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Market Commentary·March 2026

The Return of Disciplined American Banking

After more than a decade of unusual conditions, American banking is returning to a more familiar and more rigorous form. The implications are broad.

For more than a decade, American banking operated under conditions that, by historical standards, were unusual. Policy rates near zero, ample liquidity, compressed credit spreads, and benign loss experience produced a generation of borrowers, lenders, and investors who, in many cases, had not experienced the discipline of a normal credit cycle. The conditions of the last several years have changed that. Rates have reset. Liquidity has rationalized. Credit spreads have widened. Losses, while contained relative to prior downturns, have re-emerged as a routine part of the business. American banking is returning to a more familiar and more demanding form.

This is not a contraction of the banking system. It is a recalibration. The fundamental role of banks — to aggregate deposits, allocate credit, support payments, and provide financial advice to households and businesses — remains essential. What is changing is the standard at which that role is performed. The institutions that will compound through the next decade share certain characteristics, and the broader market is, slowly, rewarding them.

The first characteristic is deposit franchise quality. The events of 2023 reminded the market that not all deposits behave the same. Operating accounts of long-tenured commercial customers, consumer deposits across a broad geographic footprint, and trust and treasury balances tied to specific operational needs behave very differently in stress than rate-shopping deposits sourced through broker channels or aggressively priced digital offerings. Institutions that have invested patiently in primary banking relationships — including the kind of community presence, business banker coverage, and treasury management capability that builds operating relationships — are being recognized in the market. So are the boards and management teams that resisted the temptation, in the prior environment, to grow deposits faster than the underlying franchise warranted.

The second characteristic is credit discipline through the cycle. The loans that were originated in 2020 through 2022, particularly in commercial real estate and certain consumer categories, are now seasoning in an environment very different from the one in which they were underwritten. Institutions whose underwriting was anchored to long-run credit assumptions — conservative cap rates, debt service coverage with realistic interest rate scenarios, attention to concentration limits, and meaningful sponsor recourse where appropriate — are working through their portfolios with manageable issues. Institutions whose underwriting was anchored to the prevailing optimism of the moment are working through more.

The third characteristic is risk and compliance maturity. The supervisory environment has become more demanding, and properly so. Bank Secrecy Act and anti-money-laundering expectations, third-party risk management, model risk management, operational resilience, and cybersecurity standards have all advanced. Institutions that invested in these capabilities ahead of the supervisory cycle are in a materially stronger position than those that approached compliance as a cost to minimize. The cost of remediation, when supervisory issues arise, is consistently higher than the cost of building the function correctly in the first place.

The fourth characteristic is capital and liquidity management that respects the cycle. Strong institutions hold capital and liquidity at levels that are comfortable in a range of scenarios, not at levels that are comfortable only in the most favorable one. They manage interest rate risk with attention to both economic value and earnings sensitivity. They run liquidity stress scenarios that account for the kinds of deposit behavior that recent history has illustrated is possible. They build relationships with secondary funding sources — including the Federal Home Loan Bank system, the discount window, and contingent funding facilities — before they are needed and use those relationships deliberately rather than reactively.

The fifth characteristic, and in many ways the most important, is governance. Boards and management teams that have asked themselves hard questions about the institution's strategy, risk appetite, and operating standards — and that have made the cultural and personnel decisions consistent with the answers — tend to demonstrate the other four characteristics. Boards that have treated risk and audit committees as central to their work, rather than as procedural responsibilities, tend to have institutions that perform predictably. Governance, in the end, is the source of discipline that the other characteristics rest on.

What does the return of disciplined American banking mean for the broader market? For borrowers, it means a credit environment in which terms, structure, and pricing more accurately reflect risk. The cost of capital is higher for transactions that genuinely carry more risk, and the availability of capital is more selective. That selectivity is, in aggregate, healthy — even though it is uncomfortable for transactions and sponsors who became accustomed to a different environment. For depositors, it means a banking system in which institutional differences matter more than they did in the prior decade. The choice of banking partner is again a meaningful decision. For investors in financial institutions, it means a re-emergence of the kind of differentiation between strong and weaker franchises that has historically driven long-term returns in the sector.

There are open questions, and serious ones. The trajectory of policy rates, the path of commercial real estate values in certain geographies and asset classes, the evolution of supervisory expectations, the rate of technological change in payments and core banking, and the broader macroeconomic environment will all influence how the next several years unfold. Disciplined institutions do not claim to know the answers to those questions. They construct themselves to perform across a range of plausible outcomes.

The return of disciplined American banking is not, in the end, a return to a previous era. It is the application of long-standing principles — capital adequacy, deposit franchise quality, credit discipline, risk and compliance maturity, and serious governance — in the context of a modern, complex, and increasingly digital financial system. The institutions that combine those principles with the operating capabilities of the current era will define the next chapter of American finance. The principles themselves are not new. They have simply, and importantly, become relevant again.

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Important Disclosure

This article is provided for general informational purposes only and does not constitute investment advice, legal advice, tax advice, an offer to lend, an offer to sell securities, or a commitment to provide financing. One Continental is not currently a chartered bank, trust company, registered investment adviser, broker-dealer, or FDIC-insured depository institution.