Decide · study, back-test or both

Core deposit study every three years, or a back-test every quarter?

A core deposit study sets a bank's deposit assumptions from its own history: decay rates, betas, average lives and the core share of each account type. Nothing in the rules makes it the only evidence; they ask that assumptions be supported, documented and back-tested. This guide sets out what a study measures, how a quarterly back-test differs, and a 30-day pilot with Interest Rate Risk (IRRBB) Management that shows whether you need a new study now.

Updated · 12 min read

A core deposit study is an analysis of an institution's own account history that estimates how its non-maturity deposits behave: what share is stable "core" money, how fast balances run off (decay), how much of a market rate change is passed to depositors (beta), and the resulting average life of each account type. Its outputs become the deposit assumptions in the ALM model. A study is usually commissioned every few years; a back-test checks every quarter whether depositors still behave the way the last study said. The regulators require supported, documented and tested assumptions, not a study on a fixed cycle, so the practical question is when the evidence says the study has gone stale. Botminds' Interest Rate Risk (IRRBB) Management answers it by back-testing every assumption each quarter on your own extracts.

The examples come from a fictional sample credit union in the solution, Norrell Federal Credit Union. Durations for the pilot are design targets, not a customer's measured result.

What a deposit study is asked to carry

8

kinds of analysis the OCC lists as typical support for deposit assumptions, from decay vintages to seasonality

10yrs

of observed volume changes the Basel standardised framework uses to separate stable from non-stable deposits

1/yr

minimum review of key assumptions for reasonableness in the OCC booklet; more often when markets move fast

30days

design target for a pilot that back-tests last year's assumptions on your own extracts

OCC Comptroller's Handbook, Interest Rate Risk (2020), request letter item 20 and 'Assumption Governance'; BCBS, Interest rate risk in the banking book (2016), paragraph 112; the pilot length is a design target for Interest Rate Risk (IRRBB) Management.Source: OCC booklet; BCBS IRRBB standard

What is a core deposit study?

A core deposit study is a historical analysis of the institution's own deposit accounts, used to set and support the behavioural assumptions its interest rate risk model needs for deposits that have no maturity. The OCC lists it first among the sources for assumptions: "a historical trend analysis of portfolio and individual account behavior (i.e., deposit studies)" (OCC Comptroller's Handbook, Interest Rate Risk). A study may be built in-house or bought from a third party; either way it is the institution's assumption once the model uses it.

"Core" has a specific meaning. The Basel Committee's standard defines core deposits as "the proportion of stable NMDs which are unlikely to reprice even under significant changes in the interest rate environment", and asks banks to separate the stable and non-stable parts of each category "using observed volume changes over the past 10 years" (BCBS, Interest rate risk in the banking book, 2016). A community bank is not bound by that method, but it describes the question every deposit study answers: how much of this money is really staying, and on what terms.

What does a core deposit study measure?

A core deposit study measures, for each type of non-maturity account, how balances and accounts run off over time, how deposit rates moved relative to market rates, and how those patterns differ by segment and season. The OCC's examination request letter describes the expected support for deposit assumptions in one sentence: it "typically includes a historical trend analysis, a decay vintage analysis, driver rate sensitivity (beta), a segmentation analysis, a regression analysis, demographic analysis, seasonality, and market competition" (OCC booklet, request letter item 20).

What a core deposit study measures, and which assumption each part supports

AnalysisWhat it measuresAssumption it supports
Historical trend analysisHow balances of each account type moved over several rate cyclesCore share and overall stability
Decay vintage analysisHow accounts opened in each period ran off, cohort by cohortDecay rate and average life
Driver rate sensitivity (beta)How much of a market rate move reached the deposit rateDeposit beta, rising and falling rates
Segmentation analysisBehaviour by balance tier, customer type, channel or productSeparate assumptions per segment
Regression analysisThe statistical link between rates and balances or pricingBeta and rate-dependent decay
Demographic analysisAge, tenure and relationship depth of depositorsStability of the base
SeasonalityRegular swings in balances within a yearSeparating seasonal flows from runoff
Market competitionCompetitors' rates and the institution's positionWhether past behaviour will hold
The eight analyses are listed in the OCC Interest Rate Risk booklet, request letter item 20; the descriptions in the last two columns are ours.Source: OCC Interest Rate Risk booklet

Two inputs from the OCC's reporting expectations are often missing from studies and matter most when rates rise. The booklet asks for reports that track "accounts opened in certain periods and how they have acted (vintage analysis)" and "accounts added during published promotions and how they behaved after the promotions ended." A study fitted only to aggregate balances cannot tell a promotional inflow that will leave from a core balance that will stay.

