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AnalysisData story

Bank concentration rose in half the country. Here is where it rose the most.

The United States lost 1,732 bank holding organizations and 16,090 branches between 2015 and 2025. Delaware's statewide deposit concentration nearly tripled, five states now sit above the 2,500 HHI line, and four banks lead 296 counties between them.

Fewer banks, fewer branches, the same national number

Between 2015 and 2025 the number of bank holding organizations with FDIC-reported branches fell from 5,919 to 4,187, a 29 percent decline. Branches fell from 89,658 to 73,568, 18 percent. The national deposit HHI barely moved, from 410 to 401, because a national HHI is the wrong instrument: nobody banks nationally.

Measured where people actually bank, the picture is different. Statewide deposit concentration rose in 26 of 51 jurisdictions and fell in 25. Above the 2,500 HHI line of the 2010 merger guidelines, which the 2023 guidelines lowered to 1,800, sit 5 states: Delaware (4,967), South Dakota (4,654), Alaska (2,678), North Carolina (2,626), and Hawaii (2,569).

The states where concentration rose the most

Delaware leads by a distance. Its statewide HHI went from 1,808 to 4,967, and its leading organization, Capital One Financial Corporation, now holds 67.8% of deposits. Most of that jump arrived in 2025, the year Capital One completed its acquisition of Discover, whose bank is chartered in Delaware. It is a real consolidation of two of the largest card issuers in the country, booked in one small state.

The rest of the list is the slower story: consolidation among regional and community banks in Ohio, Connecticut, Montana, Massachusetts, and New York, where the number of organizations fell by 16 to 30 percent and the leader's share edged up.

Largest increases in statewide deposit concentration, 2015–2025
#Name2015 HHI2025 HHIChange2025 leaderOrganizations
1Delaware1,8084,967+3,159Capital One Financial Corporation (67.8%)31 → 30
2District of Columbia1,3131,739+426Bank of America Corporation (34.7%)30 → 30
3Ohio8431,094+251U.S. Bancorp (19.7%)233 → 187
4Connecticut1,0851,283+198Bank of America Corporation (23.0%)60 → 48
5Montana9711,158+187Glacier Bancorp, Inc. (21.4%)61 → 48
6Massachusetts1,4611,637+176State Street Corporation (34.5%)163 → 114
7New York1,4721,577+105JPMorgan Chase & Co. (35.7%)204 → 172
8Pennsylvania821903+82PNC Financial Services Group, Inc., The (26.2%)211 → 153
9Arkansas460540+80Arvest Bank Group, Inc. (13.3%)124 → 108
10Illinois657737+80JPMorgan Chase & Co. (17.1%)520 → 364
Source: FDIC Summary of Deposits, June 30 vintages. Annual statewide and national rows are independent June 30 branch-deposit screens, not interpolated observations or legal market definitions. Reported ownership structures, branch booking, and jurisdiction coverage can change between vintages; deposit values are nominal and should not be read as inflation-adjusted growth.

And where it fell

Nevada went the other way, from 4,517 to 1,462, with Wells Fargo & Company now holding 24.6% of a market that a decade ago had a far more dominant leader. Minnesota and Alaska also fell. Falls are worth listing for the same reason as rises: they show that the direction is not fixed, and that ownership and booking changes can move a statewide number a long way without a single branch changing hands.

Largest decreases in statewide deposit concentration, 2015–2025
#Name2015 HHI2025 HHIChange2025 leaderOrganizations
1Nevada4,5171,462−3,055Wells Fargo & Company (24.6%)41 → 45
2Minnesota2,2821,459−823U.S. Bancorp (33.2%)351 → 272
3Alaska3,3832,678−705Wells Fargo & Company (42.2%)7 → 7
4New Mexico1,066761−305Wells Fargo & Company (20.3%)57 → 53
5New Hampshire1,3791,106−273Toronto-Dominion Bank, The (23.0%)39 → 39
Source: FDIC Summary of Deposits, June 30 vintages. Annual statewide and national rows are independent June 30 branch-deposit screens, not interpolated observations or legal market definitions. Reported ownership structures, branch booking, and jurisdiction coverage can change between vintages; deposit values are nominal and should not be read as inflation-adjusted growth.

Four banks lead 296 counties

Rank the organization with the largest deposit share in each county and four names account for 296 of them: Wells Fargo & Company (119), Truist Financial Corporation (67), JPMorgan Chase & Co. (63), and Bank of America Corporation (47). The national HHI says these banks are not dominant. The county map says they are the largest bank in one county out of every ten.

