The Provision Lag — Q4 2025

Data: Q4 2025 Fed Funds: 3.64% · 10Y: 4.18% · 2Y: 3.47%
Delinquency rose through 2025 without a matching rise in charge-offs or provisions: The 60+ day delinquency ratio crossed 1% in Q4 2025, to 1.03%, the highest in the dataset. Charge-offs did not follow: the net charge-off rate held near 0.77%, and full-year provision expense was essentially flat year-over-year, so the gap between rising delinquency and flat losses widened all year. The data do not show under-provisioning inflating earnings: provisioning kept pace with realized losses, and ROAA rose in 2025. We read the delinquent loans as aging without converting to losses, and we expect the credit cost they carry to reach charge-offs and earnings in 2026.
Scope and limitations of this report are at its foot.

The Widening Gap

Delinquency and charge-offs came apart through 2025. System delinquency climbed from 0.80% in Q1 2025 to 1.03% in Q4 2025, while the annualized net charge-off rate stayed roughly flat: 0.82%, 0.79%, 0.76% and 0.77% in the four quarters. Charge-offs ran above delinquency in Q1 2025; by year-end delinquency sat 26 basis points higher. We read the difference as past-due balances accumulating in late buckets rather than resolving into losses.

All Federally Insured CUs: Delinquency Ratio (60+) and NCO Ratio (Ann./Full Year)
2Q23–4Q25

Source: NCUA Call Report, Q4 2025 · release v2026.2.27 · QuarterCall

Provisioning tracked realized losses rather than the delinquency build. Full-year 2025 provision expense was $14.4 billion, essentially flat against 2024 (up 1%), and the allowance grew to $23.2 billion. Provisions sized to flat charge-offs fit the losses taken so far and lag a delinquency pipeline that is rising.

Provisions and Earnings

We tested whether flat provisioning against rising delinquency flattered 2025 net income, with reserves lower than they should be. The data do not show it. Provision expense fell as a share of net interest income over the year, to 18.0% from 20.1%, because net interest income grew faster than provisioning, and ROAA rose year over year. Measured against the charge-offs taken in 2025, reserves kept pace and earnings were not overstated.

We read the exposure as one of timing: 2025's earnings are not overstated against the losses already taken, and they remain exposed to the losses today's delinquency has yet to produce. The provision lag is the gap between a delinquency rate that has already moved and the charge-offs and provisions that have not yet caught up.

By Asset-Size Cohort

Size splits the system aggregate. The over-$10B cohort carries both the highest delinquency (1.49%) and the highest charge-offs (1.31%). The aggregate net charge-off rate stays low because the mid-size and small tiers, charging off 0.47% to 0.60%, have not followed their delinquency higher. We read the largest credit unions as a quarter or two ahead in a conversion the rest of the system has yet to make.

Delinquency vs. Charge-offs by Asset-Size Cohort, Q4 2025 (annualized)

CohortDelinq. (60+)NCO RatioROAA
Under $100M1.09%0.47%0.77%
$100M–$500M0.89%0.50%0.75%
$500M–$1B0.88%0.57%0.70%
$1B–$10B0.85%0.60%0.78%
Over $10B1.49%1.31%0.81%

The Deferred Cost

We expect the aged delinquencies in the mid-size and small tiers to convert in 2026, as the largest cohort's appear to have done: net charge-offs rise, provisioning rises to match, and ROAA gives back part of 2025's gain. The lag moves that cost into 2026 without avoiding it, which is why we do not extrapolate 2025's earnings gain. The credit bill is in the mail, not yet delivered.

Connecting the Lines

This breakdown sits behind two of the System Signals — Q4 2025 (March 15, 2026): the breach of the 1% delinquency mark (Signal 1) and the earnings discussion (Signal 3). The provision lag connects them: a quarter can post a record margin and rising full-year earnings while the delinquency we expect to weigh on both is still building. The gap between delinquency and charge-offs is the measure to follow; we expect earnings to turn in the quarter it closes.


Scope and limitations
  • That delinquent loans are aging into late buckets is inferred from the gap between delinquency and charge-offs; the report shows no delinquency by bucket.
  • Reserves are judged against charge-offs already taken; no coverage of delinquent loans by the allowance is computed.
  • The tier comparison is one quarter's cross-section; that the largest tier leads the others in time is a reading of it, not a measured sequence.
  • The conversion of delinquency into charge-offs in 2026 is the report's expectation; its data ends at Q4 2025.
Data: Q4 2025 · Period 2Q23–4Q25 · release v2026.2.27 · How the figures are produced
Revisions
. Refrozen to release v2026.2.27; no printed figure changed. Edited for style. The claim that under-provisioning inflated 2025 earnings is now a hypothesis the report tests rather than a common worry; the aging of delinquent loans, the largest tier's lead and the 2026 conversion are stated as our reading and expectation; and an unmeasured description of the largest credit unions as the most consumer-concentrated was removed.
. Two sentence openings varied, at the summary and at the cohort section (TEX-01); no figure changed.
. Three figures corrected to release v2026.2.2: the Q1 2025 annualized net charge-off rate is 0.82% (was 0.83%); provision expense as a share of net interest income is 18.0% for 2025 (was 17.9%) and 20.1% for 2024 (was 18.7%).
Cite as: QuarterCall Research, “The Provision Lag — Q4 2025”, March 20, 2026, release v2026.2.27. https://quartercall.com/research/breakdowns/provision-lag-2025-q4/
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