Do examiners require a deposit study?

No rule requires a deposit study by name or on a fixed cycle. What the regulators require is that deposit assumptions be reasonable, supported by the institution's own data where possible, documented, and tested against what happened. For credit unions, NCUA's appendix asks management to "rely on assumptions that are reasonable and supportable" and to "document any changes to assumptions based on observed information" (12 CFR Part 741, Appendix A). For banks, the OCC's examination procedures ask "whether management performs any analysis on the bank's deposit base to support the NMD assumptions", with deposit studies named as one of the information types.

The regulators are wary of borrowed assumptions. The FDIC says management "should use NMD assumptions that reflect institution-specific factors and avoid overreliance on industry estimates or default assumptions contained in off-the-shelf IRR models", because industry averages "are often not the most accurate estimates because they are not tailored to the bank's products, pricing strategies, market, and experience" (FDIC RMS Manual 7.1). The 2012 interagency FAQ allows industry estimates as "a starting point until sufficient internal data sets can be developed", adds that an institution "can contract with an outside vendor to assist", and closes the answer with the rule that covers studies too: "For any key assumptions, back-testing should be performed to determine whether assumption estimates are reasonable" (Interagency IRR FAQ, 2012, question 11).

So a study is one acceptable way to support deposit assumptions, and often the best way to set them. It is not evidence that they still hold. That evidence is the back-test.

How often should a deposit study be updated?

No regulator sets a cycle for deposit studies; what they set is a cycle for reviewing assumptions. The OCC asks for key assumptions to be evaluated at least once a year, and more often when markets move fast or something material changes. The FDIC asks for the process behind material assumptions to be assessed at least annually for critical ones. A study done every three years can satisfy that only if the years in between include a documented check that the study still describes depositors.

A study can also be the problem rather than the answer. The Federal Reserve's review of Silicon Valley Bank found that in April 2022 the bank "made a poorly supported change in assumption to increase the duration of its deposits based on a deposit study conducted by a consultant and in-house analysis" (Federal Reserve, SVB review, April 2023). A new study that lengthens deposit lives just as rates rise deserves more challenge, not less. What happened next is told in SVB's gap assessment against the 2010 advisory.

How much does a deposit study cost?

We have found no public, independent source for what a core deposit study costs, and providers price them differently, so this page does not quote a figure. A buyer can compare offers on what they deliver rather than the headline price: which of the eight analyses above are included, how many account types and segments, how many years of data, whether the provider re-tests the assumptions afterwards, and what the next refresh costs.

The cost that is easier to see is internal. On our estimate for the sample credit union, taking one broken assumption from back-test to a cited memo in front of the validator takes about 15 business days by spreadsheet and email; the solution's design target is about two. An institution that back-tests only once a year before the exam pays that cost rarely and discovers broken assumptions late. One that back-tests every quarter needs the cost to be small, which is the case for automating the back-test rather than buying studies more often.

A study and a quarterly back-test, side by side

A study and a back-test answer different questions: the study asks what depositors' behaviour is, from years of history; the back-test asks whether last year's depositors did what the study said. Most institutions need both, at different frequencies.

A core deposit study sets the promise; a back-test checks it

Core deposit studyQuarterly back-test
Question

Core deposit study: What are our deposit decay rates, betas and core shares?

Quarterly back-test: Did depositors do what the current assumptions said?

