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Operator
Operator
Greetings and welcome to the Comerica Bank third quarter 2024 earnings call. (Operator Instructions) As a reminder, this conference is being recorded. I would now turn the conference over to your host, Kelly Gage, Director of Investor Relations. Thank you. You may begin.
歡迎參加聯信銀行 2024 年第三季財報電話會議。 (操作員指示)謹此提醒,本次會議正在錄製中。現在我將會議交給東道主投資者關係總監凱利·蓋奇 (Kelly Gage)。謝謝。你可以開始了。
Kelly Gage - Director, Investor Relations
Kelly Gage - Director, Investor Relations
Thanks Melissa. Good morning and welcome to Comerica's third quarter 2024 earnings conference call. Participating on this call will be our President, Chairman, and CEO, Curt Farmer; Chief Financial Officer, Jim Herzog; Chief Credit Officer, Melinda Chausse; and Chief Banking Officer, Peter Sefzik.
謝謝梅麗莎。早安,歡迎參加聯信 2024 年第三季財報電話會議。參加本次電話會議的包括我們的總裁、董事長兼執行長 Curt Farmer;財務長吉姆·赫爾佐格;首席信貸官 Melinda Chausse;和首席銀行官 Peter Sefzik。
During this presentation, we will be referring to slides which provide additional details. The presentation slides in our press release are available on the SEC's website as well as in the Investor Relations section of our website comerica.com.
在本次簡報中,我們將參考提供更多詳細資訊的幻燈片。我們新聞稿中的簡報投影片可在 SEC 網站以及我們網站 comerica.com 的投資者關係部分取得。
The presentation in this conference call contain forward-looking statements. In that regard, you should be mindful of the risks and uncertainties that can cause actual results to vary materially from expectations. Forward-looking statements, speak only as of the date of this presentation and we undertake no obligation to update any forward-looking statements.
本次電話會議的演示包含前瞻性陳述。在這方面,您應該注意可能導致實際結果與預期有重大差異的風險和不確定性。前瞻性陳述僅代表截至本簡報發布之日的情況,我們不承擔更新任何前瞻性陳述的義務。
Please refer to the Safe Harbor statement in today's earnings presentation on slide 2. Also, the presentation in this conference call will reference non-GAAP measures. In that regard. I direct you to the reconciliation of these measures in the earnings materials that are available on our website, comerica.com. Now I'll turn the call over to Kurt who will begin on slide 3.
請參閱投影片 2 上今天收益簡報中的安全港聲明。在這方面。我會指導您在我們的網站 comerica.com 上提供的收益資料中對這些措施進行核對。現在我將把電話轉給 Kurt,他將從幻燈片 3 開始。
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Well, thank you, Kelly, and good morning everyone. Today we reported third quarter earnings of $184 million or $1.33 per share, exceeding expectations across most line items. Strong customer activity drove higher average deposits which offset the impact of lower loans and help net interest income outperform guidance for the quarter.
好吧,謝謝你,凱利,大家早安。今天,我們報告第三季收益為 1.84 億美元,即每股 1.33 美元,超出了大多數項目的預期。強勁的客戶活動推動平均存款增加,抵消了貸款減少的影響,並幫助淨利息收入超出了本季度的指導。
The downward shift in the rate curve resulted in a meaningful improvement in AOCI [opt out], contributing to 23% growth in tangible book value. Credit quality remains solid, reflecting our proven underwriting discipline as net charge offs remain historically low.
利率曲線的向下移動導致 AOCI [選擇退出] 顯著改善,有形帳面價值成長 23%。信貸品質依然穩固,反映出我們經過驗證的核保紀律,因為淨沖銷仍處於歷史低點。
While customer sentiment remains cautiously optimistic, the initial decline in rates was well-received as select businesses showed early signs of an uptick in activity nearing quarter in. However, to see a more significant shift in behavior and reinvestment, we believe customers are looking for further rate reductions confirmation of a soft landing and getting past the impending election.
儘管客戶情緒仍保持謹慎樂觀,但由於部分企業在接近季度時顯示出活動上升的早期跡象,利率的初步下降受到了歡迎。正在尋求進一步降息確認軟著陸並度過即將到來的選舉。
Before we get into more detail on our strong quarter, I wanted to take a moment to touch on the historical milestone we celebrated on August 17, Comerica's 175th anniversary. My leadership team and I spent a lot of time this past quarter, visiting our markets, meeting with customers, colleagues, and community leaders. We have a great story and a value proposition that resonates with our target market. Our customers trust us with their business and we take that responsibility seriously.
在詳細介紹我們強勁的季度之前,我想花點時間談談我們在 8 月 17 日慶祝的歷史里程碑,即聯信銀行成立 175 週年。我和我的領導團隊在上個季度花了很多時間參觀我們的市場,認識客戶、同事和社區領袖。我們有一個精彩的故事和與我們的目標市場產生共鳴的價值主張。我們的客戶信任我們的業務,我們認真對待這項責任。
As a bank, we have successfully navigated industry changes, global conflicts, and economic cycles over many years. We feel this impressive history underscores the strength of our unique model. And we believe our consistent execution along with our strategic investments position us to successfully support our customers now and into the future.
作為一家銀行,我們多年來成功應對產業變革、全球衝突和經濟週期。我們認為這段令人印象深刻的歷史凸顯了我們獨特模式的優點。我們相信,我們一貫的執行力和策略投資使我們能夠成功地為我們的客戶現在和未來提供支援。
Moving back to results, third quarter financial highlights are on slide 4. High inflation and elevated rates continue to pressure loan demand. But we saw positive momentum in deposits as average balances grew in most of our businesses.
回到業績,第三季的財務亮點在投影片 4 上。但隨著我們大多數業務的平均餘額增長,我們看到了存款的積極勢頭。
Excluding the impact of BSBY cessation, net interest income increased 1.3% over the second quarter trough. Charge off of the 8 basis points remain below historical averages and even declined slightly from last quarter's already strong results. Lower noncustomer income offset favorable trends and customer related fees and non-interest expenses were well-managed.
剔除BSBY停止的影響,淨利息收入較第二季低點成長1.3%。扣除 8 個基點仍低於歷史平均水平,甚至比上季本已強勁的業績略有下降。非客戶收入的下降抵消了有利的趨勢,客戶相關費用和非利息支出得到了良好的管理。
We continue to favor a conservative approach to capital with our estimated CET1 increasing further to 11.97%, well above our 10% strategic target. Jim will discuss our capital management strategy later in this presentation. In all, it was a great quarter with positive momentum moving into the end of the year. I will now turn the call over to Jim to review our third quarter financial results in more detail.
我們繼續傾向於對資本採取保守態度,預計 CET1 將進一步增加至 11.97%,遠高於我們 10% 的策略目標。吉姆將在本演講稍後討論我們的資本管理策略。總而言之,這是一個偉大的季度,並以積極的勢頭進入年底。我現在將把電話轉給吉姆,以更詳細地審查我們第三季的財務業績。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Thanks, Curt, and good morning everyone. Turning to loans on slide 5, we saw some reversal of the growth signals from the second quarter with loans coming down in August. But we're encouraged to see balances relatively flat in September.
謝謝,柯特,大家早安。轉向幻燈片 5 上的貸款,我們看到第二季度的成長訊號出現了一些逆轉,8 月貸款有所下降。但我們很高興看到 9 月的餘額相對持平。
Most of the decline in average loans was in national dealer services and corporate banking. Dealers saw elevated balances in the second quarter related to the cyberattack that impacted the industry. As we look at dealer trends month to month, balances were most pressured early in the quarter and September saw more positive activity.
平均貸款下降的主要原因是全國經銷商服務和企業銀行業務。經銷商發現第二季度的餘額增加與影響該行業的網路攻擊有關。當我們逐月觀察經銷商趨勢時,本季初期的餘額壓力最大,而 9 月則出現了更多積極的活動。
Corporate banking specifically US banking saw more relative pressure than other businesses as we focus on maintaining our pricing discipline and return targets. Additionally, soft loan demand across the industry caused some bank group consolidation. US banking saw an improvement late in the quarter and period-end loans were relatively flat to June 30.
由於我們專注於維持定價紀律和回報目標,企業銀行業務(特別是美國銀行業務)比其他業務面臨更大的相對壓力。此外,整個行業的貸款需求疲軟導致了一些銀行集團的整合。美國銀行業在本季末有所改善,截至 6 月 30 日,期末貸款相對持平。
Moving the businesses that grew. Commercial real estate utilization increased which is a continuation of the trend we've seen in this elevated rate environment. However, as rates come down, we expect to see an uptick in the pace of payoffs as projects sell or refinance into the permanent market as intended.
行動成長的企業。商業房地產利用率增加,這是我們在這種高利率環境下看到的趨勢的延續。然而,隨著利率下降,隨著專案按預期出售或再融資到永久市場,我們預計回報速度將會加快。
Growth in environmental services was attributed to our renewables focus. In 2022 we formed a new renewables team and we have seen strong results. Environmental services overall is a great business for us and we feel our distinguished talent and unique expertise have allowed us to carve out a leading position in this niche industry. Touching briefly on loan yields lower [non-accrual] interest was the main driver of the 8 bps decline. And we saw only a minor drag from lower short term rates in the quarter.
環境服務的成長歸功於我們對再生能源的關注。 2022 年,我們組建了新的再生能源團隊,並取得了強勁成果。總體而言,環境服務對我們來說是一項偉大的業務,我們認為我們傑出的人才和獨特的專業知識使我們能夠在這個利基行業中佔據領先地位。簡單提及貸款收益率下降(非應計利息)是下降 8 個基點的主要驅動力。我們看到本季短期利率下降僅造成了輕微拖累。
On slide 6, we were encouraged by customer deposit activity. Average deposits increased 1.3% with growth across most business lines. Average third quarter brokered time deposits were higher due to activity late in the second quarter. However, favorable customer deposit trends allowed us to repay almost $900 million in brokered CDs by the end of the third quarter.
在投影片 6 上,我們對客戶存款活動感到鼓舞。大多數業務線的平均存款增加了 1.3%。由於第二季末的活動,第三季平均經紀定期存款較高。然而,良好的客戶存款趨勢使我們能夠在第三季末償還近 9 億美元的經紀 CD。
Despite that deliberate reduction in brokered CDs, we grew total period-end deposits by over $600 million. As we win new and expand existing relationships, we continue to see the elevated rate environment drive customers to bring those deposits into interest bearing accounts.
