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Operator
Good morning, everyone, and welcome to the Pinnacle Financial Partners' Third Quarter 2022 Earnings Conference Call. Hosting the call today from Pinnacle Financial Partners is Mr. Terry Turner, Chief Executive Officer; and Mr. Harold Carpenter, Chief Financial Officer.
Please note, Pinnacle's earnings release and this morning's presentation are available on the Investor Relations page of their website at www.pnfp.com. Today's call is being recorded and will be available for replay on Pinnacle's website for the next 90 days. (Operator Instructions)
During this presentation, we may make comments which may constitute forward-looking statements. All forward-looking statements are subject to risks, uncertainties and other facts that may cause the actual results, performance or achievements of Pinnacle Financial to differ materially from any results expressed or implied by such forward-looking statements. Many of such factors are beyond Pinnacle Financial's ability to control or predict, and listeners are cautioned not to put undue reliance on such forward-looking statements. A more detailed description of these and other risks is contained in Pinnacle Financial's annual report on Form 10-K for the year ended December 31, 2021, and its subsequently filed quarterly reports. Pinnacle Financial disclaims any obligation to update or revise any forward-looking statements contained in this presentation, whether as a result of new information, future events or otherwise.
In addition, these remarks may include certain non-GAAP financial measures as defined by SEC Regulation G, a presentation of the most directly comparable GAAP financial measures and a reconciliation of the non-GAAP measures to the comparable GAAP measures will be available on Pinnacle Financial's website at www.pnfp.com.
With that, I am now going to turn the presentation over to Mr. Terry Turner, Pinnacle's President and CEO.
Michael Terry Turner - President, CEO & Director
Thank you, Paul, and thank you for joining us this morning for the third quarter earnings call. As I'm confident you've already seen, third quarter was another fabulous quarter for us. Last quarter in my introductory comments, I tried to list a number of themes that I believe critical in order to not only understand the financial performance for the quarter, but really the better ascertain how the firm should perform going forward despite the varying operating environment we might encounter. As a quick reminder, those overarching themes that I mentioned last quarter and which I think you'll see interwoven again in the quarter -- in this quarter's numbers.
Number one, management is motivated and incented to alter outcomes given various market conditions. As an example, we don't just accept the current asset sensitivity or we don't just accept what the current overall market growth rates we set about to alter outcomes based on our actions and initiatives. A lot of people are chasing all kinds of interesting metrics like deposit cost betas and I get it. But specifically, the outcomes that we're motivated and incented to optimize at Pinnacle are the level of classified assets PPNR growth and EPS growth in the case of the annual cash incentive plan and tangible book value accretion and ROTCE in the case of the long-term equity incentive plan. And so understanding that will likely help you understand things like why we've accreted tangible book value in a year when many have not.
Number two, we enjoy a reputation for having a great culture, but our culture isn't just fun and soft stuff, any number of studies have demonstrated statistically valid correlations between associate engagement and important outcomes like reduced associate turnover, improved productivity, improved profitability, better sales outcome and total shareholder returns. And nothing is more important in the war for talent. And so I think that helps explain things like while we continue to hire record numbers of the best bankers and financial services professionals at a time many are short-staffed and suffering low associate engagement and high turnover.
Number three, our hiring success over the last several years is the single largest contributor to our balance sheet growth and ongoing momentum. It explains where so much of our loan and deposit growth comes from. And not only that, because of the level of the experience of our new hires is equal to or greater than 20 years, we believe we can grow assets without sacrificing our commitment to credit quality. It's much different than those that are trying to grow by increasing the frequency of their call program. In fact, in Greenwich Research, we're at or near the top on virtually every sales and service metric that they typically view as important with 1 notable exception, and that's prospect calling where we are dead last. That's just not how we get our business as opposed to forcing RMs to make prospect calls. In our case, long experienced bankers typically move long-standing relationships, which we believe over the long haul results in a meaningfully different credit profile.
And number four, BHG is not your typical fintech, its ability to attract loans from high-quality borrowers with very high yields and get them funded through their proprietary bank auction platform or alternately securitize them in the secondary market when many cannot continues to result in the kind of income that lets us significantly invest in people to seize all the market opportunities exist for us. while continuing to put up top quartile profitability.
I'm not aware of anyone who's been able to invest in their business model to the extent that we have while remaining extremely profitable. As I've already alluded, we believe metrics like asset quality, revenue growth, earnings per share and tangible book value accretion result in long-term shareholder returns. That's why our incentives are linked to them, and that's why we show this dashboard quarter in and quarter out, where you can see the relentless upward slope of things like revenues, earnings per share and the balance sheet volumes that produce that growth. On asset quality, we've been living in literally the best of times. We fully expect asset quality metrics to more normalize going forward. But you can see the NPAs and classified assets continue to operate at extraordinary lows as do charge-offs at just 16 basis points.
In fact, we've been in the top quartile in terms of NPAs to Tier 1 capital and classified assets to Tier 1 capital for some time. And given the continued reductions on those metrics this quarter, I'd be continuing to put structure peer metrics for the third quarter. As most of you know, given the very commercial nature of our loan book, charge-offs are generally lumpy. We had one of those this quarter, which Harold will talk more about in a moment. But again, credit metrics continue to be extraordinary. I won't spend much time on the non-GAAP measures.
Atleast not as much time as I usually do, because the idea is that virtually all the important growth in earnings metrics are up and to the right, generally well exceeding market expectations and paint the picture of what's been a beat and raise story for quite some time. As I just mentioned, the talent that we've added over the last several years results in extraordinary balance sheet momentum. As we did last quarter, we're again dissecting net loan growth based on the categories noted on the slide to help everyone better understand the source of our growth.