Data

Core deposit study: Several years of account history, ideally across rate cycles

Quarterly back-test: The last twelve months, on a fixed cohort, tied to the general ledger

Frequency

Core deposit study: Every few years, or after a material change

Quarterly back-test: Every quarter, on a calendar

Output

Core deposit study: A set of assumptions with their support

Quarterly back-test: For each assumption: held, drifting or broke, with causes and the NEV and NII impact

Strength

Core deposit study: Statistical depth; segments; rising and falling rates

Quarterly back-test: Speed; sees a change in behaviour within a quarter

Weakness

Core deposit study: Describes the past; may lag a fast market

Quarterly back-test: One year of data; cannot by itself set a new long-run value

What it triggers

Core deposit study: An assumption change through review and ALCO

Quarterly back-test: A re-affirmation, a change memo, or a decision to commission a study

Our comparison. The regulators accept both as support for assumptions; the 2012 interagency FAQ asks that key assumptions be back-tested whatever their source.Source: Interagency IRR FAQ, 2012

Interest Rate Risk (IRRBB) Management: every assumption, every quarter, with escalations

Back-test calendar: 28 assumptions by six quarters from Q3 2025 to Q4 2026, each cell coloured kept, drifting, broke, waiting or scheduled, with the next back-test on January 19, 2027 on the Q4 2026 extracts. Regular share decay was kept in Q3 and Q4 2025, drifting in Q1 and Q2 2026 and broke in Q3 2026; certificate dividend beta shows the same pattern; money market share decay and certificate renewal rate are drifting; HELOC line utilization is waiting in Q3 2026. An escalations panel lists regular share decay and certificate dividend beta escalated to the CFO on October 19 with the Supervisory Committee notified, and two assumptions drifting two quarters running with comments due November 2. A coming-up list shows the October 27 ALCO, the NCUA examination beginning November 9 and the board IRR report on November 17.
In the sample, the two assumptions that broke in the third quarter had drifted for the two quarters before. A study on a three-year cycle would not have seen the drift; a quarterly back-test saw it twice before it broke.

Can you back-test deposit assumptions without a study?

Yes. A back-test needs your own account-level extracts, the assumptions the model currently uses and a method for each; it does not need a new study. The FDIC describes the discipline as assumption variance analysis: institutions "should have formalized procedures for periodically identifying material differences between assumed and realized values", and "key assumptions should be checked against actual behaviors on a regular basis." Nothing in that requires an outside engagement.

What a back-test needs is data that most institutions already hold but rarely assemble: the core and loan servicing extracts at the start and end of the period, the general ledger balances to tie them to, and the assumption set with the study or analysis behind each value. The checklist below is what Interest Rate Risk (IRRBB) Management asks for on day one of a pilot.

What you need to back-test last year's deposit assumptions

  1. Core extracts at the start and end of the year

    Regular shares or savings, share drafts or checking, money market and certificates, at account level.

  2. Loan servicing extracts for the same dates

    Auto, mortgage, HELOC, credit card and business loans, for prepayment and utilisation assumptions.

  3. General ledger balances for both dates

    Every extract is tied to the general ledger before anything is measured.

  4. The assumption set the model used, and when ALCO approved it

    The promise being tested, value by value.

  5. The deposit study or analysis behind each value

    Including how it measured decay: by balances or by accounts.

  6. Product and promotion calendar for the year

    So a promotion's inflow and outflow can be separated from core behaviour.

  7. The interest rate risk policy and its limits

    So each broken assumption is priced against the limits it affects.

As requested by Interest Rate Risk (IRRBB) Management. Member names and account numbers are masked, and BSA fields are removed before any agent reads an extract.

A 30-day pilot on last year's data

The cleanest way to decide between a new study and a quarterly back-test is to back-test last year's assumptions on last year's data and look at the result. A closed year has a known answer, so the pilot also tests the tool: its numbers should match what your own team would compute for the assumptions you already know well.

A 30-day pilot on a closed year, week by week (target)

Pilot on last year's extracts30 days
Extracts in, tied to the general ledgerdays 1–7
Every assumption back-testeddays 8–14
Re-runs and causesdays 15–20
Memos and validator challengedays 21–25
Readout and study decisiondays 26–30
  • Extracts in, tied to the general ledgerdays 1–7
  • Every assumption back-testeddays 8–14
  • Re-runs and causesdays 15–20
  • Memos and validator challengedays 21–25
  • Readout and study decisiondays 26–30
Design target for Interest Rate Risk (IRRBB) Management, not a customer's measured result. The live model is not touched: re-runs use what-if sets, and nothing reaches the live assumption set during a pilot.

The readout should end in a decision, and the decision should be written down before the pilot starts. The sheet below is the one we suggest; your thresholds will differ.

