What community banks
pay for compliance.
Compliance officer total compensation ranges from $81K at the smallest community banks to $112K at banks over $500M, and is rising faster than any other role surveyed. Salary, bonus, and three-year trends from the 2025 Fortner Bayens compensation survey.
over $500M in assets
fastest of any role surveyed
compliance officer total comp
19 states, 2025 survey
Why Canarie publishes it.
A community bank's biggest line item, after interest expense, is people. Compliance, in particular, has become the fastest-rising labor line, growing 5.9% in 2025 against an all-bank average raise of 2.8%.
The Fortner Bayens survey is the most-cited compensation dataset for independent community banks west of the Mississippi. The figures below are reproduced from the 2025 edition, paired with our analysis of what they mean for the cost of a compliant operation. They contextualize the dollar ranges in the Compliance Cost Index that follows.
Pay scales with balance sheet.
Source: Fortner Bayens 2025 Compensation Survey. n = 132 community banks across 19 states. Bonus = cash incentive compensation, excludes equity and deferred plans.
A compliance officer at the smallest community banks earns roughly $81K in total cash compensation. At banks over $250M, that climbs to $112K+.
The jump from the $150–250M tier to the $250–500M tier is the largest in the dataset, a +$14K step. This is the point at which most community banks move from a generalist compliance officer to a credentialed BSA officer and dedicated compliance manager.
Bonuses tell their own story. Below $100M they round to $3K; above $250M they exceed $11K and approach 12% of base. Variable comp is now the lever community banks use to compete for compliance talent.
| Asset size | Base salary | Bonus | Total comp | YoY raise |
|---|---|---|---|---|
| < $100M | $77,984 | $2,955 | $80,938 | +2.00% |
| $100–150M | $79,563 | $8,728 | $88,291 | +3.23% |
| $150–250M | $90,601 | $7,559 | $98,160 | +5.24% |
| $250–500M | $100,814 | $11,575 | $112,389 | +7.14% |
| > $500M | $101,343 | $11,141 | $112,484 | +5.57% |
Rising faster than any other role.
Average compliance officer comp moved from $94K in 2023 to $102K in 2025, up 8.6% in three years. The median grew faster still, narrowing the gap between average and median by $6K.
The compression between average and median is the interesting signal: the smaller banks that pull the median down are catching up, raising compliance pay to retain officers who would otherwise be poached by larger institutions and fintechs.
Against an all-bank average raise of 2.8%, compliance officer raises came in at 5.89%, faster than CEO raises of 4.44%. The talent squeeze is real and recent.
The geography of compliance pay.
Mountain states pay a $108K average for compliance officers, the highest of any well-represented region. The Plains follow at $106K. Regions with small sample sizes (≤ 6 banks) are shown for completeness but should not be read as broadly representative.
Bars in muted grey indicate regions with fewer than 7 survey responses; treat as directional only. Mountain (CO/ID/MT/UT/WY) and Plains (IA/KS/MO/ND/NE/SD) account for 45% of all responses.
Where the premium sits.
Comp by community type
Resort markets command a $31K premium over rural — a 32% gap that mirrors the broader cost-of-living spread between mountain resort communities and the agricultural economies that dominate the survey.
2025 raise distribution (all roles)
62% of banks raised base salaries by 0–3% across all roles. Compliance officers specifically saw +5.89% — more than 2x the all-role average.
What the C-suite earns.
Compliance comp is additive to existing leadership spend. These figures anchor the conversation: when a bank says it cannot afford a dedicated compliance hire, the comparable line is usually a second lending officer or an EVP's incentive plan.
| Role | Base salary range | Total comp range | vs. compliance officer |
|---|---|---|---|
| President / CEO | $196K – $302K | $167K – $413K | up to 3.7× |
| CFO | $122K – $188K | $143K – $239K | up to 2.1× |
| COO | $114K – $181K | $127K – $222K | up to 2.0× |
| Senior Lending Officer | $121K – $198K | $139K – $242K | up to 2.2× |
| Compliance Officer (top tier) | $77,984 – $101,343 | $80,938 – $112,484 | 1.0× |
Who answered the survey.
