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FinObservatory

Deposit market structure / counties

County banking markets

The county is close to the geography bank merger review runs on. The Federal Reserve says that “many geographic markets follow Metropolitan Statistical Area (MSA) definitions or rural county lines, but some markets comprise multiple MSAs/counties or parts of MSAs/counties”, and its delegation screen turns on a deal raising a local HHI by 200 points or more to a level of 1,800 or higher. This page builds that lens from the FDIC Summary of Deposits county file, 19942025: 3,237 FIPS codes across the panel, 3,194 of them in the 2025 survey.

3,194
Geographies in the county file
June 30, 2025
6
Institutions, median county
6 in 1994
2,222
Branch HHI, median county
2,222 in 1994
236
One-institution counties
220 in 1994
Which HHI. Two are computable from this survey. The branch-count HHI squares each institution’s share of the county’s branch offices. The deposit HHI squares its share of county deposits, and SOD books a deposit at the branch of record, so a bank that centrally books balances can hold 98.2% of a county’s deposits from 2 of its 37 branches (Citibank, National Association in Lincoln, South Dakota, 2025). Every headline here is the branch measure; the deposit measure is shown beside it, labelled. The national and state pages carry the deposit HHI only.

The consolidation did not reach the median county

Between 1994 and 2025 the number of institutions operating branches fell 66% and the branch network shrank 6%. The median county market did not move. It had 6 institutions in 1994 and 6 in 2025, and its branch-count HHI is 2,222 against 2,222. It fell to 2,000 in 2008 and came back. The mean county, which is not confined to the lattice the branch HHI takes in small markets, does the same: 2,993 in 1994, 2,690 in 2009, 2,988 in 2025. This is a null result, and it is the finding. What the module cannot tell you is why.

Measure19942025Change
Institutions operating branches, nationally13,0024,43166% fewer
Branch offices, nationally81,29776,1206% fewer
Institutions in the median county66unchanged
Branch-count HHI, median county2,2222,222moderately concentrated, both years
Deposit HHI, median county2,6312,888+257 points, and see central booking below
Counties with a branch HHI above 1,8002,045 of 3,2091,998 of 3,19463.7% then, 62.6% now
Counties served by one institution220236+16
Branch-count HHI, median countyDeposit HHI, median county
01,0002,0003,0004,0001,800 (Fed screen)19942000201020202025

Source: FDIC Summary of Deposits | Federal Reserve, Competitive Effects of Mergers and Acquisitions FAQs Median across the counties in each survey, unweighted. The survey does not carry the same number of counties every year: the count runs from 3,194 to 3,210, and is 3,194 in 2025. Bands are the 2010 Horizontal Merger Guidelines classification. Branch-count HHI in a small market takes discrete values, so the median steps rather than glides. Methodology

Counties above 1,800 (branch HHI)Counties with one institution
01k2k3k19942000201020202025

Source: FDIC Summary of Deposits Counts of counties, 1994-2025. Each series has its own low year. Counties above 1,800 on branch HHI: 2,045 in 1994, 1,820 in 2009, 1,998 in 2025. Counties with one institution: 220 in 1994, 159 in 2006, 236 in 2025. Methodology

Why the deposit HHI cannot carry a county page

The Fed has a name for the problem. “Central booking occurs when a bank records deposits at a central office and does not book the deposits to a branch that is connected to the location of the depositor. As a result, centrally booked deposits of an applicant can overstate the presence of an institution in the local banking market.” SOD is a survey of branches of record, so it contains the distortion unadjusted. Below are the 2025 counties where the two indices disagree most, each with at least 20 branch offices, ranked by deposit HHI minus branch HHI.

CountyLargest by depositsDeposit HHIBranch HHIIts deposit shareIts branch share
Lincoln SDCitibank, National Association9,65048998.2%5.4% (2/37)
Minnehaha SDWells Fargo Bank, National Association9,10769495.4%8.3% (7/84)
Sussex DECapital One, National Association8,64091492.9%1.4% (1/70)
Denton TXCharles Schwab Bank, SSB6,76955581.7%0.6% (1/162)
Ramsey MNU.S. Bank National Association5,99176176.9%18.1% (17/94)
Westchester NYMorgan Stanley Private Bank, National Association6,1181,01177.8%0.4% (1/249)
Garfield OKStride Bank, National Association5,54999273.6%13.6% (3/22)
Mecklenburg NCBank of America, National Association5,35984570.4%11.5% (28/243)
Richmond (City) VABank of America, National Association5,4771,01972.7%5.1% (2/39)
Hamilton OHU.S. Bank National Association4,61479163.3%10.4% (25/240)

Source: FDIC Summary of Deposits | Federal Reserve, Competitive Effects of Mergers and Acquisitions FAQs June 30, 2025. Counties with 20 or more branch offices, ranked by deposit HHI minus branch HHI. The Fed also drops credit-card banks, trust companies and internet banks from local market shares and weights thrift deposits at 50%; neither index here does any of that. Methodology

Most and least concentrated county markets, 2025

By branch-count HHI, among counties with at least 20 branch offices. The floor is doing work: 236 counties in the 2025 survey are served by a single institution, which puts every one of them at the 10,000 ceiling by construction, so without a floor the most-concentrated table would be a list of those and nothing else. Deposit HHI is in the last column for comparison, not as the ranking key.