儘管有意減少經紀 CD,我們的期末存款總額仍增加了 6 億多美元。隨著我們贏得新的並擴大現有的關係,我們繼續看到利率上升的環境促使客戶將這些存款存入計息帳戶。
Despite continued modest cyclical pressure on non-interest bearing balances, they performed in line with their expectations and remained favorable with 38% of total deposits. We took steps to adjust pricing as the Fed began to cut rates. We plan to continue monitoring the competitive environment as we manage ongoing deposit pricing alongside additional rate cuts in the future.
儘管無息餘額持續承受適度的週期性壓力,但其表現符合預期,佔總存款的 38%,仍保持良好狀態。隨著聯準會開始降息,我們採取了調整定價的措施。我們計劃在管理持續的存款定價以及未來進一步降息的同時,繼續監控競爭環境。
With our strong relationship model, we feel well-positioned to strike the right balance between our customers' objectives with our own funding needs and profitability. Our securities portfolio on slide 7 benefited from the shift in the rate curve as we saw a 24% improvement in our valuation adjustment in the quarter. This favorable mark to market impact more than offset repayments and maturities and drove a net $130 million increase in the portfolio.
憑藉我們強大的關係模型,我們有能力在客戶的目標與我們自己的資金需求和獲利能力之間取得適當的平衡。我們投影片 7 上的證券投資組合受益於利率曲線的變化,因為我們看到本季估值調整提高了 24%。這種有利的市場影響不僅抵消了還款和到期日的影響,還推動了投資組合淨成長 1.3 億美元。
We continue to believe the expected repayments and maturities of this portfolio will enhance earnings in the coming quarters even if we resume investment at some point in 2025.
我們仍然相信,即使我們在 2025 年某個時候恢復投資,該投資組合的預期還款和到期日也將提高未來幾季的收益。
Turning to slide 8, net interest income increased $1 million to $534 million. Excluding the impact of the BSBY cessation, net interest income would have grown $7 million quarter over quarter. The shift in the rate curve allowed us to reallocate cash collateral from the CME to the Fed, benefiting net interest income.
轉向幻燈片 8,淨利息收入增加 100 萬美元,達到 5.34 億美元。排除 BSBY 終止的影響,淨利息收入將季增 700 萬美元。利率曲線的轉變使我們能夠將現金抵押品從芝商所重新分配給聯準會,從而使淨利息收入受益。
That coupled with strong customer deposits, which allowed us to pay down wholesale funding and the benefit of ensuring swaps and securities offset pressures from BSBY cessation, lower loans, and non-interest bearing deposit balances.
再加上強勁的客戶存款,使我們能夠支付批發資金,並確保掉期和證券抵消 BSBY 停止、貸款減少和無息存款餘額帶來的壓力。
As shown on slide 9, successful execution of our interest rate strategy and the composition of our balance sheet has made us slightly liability sensitive and allows us to better protect our profitability from a declining rate environment. By strategically managing our swap and securities portfolio, while considering balance sheet dynamics, we intend to maintain our insulated position over time.
如投影片 9 所示,我們的利率策略的成功執行和資產負債表的組成使我們對負債稍微敏感,並使我們能夠更好地保護我們的獲利能力免受利率下降環境的影響。透過策略性地管理我們的掉期和證券投資組合,同時考慮資產負債表的動態,我們打算隨著時間的推移保持我們的絕緣頭寸。
We feel credit quality remains a competitive strength as our overall trends in the third quarter remain solid and relatively unchanged from the second quarter, as shown in slide 10. Net charge offs remained low at 8 bps. Criticized loans were essentially flat and nonperforming assets remained well below historical averages. The overall economic outlook was also relatively unchanged, but lower average loans especially in lower risk portfolios drove an increase in the allowance for credit losses to 1.43% of total loans.
我們認為信貸品質仍然是一種競爭優勢,因為我們第三季的整體趨勢保持穩健,並且與第二季相比相對沒有變化,如投影片10 所示。 。受批評的貸款基本上持平,不良資產仍遠低於歷史平均。整體經濟前景也相對沒有變化,但平均貸款(尤其是風險較低的投資組合)的下降推動信貸損失準備金增加至貸款總額的 1.43%。
Even though our portfolio remains strong, we have potential for even further improvement if lower rates materialize and inflationary pressures abate. Regardless, we feel our proven conservative credit discipline continues to position us well to outperform peers through the cycle.
儘管我們的投資組合仍然強勁,但如果利率下降且通膨壓力減弱,我們還有進一步改善的潛力。無論如何,我們認為我們經過驗證的保守信貸紀律繼續使我們能夠在整個週期中跑贏同行。
On slide 11 third quarter, non-interest income of $277 million decreased $14 million from the second quarter, primarily due to non-customer related income. Changes in the value related to our BSBY derivative drove a negative $11 million variance as we recognized a $5 million loss in the third quarter compared to a $6 million gain in the second quarter.
在投影片 11 中,第三季非利息收入為 2.77 億美元,較第二季減少 1,400 萬美元,主要是由於非客戶相關收入。與我們的 BSBY 衍生性商品相關的價值變化導致了 1,100 萬美元的負差異,因為我們確認第三季虧損 500 萬美元,而第二季則獲利 600 萬美元。
Risk management hedging income declined $10 million as the lower rate curve reduced the amount of required collateral held at the CME. While this resulted in a decline in non-interest income, part of this benefited net interest income.
由於較低的利率曲線減少了 CME 所需抵押品的數量,風險管理對沖收入下降了 1000 萬美元。雖然這導致非利息收入下降,但其中一部分受益於淨利息收入。
We saw encouraging trends in several customer related categories with increased syndication fees, derivative income, commercial lending fees, and a small increase in commercial service charges. Fiduciary income was down, but excluding the $3 million seasonal tax related benefit in the second quarter, it would have been up consistent with improved market performance. We continue to be encouraged by the progress and targeted initiatives designed to further enhance non-interest income.
我們看到一些與客戶相關的類別出現了令人鼓舞的趨勢,銀團費用、衍生性商品收入、商業貸款費用以及商業服務費小幅增加。信託收入有所下降,但如果不包括第二季 300 萬美元的季節性稅收相關收益,信託收入將會隨著市場表現的改善而成長。我們繼續對旨在進一步提高非利息收入的進展和有針對性的舉措感到鼓舞。
Expenses on side 12, increased $7 million over the prior quarter. Salaries and benefits were up $12 million, which included a $4 million increase in deferred compensation, which was mostly offset with a non-interest income and various other smaller increases.
Side 12 的費用比上一季增加了 700 萬美元。工資和福利增加了 1200 萬美元,其中包括增加了 400 萬美元的遞延薪酬,這大部分被非利息收入和其他各種較小的增長所抵消。
FDIC expenses declined by $8 million partially due to a $4 million favorable accrual adjustment in the third quarter compared to a $3 million expense in the second quarter, both related to the special assessment. In all, we feel expenses were well-controlled and we continue to prioritize opportunities to drive positive operating leverage and improved efficiency.
FDIC 支出下降了 800 萬美元,部分原因是第三季進行了 400 萬美元的有利應計調整,而第二季支出為 300 萬美元,兩者都與特別評估有關。總而言之,我們認為費用得到了很好的控制,我們繼續優先考慮推動積極營運槓桿和提高效率的機會。
As shown on slide 13, our already strong capital position improved further in the third quarter. Solid profitability, lower loans, and conservative capital management, drove our estimated CET1 to 11.97%. Adjusting for the AOCI opt out, our estimated CET1 would have been 9.12% which is well above required regulatory minimums and buffers.
如投影片 13 所示,我們本已強勁的資本狀況在第三季進一步改善。穩健的獲利能力、較低的貸款和保守的資本管理使我們估計的 CET1 達到 11.97%。在根據 AOCI 選擇退出進行調整後,我們估計的 CET1 將為 9.12%,遠高於監管最低要求和緩衝。
Movement in the forward curve coupled with ongoing repayments and maturities in our securities portfolio resulted in a 32% improvement in AOCI, increasing our tangible common equity ratio by over 150 basis points.
遠期曲線的變動加上我們證券投資組合的持續還款和到期,使 AOCI 提高了 32%,使我們的有形普通股權益比率增加了 150 個基點以上。
Considering our compelling estimated CET1 well in excess of our strategic target and the favorable movement in the rate curve, we plan to utilize a portion of our excess capital to repurchase $100 million of our common stock shares starting in the fourth quarter.
考慮到我們令人信服的估計 CET1 遠遠超過我們的戰略目標以及利率曲線的有利變動,我們計劃從第四季度開始利用部分超額資本回購 1 億美元的普通股。
Allocating capital to support our customers' loan needs always remains our first priority. So we intend to be measured in our approach and calibrate the size and frequency of future repurchases with expected loan trends. We will also continue to closely watch the forward curve, our profitability, the broader economic environment, and any regulatory updates as they may also influence our strategy.
分配資金來支持客戶的貸款需求始終是我們的首要任務。因此,我們打算透過我們的方法進行衡量,並根據預期的貸款趨勢來校準未來回購的規模和頻率。我們也將繼續密切關注遠期曲線、我們的獲利能力、更廣泛的經濟環境以及任何監管更新,因為它們也可能影響我們的策略。
Moving to slide 14, we do not yet have any meaningful update regarding the timing or specifics of the transition of the Direct Express Program. As a reminder, our current contract allows fiscal service to utilize up to a three year extension under our current terms. Fiscal Service would need to notify us of their intention to extend no later than early December, so we expect to hear more before the end of the year.
轉到幻燈片 14,我們還沒有關於 Direct Express 計劃過渡的時間或細節的任何有意義的更新。提醒一下,我們目前的合約允許財務服務根據我們目前的條款延長最多三年。財政服務部門需要在 12 月初之前通知我們他們延長延期的意向,因此我們預計在年底之前會聽到更多消息。
However, our expectation of the timing of deposit transition has not changed. Based on the size, complexity, and critical nature of this program, our experience leads us to believe this transition may be longer rather than shorter. We do not anticipate an impact to 2024 deposit balances, non-interest income or expenses. In fact, it is possible we may not see a significant impact to average deposit balances in 2025, although we need more information on the proposed transition plan to confirm.
