Distress Index™
Methodology
The Distress Index aggregates public regulatory, financial, and SEC filing data into a single 0–100 score per institution. This page documents exactly how that score is calculated: every weight, every threshold, every exclusion. Nothing is proprietary. If you can read a public filing, you can reproduce any score.
The Six Signal Lenses
Signals are grouped into six lenses. Each lens has a fixed weight (how many index points a single qualifying signal contributes at full age weight) and a cap on how many signals from that lens can score simultaneously. The cap prevents a flood of routine disclosures (30 board-change 8-Ks, for example) from inflating the score beyond what the underlying distress picture warrants.
| Lens | Name | Weight | Cap | Max pts* | Phase 0 data source |
|---|---|---|---|---|---|
| C | Confirmed Action A federal or state regulator publicly took action: consent orders, Matters Requiring Attention (MRAs), formal agreements, civil money penalties, prohibition orders. Also includes regulator merger-approval orders and recorded bank merger / consolidation events as confirmed structural-change context (reduced weight, because these are not distress). | 25 pts | 4 | 100 pts | OCC enforcement database Federal Reserve enforcement actions CFPB enforcement database FDIC enforcement orders, direct from the FDIC's own orders database, each signal citing its own order PDF (launched July 2026; the Federal Register + press-release chain stays live as the documented backup path) FinCEN enforcement actions NY DFS enforcement actions (restored July 2026 after a verified rebuild) NY DFS mortgage-industry enforcement actions: mortgage lenders, brokers, servicers, and individual originators, each citing its own order document (launched July 2026 under the non-bank expansion; the listing has been dormant since October 2023 by the source's own content, which is disclosed, and a revival is picked up automatically) Texas Department of Banking enforcement press releases (restored July 2026 after a verified rebuild) California DFPI actions and orders (restored July 2026 after a verified rebuild) Illinois IDFPR banking enforcement actions (restored July 2026 after a verified rebuild) Illinois IDFPR Residential Finance enforcement actions: mortgage licensees, each citing its own order document (launched July 2026 under the non-bank expansion) Illinois IDFPR Consumer Credit Section discipline: installment / sales-finance / payday licensees from the monthly consolidated disciplinary report; dates carry month precision, stated on every citation (launched July 2026 under the non-bank expansion) Georgia DBF unauthorized banking orders (restored July 2026 after a verified rebuild) Florida OFR final agency actions: banking AND licensed-lender categories (banking restored July 2026; mortgage / consumer-finance / auto-finance categories added July 2026 under the non-bank expansion) Texas OCCC enforcement actions against non-bank lenders: regulated lenders, credit access businesses, motor vehicle sales finance, property tax lenders (launched July 2026) Texas SML enforcement orders: mortgage companies and individual originators from the department's published enforcement-orders dataset, cited to its enforcement page with the row quoted verbatim and the snapshot named (launched September 2026; individual originators are shown and excluded from the Index) FTC cases and proceedings: consumer-credit / mortgage / auto-finance categories (launched July 2026) State attorney-general enforcement press releases: consumer-finance actions, six states (launched July 2026). CA, TX, WA passed their real-action launch gates at launch; NY, PA, IL run live and are launch-gated pending their first in-window action. FL and MA block automated access and are documented gaps; the NAAG multistate settlements database is a planned discovery backstop. Missouri Division of Finance removal / prohibition orders (restored July 2026; individual-level, excluded from the Index) IA, KS, IN, MN state banking regulators publish no scrapeable public enforcement listing (verified July 2026, re-verified for non-depository divisions); these states' institution-level enforcement arrives via the federal streams NCUA administrative orders (credit unions) Federal Reserve orders approving banking applications: mergers / acquisitions (reduced weight) FDIC-recorded bank mergers & consolidations, from BankFind history (reduced weight) |
| F | Financial Deterioration Capital, earnings, liquidity, or credit-quality deterioration crossing a material threshold in the institution's own quarterly regulatory filing. For banks: capital ratios below regulatory thresholds, the Tier 1 leverage ratio, net interest margin decline, deposit outflow, efficiency ratio deterioration, loans 30 to 89 days past due, net charge-offs, reserve coverage of noncurrent loans, and other real estate owned. For credit unions: the net worth ratio, delinquency, return on assets, net charge-offs, and allowance coverage. | 20 pts | 3 | 60 pts | FDIC BankFind Suite: quarterly Call Report data FDIC peer-group comparison (UBPR-style ratios, reduced weight) NCUA 5300 Call Report: net worth ratio / Prompt Corrective Action capital category (credit unions) NCUA 5300 Call Report, earnings and credit quality: delinquency, return on assets, net charge-offs, allowance coverage (credit unions) |