Most concentrated

CountyBranch HHIInst.BranchesDep. HHI
San Juan PR3,6416614,689
Bayamon PR3,6003204,101
Pike KY3,4507205,578
Aroostook ME3,3086232,325
Columbia PA3,2236223,216
Anchorage AK2,9374293,484
Robeson NC2,7787242,509
Garfield CO2,7006203,776
Sanilac MI2,7006202,097
Cowley KS2,6507202,921

Least concentrated

CountyBranch HHIInst.BranchesDep. HHI
Johnson KS36760228509
Oklahoma OK387612361,310
St. Louis MO45054299710
Stearns MN45129481,331
El Paso CO45240126874
St. Charles MO45435106743
Polk IA459411301,404
Williamson TN46736103766
Dallas TX4701135702,296
Worcester MA47228193666

Source: FDIC Summary of Deposits June 30, 2025. Branch-count HHI, counties with 20+ offices. Methodology

The counties that did lose banks

Of the 3,172 counties in both the 1994 and 2025 surveys, 1,188 have fewer institutions in 2025, 1,183 have more, and 801 are unchanged. 87 that had more than one institution in 1994 have exactly one now. The ten counties below are those with the largest fall in institution count; they are not a random sample, and nothing here measures where losses fall in general.

CountyInst. 1994Inst. 2025ChangeBranches 1994Branches 2025Change
Cook IL28995-1949911,131+140
Los Angeles CA20292-1101,7251,394-331
Orange CA12472-52625535-90
New York NY12183-38605515-90
DuPage IL8245-37249250+1
Baltimore MD6025-35293167-126
Miami-Dade FL8957-32542582+40
San Diego CA7745-32538437-101
Hamilton OH5933-26363240-123
Allegheny PA5632-24493365-128

Source: FDIC Summary of Deposits Counties present in both the 1994 and 2025 surveys, ranked by change in institution count, ties broken by 1994 branch count then FIPS. 3 of these 10 lost institutions while their branch count grew. Methodology

Codes that leave the survey, and what leaving does not prove

3,237 county FIPS codes appear across the panel; 3,194 are in the 2025 survey. That leaves 43 absent. Reading all 43 as counties that lost their last bank would be wrong for 16 of them, which are not county equivalents in the 2025 geography: 14 are recodes, where the geography still exists under a different FIPS code, and 2 are codes Census does not treat as county equivalents. By jurisdiction: 8 Connecticut, 4 Alaska, 1 Florida, 1 Marshall Islands, 1 Northern Mariana Islands, 1 Virginia.

Codes that are not counties in the 2025 geography (16)

CodeLast reported asLast surveyClassWhy it is not a countySuccessor codes
12025Miami FL2024recodeDade County, renamed Miami-Dade and recoded in 1997; rows after that are branches inside Miami-Dade filed under the retired code12086
69010Mariana Islands MP2024not a county equivalent69010 is not one of the four Census county equivalents for the Northern Mariana Islands (69085 Northern Islands, 69100 Rota, 69110 Saipan, 69120 Tinian)69110
02261Valdez-Cordova AK2023recodeValdez-Cordova Census Area, split02063, 02066
02280Wrangell Petersburg AK2023recodeWrangell-Petersburg Census Area, split02275, 02195
09001Fairfield CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09003Hartford CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09005Litchfield CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09007Middlesex CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09009New Haven CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09011New London CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09013Tolland CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
09015Windham CT2022recodeConnecticut county, replaced by COG planning regions09110, 09120, 09130, 09140, 09150, 09160, 09170, 09180, 09190
02201Prince of Wales-Outer Ke AK2013recodePrince of Wales-Outer Ketchikan Census Area, reorganised02198
02232Skagway-Hoonah-Angoon AK2013recodeSkagway-Hoonah-Angoon Census Area, split02230
51515Bedford (City) VA2013recodeBedford (City) reverted to a town within Bedford County51019
68150Kwajalein MH2004not a county equivalentMarshall Islands is a sovereign state in free association with the United States, not US territory, and Census does not treat its FIPS codes as county equivalentsnone

Source: FDIC Summary of Deposits | US Census Bureau, Substantial Changes to Counties and County Equivalent Entities Every successor code above carries at least one branch in its first survey. Each successor is matched by FDIC cert, not by proximity: 69010's last branch is First Hawaiian Bank (cert 17985), and cert 17985 files under Saipan (69110) in 2025, so Saipan is the successor and Tinian, which is merely new in 2025, is not. The switch is not clean either: 2 of the 4 retired Alaska codes keep receiving branches after their successors appear (02261 for 2 surveys, 02280 for 5), so a raw count of distinct county_fips double-counts those geographies in the overlap years. Methodology

Absent codes the register does not flag, with no SOD branch since the year shown (27)

These are the 27 absent codes the register above does not flag. The claim each row supports is the one printed in it: no SOD branch reported under this code after that year. That is not “no banking access”. SOD counts branches of FDIC-insured institutions only, so a county served entirely by credit unions carries no row here, and a resident may bank at a branch one county over, or online. American Samoa left the survey outright: none of its 3 codes appears after 2023, when its last 2 branches reported.

