broader systemic pressure or housing-momentum softening. Macro context supports the risk story far more often than it contradicts it.

Table 2. $100M–$250M band risk lean by theme, Q4 2025 — elevated share, separation, raw-metric corroboration, and model confidence. Shares are independent and do not sum to the cohort.
Risk themeElevatedTop-decile cutoffConfirmed evidenceModel confidence
Growth / expansion stress25.4%0.17689.1%High
Asset quality17.1%0.21284.3%High
Portfolio deterioration17.0%0.21784.3%Strong High
Earnings stress15.5%0.20585.3%High
Liquidity pressure12.8%0.23281.0%Strong High
Management efficiency11.7%0.10084.6%High
Composite risk signal11.2%0.28980.7%High

06 Raw metrics supporting the signal

The model direction is corroborated by these reported call-report metrics, the most frequently deteriorating across flagged institutions in this cycle:

  • Growth quality: member-, asset-, and loan-growth running ahead of peers, paired with allowance-to-delinquent-loans and net charge-off context.
  • Asset quality: net charge-off, total and 60–179-day delinquency rates, allowance coverage — already surfacing in this band.
  • Portfolio: segment-level delinquency and charge-off (used-auto, other real estate) and intermediate income and charge-off flows.
  • Earnings / efficiency: operating-expense-to-assets and cost-to-income elevated; ROA soft.
  • Liquidity (secondary): loans-to-shares and cash-to-assets — present but not the lead cluster in this band.

The lead corroboration is growth-quality and credit performance — which is why a forward model adds value: it flags the expansion posture before the credit metrics fully confirm.


07 Model drivers

The features carrying the most weight are overwhelmingly peer-relative and percentile-based, not raw levels — the models flag institutions that are off-peer, not merely large or small:

  • Growth: member-, asset-, and loan-growth levels with state-level deterioration context, plus loan-to-share and portfolio-concentration dynamics relative to peers.
  • Asset quality: total delinquency and net charge-off relative to peers and as state percentiles, with allowance-coverage context.
  • Portfolio: used-auto and other-real-estate delinquency dynamics relative to peers, and intermediate income and charge-off flows.
  • Earnings & efficiency: operating-expense-to-assets, ROA peer percentiles, cost-to-income asset-band percentiles, and a negative-ROA flag.
  • Liquidity: loans-to-shares and cash-to-assets relative to peers — a secondary driver in this band.

The recurring theme is relative position — growth and credit metrics measured against peer group and state — which makes the signal portable across the band rather than an artifact of any one institution.


08 Practical implications

For the CRO

The lead risk in this band is growth quality, not funding. The usable question is whether loan and asset growth are running ahead of the peer band while allowance coverage and charge-off context move the wrong way — that combination is where the model concentrates its forward signal, confirmed by raw metrics in the large majority of flagged cases.

For lending leadership

This is the front line for this cohort. Underwriting standards and reserve discipline in the fastest-growing segments are the most direct response to a forward growth-stress flag — particularly where asset-quality and portfolio metrics are already beginning to confirm.

For the CFO

Model the provisioning path: if growth continues at the current pace and the credit-quality drift in the book continues, what does the reserve build do to the earnings and net-worth trajectory over the next three to four quarters? At this size, that is the highest-leverage scenario.

For the board

Frame it forward and probabilistic. The models discriminate well (AUC ≈0.82 median, lift ≈3.5×) and the institutions’ own reported metrics corroborate the direction for roughly four-fifths or more of flagged cases — strong raw-metric support — though full-cycle backtesting is still accruing and these remain discrimination signals, not calibrated loss probabilities. As of Q4 2025, growth running ahead of credit discipline is the clearest forward risk in the $100M–$250M peer cohort, visible three to four quarters before credit metrics fully confirm.

Methodology: Signals derive from NCUA call-report data through the December 31, 2025 cycle, modeled at the credit-union/quarter grain with forward targets at the three- and four-quarter horizon. Reported AUC, KS, and top-decile lift are held-out validation metrics; out-of-time backtesting is ongoing. “Strong evidence” denotes model direction corroborated by raw reported metrics — trend, peer position, and macro context — for the large majority of flagged cases. Theme shares are independent and overlapping and do not sum to the cohort. This analysis is directional and cohort-level; it does not identify individual institutions and is not investment, legal, or supervisory advice.

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