| D | Disclosed Risk Risk-disclosure language referenced in an SEC 10-K (annual) or 10-Q (quarterly) filing: material weakness, BSA/AML compliance, the Prompt Corrective Action framework, cybersecurity-incident language, or going-concern language ('substantial doubt'). A full-text match reports that the filing contains the phrase; it does not assert the event occurred. Confirmed events are the C-lens. | 15 pts | 1 | 15 pts | SEC EDGAR full-text search (EFTS): 10-K and 10-Q filings |
| L | Leadership Transition Executive departure or new appointment for CRO (Chief Risk Officer), CFO (Chief Financial Officer), CIO (Chief Information Officer), or Chief Compliance Officer. Presence is the signal. A bank with 30 board changes doesn't score 30× a bank with one new CRO. Partial: public BHCs via SEC EDGAR only | 10 pts | 1 | 10 pts | SEC EDGAR 8-K filings, Item 5.02, via the SEC submissions API, per institution CIK |
| O | Operational Signal Core banking system evaluation or replacement announced in an SEC 8-K filing, material cybersecurity incident disclosure (mandatory under Item 1.05 of Form 8-K), or digital banking platform initiative. Each indicates a live technology procurement cycle. Partial: SEC EDGAR filings only | 8 pts | 1 | 8 pts | SEC EDGAR 8-K current-event filings (EFTS full-text search) |
| U | Unverified Industry press, trade publication clustering, news feed output. Not citable in the same way as regulatory filings. Excluded from the scored index unless the user explicitly opts in. Never the sole basis for outreach. Off by default | 5 pts | 1 | 5 pts | Free-tier news RSS aggregation |
| * Maximum contribution per lens at full age weight (signal filed within 89 days). All six lenses active simultaneously at full weight = 193 raw points → capped at 100. With U-lens enabled: 198 raw pts. | |||||
Three within-lens exceptions. Within the Financial (F) lens, peer-comparison signals (an institution ranking below its FDIC peer-group median on a Call Report ratio (the peer group is the FDIC specialization group: banks with the same business-model concentration, e.g. commercial-lending or agricultural) carry a reduced 8 points rather than the full 20. Being below a peer median is true for roughly half of all banks on any given metric by mathematical design, so it is weaker evidence than an absolute deterioration signal (for example, a capital ratio crossing a regulatory threshold), which keeps the full 20-point F weight. The peer signal still counts toward the F-lens cap; only its point value is reduced.
What the attention surface puts first. The signed-in home page shows at most five items and ranks them by a fixed, published rule rather than by a model: Distress Index band changes first (upward before downward, larger moves before smaller), then new full-weight signals in lens-severity order, then Call Report restatements, then institutions with two or more context-weight crossings in the same period, then pattern lines. One item per institution. Nothing renders without a citation, and when nothing qualifies the page says so and shows what it checked.
Peer position is context, not score. An institution's page shows where it sits among its peer group on each measure the Financial lens reads, against the group's median and quartiles for a named reporting quarter. The peer group is the FDIC specialization group crossed with an asset band; a group with fewer than fifteen members falls back to the asset band alone and the label says so. That percentile never enters the Distress Index. The peer-comparison signals that do enter it are weighted separately, at the reduced context weight described above.
Patterns are labels, never scored. A pattern line names a co-occurrence of Financial signals on one filing (early credit deterioration alongside a doubled provision, for example). It renders on the institution's page, the briefing pack and the attention layer with the signals it rests on, each carrying its own citation. A pattern never enters the Distress Index.
Financial signals are weighted by what drew the line. A financial signal that crosses a regulatory guidance line scores at full weight; a signal that crosses a rule-of-thumb line scores at the reduced context weight of 8 points. A guidance line is one a regulator drew: a prompt-corrective-action capital category, a brokered-deposit restriction threshold, an interagency concentration limit. A rule of thumb is one that examiners and analysts use in practice but no rule states. Every threshold this lens applies carries the authority behind it, and the reduced tier is why a single rule-of-thumb crossing cannot on its own move an otherwise quiet institution into Watch.