Top states by responses
Compliance officer salaries grew faster than CEO salaries in 2025 (5.89% vs 4.44%). The fight for compliance talent has overtaken the fight for executive talent at community banks.
Fortner Bayens, PC — 2025 Independent Financial Institution Compensation Survey, 36th Edition, October 2025. Contact: Philip Schuyler, schuylerp@fbl.cpa · www.fbl.cpa.
A compliance officer costs $112K+ before benefits.
Below: how much of your bank's operating expense actually goes to compliance, what your peers spend, and where you rank in your state and asset tier — built from the same FFIEC call report data the regulators use.
The Community Bank
Compliance Cost Index.
A peer benchmark of operating efficiency and estimated compliance spend across 4,053 U.S. community banks. Built from FFIEC call report data, Q1–Q4 2025.
efficiency ratio
vs. largest tier
median bank (upper bound)
ranked this edition
Why Canarie publishes it.
Canarie builds compliance automation for community banks: document review, exam preparation, and BSA/AML and CRA workflows.
The FFIEC publishes the underlying numbers every quarter. We read them so the conversation about where compliance cost lives, and how it scales with bank size, can be grounded in data instead of anecdote.
The Index is free and ungated. The methodology is fully disclosed. If a personalized tear-sheet for your institution would be useful, the form at the end of this page will get you one within two business days.
The national snapshot.
Across 4,053 U.S. community banks meeting our peer criteria, the median efficiency ratio in Q4 2025 was 63.0%. The typical bank spent 63 cents in operating expense for every dollar of revenue.
The distribution is right-skewed. A long tail of banks above the 90th percentile, those operating at 83% or worse, pull the average meaningfully above the median. These are the institutions where compliance, technology, and infrastructure costs have begun to compound faster than revenue can keep up.
The trend across 2025 was modestly favorable: the national median fell from 65.0% in Q1 to 63.0% in Q4. Improvements were uneven. The smallest banks captured the least of it.
Distribution, Q4 2025
Source: FFIEC call reports, Q4 2025. n = 4,053 banks. Bins of 5 percentage points.
Quarterly trend by asset tier
Every tier improved over 2025, but unevenly. The largest banks (over $10B) compressed their median by 1.4 pts, while sub-$100M banks improved by only 1.0 pts.
The economic gap between tiers is structural. Compliance, core technology, and risk infrastructure are largely fixed costs. A $10 billion bank can spread them across one hundred times more revenue than a $100 million bank, and it shows up in the ratio every quarter, the same way.
The spread between the smallest and largest banks, 12.6 percentage points at the median, is the entire story of this Index.
The compliance cost estimate.
If your bank is the median bank: roughly $404M in assets, operating at the national median ratio of 63.0%, you are likely spending between $318K and $763K annually on compliance.
That estimate applies an industry-standard 5 to 12% multiplier to estimated non-interest expense, a range derived from compliance officer surveys conducted by community banking trade associations. As a percentage of revenue, the smallest banks pay roughly twice what the largest pay for the same regulatory perimeter.
Estimated annual compliance cost: median bank, by tier
Methodology: revenue proxy = 2.5% NIM × total assets; non-interest expense = efficiency ratio × revenue; compliance share = 5–12% of non-interest expense. Figures are illustrative and intended for peer benchmarking only.
Asset tier benchmarks.
If the national median is the headline, the tier median is the verdict. The harder question for any community bank executive is where they sit against banks of their own size.
The chart below plots, for each tier, the 25th-to-75th percentile range (the middle half of banks). The dark mark inside each box is the tier median. The thin lines extend to the 10th and 90th percentile whiskers. If your Q4 2025 ratio places you to the right of your tier's box, you are in the worst quartile of your peer group.
State rankings.