Bank organizations that lead the most counties, 2025
#NameCounties ledDeposits in those countiesLargest county led
1Wells Fargo & Company119$1.1TMinnehaha, SD
2Truist Financial Corporation67$429BFulton, GA
3JPMorgan Chase & Co.63$3.9TNew York, NY
4Bank of America Corporation47$2.6TMecklenburg, NC
5First Citizens Bancshares, Inc.42$295BSanta Clara, CA
6Huntington Bancshares Incorporated42$234BFranklin, OH
7U.S. Bancorp40$547BHamilton, OH
8PNC Financial Services Group, Inc., The29$364BAllegheny, PA
Source: FDIC Summary of Deposits, June 30 vintages. County rows are screens of positive FDIC Summary of Deposits branch balances grouped to the reported top bank holding company when available and otherwise to the insured institution. Branch-reported deposits may not represent where every customer lives or competes, county boundaries may not match a banking market, deposits are not every banking product, and these screens are not legal market definitions.

Reading the county jumps carefully

The counties with the biggest HHI increases are a mix of two things, and it would be dishonest to run the list without separating them. Some are ordinary consolidation: a county with a few banks that lost one to a merger. Others are booking effects: a national bank reports its deposits at a headquarters branch, so a suburban county in Texas or South Dakota shows a near-monopoly that no resident experiences. The rows flagged in the table are the second kind. They are real entries in the FDIC ledger and a real limit of the screen, and we show them so readers can see where the screen stops being about local competition.

Largest HHI increases among counties with at least $1 billion in deposits and three or more organizations, 2015–2025
#Name2015 HHI2025 HHIChange2025 leaderDeposits
1Denton, TXBooking effect: Charles Schwab's bank subsidiary reports deposits at its Westlake, Texas headquarters branch.1,3628,807+7,445Charles Schwab Corporation, The (93.8%)$256B
2Lincoln, SDBooking effect: Citigroup books national card and retail balances through its Sioux Falls, South Dakota charter.4,8469,650+4,804Citigroup Inc. (98.2%)$532B
3Westchester, NYBooking effect: Morgan Stanley's bank subsidiaries report deposits at a Purchase, New York branch.1,8336,118+4,285Morgan Stanley (77.8%)$273B
4Greene, NY2,7056,881+4,176Greene County Bancorp, MHC (82.3%)$3.6B
5Shelby, IN1,1935,217+4,024PNC Financial Services Group, Inc., The (71.2%)$2.4B
6Minnehaha, SDBooking effect: Wells Fargo books balances through its Sioux Falls, South Dakota charter.5,1219,107+3,986Wells Fargo & Company (95.4%)$362B
7Garfield, OK1,7125,549+3,837Central Service Corporation (73.6%)$4.3B
8Jackson, LA3,1676,976+3,809Jonesboro Bancshares, Inc. (83.0%)$1.3B
9Warren, PA4,7458,078+3,333Northwest Bancshares Inc (89.7%)$2.7B
10Gulf, FL5,1408,329+3,189Home Bancshares, Inc. (91.0%)$1.0B
11Bryan, OK4,7247,899+3,175Spend Life Wisely Company, Inc. (88.7%)$4.0B
12Wake, NC1,4794,221+2,742First Citizens Bancshares, Inc. (63.7%)$98B
Source: FDIC Summary of Deposits, June 30 vintages. Annual county rows are independent June 30 branch-deposit screens, not interpolated observations or legal market definitions. Reported ownership structures, branch booking, county names, and FIPS boundaries can change between vintages; deposit values are nominal and should not be read as inflation-adjusted growth.

What should happen

Bank merger review uses market definitions drawn decades ago and a screening process that has approved essentially every application put before it. The evidence here says the harm, where it exists, is local and cumulative: a branch closure here, an acquisition there, until a county has one bank. We think the banking agencies and the Justice Department should publish the local market definitions they use, screen every application against the county deposit table, and explain in writing when they approve a deal that pushes a county above 2,500 or leaves it with two organizations or fewer.

We also think the annual Summary of Deposits release should come with the FDIC's own concentration screen, so that the public benchmark is the agency's rather than ours.

How we counted

Statewide and national rows are independent June 30 branch-deposit screens for each year from 2015 to 2025, grouped to the reported top bank holding company. Jurisdiction counts include the District of Columbia. The county change table keeps counties with at least $1 billion in deposits and three or more organizations in 2025 so the ranking is not a list of villages; booking effects are labelled where the leading organization is a national bank reporting at a headquarters branch.

Annual statewide and national rows are independent June 30 branch-deposit screens, not interpolated observations or legal market definitions. Reported ownership structures, branch booking, and jurisdiction coverage can change between vintages; deposit values are nominal and should not be read as inflation-adjusted growth.

Analysis pieces state Antitrust Radar's editorial position. Every figure is computed from the site's published datasets at build time and links to the page that holds it. Concentration measures identify where to look; they do not by themselves establish market power, harm, or unlawful conduct.