不過,我們對存款過渡時機的預期並沒有改變。根據該計劃的規模、複雜性和關鍵性質,我們的經驗使我們相信這一過渡可能會更長而不是更短。我們預計 2024 年存款餘額、非利息收入或支出不會受到影響。事實上,我們可能不會看到 2025 年平均存款餘額受到重大影響,儘管我們需要有關擬議過渡計劃的更多資訊來確認。
In the meantime, we plan to continue prioritizing targeted deposit strategies aligned with our core relationship operating model to further enhance our funding position and prepare for an eventual transition.
同時,我們計劃繼續優先考慮與我們的核心關係營運模式一致的有針對性的存款策略,以進一步增強我們的融資狀況並為最終過渡做好準備。
Our outlook for 2024 is on slide 15. We project 2024 average loans to be 5% lower than 2023. Muted demand which we feel has been consistent across the industry and our deliberate optimization efforts in the latter half of 2023 are the major drivers for this decline. With some customer optimism following the third quarter rate cuts and normal seasonal patterns, we anticipate modest broad-based growth in the fourth quarter.
我們對2024 年的展望見幻燈片15。驅動因素衰退。由於第三季降息和正常季節性模式後一些客戶持樂觀態度,我們預計第四季將出現溫和的廣泛成長。
One of the bigger variables will be our commercial real estate business as we believe loan balances in this business may have peaked. Depending on the pace and size of further rate cuts, we could see a more rapid reduction in balances than projected in that business. Full year average deposits are projected to be down 3% to 4% from 2023.
更大的變數之一將是我們的商業房地產業務,因為我們認為該業務的貸款餘額可能已經達到頂峰。根據進一步降息的速度和規模,我們可能會看到該業務的餘額減少速度比預期更快。預計全年平均存款較 2023 年下降 3% 至 4%。
This slight reduction relative to last quarter's guidance is driven by the expectation of an approximate $1 billion decline in year-over-year brokered time deposits, not customer related trends. Further reductions in brokered time deposits are also driving the projected 2% decline in average deposits in the fourth quarter as fourth quarter customer deposits are projected to remain relatively flat.
與上季指引相比略有下降的原因是經紀定期存款年減約 10 億美元的預期,而不是與客戶相關的趨勢。經紀定期存款的進一步減少也導致第四季平均存款預計下降 2%,因為第四季度客戶存款預計將保持相對穩定。
Although we are projecting some level of modest fourth quarter seasonality, third quarter averages were elevated by large temporary customer deposits which were distributed by quarter end as expected. Based on the high interest rate environment, we project deposit growth to continue to be concentrated in interest bearing accounts, but we still expect to maintain a favorable deposit mix in the upper 30% range.
儘管我們預計第四季度的季節性會出現一定程度的溫和,但第三季的平均水平因大量臨時客戶存款而上升,這些存款按預期在季度末分配。基於高利率環境,我們預期存款成長將繼續集中在計息帳戶,但我們仍預期將保持有利的存款結構在30%以上的範圍內。
We expect full year 2024 net interest income to decline 13% to 14% compared to 2023. This slight improvement relative to prior guidance is a result of our strong third quarter results. Fourth quarter net interest income is expected to grow 6% over the third quarter or 1% to 2% adjusting for the impact of BSBY cessation.
我們預計 2024 年全年淨利息收入將比 2023 年下降 13% 至 14%。第四季淨利息收入預計將比第三季增加 6%,或根據 BSBY 停止的影響調整後增加 1% 至 2%。
We expect no sparing deposit pressures to be more than offset by benefits from swaps, securities, and the forward curve. However, we continue to watch non-interest bearing balances and overall pricing dynamics as they could impact results.
我們預計,掉期、證券和遠期曲線的好處將足以抵消寬鬆的存款壓力。然而,我們繼續關注無息餘額和整體定價動態,因為它們可能會影響結果。
Credit quality remains strong as we produce another quarter of low net charge offs. Interest rates remain elevated and as customers continue to navigate high borrowing costs and inflationary pressures, we believe modest, manageable migration will continue.
由於我們又一個季度的淨沖銷額較低,信貸品質依然強勁。利率仍然居高不下,隨著客戶繼續應對高借貸成本和通膨壓力,我們相信適度、可控的移民將會持續。
However, given our strong results to date, we forecast full year net charge offs to remain well below our normal 20 basis point to 40 basis point range. We expect non-interest income to be flat year over year or down 2% to 3% when adjusting for BSBY and the impact of the Ameriprise transition. This reflects a modest reduction in prior guidance due to trends in risk management hedging income.
然而,鑑於我們迄今為止的強勁業績,我們預計全年淨沖銷將遠低於我們正常的 20 個基點至 40 個基點範圍。我們預計,在調整 BSBY 和 Ameriprise 轉型的影響後,非利息收入將同比持平或下降 2% 至 3%。這反映出由於風險管理對沖收入的趨勢,先前的指導略有減少。
Although the lower forward curve benefited AOCI and net interest income, it does pressure this line item. Fourth quarter non-interest income is projected to decline 1% to 2% relative to the third quarter, also driven by lower risk management hedging income.
儘管較低的遠期曲線有利於 AOCI 和淨利息收入,但它確實給該專案帶來了壓力。第四季非利息收入預計將較第三季下降 1% 至 2%,這也是受到風險管理對沖收入下降的推動。
Despite this and other non-customer related pressures, we continue to be encouraged by customer related fee income trends. Full year non-interest expenses are expected to decline 2% to 3% on a reported basis and grow 4% after adjusting for special FDIC assessments, expense recalibration, modernization, and the impact from the Ameriprise transition.
儘管有這種壓力和其他非客戶相關的壓力,我們仍然對客戶相關的費用收入趨勢感到鼓舞。根據報告,全年非利息支出預計將下降 2% 至 3%,並在根據 FDIC 特別評估、費用重新調整、現代化以及 Ameriprise 轉型的影響進行調整後增長 4%。
Fourth quarter expenses are projected to increase 3% over our strong third quarter results or 4% on an adjusted basis, as detailed on the slide. Expense discipline remains a priority as we work towards our objective of positive operating leverage. Even with modest projected loan growth in the fourth quarter and the resumption of share purchases, we expect our CET1 ratio to remain well above our 10% strategic target through year end. In all, we expect a solid fourth quarter, which will set us up nicely for a strong start to 2025. Now I'll turn the call back to Curt.
第四季支出預計將比我們強勁的第三季業績成長 3%,調整後成長 4%,如幻燈片所示。在我們努力實現積極的營運槓桿目標的過程中,費用紀律仍然是優先事項。即使預計第四季度貸款成長溫和且恢復股票購買,我們預計到年底我們的 CET1 比率仍將遠高於 10% 的策略目標。總而言之,我們預計第四季度將取得穩健的業績,這將為我們在 2025 年的強勁開局奠定良好的基礎。
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Thank you, Jim. This was an important quarter. As an industry, we saw the Fed take their first steps away from a higher for longer rate environment. For Comerica, the actions we took to deliberately minimize our natural asset sensitivity position allow us to better protect our net interest income from lower rates.
謝謝你,吉姆。這是一個重要的季度。作為一個產業,我們看到聯準會邁出了擺脫長期較高利率環境的第一步。對於聯信銀行而言,我們採取的有意盡量減少自然資產敏感性頭寸的行動使我們能夠更好地保護我們的淨利息收入免受較低利率的影響。
Additionally, rate decline should be a net positive for credit quality and loans as customer profitability improves and they resume investing in their businesses. Coupling those tailwinds with our disciplined approach to credit and expenses, along with the resumption of share repurchases creates what we believe to be positive momentum for generating compelling returns over time. We appreciate your time this morning and now we'd be happy to take your questions.
此外,隨著客戶獲利能力的提高以及他們恢復對其業務的投資,利率下降應對信貸品質和貸款產生淨正面影響。將這些有利因素與我們嚴格的信貸和支出方法結合起來,再加上股票回購的恢復,我們相信將創造出積極的勢頭,隨著時間的推移產生令人信服的回報。感謝您今天早上的寶貴時間,現在我們很樂意回答您的問題。
Operator
Operator
(Operator Instructions) Manan Gosalia, Morgan Stanley.
(操作員指令)Manan Gosalia,摩根士丹利。
Manan Gosalia - Analyst
Manan Gosalia - Analyst
So I wanted to dig in on deposits. The average deposit rates went up a little bit this quarter. I think in the prepared marks you noted that there was some brokered time deposits that were higher earlier in the quarter that you paid down. So maybe if you can expand on what drove those overall average interest bearing deposit rates higher. And if you have it, what the spot deposit costs are as of September 30 or October 15, whatever you have.
所以我想挖掘存款。本季平均存款利率略有上升。我認為在準備好的標記中,您注意到有一些經紀定期存款在您支付的季度早些時候較高。因此,也許您可以詳細說明推動整體平均計息存款利率走高的原因。如果您有的話,截至 9 月 30 日或 10 月 15 日的現貨存款費用是多少,無論您有多少。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Good morning, Manan, it's Jim. Thanks for the question. You know, we were really encouraged by the success we had in interest bearing deposits in the third quarter. On average, they were up $1.5 billion and notably on an ending basis, they were up $2.2 billion. Now we know $300 million of that was brokered, but overall just really great success in gathering interest bearing deposits.
早安,馬南,我是吉姆。謝謝你的提問。您知道,我們對第三季計息存款的成功感到非常鼓舞。平均而言,它們增加了 15 億美元,尤其是在期末基礎上,增加了 22 億美元。現在我們知道其中有 3 億美元是透過經紀進行的,但總的來說,在收取有息存款方面確實取得了巨大成功。
So I will say in the higher for longer environment that we experienced through mid to late September, I mean, increasing pay rates has been somewhat of a common trend in the industry, including Comerica. You couple on to that the fact that we had such great success in bringing in these deposits, which by the way, were very intentional. We've been really successful in paying down wholesale funding in the last few quarters.