Each financial metric is also counted once, at its most severe crossed threshold. A ratio that trips several nested levels, for example an efficiency ratio above the 70%, 80%, and 90% marks, is a single deterioration signal, scored at the 90% level, not three separate signals. This keeps one weak metric from being counted multiple times toward the Distress Index.
For credit unions, the net worth ratio is the statutory capital metric and is weighted by its own severity band rather than by the tier rule above. It is no longer the only credit-union financial metric: delinquency, return on assets, net charge-offs, and allowance coverage were added in August 2026 (see the dated note below). The net-worth signal is weighted by its statutory NCUA Prompt Corrective Action (PCA) category: below well-capitalized scores 25 points, undercapitalized 45, significantly undercapitalized 65, and critically undercapitalized (including negative net worth) 90, before age decay. This scores an insolvent credit union as Critical and one only just below the well-capitalized line as Watch, rather than collapsing every distressed credit union to the same value.
Within the Confirmed (C) lens, merger-approval and recorded merger/consolidation signals, a Federal Reserve order approving a banking application or an FDIC-recorded bank merger, carry a reduced 8 points rather than the full 25. A merger is a confirmed public action and a material one, but it is not financial distress. A healthy acquirer cleared to buy a competitor should not read as elevated on a distress index. These carry the same context weight as an Operational signal; each still counts toward the C-lens cap.
Scoring Formula
The algorithm has three steps. All three are deterministic: run it twice on the same data and you get the same answer.
- Gather signals. All signals for the institution from the ingestion pipeline. Signals below 70% confidence are excluded (see Confidence Threshold below). Unverified (U-lens) signals are excluded unless the user has opted in.
- Apply cap and decay per lens. Signals are sorted most-recent first; when several share the same date, the strongest evidence is kept first (higher point weight), then the lowest signal identifier, a fully deterministic order, so the score and the on-screen breakdown always select the same signals. The cap (C=4, F=3, D=1, L=1, O=1) limits how many signals from each lens contribute to the score. Each contributing signal is multiplied by its age-decay multiplier (see Age Decay table).
- Sum and cap. The weighted, decayed contributions are summed across all lenses and capped at 100. The lens_breakdown field always shows the full signal count, the cap only affects scoring, not display.
Age Decay
A consent order from two years ago matters less than one from last month. Age decay discounts older signals without removing them. A signal is never worthless; it just contributes less as time passes.
| Signal age | Decay multiplier | Effect |
|---|---|---|
| 0 – 89 days | 1.00× | Full weight |
| 90 – 364 days | 0.75× | — |
| 365 – 729 days | 0.50× | — |
| 730+ days | 0.25× | Signal still counts; heavily discounted |
| Date unknown | 0.50× | Conservative fallback |
Score Bands
The 0–100 score is bucketed into five bands. The bands are thresholds, not percentile rankings. An institution at 81 is Critical because of what its signals say, not because it ranks in the top 5% of the universe.
Worked Example
First National Bank of Example, a fictional institution. Signal set as of June 2026. All eight signals have been collected; the algorithm processes them as follows.
Note: F-lens cap is 3, so all three F-lens signals score. C-lens cap is 4, so both C-lens signals score. All signals filed within 90–364 days receive 0.75 decay; signals under 90 days receive 1.00.
| Signal | Lens | Filed | Age | Decay | Weight | Contribution |
|---|---|---|---|---|---|---|
| Formal agreement (OCC) | C | Nov 2025 | 210d | 0.75× | 25 | 18.75 |
| Consent order (CFPB) | C | Jan 2026 | 150d | 0.75× | 25 | 18.75 |
| Net interest margin below 2.5% | F | Dec 2025 | 182d | 0.75× | 20 | 15.00 |
| Tier 1 capital ratio at 8.1% | F | Mar 2026 | 88d | 1.00× | 20 | 20.00 |
| Domestic deposit decline >10% | F | Mar 2026 | 88d | 1.00× | 20 | 20.00 |
| Material weakness, BSA/AML controls | D | Jan 2026 | 150d | 0.75× | 15 | 11.25 |
| New CRO appointed | L | Apr 2026 | 60d | 1.00× | 10 | 10.00 |
| Core banking initiative (8-K) | O | Mar 2026 | 88d | 1.00× | 8 | 8.00 |
| Raw score (sum of contributions) | 121.75 | |||||
| Final Score = min(100, 121.75) | 100Critical | |||||
Example only: fictional institution and signal dates. Not derived from any real institution.