Geography is destiny in community banking, or close to it. Banks in Utah operate at a median of 51.5%; banks in New Hampshire operate at 81.7%. A 30.2-point gap inside one country, one currency, and one regulatory regime.
Most efficient states
| State | Median | vs Nat'l | Banks |
|---|---|---|---|
| Utah | 51.5% | −11.5 | 37 |
| New Mexico | 51.6% | −11.4 | 27 |
| Puerto Rico | 53.5% | −9.5 | 3 |
| Delaware | 58.0% | −5.0 | 16 |
| South Dakota | 58.1% | −4.9 | 51 |
Least efficient states
| State | Median | vs Nat'l | Banks |
|---|---|---|---|
| New Hampshire | 81.7% | +18.7 | 16 |
| District of Columbia | 77.8% | +14.8 | 3 |
| Arizona | 77.0% | +14.0 | 11 |
| Connecticut | 76.0% | +13.0 | 27 |
| Vermont | 74.8% | +11.8 | 12 |
Most efficient banks
Lowest Q4 ratio| Bank | Q4 | Δ |
|---|---|---|
SERVISFIRST BANK HOMEWOOD | 31.7 | -3.0 |
EVABANK EVA | 39.6 | -6.8 |
FIRST JACKSON BANK STEVENSON | 42.0 | +1.1 |
COMMERCEONE BANK BIRMINGHAM | 42.5 | 0.0 |
FIRST STATE BANK OF DEKALB COUNTY, INC. FORT PAYNE | 42.7 | +1.0 |
FIRST METRO BANK MUSCLE SHOALS | 43.7 | -2.1 |
METRO BANK PELL CITY | 47.1 | -0.1 |
FIRST COMMUNITY BANK OF CENTRAL ALABAMA WETUMPKA | 48.1 | -3.9 |
FIRST BANK OF ALABAMA TALLADEGA | 48.1 | -5.7 |
RIVER BANK & TRUST PRATTVILLE | 48.3 | -1.5 |
Least efficient banks
Highest Q4 ratio| Bank | Q4 | Δ |
|---|---|---|
NOVA BANK HUNTSVILLE | 102.2 | -35.8 |
COMMONWEALTH NATIONAL BANK MOBILE | 101.7 | -12.2 |
LOCAL BANK TUSCALOOSA | 100.7 | -7.6 |
FIRST FEDERAL BANK, A FSB TUSCALOOSA | 97.1 | -2.7 |
FARMERS & MERCHANTS BANK WATERLOO | 86.1 | +21.3 |
UNION STATE BANK PELL CITY | 82.9 | -14.1 |
SOUTHERN BANK COMPANY, THE GADSDEN | 82.8 | +0.4 |
BRANTLEY BANK & TRUST COMPANY BRANTLEY | 80.4 | -9.2 |
FIRST NATIONAL BANK AND TRUST ATMORE | 78.9 | +0.1 |
COMMERCIAL BANK OF OZARK, THE OZARK | 78.9 | +8.4 |
Showing top & bottom 10 of 88 banks in Alabama.
Get the full state breakdown with individual bank scores, peer comparisons, and compliance cost estimates.
The watch list.
The ten community banks with the highest efficiency ratios in their asset tier as of Q4 2025. It is uncomfortable. It is also entirely public information, sourced from FFIEC call reports, assembled here for the first time as a peer-comparable list.
A high ratio is not, by itself, a sign of poor management: newly chartered institutions, banks executing a major systems conversion, and trust-only institutions all read high for reasons unrelated to operational discipline. We name the banks; the explanation is theirs to provide. Δ shows Q1 to Q4 change. Negative means improvement.