因此,我想說的是,在我們九月中下旬經歷的長期較高的環境中,我的意思是,提高工資率已經成為該行業的普遍趨勢,包括聯信銀行。你可以考慮一下這樣一個事實:我們在引入這些存款方面取得了巨大的成功,順便說一句,這是非常有意的。在過去的幾個季度中,我們在償還批發資金方面非常成功。
That trend continues with brokered deposits being reduced, both this quarter and next quarter. And we're very happy to have those core interest bearing deposits even if we have to pay up just a little bit. So I feel like the 8 bps increase we had on a quarter-to-quarter basis was really in line, not just with the industry but well, in line with our intentions and our goal of just raising strong core customer deposits. So it's something we just felt really good about and think it's a great value proposition.
隨著本季和下季經紀存款的減少,這一趨勢仍在繼續。我們很高興擁有這些核心計息存款,即使我們只需要支付一點點。因此,我覺得我們每季成長 8 個基點確實符合產業要求,也符合我們提高核心客戶存款的意圖和目標。所以我們對此感覺非常好,並認為這是一個很好的價值主張。
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Got it and any indication on how deposit costs have [Fed] rejected since the Fed rate cut.
明白了,以及自聯準會降息以來存款成本如何被拒絕的任何跡象。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Yeah, we are really projecting very closely to what we've been planning all along. I will say the spot rate at the end of the quarter was maybe slightly lower than the month before as we started to see success with our pricing strategy.
是的,我們的計劃確實非常接近我們一直以來的計劃。我想說的是,本季末的即期匯率可能略低於前一個月,因為我們開始看到我們的定價策略取得了成功。
Overall, rates trended up a little bit as the quarter went on, I'm always hesitant to give a very spot rate on a given day because it does move around a little bit. But I will say that we are having success with our repricing.
總體而言,隨著本季的進行,利率略有上升,我總是猶豫是否要在某一天給出非常即期的利率,因為它確實會發生一點變化。但我要說的是,我們的重新定價取得了成功。
A lot of work went into this, a lot of strategy. I'm really proud of our product managers for what they've put together, not just in terms of what we're repricing, but just some of the product designs they've done to make sure that we have mix shifts that are mutually beneficial to both us and our customers.
為此做了很多工作,制定了很多策略。我真的為我們的產品經理感到自豪,因為他們所做的一切,不僅僅是我們重新定價的方面,而是他們所做的一些產品設計,以確保我們擁有相互兼容的組合轉變對我們和我們的客戶都有利。
But there will be a lot of moving parts and maybe just looking forward to the fourth quarter because I know that's really what you're interested in, the success we had in repricing deposits, I think really approached on a product basis, something approaching or a cumulative beta just north of 60%, so really happy about that.
但會有很多變化,也許只是期待第四季度,因為我知道這確實是您感興趣的,我們在重新定價存款方面取得的成功,我認為確實在產品基礎上接近,接近或累積Beta 值略高於60%,對此我感到非常高興。
But of course, a number of other things are going on, we are bringing in core deposits and being very successful in that. And that puts a little pressure on the overall beta as we looked from third quarter to fourth quarter.
但當然,還有許多其他事情正在發生,我們正在引入核心存款,並且在這方面非常成功。從第三季到第四季來看,這給整體測試版帶來了一些壓力。
We do have a little bit of mix shift going on. We do continue to survey both our customer reaction as well as the competition and what they're doing. And as I mentioned, just a little higher, jumping off point maybe at the end of the quarter than perhaps on average prior to that FOMC cut.
我們確實正在進行一些混合轉變。我們確實會繼續調查客戶的反應以及競爭對手及其正在做的事情。正如我所提到的,季度末的起點可能比 FOMC 降息之前的平均值稍高。
So if you put all that together and there's a lot going on there and a lot of variables, I do think when we get to the fourth quarter, you're going to see an overall beta relative to average FOMC rate changes probably hovering somewhere between our standard beta of 47% and that cumulative beta that we had just north of 60%.
因此,如果你把所有這些放在一起,你會發現有很多事情發生,有很多變量,我確實認為,當我們進入第四季度時,你會看到相對於平均FOMC 利率變化的整體貝塔值可能徘徊在我們的標準貝塔值為 47%,累積貝塔值為 60% 以上。
So that's something we're really pleased about, but I will say a lot of moving parts, a lot of mix shift again by design on our part as well as our customers. So it's something we're just going to have to continue to monitor, but so far a pretty successful outcome.
所以這是我們真正感到高興的事情,但我會說很多移動部件,透過我們以及我們的客戶的設計再次進行了很多混合轉換。所以這是我們必須繼續監控的事情,但到目前為止,這是一個相當成功的結果。
Manan Gosalia - Analyst
Manan Gosalia - Analyst
Got it. And do you think betas from there as we think, as we look out into 2025, what's your best guess on whether deposit betas accelerate from there? Because we get through more rate cuts or do they roughly stay the same? Because I guess, loan growth could be improving next year, maybe help us with how you're thinking through that. Thanks.
知道了。當我們展望 2025 年時,您認為貝塔值是否像我們所想的那樣,您對存款貝塔值是否會加速增長的最佳猜測是什麼?因為我們經歷了更多的降息,還是大致不變?因為我猜,明年貸款成長可能會有所改善,也許可以幫助我們了解您的想法。謝謝。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Well, first of all, I would say the rate or cuts always depends on what kind of landing we have. I've been very consistent in saying that and it does look like we're going to have a soft landing, which I think puts a little pressure on the pace of betas because it's always easier to change rates when there's perhaps a little more fear in the economy, which typically does accompany a rate reduction.
好吧,首先,我想說的是,利率或削減始終取決於我們的著陸類型。我一直非常一致地這麼說,看起來我們確實將實現軟著陸,我認為這對測試版的速度帶來了一些壓力,因為當可能有更多的恐懼時,改變利率總是更容易在經濟中,這通常伴隨著降息。
But the way I look at it is we're starting from a strong position. You know, there are probably some mid-tier rates that were hesitant to move down to this point. So I think the betas will pick up a little pace as we start to move through mid-2025, late 2025.
但我的看法是,我們是從一個有利的位置開始的。您知道,可能有一些中等水平的利率對於降低到這一點猶豫不決。因此,我認為隨著我們開始進入 2025 年中期、2025 年末,測試版的速度將會加快一些。
I think they will accelerate a little bit and then they'll probably back off as some of those rates start to approach a floor and you have to pull back a little bit. So it'll be a little bit of a U-shaped curve I suspect for the industry. But again, a lot of it's going to depend on just what happens in the overall economy and what type of landing the economy has.
我認為它們會加速一點,然後可能會回落,因為其中一些利率開始接近底部,你必須稍微回落。所以我懷疑這個產業會出現一點點 U 型曲線。但同樣,這在很大程度上取決於整體經濟的情況以及經濟的著陸類型。
Operator
Operator
John Pancari, Evercore ISI.
約翰潘卡里 (John Pancari),Evercore ISI。
John Pancari - Analyst
John Pancari - Analyst
On management's prepared comments, good to see the upside guide despite the lower deposit growth expectation and your loan growth expectation. And I know you mentioned a lot of that is partly given the third quarter performance and your fourth quarter expectation on NII, the 6% or the 1% to 2% up ex-BSBY is noted, given that curious, its loan demand remains relatively modest and you still see some continued competitive pressures around deposit pricing.
根據管理層準備好的評論,儘管存款成長預期和貸款成長預期較低,但很高興看到上行指引。我知道您提到的許多內容部分是考慮到第三季度的表現以及您對NII 的第四季度預期,注意到前BSBY 增長6% 或1% 至2%,考慮到好奇,其貸款需求仍然相對較高溫和,您仍然會看到圍繞存款定價的一些持續的競爭壓力。
How do you see NII trajecting beyond the fourth quarter? I know, looking out there, it looks like expectations could be in the mid to high single digit growth for net interest income as we look into 2025. Do you think that is reasonable if you've got a slower rebound in loan growth as we move into next year.
您如何看待第四季度之後的 NII 軌跡?我知道,展望 2025 年,預期淨利息收入可能會出現中高個位數成長。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Good morning John. It's Jim. I'm happy to take that question. Overall we're pretty bullish about net interest income in 2025. It does look like we hit an inflection point in the second quarter of this year and that's even with a little bit of BSBY drag in the third quarter, so really pleased with how that's trending,
早安,約翰。是吉姆。我很高興回答這個問題。總體而言,我們對 2025 年的淨利息收入非常看好。
I would say and as I've been saying, I think the overall trend quarter to quarter to quarter beyond where we're at now is going to be up. There could always be some anomalous quarter, whether it has to do with the timing of FOMC reductions or day count or whatever, you could always have a quarter where maybe it starts to plateau a little bit.
我想說,正如我一直在說的,我認為每個季度的整體趨勢都會超出我們現在的水平。總是會有一些異常的季度,無論是與 FOMC 降息的時間或日數或其他什麼有關,總有一個季度可能會開始趨於平穩。
But I think the general trend is going to be just continuously increasing net interest income as we move beyond 2024. So that's something we're really looking forward to. We do expect loan growth on a somewhat continuous basis in 2025. So that will be helpful also.
但我認為,隨著 2024 年之後,整體趨勢將是淨利息收入不斷增加。我們確實預計 2025 年貸款將持續成長。
I will say we're not ready to give guidance for 2025. So I'm hesitant to quote any specific loan growth numbers or net interest income numbers. But I would say overall it's a pretty nice picture in terms of just ever increasing net interest income as we move through the next not just few quarters, but few years.
我想說的是,我們還沒有準備好給出 2025 年的指導。但我想說,總體而言,隨著我們在接下來的幾個季度,甚至幾年內不斷增加淨利息收入,這是一幅相當不錯的圖景。
John Pancari - Analyst
John Pancari - Analyst
And then separately on if I could skip over to capital, your CET1 that's just shy of 12% versus your 10% target is certainly noted and I know you expect a resumption of buybacks of about $100 million in the fourth quarter. Maybe could you give us at least a trajectory on how you feel about the possible acceleration of buybacks as you go through 2025, just given that type of margin where you're running right now above your target?
然後,如果我可以跳到資本方面,您的 CET1 與您 10% 的目標相比僅差 12%,我知道您預計第四季度將恢復約 1 億美元的回購。考慮到您現在的利潤率高於目標,您能否至少給我們一個軌跡,說明您對 2025 年可能加速回購的看法?