Confidence Threshold
Every signal carries a confidence score (0–100%) representing the estimated probability that the signal corresponds to a genuine buying event within 180 days. Signals below 70% confidence are excluded from scoring.
Confidence is assigned per source, not per lens. Each source carries a value calibrated to its record quality and matching method. These are the production values:
| Lens | Source | Confidence |
|---|---|---|
| C | OCC, Federal Reserve, and CFPB enforcement databases (direct) | 95% |
| C | FDIC Enforcement Decisions and Orders database (orders.fdic.gov, direct) | 95% |
| C | Federal Register API (FDIC enforcement backup path) | 92% |
| C | FinCEN enforcement actions | 92% |
| C | FDIC press releases (FDIC enforcement backup path) | 90% |
| C | NY DFS enforcement actions (dfs.ny.gov) | 88% |
| C | NY DFS mortgage-industry enforcement actions (dfs.ny.gov) | 88% |
| C | Texas Department of Banking enforcement press releases (dob.texas.gov) | 88% |
| C | California DFPI actions and orders (dfpi.ca.gov) | 88% |
| C | Illinois IDFPR banking enforcement actions (idfpr.illinois.gov) | 88% |
| C | Illinois IDFPR Residential Finance enforcement actions, mortgage licensees (idfpr.illinois.gov) | 88% |
| C | Illinois IDFPR Consumer Credit Section monthly discipline, non-bank lenders (idfpr.illinois.gov) | 88% |
| C | Georgia DBF unauthorized banking orders (dbf.georgia.gov) | 88% |
| C | Florida OFR final agency actions, banking + licensed-lender categories (DOAH repository) | 88% |
| C | Texas OCCC enforcement actions, non-bank lenders (occc.texas.gov) | 88% |
| C | Texas SML enforcement orders, mortgage companies and originators (sml.texas.gov) | 88% |
| C | FTC cases and proceedings, consumer-credit categories (ftc.gov) | 88% |
| C | State AG enforcement press releases: CA, TX, WA, NY, PA, IL (each AG's own newsroom) | 90% |
| C | Missouri Division of Finance removal / prohibition orders (finance.mo.gov) | 88% |
| C | Federal Reserve orders approving banking applications: mergers / acquisitions (federalreserve.gov) | 92% |
| C | FDIC-recorded bank mergers & consolidations, from BankFind institution history (api.fdic.gov/banks/history) | 90% |
| F | FDIC Call Report, absolute deterioration thresholds | 85% |
| F | FDIC peer-group comparison (reduced-weight peer signals) | 83% |
| F | NCUA 5300 Call Report: net worth ratio / PCA category (credit unions) | 85% |
| D | SEC EDGAR full-text search, 10-K / 10-Q risk language | 75% |
| L | SEC 8-K Item 5.02, via the SEC submissions API per CIK | 85% |
| O | SEC 8-K operational events (EFTS full-text search) | 80% |
| U | News / RSS aggregation (off by default) | 40% |
U-lens signals fail the 70% threshold by default, reinforcing the opt-in requirement. Signals with no confidence score (NULL) are included: not yet scored ≠ invalid.
One internal-consistency gate applies to the credit-union Financial lens: an NCUA 5300 net-worth signal is suppressed when the same filing’s quarter-over-quarter net-worth change cannot be reconciled with its own reported net income, with equity falling far faster than any reported loss can explain. Such a filing contradicts itself, so its precision falls below the 70% floor and it does not fire. The check is two-part and deliberately narrow (the unexplained drop must clear both an absolute floor and a multiple of the quarter’s income), so genuine deterioration, where a reported loss explains the decline, still scores.
Unverified Lens (U): Opt-In Rules
- U-lens signals are excluded from the Distress Index by default. They do not affect any institution's score unless the user explicitly enables them.
- U-lens signals can appear in the signal timeline (labelled “Unverified”) as color commentary, but are never the sole basis for a briefing claim.
- When opted in, U-lens carries 5 pts, capped at 1 signal. Even full opt-in cannot raise an institution's Quiet score above Watch on U-lens data alone.