Tier 1 < $100M
| Institution | Location | Assets | Q1 '25 | Q4 '25 | Δ | |
|---|---|---|---|---|---|---|
| 01 | West Valley National Bank | Goodyear, AZ | $78M | 143.5 | 142.0 | -1.5 |
| 02 | Granger National Bank, the | Granger, TX | $52M | 138.2 | 139.7 | +1.5 |
| 03 | Talbot State Bank | Woodland, GA | $53M | 142.4 | 138.6 | -3.7 |
| 04 | Tarboro Savings Bank, SSB | Tarboro, NC | $55M | 142.5 | 137.5 | -5.0 |
| 05 | Eureka Homestead | Metairie, LA | $92M | 126.6 | 129.5 | +2.9 |
| 06 | Producer Bank of Texas | Powell, TX | $54M | 112.6 | 125.4 | +12.8 |
| 07 | State National Bank of Groom, the | Groom, TX | $62M | 110.8 | 125.3 | +14.5 |
| 08 | First State Bank of Michigan | Decatur, MI | $81M | 136.6 | 124.9 | -11.7 |
| 09 | Sunnyside Federal Savings and Loan Association of Irvington | Irvington, NY | $87M | 123.2 | 123.6 | +0.4 |
| 10 | Vista National Bank & Trust | Harveyville, KS | $63M | 98.7 | 113.8 | +15.1 |
Tier 2 $100M – $300M
| Institution | Location | Assets | Q1 '25 | Q4 '25 | Δ | |
|---|---|---|---|---|---|---|
| 01 | Midland Federal Savings and Loan Association | Bridgeview, IL | $117M | 114.2 | 132.2 | +18.0 |
| 02 | Dearborn Federal Savings Bank | Dearborn, MI | $289M | 107.0 | 121.7 | +14.7 |
| 03 | New Horizon Bank, National Association | Powhatan, VA | $251M | 134.4 | 120.1 | -14.3 |
| 04 | United Republic Bank | Omaha, NE | $197M | 104.6 | 118.2 | +13.5 |
| 05 | Wrentham Co-Operative Bank | Wrentham, MA | $188M | 124.2 | 118.1 | -6.2 |
| 06 | Adelphi Bank | Columbus, OH | $106M | 138.0 | 114.6 | -23.4 |
| 07 | East Wisconsin Savings Bank | Kaukauna, WI | $271M | 144.8 | 114.2 | -30.6 |
| 08 | Hibernia Bank | New Orleans, LA | $246M | 114.3 | 113.9 | -0.5 |
| 09 | Sonata Bank | Brentwood, TN | $282M | 134.2 | 112.9 | -21.3 |
| 10 | Commonwealth Community Bank, Inc. | Hartford, KY | $152M | 136.0 | 111.9 | -24.1 |
Tier 3 $300M – $1B
| Institution | Location | Assets | Q1 '25 | Q4 '25 | Δ | |
|---|---|---|---|---|---|---|
| 01 | Generations Bank | Seneca Falls, NY | $347M | 124.3 | 139.3 | +14.9 |
| 02 | Unibank | Lynnwood, WA | $409M | 101.2 | 129.5 | +28.3 |
| 03 | Community Savings Bank | Chicago, IL | $409M | 144.0 | 128.2 | -15.8 |
| 04 | Carver Federal Savings Bank | New York, NY | $696M | 144.9 | 123.1 | -21.7 |
| 05 | Piermont Bank | New York, NY | $520M | 116.7 | 120.4 | +3.7 |
| 06 | Haddon Savings Bank | Haddon Heights, NJ | $407M | 125.1 | 113.8 | -11.3 |
| 07 | Modern Bank, National Association | New York, NY | $664M | 105.6 | 110.3 | +4.7 |
| 08 | Devon Bank | Chicago, IL | $457M | 123.3 | 109.6 | -13.7 |
| 09 | First Seacoast Bank | Dover, NH | $600M | 117.8 | 109.6 | -8.2 |
| 10 | Axiom Bank, National Association | Maitland, FL | $784M | 97.8 | 108.6 | +10.8 |
Tier 4 $1B – $10B
| Institution | Location | Assets | Q1 '25 | Q4 '25 | Δ | |
|---|---|---|---|---|---|---|
| 01 | Intercredit Bank, National Association | Coral Gables, FL | $1611M | 137.7 | 138.2 | +0.5 |
| 02 | Blue Foundry Bank | Rutherford, NJ | $2162M | 118.3 | 108.4 | -10.0 |