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
I don't think we're prepared yet to talk about 2025. We do acknowledge that we're carrying very strong levels of capital. Now, we do want to stay maturely above our 10% target CET1. And frankly, I think we want to stay above probably an 11% well above an 11% CET1 target because we want to make sure we're ready for Basel III end game as it approaches, even though those rules are not quite final yet.
我認為我們還沒有準備好談論 2025 年。現在,我們確實希望成熟地保持在 10% 的 CET1 目標之上。坦白說,我認為我們希望保持在 11% 以上,遠高於 11% CET1 目標,因為我們希望確保我們為巴塞爾 III 的最終遊戲做好準備,儘管這些規則尚未最終確定。
But that still does give us a little bit of flexibility. We expect earnings to continue to be very strong going forward. But we do have to as always continue to make sure we prioritize capital for loan growth and our customers.
但這仍然為我們帶來了一點靈活性。我們預計未來獲利將持續強勁。但我們必須一如既往地繼續確保我們優先考慮貸款成長和客戶的資本。
We have to keep an eye on rates in the overall economic environment. Longer term rates and the curve shift up a little bit since the end of the quarter. And again, we are sensitive to what's going on with the AOCI and making sure that we don't get a surprise there, continue to monitor this profitability in the regulatory environment.
我們必須關注整體經濟環境中的利率。自本季末以來,長期利率和曲線略有上移。再說一次,我們對 AOCI 的情況很敏感,並確保我們不會感到意外,繼續在監管環境中監控這種獲利能力。
So it's just something we're going to have to monitor on a quarter-by-quarter basis as we move through 2025. But we do feel very comfortable with our capital position and really proud of the fact that we're starting to share repurchase this quarter.
因此,隨著 2025 年的到來,我們必須逐季度進行監控。
Operator
Operator
Jon Arfstrom, RBC Capital Markets.
喬恩‧阿夫斯特羅姆 (Jon Arfstrom),加拿大皇家銀行資本市場部。
Jon Arfstrom - Analyst
Jon Arfstrom - Analyst
Jim, maybe just bigger picture for you, can you just talk a little bit about your philosophy on hedging right now and your approach to rate management? It feels like there's a better outcome on NII and the margin if rates fall further, but just talk a little bit about what you're trying to accomplish and how we should think about NII trajectory and margin trajectory if the Fed continues cutting.
吉姆,也許對您來說只是更大的願景,您能談談您目前的對沖理念以及您的利率管理方法嗎?感覺如果利率進一步下降,NII 和利潤率會有更好的結果,但只要談談你想要實現的目標,以及如果聯準會繼續降息,我們應該如何考慮 NII 軌跡和利潤率軌跡。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Good morning, John. As you see on our sensitivity slide in the deck, we are just very slightly liability sensitive, actually a little less liability sensitive than last quarter, but still slightly liability sensitive. I've been saying that I really think of it as largely interest neutral.
早安,約翰。正如您在我們的敏感性幻燈片中看到的那樣,我們只是非常輕微的責任敏感度,實際上比上季度的責任敏感度要低一些,但仍然是輕微的責任敏感度。我一直在說,我確實認為這在很大程度上是利益中立的。
There's always a somewhat of a fixed component of that sensitivity equation that ties back to balances and the assumption that non-interest bearing balances will grow if rates continue to go down. And we may not get the full effect of that until we see a few more rate cuts. And we have some type of inflection point in terms of how customers manage their money.
在此敏感性方程中總是有一個固定的組成部分,它與餘額有關,並且假設如果利率繼續下降,無息餘額將會成長。在我們看到更多的降息之前,我們可能無法充分感受到這一點。就客戶如何管理資金而言,我們存在某種類型的轉折點。
And so I don't necessarily expect to get the full benefit of that balance until we get a few more cuts down the road. So as a result from a pure rate standpoint, I really think of us as being closer to interest neutral. And eventually, we'll get the balanced benefit of that liability sensitivity also.
因此,在我們進一步削減開支之前,我不一定期望能夠充分利用這種平衡。因此,從純粹利率的角度來看,我確實認為我們更接近利率中性。最終,我們也將獲得責任敏感性的平衡效益。
And so I don't see the rate picture really changing things materially for us on a quarter-to-quarter basis because we are so close to neutral. And I think the real wild card really for us is going to be deposit pay rates, how competition and the customers react.
因此,我認為利率狀況不會真正對我們每季產生重大改變,因為我們非常接近中性。我認為對我們來說真正的變數是存款利率、競爭和客戶的反應。
I think that's probably got a wider range of outcome than what you might argue in terms of asset and liability sensitivity assumption, so much closer to interest neutral. The good news is I feel like we are insulated from any drop in rates and should be protected from that
我認為這可能比你在資產和負債敏感性假設方面所爭論的結果更廣泛,更接近利益中性。好消息是我覺得我們不會受到任何利率下降的影響,並且應該受到保護
Jon Arfstrom - Analyst
Jon Arfstrom - Analyst
Okay. And it feels like you're starting to get the early signs of maybe a little bit of customer acceptance to lower deposit rates. Is that a fair assessment?
好的。感覺就像你開始看到客戶可能接受降低存款利率的早期跡象。這是一個公平的評價嗎?
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Yeah, I think so. We feel so and Peter may want to comment too, but I've been really pleased with how it's received and our relationship managers are doing a great job shepherding these through and explaining to the customers and I'll give credit to our customers. They understand it. And when they ask for rate increases as rates were going up and I think they understand that when rates go down, we have to be a little bit symmetrical there. And so overall, I feel like it's going really well,
是的,我想是的。我們也這麼認為,彼得也可能想發表評論,但我對收到的回饋感到非常滿意,我們的客戶關係經理在引導這些問題並向客戶解釋方面做得很好,我會讚揚我們的客戶。他們明白。當他們要求隨著利率上升而提高利率時,我認為他們明白,當利率下降時,我們必須在那裡保持一點對稱。總的來說,我覺得一切都很順利,
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Jon, it's Peter. I would echo that we feel like it's going really well and we're being very selective across each of our businesses. I mean, some of them, we can achieve more success than others. But I think our continuous message is about our relationship strategy and being able to have these conversations before customers make moves is proven to be very successful. So I would echo what Jim's comments are there.
喬恩,是彼得。我想說的是,我們感覺進展非常順利,而且我們對每項業務都非常有選擇性。我的意思是,對於其中一些人,我們可以比其他人取得更多的成功。但我認為我們持續傳達的訊息是關於我們的關係策略,並且能夠在客戶採取行動之前進行這些對話被證明是非常成功的。所以我同意吉姆的評論。
John Pancari - Analyst
John Pancari - Analyst
Okay. And then just one kind of a follow up on John's question on loan growth, but you talked, you guys flagged a couple of times CRE payoffs and maybe an uptick in CRE payoffs, but on the flip side, maybe some better potential lending growth if rates do fall. How do you kind of square that, how material do you think the CRE payoffs might be? And this kind of gets to the '25 loan growth question, but is that just a real impediment to 2025 growth?
好的。然後只是對約翰關於貸款增長的問題的一種跟進,但你們談到了,你們標記了幾次 CRE 收益,也許 CRE 收益有所上升,但另一方面,也許一些更好的潛在貸款增長,如果利率確實下降了。您認為 CRE 的回報可能有多大?這就涉及到 25 年貸款成長問題,但這真的是 2025 年成長的真正障礙嗎?
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Yeah, Jon, it's Peter. It's certainly something we're watching. I think it's yet to be determined of how much of a headwind it is or isn't. I would say we feel like CRE loans have peaked in the third quarter here. And so it probably is sort of a downward slope as we get into next year.
是的,喬恩,是彼得。這當然是我們正在關注的事情。我認為目前還無法確定這到底是多大的逆風。我想說的是,我們認為商業房地產貸款已在第三季達到頂峰。因此,當我們進入明年時,它可能會呈下降趨勢。
Now that said, I think we feel like the rest of the portfolio will perform in the opposite direction and hopefully be able to offset that headwind. So and we'll talk more about '25 outlook when we talk about our next call. But at least as we sit today, I think CRE is probably a downward slope from here on and our expectation is with rates coming down further, sort of where we feel like the rest of the portfolio maybe has bottomed a little bit, that will hopefully offset the headwind on CRE.
話雖如此,我認為我們認為投資組合的其餘部分將朝著相反的方向表現,並希望能夠抵消這種不利因素。因此,當我們談論下一次電話會議時,我們將更多地討論 '25 的前景。但至少就我們今天而言,我認為從現在開始,CRE 可能會呈下降趨勢,我們的預期是利率進一步下降,我們感覺投資組合的其餘部分可能已經觸底,這將有望實現抵消華商創業的逆風。
Operator
Operator
Bernard Von Gizycki, Deutsche Bank.
伯納德·馮·吉茲基,德意志銀行。
Bernard Von Gizycki - Analyst
Bernard Von Gizycki - Analyst
So just a quick question, a modeling question on the risk management hedge income, given the geography change. So is there a rule of thumb on how much risk management income would decline and [net I] increase on a 25 basis points rate cut?
這只是一個簡單的問題,考慮到地理變化,風險管理對沖收入的建模問題。那麼,對於降息 25 個基點,風險管理收入會下降多少,[淨 I] 會增加多少,是否有一個經驗法則呢?
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Good morning, Bernard. I don't necessarily have a rule of thumb for you, but you can probably look at how three to five year treasuries move this quarter and draw a little bit of a conclusion relative to the previous quarter because it is tied to our swaps and our swaps do have a much shorter duration than our bond portfolio.
早安,伯納德。我不一定有適合您的經驗法則,但您可能可以看看本季度三到五年期國債的走勢,並相對於上一季度得出一些結論,因為它與我們的掉期和我們的利率有關。
But we did see a shift of income as we mentioned in the script from non-interest income to net interest income, you see that on the non-interest income slide, risk management hedge income was down $10 million. Net interest income probably benefited from $8 million of that in the third quarter and net interest income will continue to benefit from that in the fourth quarter.