Pass or fail: what the pilot has to show

TestPassWhat a fail means
Extracts tie to the general ledgerEvery extract within your tolerance, differences shownData work comes before any assumption work
Known assumptions reproduceFor three assumptions your team already measured, the numbers matchMethod or cohort definitions need agreeing first
Every figure opens its sourceA validator can trace each number to an extract line or a model runThe output cannot go to the second line as it stands
Failures are shown, not filled inA missing extract or failed run is reported and that step stopsThe tool estimates where it should stop
The validator's recompute agreesThe second line's independent number matches within a stated toleranceOne of the two methods is wrong; find out which
The study question is answeredYou can say which assumptions held, drifted or broke, and whyRepeat on a second year, or commission the study
Our suggested criteria for a pilot of Interest Rate Risk (IRRBB) Management. Set the tolerances and the decision rule with your validator before the pilot starts.

When a new study is still the right call

A new core deposit study is the right call when the back-test shows the old one no longer describes depositors and one year of data cannot say what the new long-run values are. Several broken or drifting deposit assumptions with causes that will recur, a deposit mix that has shifted, a merger, a new product line, or a market the institution has not seen are each a reason. The FDIC recognises the data problem directly: some institutions "have difficultly measuring decay rates on NMDs due to limited historical data, acquisitions, mergers, or a lack of technical expertise", and may engage third parties.

The sample credit union's own memo reaches that conclusion. Its recommendation adopts the observed 22.6% regular share decay for the next assumption set, re-tests it next quarter, and commissions the next deposit study in 2027. The back-test did not replace the study; it showed when to buy the next one and what it must explain. What the stale rate cost in the meantime is set out in the deposit decay rate guide.

The memo that adopts the observed value and schedules the next study

Change memo P-2026-15, regular share decay 14.0% to 22.6%, from the ALM manager to ALCO and Model Validation, October 22, 2026. Section 1 says the assumption set approved by ALCO on October 28, 2025 assumes regular shares run off at 14.0% a year, balance-weighted, from the 2024 deposit study built on 2019 to 2023 data. Section 2 reports $321.0 million of $1,420.6 million run off by September 30, 2026, 22.6%, with runoff above the assumption for three quarters. Section 3 gives the causes. Section 4 gives the impact at +300 bp. Section 5 recommends adopting 22.6% in the next assumption set, re-testing in the Q4 2026 back-test on January 19, 2027, and commissioning the next deposit study in 2027.
In the sample, the back-test changes one value now and puts the next deposit study on the calendar. The memo is drafted by an agent and submitted by the ALM manager.

For institutions deciding what else to look for in tools that run these back-tests, interest rate risk management software sets out the questions to ask.

Questions people ask

What is the difference between a deposit study and a back-test?

A deposit study estimates deposit behaviour from years of history and produces assumptions. A back-test compares those assumptions with what depositors did over the latest period and reports which held. The 2012 interagency FAQ asks for back-testing of any key assumption, including one taken from a study.

What is a deposit study for banks?

It is the same analysis as a core deposit study: a review of the bank's own deposit history that estimates decay rates, betas, average lives and the stable share of each account type. The OCC lists deposit studies among the information examiners expect behind deposit assumptions.

Can a credit union use a third party's deposit study?

Yes, but the assumptions must be reasonable and supportable for that credit union, as NCUA's Appendix A requires. The FDIC and the 2012 FAQ warn against relying on industry estimates or vendor defaults, and expect the institution to test them on its own data.

How long does a core deposit study take?

That depends on the provider and the data; we have no public benchmark to cite. The internal work is predictable: account-level history for each deposit type, several years long, cleaned and tied to the books. A back-test of one closed year can be run in weeks on data the institution already holds.

What data do you need for a deposit study?

Account-level balances and rates for each non-maturity deposit type over several years, the market rates they are compared with, account open and close dates for vintage analysis, and a promotions calendar. The Basel standardised framework uses ten years of volume changes to separate stable from non-stable deposits.

Interest Rate Risk (IRRBB) Management.
See it on your own files.

An agentic solution from Botminds. Agents back-test every key assumption against what members did, put a number on each gap, and send changes through a validator and ALCO Book a demo, or explore how it works.