| 03 | Bayfirst National Bank | Saint Petersburg, FL | $1299M | 79.0 | 108.0 | +29.0 |
| 04 | Torrington Savings Bank, the | Torrington, CT | $1014M | 94.8 | 106.5 | +11.7 |
| 05 | Evolve Bank & Trust | West Memphis, AR | $1287M | 117.1 | 104.4 | -12.7 |
| 06 | Patriot Bank, National Association | Stamford, CT | $1089M | 114.9 | 103.2 | -11.8 |
| 07 | United Fidelity Bank, FSB | Evansville, IN | $6292M | 127.8 | 100.6 | -27.2 |
| 08 | Newburyport Five Cents Savings Bank | Newburyport, MA | $1587M | 94.5 | 95.0 | +0.5 |
| 09 | Lincoln Savings Bank | Reinbeck, IA | $1753M | 94.4 | 94.7 | +0.3 |
| 10 | Federal Savings Bank, the | Chicago, IL | $1139M | 101.9 | 94.2 | -7.6 |
Tier 5 $10B+
| Institution | Location | Assets | Q1 '25 | Q4 '25 | Δ | |
|---|---|---|---|---|---|---|
| 01 | Flagstar Bank, National Association | Hicksville, NY | $87512M | 102.9 | 98.3 | -4.6 |
| 02 | Arvest Bank | Fayetteville, AR | $27787M | 85.9 | 83.4 | -2.6 |
| 03 | Apple Bank | New York, NY | $19220M | 83.5 | 78.9 | -4.6 |
| 04 | Bell Bank | Fargo, ND | $14444M | 78.3 | 77.1 | -1.3 |
| 05 | Usaa Federal Savings Bank | Phoenix, AZ | $107989M | 77.6 | 76.0 | -1.6 |
| 06 | Dollar Bank, Federal Savings Bank | Pittsburgh, PA | $12513M | 78.6 | 75.7 | -2.9 |
| 07 | Plainscapital Bank | University Park, TX | $12750M | 75.3 | 74.5 | -0.8 |
| 08 | Townebank | Portsmouth, VA | $19687M | 69.4 | 73.4 | +4.0 |
| 09 | Toyota Financial Savings Bank | Henderson, NV | $15432M | 58.9 | 73.3 | +14.4 |
| 10 | Washington Trust Bank | Spokane, WA | $10683M | 74.4 | 71.5 | -2.8 |
The year's biggest movers.
A 30-point swing in efficiency ratio over four quarters, in either direction, is rarely random. It is almost always the signature of a deliberate intervention, or the absence of one.
Largest improvements, 2025
| Institution | Tier | Q1 | Q4 | Δ | |
|---|---|---|---|---|---|
| 01 | Eastbank, National Association New York, NY | $100M – $300M | 104.7 | 34.6 | -70.0 |
| 02 | New Republic Bank Charlotte, NC | $100M – $300M | 121.0 | 61.9 | -59.1 |
| 03 | Salem Co-Operative Bank Salem, NH | $300M – $1B | 148.2 | 101.5 | -46.7 |
| 04 | Snb Bank, National Association Shattuck, OK | $100M – $300M | 110.8 | 66.5 | -44.2 |
| 05 | Mission National Bank San Francisco, CA | $100M – $300M | 128.5 | 86.8 | -41.7 |
| 06 | Finance Factors, Limited Honolulu, HI | $300M – $1B | 120.9 | 79.4 | -41.4 |
| 07 | Bank Michigan Brooklyn, MI | $100M – $300M | 96.0 | 55.7 | -40.3 |
| 08 | Choiceone Bank Sparta, MI | $1B – $10B | 107.3 | 67.4 | -39.8 |
| 09 | Emigrant Bank Miami, FL | $1B – $10B | 110.2 | 70.9 | -39.3 |
| 10 | Versabank USA, National Association Holdingford, MN | $300M – $1B | 96.4 | 59.0 | -37.5 |
| 11 | F & M Bank and Trust Company Manchester, GA | < $100M | 77.5 | 40.2 | -37.2 |
| 12 | Colonial Savings, Fa Fort Worth, TX | $300M – $1B | 91.6 | 55.3 | -36.4 |
Largest deteriorations, 2025
| Institution | Tier | Q1 | Q4 | Δ | |
|---|---|---|---|---|---|
| 01 | Applied Bank Wilmington, DE | $100M – $300M | 35.3 | 95.5 | +60.2 |
| 02 | Redemption Bank Salt Lake City, UT | < $100M | 57.8 | 96.7 | +38.9 |