但我們確實看到了收入的轉變,正如我們在腳本中提到的,從非利息收入到淨利息收入,你會看到在非利息收入幻燈片上,風險管理對沖收入減少了 1000 萬美元。淨利息收入可能受益於第三季的800萬美元,淨利息收入將繼續受益於第四季。
So we do have some positive inflows in the net interest income. And I think on the strength of those, we did improve our outlook reflecting in part the great third quarter success. And I do think as I look to that down 13% to 14% guide, I do think we have a really good shot at being closer to the 13% than the 14%. So we continue to look at really strong in [net interest income]. And I think that explains some of the weakness in the non-customer portion on the non-interest income side.
因此,我們的淨利息收入確實有一些正流入。我認為,憑藉這些優勢,我們確實改善了我們的前景,部分反映了第三季的巨大成功。我確實認為,當我查看 13% 至 14% 的下降指引時,我確實認為我們很有可能更接近 13%,而不是 14%。因此,我們持續關注[淨利息收入]的強勁表現。我認為這解釋了非利息收入方面非客戶部分的一些弱點。
Bernard Von Gizycki - Analyst
Bernard Von Gizycki - Analyst
Got it. And then just separately, I appreciate that the forward curve has changed. It feels like it's ebbed and flowed, just even day by day. But on slide 7 of the deck, you estimate the securities, AOCI, unrealized losses were declined by, I think it's about 16% by [1C '26]. The footnote, I believe it's the forward curve at 9/30, you know, given changes in the forward curve since then, there's like two less rate cuts priced in. Just wondering any idea of the impact from, from just higher forward curve versus the 9/30 that I believe is assumed in that assessment?
知道了。然後單獨地,我意識到遠期曲線已經改變了。感覺就像潮起潮落,甚至日復一日。但在投影片 7 上,您估計證券、AOCI、未實現損失下降了,我認為 [1C '26] 下降了大約 16%。腳註,我相信這是 9/30 的遠期曲線,你知道,考慮到自那時以來遠期曲線的變化,定價中似乎減少了兩次降息。該評估中假設的是9/30?
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
You know, it's been moving around quite a bit since 9/30 trending up somewhat. So I don't really have a number for you as to where it sits today. We do have some sensitivities on the capital slide that point to overall AOCI and a large portion of that, a vast majority of that relates to bonds. So that's a little bit of a harbinger that you can look at there. But overall, we'll just have to wait and see, where rates end up in the fourth quarter.
你知道,自 9/30 以來,它一直在波動,有一定的上升趨勢。所以我真的沒有具體的數字告訴你它今天的位置。我們確實對資本下滑有一些敏感性,這些敏感性指向整體 AOCI,其中很大一部分與債券有關。所以這是一個你可以看到的預兆。但總的來說,我們只能拭目以待,看看第四季的利率最終會如何。
Operator
Operator
Ben Gerlinger, Citi.
班傑林格,花旗銀行。
Ben Gerlinger - Analyst
Ben Gerlinger - Analyst
Just kind of high level, a little more philosophical than anything. So you guys, you stuck your neck out a little bit this year in terms of loan growth expectations and please by no means feel like I'm picking on you because everyone seemed to and then everyone seemed to walk it back a bit just because you have a little bit more of a national and commercial footprint than most of my coverage, I'd say on average. When you think about kind of the impediments, why loan demand really wasn't there?
只是有點高水平,比任何東西都更有哲理一點。所以,你們今年在貸款成長預期方面有點不顧一切,請不要覺得我在挑剔你們,因為每個人似乎都這樣,然後每個人似乎都因為你們而退縮了一點。它的全國性和商業足跡比我的大部分報告要多一些。當您考慮各種障礙時,為什麼貸款需求真的不存在?
And is there anything that stood out, is it other than just lack of rate cuts? And then kind of as we go into next year, I mean, does political uncertainty actually fix anything or is there kind of inflection points on rates where you might see demand? Just kind of thoughts on what you're hearing from boots on the ground level,
除了沒有降息之外,還有什麼值得注意的地方嗎?然後,當我們進入明年時,我的意思是,政治不確定性是否真的能解決任何問題,或者利率是否存在某種拐點,您可能會看到需求?只是對你在地面上聽到的聲音的一些想法,
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Ben. It's Peter. It's a really good question. I don't know that my story is any more compelling than maybe some of the other things that you're hearing. But I think I would probably say that we all felt like some interest rate relief would really drive loan demand. And I think that's kind of proven to be not necessarily the case.
本.是彼得。這是一個非常好的問題。我不知道我的故事比你聽到的其他一些事情更引人注目。但我想我可能會說,我們都覺得一些利率減免確實會推動貸款需求。我認為事實證明事實並非如此。
So the feedback we're getting from our portfolio was that 50 basis points was nice, but not inspiring necessarily. And that really, I think what most of the economy is going to need to see is another 50 basis points to 100 basis points to really see some stimulation there.
因此,我們從投資組合中得到的回饋是,50 個基點很好,但不一定會鼓舞人心。事實上,我認為大多數經濟體需要看到另外 50 個基點到 100 個基點才能真正看到一些刺激。
So we certainly were feeling earlier in the year that the second half of 2024 we would start to see loan demand pick up and that really hasn't occurred. So what does that mean for going into the future? I think that probably it does become a little more of even a second half of '25 conversation about what does loan demand look like in the economy?
因此,我們在今年稍早確實感覺到,到 2024 年下半年,我們將開始看到貸款需求回升,但這實際上並沒有發生。那麼這對於走向未來又意味著什麼呢?我認為這可能確實成為 25 年下半年關於經濟中貸款需求是什麼樣的對話?
And certainly getting to the other side of the election, I think will be helpful because I do believe that business owners wait to make decisions until they understand what the tax outlook might look like for them. I think to Jim's point continuing to see the economy kind of level out here.
當然,我認為站在選舉的另一邊會有所幫助,因為我確實相信企業主會等待做出決定,直到他們了解稅收前景對他們來說可能會有所幫助。我認為吉姆的觀點是這裡的經濟持續保持穩定。
But I don't know that there's anything more compelling other than to tell you that what we are hearing is that interest rates are going to need to come down, probably another 50 basis points to 100 basis points to really start to inspire business owners to make more decisions here on investing capital.
但我不知道還有什麼比告訴你,我們聽到的是利率需要下降,可能還要再下降 50 個基點到 100 個基點,才能真正開始激勵企業主在這裡做出更多有關投資資本的決定。
Ben Gerlinger - Analyst
Ben Gerlinger - Analyst
I mean, some clarity on the political front, whether team red or team blue would definitely help. But I get what you're saying, it's kind of more of this lack of animal spirits across the board. But if you do kind of have to rank order in certain areas, that kind of might be chomping at a bit. Like economically speaking, that seem to probably want to take loans a little bit faster or anything that comes to mind that might be kind of first out of the gate to increase loan demand.
我的意思是,政治方面的一些明確性,無論是紅隊還是藍隊肯定會有所幫助。但我明白你的意思,這比較是因為全面缺乏動物精神。但如果你確實需要在某些領域進行排序,那麼可能會有點困難。從經濟角度來看,這似乎可能希望更快獲得貸款,或者任何想到的可能首先增加貸款需求的事情。
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Ben, when you look at our portfolio, I would say our national and specialty businesses have probably started to see a little bit more pick up across the board. Our pipeline feel like it actually has grown a little bit more in those businesses in the last quarter.
本,當您查看我們的投資組合時,我會說我們的國內和專業業務可能已經開始全面回升。我們的管道感覺上個季度這些業務實際上已經成長了一些。
I think it's really more general middle market C&I, where you're just going to have to have that reduction in interest rates to get the stimulant of borrowing and to your comment about animal spirits. I think your average middle market business in the country right now is just waiting for that interest rate relief. So they're not in a situation where they have to do anything. If anything they're building a little bit of cash, they're making good money.
我認為這實際上是更普遍的中間市場 C&I,你只需要降低利率即可刺激借貸並發表對動物精神的評論。我認為目前該國的平均中間市場業務只是在等待利率減免。所以他們並不處於必須做任何事情的境地。如果說他們賺了一點現金的話,那就是他們賺了很多錢。
You know, why take any chances when they believe that the outlook on interest rates is really going to be in their favor next year. On the other hand, our national specialty businesses, I think, they're going to kind of run their businesses. I don't want to say, despite interest rates, but we are seeing some pick up there. And so that's where I think you put all that together between sort of muted middle market growth, CRE coming down, and some of our other specialty businesses picking up. That's where you're hearing us talk about sort of modest to flat loan growth going into the fourth quarter and possibly next year.
你知道,當他們相信明年的利率前景確實對他們有利時,為什麼要冒險呢?另一方面,我認為,我們的國家特色企業將繼續經營自己的業務。我不想說,儘管有利率,但我們看到了一些回升。因此,我認為這就是中間市場成長疲軟、商業房地產下降以及我們其他一些專業業務回升之間的所有因素。這就是我們談論第四季度甚至明年可能出現的適度到持平的貸款成長的地方。
Operator
Operator
Chris McGratty, KBW.
克里斯·麥克格拉蒂,KBW。
Chris McGratty - Analyst
Chris McGratty - Analyst
Just wanted to get a better understanding of the guide for Q4 for NII. The plus 6% or the plus 1% to 2%, the gap was [534] in the third quarter. Is the math 6% off of that? I'm just trying to make sure I get the right NII for the fourth quarter.
只是想更了解 NII 第四季的指南。加6%或加1%至2%,第三季差距為[534]。算起來是6折嗎?我只是想確保我在第四季度獲得正確的 NII。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
It is. Yeah, it's the printed number 6% above that BSBY, obviously has about a $25 million swing. If you look at the BSBY schedule that we have from the third quarter to the fourth quarter and again, that schedules in the deck. But yeah, it is 6% on the printed number.
這是。是的,印刷數字比 BSBY 高 6%,顯然有大約 2500 萬美元的波動。如果你看一下我們從第三季到第四季的 BSBY 賽程表,你會發現這些賽程表都在甲板上。但是,是的,它是印刷數字的 6%。
Chris McGratty - Analyst
Chris McGratty - Analyst
Okay. So that would to get to that closer to 13% down, you'd be north of [560] kind of ballpark for Q4.
好的。因此,要達到接近 13% 的下降,第四季的下降幅度將達到 [560] 左右。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Yeah, pretty closer to [mid-560s to 570].