- Every U-lens signal carries the same citation requirements (source_url, source_excerpt, as_of_timestamp) as verified lenses. The “Unverified” label refers to the data class, not to a missing citation.
Per-User Lens Filtering
Every user, at every subscription tier, can choose which lenses feed their view of the Distress Index. There is no hidden math in this: the filtered view is recomputed from the same published arithmetic on this page, each enabled lens's contribution (its weighted, age-decayed, capped signal points exactly as described above) is summed, and the total is capped at 100. Disabling a lens removes its contribution; nothing else changes. Enabling the Unverified lens adds its recorded contribution under the opt-in rules above.
The canonical Distress Index, the score stored in our database, shown by default, and printed on every briefing pack, is always the all-verified-lenses computation (C, D, F, L, O) with Unverified excluded. A user's lens filter changes what that user sees; it never changes the canonical score, and a briefing pack generated by any user shows the canonical Index regardless of the generating user's view settings.
Data Sources (Phase 0)
Every Phase 0 source is publicly available and free to ingest. No paid feeds, no licensed workforce data, no premium APIs. Every signal links directly to the originating document.
- OCC Enforcement Actions Search (apps.occ.gov/EASearch)
- Federal Reserve enforcement actions (federalreserve.gov)
- CFPB enforcement actions database (consumerfinance.gov)
- FDIC Enforcement Decisions and Orders (orders.fdic.gov), launched July 2026, read directly from the FDIC's own database: every signal cites its own order PDF and carries the FDIC docket number; institutions attach by exact FDIC certificate number. Orders against affiliated individuals (prohibitions, personal penalties) are shown with citations but excluded from the institution Distress Index. Terminations of prior orders, Section 19 applications, and voluntary deposit-insurance terminations are excluded by design. The Federal Register + FDIC press-release chain stays live as the documented backup path.
- FinCEN enforcement actions (fincen.gov)
- NY DFS enforcement actions (dfs.ny.gov), restored July 2026: the rebuilt stream passed its real, dated-action launch gate and is live.
- NY DFS mortgage-industry enforcement actions (dfs.ny.gov), launched July 2026 under the non-bank expansion: mortgage lenders, brokers, and servicers (individual loan originators are shown with citations but excluded from the institution Distress Index), each signal citing its own order document. Two facts are disclosed rather than smoothed: the listing has published nothing since October 2023, so the leg carries the in-window record and picks up a revival automatically; and rows whose listed date contradicts the order document's own date are excluded, never guessed.
- Texas Department of Banking enforcement press releases (dob.texas.gov), restored July 2026: the rebuilt stream passed its real, dated-action launch gate and is live.
- California DFPI actions and orders (dfpi.ca.gov, via the state's own public search API), restored July 2026: the rebuilt stream passed its real, dated-action launch gate and is live.
- Illinois IDFPR banking enforcement actions (idfpr.illinois.gov), restored July 2026: the rebuilt stream passed its real, dated-action launch gate and is live.
- Illinois IDFPR Bureau of Residential Finance enforcement actions (idfpr.illinois.gov), launched July 2026 under the non-bank expansion: mortgage-licensee orders (revocations, suspensions, fines, consent orders), each signal citing its own order document. Rows publishing ambiguous dates and application denials are excluded by design.
- Illinois IDFPR Consumer Credit Section discipline (idfpr.illinois.gov monthly consolidated disciplinary reports), launched July 2026 under the non-bank expansion: consumer installment, sales-finance, and payday licensees, classified by the statute the regulator itself names. The report publishes discipline by month, not by day, so these signals carry month-precision dates; the report month is stated on every citation. Out-of-class licensees (collection agencies, debt management, legal funding) are stored with citations but never join the observed universe.
- Georgia DBF unauthorized banking orders (dbf.georgia.gov), restored July 2026: cease-and-desist orders against unauthorized banking activity; enforcement against chartered Georgia depositories is published federally and arrives via the FDIC / Federal Reserve streams.
- Florida OFR final agency actions (DOAH statutory repository, doah.state.fl.us): banking categories restored July 2026; the licensed-lender categories (mortgage lenders and brokers, motor vehicle retail installment, retail installment sellers, sales finance, consumer finance) added July 2026 under the non-bank expansion, read from the order documents themselves; approvals excluded; money-services and collection-agency categories stay out of the observed universe.