CountyCodeFirst surveyLast surveyBranches thenInstitutions then
Coosa AL010371994202321
Eastern AS600101994202321
Jones NC371031994202211
Tyrrell NC371771994202211
Forest PA420531994202211
Catano PR720331994202211
Keweenaw MI260831994202111
Lincoln ID160631994202011
Blaine NE310091994202011
Sierra CA060911994201911
Costilla CO080231994201511
Quitman GA132391999201511
Stewart GA132591994201521
Butte ID160231994201511
Golden Valley MT300371999201511
Mineral NV320211994201411
Manu'a AS600201994201311
Storey NV320291994201311
Western AS600502006201111
Gilpin CO080471994201011
Guanica PR720551994200811
Yakutat AK022821998200511
Clark ID160331994200111
Boise ID160151997200011
Northern Islands MP690851994200011
Aleutians East AK020131994199711
Sioux ND380851994199611

Source: FDIC Summary of Deposits | US Census Bureau, Substantial Changes to Counties and County Equivalent Entities Codes with no SOD branch after the year shown. Leaving is not always permanent: 19 FIPS codes in the panel dropped out of the survey for one or more years and came back. Methodology

What this cannot tell you

  • A county is not a banking market. The Fed defines markets from commuting and shopping patterns; some are MSAs, some are groups of counties, some are parts of counties. Its actual definitions live in CASSIDI, not here. County HHI is a proxy for the merger-review lens, not the lens.
  • Neither HHI on this site is the Fed’s screen HHI. The Fed weights thrift deposits at 50%, excludes credit-card banks, trust companies and internet banks from local shares, and adjusts case by case for central booking and large government deposits. These indices are unweighted and include every reporting institution. Do not read a number here as a merger-review outcome.
  • The deposit HHI is not a measure of local competition. Central booking makes it an upper bound in the county where a bank books, and a lower bound in every county the money actually came from. That is why it is never the headline here.
  • SOD counts branches, not access. Credit unions are not in this survey (they file with the NCUA), branchless banks hold deposits that no county sees, and a branch office is not the same thing as available credit. A county with no SOD branch is not proven to be a banking desert.
  • There is no county master list in this estate. Every code here is one that reported at least one SOD branch at some point since 1994. A county that never reported one is invisible to this module and cannot be counted by it, so the absent-code tables above are a lower bound on counties without a branch, not the full set.
  • Not every code in the county file is a US county. The FDIC surveys the branches of insured institutions in the Compact of Free Association states (Federated States of Micronesia, Marshall Islands, Palau), which are sovereign countries and whose FIPS codes Census does not treat as county equivalents. 6 such codes are in the 2025 survey, carrying 12 branches, and 1 has left it. They are kept, labelled on their own pages, and counted in the medians. Read “county” on this page as a row of the SOD county file.
  • Medians describe counties, not people. Every median here is unweighted: a county of 10 million and a county of 500 count once each. This module holds no population data, so it cannot say how many people live in the counties that lost institutions, and the flat median above is not a statement about the typical depositor.

Every geography in the 2025 survey

3,194 codes, grouped by jurisdiction. Each has its own page, covering only the surveys that code appears in: 3,159 of the 3,194 appear in all 32 surveys, and the other 35 in fewer. The figure beside each is its 2025 branch-count HHI. 6 of them are in the Compact of Free Association states, which the FDIC surveys and Census does not count as county equivalents. The 43 codes absent from this survey have pages too, and are listed above.

Alabama 66

Arkansas 75

Arizona 15

California 56

Colorado 62

Florida 67

Georgia 156

Guam 1

Hawaii 4

Iowa 99

Idaho 40

Illinois 102

Indiana 92

Kansas 105

Kentucky 120

Louisiana 64

Maine 16

Michigan 82

Minnesota 87

Missouri 115

Mississippi 82

Montana 54

North Carolina 98

North Dakota 51

Nebraska 91

New Mexico 33

Nevada 14

New York 62

Ohio 88

Oklahoma 77

Oregon 36

Pennsylvania 66

Puerto Rico 76

Palau 1

South Carolina 46

South Dakota 64

Tennessee 95

Texas 250

Utah 28

Virginia 133

Vermont 14

Washington 39

Wisconsin 72

West Virginia 55

Wyoming 23

Source: FDIC Summary of Deposits June 30, 2025. County branch counts sum to 76,120, the same total as the state file and as the raw branch rows, so no branch is unassigned to a county and none is counted twice. Methodology

Up one level to the national and state deposit pages, or read the county methodology for the two HHI constructions, the verification that the county rollup reproduces the branch file exactly, and the FIPS recode register.