是的,非常接近 [560 年代中期到 570 年代]。
Chris McGratty - Analyst
Chris McGratty - Analyst
Okay, awesome. And then second on ECRs is a commercial bank. You know, it's kind of a hidden deposit beta. Can you maybe opine about what lever that might be in the expense line over the next few quarters?
好吧,太棒了。在 ECR 上排名第二的是商業銀行。你知道,這是一種隱藏的存款測試版。您能否對未來幾季的費用支出槓桿有何看法?
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
I think there is a little bit of opportunity with ECRs as rates continue to come down. Our ECR is actually had a much lower beta than our deposits did. So I do expect service charges to benefit over time as rates continue to come down. And I think it'll be noticeable, but I don't think it'll be huge. It'll be really just a fraction of what you're going to get on the pure deposit pay rate side.
我認為隨著利率持續下降,ECR 存在一些機會。我們的 ECR 實際上比我們的存款的貝塔值低得多。因此,我確實預計,隨著費率持續下降,服務費將隨著時間的推移而受益。我認為它會很引人注目,但我不認為它會很大。這實際上只是您在純存款支付率方面獲得的一小部分。
Operator
Operator
Samuel Varga, UBS.
塞繆爾·瓦爾加,瑞銀集團。
Samuel Varga - Analyst
Samuel Varga - Analyst
I just wanted to ask if you can put maybe a finer point on the margin in 4Q. I understand that you're looking to pay back some of the broker deposits, but I just wanted to get a sense for, I guess a finer point on how you're managing that extra liquidity and what your level of willingness is to move cash lower, move brokered lower, and sort of protect the margin a bit more.
我只是想問您是否可以在第四季的利潤率上提出更具體的觀點。我知道您希望償還一些經紀人存款,但我只是想了解一下,我想更詳細地了解您如何管理額外的流動性以及您轉移現金的意願程度走低,經紀走低,並在一定程度上保護利潤。
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Hey, good morning Samuel, we do expect the balance sheet to become a little bit more efficient as we move into the fourth quarter. On a quarter-to-quarter basis, we will see a little bit lower wholesale funding on average brokered deposits where you're going to see the biggest change as we pay down quite a few almost $900 million at the end of the third quarter in a somewhat similar amount as we move through the fourth quarter.
嘿,早上好,塞繆爾,我們確實預計,隨著進入第四季度,資產負債表會變得更有效率。按季度計算,我們將看到平均經紀存款的批發資金略有下降,其中最大的變化是我們在第三季末支付了近 9 億美元。
So we did inflate the balance sheet a little bit with excess cash supported by those higher level of broker deposits because frankly, the loan growth that we might have expected at one-time when we took those broker deposits out didn't fully materialize.
因此,我們確實用較高水準的經紀人存款支持的過剩現金稍微誇大了資產負債表,因為坦白說,當我們取出這些經紀人存款時,我們可能預期的貸款成長並沒有完全實現。
And so, I will say that we expect improvement in the NIM as we move into the fourth quarter. I think many of, you know, on the call that I really hate talking about NIM. And I think yet again, we have another example where net interest income increased even with the BSBY drag, yet the NIM went down because of dynamics of the balance sheet. So never really like to talk a lot about NIM percentage.
因此,我想說,隨著進入第四季度,我們預計淨利差將有所改善。我想,你知道,在電話會議上,我真的很討厭談論 NIM。我再次認為,我們還有另一個例子,即使受到 BSBY 的拖累,淨利息收入仍然增加,但由於資產負債表的動態,淨利息收入卻下降了。所以從來沒有真正喜歡過多談論淨利差百分比。
Having said that, it is going to move up, you know, materially just because of a more efficient balance sheet and probably end up somewhere near 3 handle, 3% as we move through the fourth quarter. But a lot of that will just depend on just the various levers within the balance sheet and how they move.
話雖如此,你知道,它將會大幅上升,因為資產負債表效率更高,而且隨著我們進入第四季度,最終可能會達到接近 3 個手柄,即 3%。但很大程度取決於資產負債表中的各種槓桿及其運作方式。
Samuel Varga - Analyst
Samuel Varga - Analyst
And then the other question I had is just around the environmental services teams that you have and obviously you're pretty bullish on the opportunity set here. So can you talk a little bit more about the business in terms of the growth ramp with the teams that you have and what your expectations might be over the next couple of years in terms of where that business can go?
我的另一個問題是關於你們擁有的環境服務團隊,顯然你們非常看好這裡提供的機會。那麼,您能否多談談您所擁有的團隊的業務成長情況,以及您對未來幾年業務發展的期望是什麼?
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Yeah, Sam, this is Peter. So it is a business that we're very proud of. We've been, we've been at this business for a long time now, a couple of years ago, we started a renewables group as well that shows up in that line item. And quite candidly, our environmental services business has been a quarterly positive performer for several years now and I think that outlook will continue.
是的,山姆,這是彼得。所以這是一項我們非常自豪的業務。我們已經從事這項業務很長時間了,幾年前,我們還成立了一個可再生能源集團,該集團也出現在該行項目中。坦白說,我們的環境服務業務多年來一直在季度表現良好,我認為這種前景將持續下去。
We've got a great team. I think we're the best in the business. We continue to try to give resources to those folks. So I'd be surprised to see anything other than the pace that you've seen the last few years continue in that space. It's a fantastic, it's really a great middle market business. It's a specialty business, but the size of the loans, the fee income that it generates, it's just a fantastic business for us.
我們有一支很棒的團隊。我認為我們是業內最好的。我們繼續努力為這些人提供資源。因此,我會很驚訝地看到除了過去幾年該領域繼續保持的步伐之外的任何其他情況。這太棒了,這確實是一個很棒的中間市場業務。這是一項專業業務,但貸款規模及其產生的費用收入對我們來說是一項非常棒的業務。
And so it's one that we're going to continue to lean into. And I would expect that on a go-forward basis, the growth rates would be similar to what you've seen in the last few years. So that's how I would think about it that way if I were you.
因此,這是我們將繼續關注的方向。我預計,在未來的基礎上,成長率將與過去幾年相似。如果我是你,我也會這麼想。
Operator
Operator
Michael Rose, Raymond James.
麥可羅斯、雷蒙詹姆斯。
Michael Rose - Analyst
Michael Rose - Analyst
I think both the NIM and the loan growth questions have been asked. So maybe I'll ask on just the pace of future investments, specifically as it relates to the loan hires. I think we're hearing more commentary. You know, across other banks that, you know, hiring efforts are going to be a little bit more robust as we enter next year. Wanted to get your thoughts there and maybe drive some incremental loan growth and then, you know, maybe any sort of updates you have just in terms of costs related to eventually crossing the $100 billion in assets.
我認為淨利差和貸款成長問題都被問到了。因此,也許我只會詢問未來投資的步伐,特別是與貸款僱用有關的投資。我認為我們聽到了更多評論。你知道,隨著明年的到來,其他銀行的招募力道將會更加強勁。希望了解您的想法,也許會推動一些增量貸款成長,然後,您知道,也許您會得到與最終突破 1000 億美元資產相關的成本方面的任何更新。
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Michael, it's Peter. I might take the first one and then I'll probably let Jim take the second one. I think the thing that, you're exactly right, the competition for talent is tremendous right now. I think whether you're no matter which market we're in, no matter what kind of line of business you look at, there's a lot of competition for talent.
邁克爾,是彼得。我可能會拿第一個,然後我可能會讓吉姆拿第二個。我認為,你說得很對,現在人才的競爭非常激烈。我認為,無論我們處於哪個市場,無論您從事哪種業務,人才的競爭都非常激烈。
I continue to believe that something that makes us very special is we have a fantastic training program where a lot of our relationship manager growth over the next few years is because of talent that we have hired and trained and developed and they go to market with that sort of culture and expectation. And I think a better knowledge of credit than our peers.
我仍然相信,讓我們非常特別的一點是,我們有一個出色的培訓計劃,未來幾年我們的客戶關係經理的成長很大程度上歸功於我們僱用、培訓和發展的人才,他們帶著這些人才進入市場某種文化和期望。我認為比我們的同齡人更了解信用。
And so that program is one that we are leaning heavily into, of trying to get folks into that program and out of it as well-trained and ready to be successful as we possibly can. I think hiring from other banks can be successful, but I also think it's expensive and I don't think it's necessarily the best way to grow your culture or your brand.
因此,這個計劃是我們非常重視的一個計劃,試圖讓人們接受並退出該計劃,並盡可能地接受良好的培訓並準備好取得成功。我認為從其他銀行招募可以成功,但我也認為它很昂貴,而且我認為這不一定是發展您的文化或品牌的最佳方式。
So I think that distinguishes us when you look at Comerica from others as to why we've got a really good outlook there. And so we're intending to grow that population, especially in our middle market and business banking businesses where we've got opportunities in Texas and California.
因此,我認為,當你觀察聯信公司和其他公司時,我們就知道為什麼我們在那裡擁有非常好的前景。因此,我們打算增加這一人口,特別是在我們的中間市場和商業銀行業務中,我們在德克薩斯州和加利福尼亞州有機會。
And we will certainly add talent from other banks. We do that all the time, but I think that you put those two things together. It's a very compelling story as to why you would look at Comerica compared to others. And so Jim, I might flip to you on the $100 billion number
我們肯定會增加其他銀行的人才。我們一直這樣做,但我認為你把這兩件事放在一起。這是一個非常引人入勝的故事,說明了為什麼您會將聯信與其他公司進行比較。所以吉姆,我可能會向你提出 1000 億美元的數字
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
Yeah, specific to the $100 billion efforts, I always remind people that we're one of two existing banks that have been in that regime in the past. So we've been there, we know how to do it. We kept some of the practices that we had in place at that point in time. Of course, the bar has gone up since then.
是的,具體到 1000 億美元的努力,我總是提醒人們,我們是過去曾參與該制度的兩家現有銀行之一。所以我們已經經歷過,我們知道該怎麼做。我們保留了當時的一些做法。當然,從那時起,標準就提高了。
But we feel like we have really strong capital planning and stress testing practices, liquidity and stress testing practices. When I look at what it takes to get ready for $100 billion, beyond just having that general good risk framework, which we're making great progress on, the task that probably takes the most effort is just the data and all the reporting that's required.