- Missouri Division of Finance removal / prohibition orders (finance.mo.gov), restored July 2026: orders against affiliated individuals; shown with citations but excluded from the institution Distress Index. Institution-level Missouri bank enforcement is published federally and arrives via the FDIC / Federal Reserve streams.
- Iowa Division of Banking, Kansas OSBC, Indiana DFI, and Minnesota Commerce (Division of Financial Institutions) publish no scrapeable public enforcement listing (each site verified July 2026, and re-verified for separate non-depository / consumer-credit divisions on 2026-07-16: Iowa and Indiana publish none; Kansas's division pages are reachable but list no enforcement actions; Minnesota's records remain bot-gated on every route, which Tellsign does not bypass). This is an accepted Phase 0 coverage gap: institution-level enforcement in these states is published federally and arrives via the FDIC / Federal Reserve / OCC streams.
- NCUA administrative orders (ncua.gov), credit unions
- State attorney-general enforcement press releases, launched July 2026, consumer-finance enforcement actions only (settlements, filed suits, judgments; investigations and consumer alerts are below the bar). Six states run live from each AG's own newsroom: California (oag.ca.gov), Texas (texasattorneygeneral.gov), Washington (atg.wa.gov), New York (ag.ny.gov), Pennsylvania (attorneygeneral.gov), Illinois (illinoisattorneygeneral.gov). CA, TX, and WA passed their real-action launch gates at launch; NY, PA, and IL are launch-gated pending their first in-window action. The citation on every signal is the AG's own release. Florida and Massachusetts block automated access to their newsrooms and are documented gaps; the NAAG multistate settlements database is a planned discovery backstop. Actions against private individuals and releases that do not name a respondent are excluded by design.
- Federal Reserve orders approving banking applications: mergers / acquisitions (federalreserve.gov banking-applications feed; reduced weight)
- FDIC-recorded bank mergers & consolidations, from BankFind institution history (api.fdic.gov/banks/history; covers OCC-, Fed-, and FDIC-supervised banks; reduced weight)
- FDIC BankFind Suite: quarterly Call Report data (api.fdic.gov/banks)
- Bank fields: Tier 1 risk-based capital ratio, total risk-based capital ratio, Tier 1 leverage ratio, common equity tier 1 ratio, return on assets, net interest margin, efficiency ratio, domestic deposits, noncurrent loans, loans 30 to 89 days past due, net charge-off rate, allowance for loan and lease losses, other real estate owned
- Peer-group comparison: the same Call Report ratios measured against FDIC peer-group medians (UBPR-style; reduced weight, see above)
- NCUA 5300 Call Report (ncua.gov): net worth ratio / Prompt Corrective Action capital category, for credit unions
- Credit-union fields: total assets, total shares, total loans, delinquent loans 60 days and over, year-to-date charge-offs and recoveries, year-to-date net income, allowance for credit losses on loans, net worth and net worth ratio
- Signal families added 2026-08-27. Banks: loans 30 to 89 days past due, net charge-off rate, reserve coverage of noncurrent loans, other real estate owned, and the Tier 1 leverage ratio. The last of these gives a bank electing the community bank leverage ratio framework a capital reading it previously had none of, because such a bank files no risk-based capital ratios at all. Also for banks: a provision-spike signal, which fires when the provision for credit losses more than doubles against the same quarter a year earlier. A provision is management's own estimate of losses it has not yet taken, so a sharp increase is the institution's forward judgement rather than a reported outcome, which is why it carries full weight. Credit unions: delinquency, return on assets, net charge-offs, allowance coverage, and a sustained-loss signal that fires only after two consecutive quarterly losses. Each family entered scoring only after a published distribution check showed no threshold firing on more than 15% of its universe; families above that line are ingested and cited but score zero until their thresholds are reviewed. Adding these moved the Distress Index for institutions that were already crossing the new lines and had simply not been read before.