| 03 | Port Richmond Savings Philadelphia, PA | < $100M | 33.7 | 71.4 | +37.7 |
| 04 | Banner Banks Birnamwood, WI | $100M – $300M | 63.4 | 100.7 | +37.3 |
| 05 | First National Bank and Trust Company of Miami, the Miami, OK | $100M – $300M | 45.7 | 78.3 | +32.6 |
| 06 | Bayfirst National Bank Saint Petersburg, FL | $1B – $10B | 79.0 | 108.0 | +29.0 |
| 07 | Unibank Lynnwood, WA | $300M – $1B | 101.2 | 129.5 | +28.3 |
| 08 | Bank of Wiggins Wiggins, MS | $100M – $300M | 74.2 | 101.7 | +27.6 |
| 09 | Peoples Bank of Kankakee County Bourbonnais, IL | $300M – $1B | 29.8 | 55.6 | +25.9 |
| 10 | Farmers State Bank of Aliceville, Kansas, the Westphalia, KS | $100M – $300M | 50.3 | 75.3 | +25.1 |
| 11 | Security State Bank Alexandria, SD | $100M – $300M | 46.0 | 70.8 | +24.9 |
| 12 | Commercial State Bank Republican City, NE | < $100M | 39.8 | 64.5 | +24.7 |
Your bank's number, by name.
A one-page version of this Index, personalized to your institution: your Q4 2025 efficiency ratio, your tier and state rank, your four-quarter trajectory, and your estimated compliance spend range, built from the same FFIEC data used in this report.
Book a short call and we'll walk you through your institution's numbers. Your personalized tear-sheet will follow within two business days.
Methodology.
Source data
FFIEC quarterly Reports of Condition and Income (call reports), filed by every U.S. depository institution and aggregated by the Federal Financial Institutions Examination Council. All four quarters of 2025.
Peer set
Banks with total assets > $50M and reported quarterly efficiency ratios in [20%, 150%] across all four 2025 quarters. The filter excludes 268 institutions (primarily trust-only entities and special-purpose banks), yielding a peer set of 4,053 banks.
Efficiency ratio
Non-interest expense ÷ net operating revenue (net interest income + non-interest income), per the standard FFIEC definition. Lower is better.
Asset tiers
Five tiers calibrated to community banking practice: under $100M; $100M–$300M; $300M–$1B; $1B–$10B; and over $10B.
Compliance cost estimate
The figures in Section 02 are estimates, intended for peer benchmarking and not for financial reporting. Constructed in three steps:
- Revenue proxy: 2.5% NIM × total assets.
- Non-interest expense: efficiency ratio × revenue.
- Compliance share: 5–12% of non-interest expense.
The 5–12% range is drawn from compliance-officer surveys conducted by the ICBA, ABA, and academic studies of regulatory cost incidence at community banks.
Watch list & movers
Watch list: ten banks with the highest Q4 2025 efficiency ratio in each tier. Movers: fifteen banks with the largest Q1→Q4 ratio decrease and increase, across all tiers.
Disclosure
Canarie builds compliance automation tools for community banks: document review, exam preparation, and BSA/AML workflow systems. We have a commercial interest in the conversations this Index provokes, not in any specific bank's ranking. The data is sourced exclusively from public FFIEC filings; no Canarie customer data is used in compiling this report.