但我們覺得我們有非常強大的資本規劃和壓力測試實踐、流動性和壓力測試實踐。當我考慮如何為 1000 億美元做好準備時,除了擁有良好的整體風險框架之外(我們正在這方面取得了巨大進展),最需要付出努力的任務可能只是數據和所需的所有報告。
And that is probably the longest tail on it. And we've been working on that really for the last year, year-and-a-half, we're making great progress. We plan on being done well ahead of hitting the $100 billion. And so our goal overall is to do this in layers so that any one year, there's not a huge step up in expenses, we will ultimately have a higher run rate, you know, a modestly higher run rate because of $100 billion in Category 4 readiness. But we're also working to offset those costs.
這可能是它最長的尾巴。過去一年半以來,我們一直在努力實現這一目標,並取得了巨大進展。我們計劃在達到 1000 億美元之前儘早完成。因此,我們的總體目標是分層次進行,以便任何一年,費用都不會大幅增加,我們最終將獲得更高的運行率,你知道,由於第4 類的1000 億美元,運行率會稍高一些準備狀態。但我們也在努力抵銷這些成本。
And my goal is to put it in context of you'll never actually notice a big step up specifically due to a Category 4 readiness effort because we are layering them in as time goes on and feel like we're on a really good track to be ready well ahead of hitting $100 billion.
我的目標是把它放在這樣的背景下:你永遠不會真正注意到由於4 類準備工作而取得的巨大進步,因為隨著時間的推移,我們正在將它們分層,感覺我們正處於一個非常好的軌道上在達到 1000 億美元之前做好準備。
Michael Rose - Analyst
Michael Rose - Analyst
Very helpful. And then maybe the natural follow-up question is that relates to next year and I'm not trying to pin you down here, but I think we're hearing other banks at least plan for positive operating leverage next year. I heard your comments on NII trajectory. You know, balance that with, you know, maybe some, some expense growth related to what you just talked about, but it is at least the initial plan or expectation that you can generate positive operating leverage next year. Thanks,
非常有幫助。也許自然的後續問題與明年有關,我並不是想把你固定在這裡,但我認為我們至少聽到其他銀行計劃明年實現積極的營運槓桿。我聽到了您對 NII 軌蹟的評論。你知道,平衡這一點,你知道,也許有一些與你剛才談到的相關的費用增長,但這至少是你明年可以產生正營運槓桿的初步計劃或期望。謝謝,
James Herzog - Chief Financial Officer, Senior Executive Vice President
James Herzog - Chief Financial Officer, Senior Executive Vice President
It's always our goal to have positive operating leverage and obviously '23 with the regional bank crisis and its trailing effects on '24 made that very challenging, but positive operating leverage is always our goal and I would say 2025 is no exception to that. That's our own expectation and that's what we are shooting for. And that will be through a combination of both revenue efforts as well as making sure that we calibrate expenses appropriately.
擁有正的營運槓桿始終是我們的目標,顯然,23 年地區銀行危機及其對24 年的後續影響使這一目標變得非常具有挑戰性,但正營運槓桿始終是我們的目標,我想說2025 年也不例外。這是我們自己的期望,也是我們努力的目標。這將透過收入努力和確保我們適當調整支出相結合來實現。
Operator
Operator
Anthony Elian, JPMorgan Chase.
安東尼·埃利安,摩根大通。
Anthony Elian - Analyst
Anthony Elian - Analyst
I appreciate the comments you provide on loan growth and customer sentiment towards quarter-end. Just asking the question around loan growth expectations a different way. Once borrowers get past hurdles of the election and we see more rate cuts, do you see a loan growth at the company at a level comparable to the rest of the industry or do you think you can grow faster than the industry, just given your footprint and other segments you've mentioned?
我感謝您對季末貸款成長和客戶情緒的評論。只是以不同的方式詢問有關貸款成長預期的問題。一旦借款人克服了選舉的障礙,並且我們看到更多的降息,您是否認為該公司的貸款增長水平與行業其他公司相當,或者您是否認為您可以比行業增長得更快,只要考慮到您的足跡以及您提到的其他部分?
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Peter Sefzik - Senior Executive Vice President, Chief Banking Officer
Yeah, Anthony, it's Peter. I'd answer that a couple of ways. We had a lot of years where we were growing at the rate of the industry, if not even slightly below for a while. But if you kind of went back 2019, 2022, so call it the non-COVID, the non-2023 years, we were growing at a rate equal to or above the industry.
是的,安東尼,是彼得。我會用幾種方式來回答這個問題。多年來,我們一直以行業的速度成長,甚至一度略低於行業水平。但如果你回顧 2019 年、2022 年,即非新冠疫情、非 2023 年,我們的成長速度等於或高於產業水準。
So I think on a go forward basis, particularly when we get to the other side of, as I talked earlier about CRE kind of downward slope from here, I think we should be able to grow at the industry growth rate or better when we get into '25 and '26 that would be the expectation.
因此,我認為,從長遠來看,特別是當我們到達另一邊時,正如我之前談到的商業房地產從這裡開始的下降趨勢,我認為我們應該能夠以行業增長率或更好的速度增長,當我們得到進入'25和'26這將是期望。
And I certainly think when you look at our portfolio, all of our specialty businesses being highly exposed in Texas and in California, we would expect of ourselves to be growing better than the overall industry. And we've proven that we could do that the last couple of years absent sort of these major events. So the only part of that I would just, you know, caution again is the CRE headwind that we have. But the rest of the book on a go-forward basis, we would expect to be able to grow better than the industry.
我當然認為,當你看看我們的投資組合時,我們所有的專業業務在德克薩斯州和加利福尼亞州都有很高的曝光度,我們期望自己的成長比整個行業更好。我們已經證明,在過去幾年沒有發生此類重大事件的情況下,我們可以做到這一點。因此,我唯一要再次謹慎的是我們所面臨的商業房地產逆風。但在本書的其餘部分中,我們預期能夠比整個產業成長得更好。
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
I might just add to that when you look at -- this is Curt, that the markets we operate in really all of our geographies have grown this year and expected to grow next year above GDP. So we feel really good about sort of the markets we operate in the national, especially businesses that Peter referenced earlier. Part of our capital management strategy is to reserve capital for long growth.
我可能會補充一點,當你看到時,我是 Curt,我們在所有地區運營的市場今年都在增長,預計明年的增長將超過 GDP。因此,我們對我們在全國各地經營的市場感覺非常好,尤其是彼得之前提到的企業。我們資本管理策略的一部分是為長期成長儲備資本。
So we are anticipating long growth on a forward basis where we feel really good about our funding position and credit continues to be very well-behaved. So we're ready, willing, and able, and we got a great team on the field. And back to the question earlier about relationship managers, we've got plenty of capacity right now for growth. But again, we are building in additions of capacity through our training programs and selectively in some of our businesses' external hires.
因此,我們預計未來會出現長期成長,我們對我們的融資狀況感覺非常好,信貸也將繼續表現良好。所以我們已經準備好了、願意並且有能力,並且我們在球場上擁有一支優秀的團隊。回到之前關於客戶關係經理的問題,我們現在有足夠的能力來實現成長。但我們再次透過我們的培訓計劃和選擇性地招募一些企業的外部員工來增強能力。
Anthony Elian - Analyst
Anthony Elian - Analyst
Thank you. And then my follow-up, you saw good growth in equity fund services deposits during the quarter. Can you talk about what specifically you saw in that segment that drove the growth and the expectations from your end? Thank you.
謝謝。然後我的後續行動是,您看到本季股票基金服務存款的良好成長。您能否具體談談您在該細分市場中看到的推動成長的因素以及您的期望?謝謝。
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Yeah, Anthony. So I mean, equity fund services has been a really good business for us and in 2023 it was one that we did optimize quite a bit, I think through last year. We are seeing good success in that business. It's a little bit of a different environment there, there's not maybe as much fund formation as there was for a while.
是的,安東尼。所以我的意思是,股票基金服務對我們來說是一項非常好的業務,我認為到去年,我們在 2023 年確實對其進行了相當多的優化。我們在該業務中看到了良好的成功。那裡的環境有點不同,基金的形成可能不像一段時間那麼多。
There's not as much activity in the private equity space as you know, but on a loan outlook standpoint, I feel like it's sort of up from here. We did sort of expect to see a little more growth in Q3. It worked a little bit against us in August.
如您所知,私募股權領域的活動並不多,但從貸款前景的角度來看,我覺得情況有所改善。我們確實預計第三季會出現更多成長。八月這對我們有點不利。
But I think that's starting to flatten out. And on the deposit side, I mean, I just think we're continuing to add sort of more what I would call bilateral relationships where we're the only bank which leads to more deposits, which leads to more treasury and fee income. We're trying to do less participations per se in that business and more bilateral deals.
但我認為這種情況開始趨於平緩。在存款方面,我的意思是,我只是認為我們正在繼續增加更多我所說的雙邊關係,我們是唯一一家帶來更多存款的銀行,從而帶來更多的財務和費用收入。我們正在努力減少對該業務的參與,並增加雙邊交易。
And so I think we're just capturing relationship. And I think as events occur in the book that our customers have, we've proven as a really good bank for them to place their deposits with and as we talked about earlier, that's at appropriate rates across our portfolio.
所以我認為我們只是在捕捉關係。我認為,隨著我們客戶所擁有的書中發生的事件,我們已經被證明是一家非常好的銀行,可以讓他們存入存款,正如我們之前談到的,我們的投資組合中的利率是適當的。
Operator
Operator
Thank you. Ladies and gentlemen, that concludes our question-and-answer session and I'll now turn the call back to Mr. Curt Farmer, President, Chairman, and Chief Executive Officer, for final comments.
謝謝。女士們、先生們,我們的問答環節到此結束,現在我將把電話轉回總裁、董事長兼首席執行官 Curt Farmer 先生,請其發表最後評論。
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Curtis Farmer - Chairman of the Board, President, Chief Executive Officer
Well, thank you all of you for joining us again today as always. Thank you for your ongoing interest in Comerica and we hope you have a good day.
好的,感謝大家今天一如既往地再次加入我們。感謝您對聯信的持續關注,祝您有個愉快的一天。
Operator
Operator
Thank you. This concludes today's conference call. You may disconnect your lines at this time. Thank you for your participation.
謝謝。今天的電話會議到此結束。此時您可以斷開線路。感謝您的參與。