- SEC EDGAR Full-Text Search (EFTS) at efts.sec.gov
- Forms: 10-K (annual), 10-Q (quarterly)
- Terms: substantial doubt, material weakness, BSA/AML, cybersecurity incident, significant deficiency
- SEC EDGAR 8-K filings, Item 5.02 (departure/appointment of directors/officers)
- Retrieved via the SEC submissions API, one request per institution CIK
- SEC EDGAR 8-K full-text search (EFTS)
- Terms: 'core banking', 'digital banking', 'Item 1.05' (cybersecurity incident)
- 8-Ks are mandatory current-event filings, so they carry higher signal quality than job postings
- Free-tier news API or RSS aggregation
- Off by default: excluded from scored index unless opted in
- Never the sole basis for outreach
Phase 0 Limitations
Phase 0 is built entirely on free public data sources. This is a deliberate architectural choice. It establishes the citation standard and the product experience before any paid feeds are introduced. It also means there are real coverage gaps, documented here.
- L-lens is partial. Leadership transitions for publicly traded bank holding companies are captured via SEC 8-K filings. Private community banks (~90% of the universe) do not file 8-Ks for executive changes. Full leadership coverage requires licensed workforce data (Revelio Labs, Live Data Technologies), available at the Wire tier.
- O-lens is partial. Operational signals are sourced from SEC EDGAR 8-K filings, so only public BHCs that file 8-Ks. Private-bank RFPs and job-posting data require licensed feeds, available at Wire tier.
- FDIC enforcement is read directly from the FDIC's own orders database. Since July 2026, Tellsign ingests orders.fdic.gov directly, and every FDIC signal cites its own order PDF and carries its docket number. The two prior ingestion paths (the Federal Register API and FDIC press releases) stay live as the documented backup, so an FDIC website change degrades freshness, never coverage. OCC, Federal Reserve, and CFPB enforcement is likewise ingested directly.
- Ingestion is daily; Brief-tier alerting is weekly. Each signal lens is ingested once per day on a staggered morning schedule (11:00–13:20 UTC), and the Distress Index recomputes every three hours from whatever signals exist. Brief-tier email alerting is a weekly Monday digest; Wire adds daily and real-time alerts.
- No licensed financial data. The F-lens uses publicly available FDIC Call Report data, refreshed quarterly with a ~45-day lag after quarter-end. Licensed intra-quarter data (SNL, S&P Market Intelligence) is out of Phase 0 scope.
- Credit-union coverage is Financial-led. Phase 0 covers both FDIC-insured banks and NCUA-insured credit unions (~4,300), reachable as an independent universe segment. For credit unions the deep, live, cited lens is Financial the NCUA 5300 Call Report net worth ratio / Prompt Corrective Action capital category, matched directly by charter. Confirmed coverage is thin at the institution level: the NCUA administrative orders are overwhelmingly actions against affiliated individuals (former employees), which we cite and show but exclude from the institution Distress Index; institution-level credit-union Confirmed signals come only from the cross-regulator sources that act against the institution itself. The Disclosed, Leadership, and Operational lenses ride SEC EDGAR filings, which member-owned credit unions do not file, so those three are structurally thin for credit unions in Phase 0. Every gap is surfaced on the credit-union profile, not hidden.
- Non-bank lender coverage is Confirmed-led.The observed universe includes the covered non-bank lenders Tellsign's customers also sell into: consumer and auto finance companies, mortgage companies, and similar licensed lending companies. Every non-bank entity carries a registry anchor (an SEC CIK, a state regulator's own license identifier, or a federal case document naming the registered legal entity); no entity is created from a scraped name alone. The deep, live, cited lens is Confirmed, from state regulator enforcement (led by the California DFPI actions-and-orders record) and CFPB enforcement, each cited to the regulator's own published action. Disclosed, Leadership, and Operational ride SEC filings and cover SEC-registered lenders only. Financial is structurally absent for this class: no Call Report exists for non-bank lenders, so no capital or liquidity signal is shown at any tier, ever, rather than faking a proxy. Respondents the publishing regulator classifies outside the lending classes (investment advisers, debt collectors, escrow companies) are stored and cited but never attached to the universe. Every gap is surfaced on the non-bank profile, not hidden.
Legal Notice
The Tellsign Distress Index™ is a signal-aggregation indicator derived from publicly available regulatory filings, public financial data, and public SEC filings. It is not a regulatory rating, a determination of financial condition, an investment recommendation, or a legal opinion regarding any financial institution.
All source excerpts are reproduced verbatim from the cited public documents. Users are responsible for independent verification before taking any action based on Tellsign output. Tellsign does not guarantee the accuracy, completeness, or timeliness of the underlying source data.