We've again categorized our growth in the 4 broader segments. Number one, our pure asset generation plays like BHG, Advocate Capital, JB&B Leasing; b, our strategic market expansions, which are not only the geographies like Atlanta, D.C., Birmingham and so forth, but also expansions into specialty lending groups like franchise and equipment lending; c, growth from our recruiting over the last 2.5 years. So this is the growth of our newer RMs that have been with us for only 2.5 years or less and that are not included in our strategic expansion markets. And then finally, d, our legacy markets and what they contributed from RMs that have been with us more than 2.5 years.
So thus far, through the first 9 months, we've experienced 24.5% EOP loan growth annualized between December 31, 2021 and September 30, 2022, which is inclusive of PPP paydowns, which are denoted in red on the slide. Almost 46% of our $4.3 billion in net loan growth is from our legacy markets, while the rest is primarily from new markets, new initiatives and new people. We've said this countless times. We think we're in many of the best banking markets in the Southeast. Many of you know that for lenders to come to work for us, they have to have at least 10 years of experience in our markets. And on average, it's more like 20 years. So to characterize all this loan growth as new loans is a little bit of a stretch as these borrowers have been working with our 10-year plus experienced lenders for years. The loans are just new to PNFP.
We get asked frequently about how the new markets and specialties are performing. I simply want to get you this information where you can see that we're having extraordinary success moving talent and clients to the Pinnacle platform. For those that struggle with the value of the emphasis we place on culture, here's just one of the examples of where it pays off, putting associates in a position where they can serve their clients well is what enables us to attract the best associates as well as their clients.
I know everyone is aware that the annual FDIC deposit market share information was released in the third quarter. Here, you can see, first of all, we're in great markets, as evidenced by the rate of deposit growth in the market, and that will be an important success variable going forward. But more importantly, we've been able to grow our deposits faster than the market, which is just another way of saying we've had great success moving market share. Many are concerned with the shrink in M2 and the impact that could have on funding.
And so I would say, I don't think we could grow anywhere near the pace that we currently grow. If we were unable to take deposit share from these larger, more vulnerable banks in our markets. Harold will comment further on our deposit growth in a minute.
A couple of slides we've used from time to time. What you're looking at here is data from Greenwich Associates, the foremost provider of commercial market research to large banks in the United States virtually all the top 50 banks in the country purchased this same data. So I would say it's universally accepted by all our primary competitors, is based on client responses across our entire footprint, meaning businesses with annual sales from $1 million to $500 million in Tennessee, North Carolina, South Carolina, Atlanta and Roanoke.
So let's focus on the Pinnacle line at the bottom of the small business Net Promoter chart, which is on the top left of the slide. You see in the navy blue portion of the bar that 76% of the Pinnacle client survey rated us a 9 or a 10 on the question, how likely are you to recommend your lead provider to a friend or colleague using a scale of 0 to 10, where 0 means not likely at all and 10 means extremely likely. In other words, 76% of our clients are highly engaged active promoters. Trust me, that's an extremely unusual level of engagement. Another 22% rated us a 7% or 8%, and that's not bad. Combining the 2, 98% of our clients rated is 7 or better on a 10-point scale.
But that 22%, that gold portion of the bar scoring us of 7 or 8 are referred to as passive because while they generally rate well, they're not really so fired up as to be vocal advocates for you in the market. And then the last 2%, the red portion of the bar are detractors, meaning they rated you somewhere between 0 and 6. And out beside the bar, you see a 74 that's the Net Promoter Score, the number of promoters less the number of detractors.
As you can see, that score is wildly differentiated from all our major competitors in our footprint, and not only is that a fabulous Net Promoter Score in the Southeast, according to Greenwich is 1 of the best in the country. And the story is the same, only better among middle market businesses on the lower right of the slide where you can see our Net Promoter Score is 81. Now you might look at the percentage of the tractors for each of our major competitors that red portion on each of their bars. And keep in mind, the banks are generally listed in market share order. So as you can see, all the top 3 banks in our footprint have enormous volumes of detractors. And that's the opportunity we have been seasoned for some time and expect to continue season.
So as you think about the speed and reliability of our growth, which is largely dependent on taking share as opposed to economic loan demand, this explains why we've been so successful taking share over the last 20 years. Why we grew loans 20.9% on an annualized basis this quarter. Why we grew core deposits 9.8% on an annualized basis this quarter and why I believe we'll continue to produce outsized growth for the foreseeable future.
And it's not just that many of the banks with whom we compete have upset a great number of their clients, a large percentage of their clients expressly intend to move some or all of their business away from them in the next 12 months. That group, the percentage of their clients who have expressly indicated their intent to move is represented by the blue bar. And happily, more than to any of the major banks with whom we compete, a large percentage of clients intend to increase their relationship with us meaningfully more. My purpose in walking through this is really to tighten the linkage for you between our distinctive culture and the revenue and the EPS growth. So you don't have to just take a leap of faith at a distinctive culture we've been building here over the last 22 years almost seriously result in something good. You can actually connect the dots with Greenwich data reflecting the actual client feedback to better understand the quality and sustainability of our market share and revenue growth. that's the 30,000-foot view.
With that, I'll turn it over to Harold for a more in-depth review of the quarter.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Thanks, Terry. Good morning, everybody. As usual, we will start with loans. The third quarter was another strong loan growth quarter for us with almost 22% linked quarter EOP annualized growth.
Our current pipeline support low double-digit loan growth going into the fourth quarter which would yield low 20% growth for this year. Loan yields were up in the third quarter due primarily to rate hikes. We anticipate further escalation in loan yields with rate increases in November and December. Our current planning assumption is for 75 basis points in November and 50 basis points in December. Since there were 150 basis points hikes during the third quarter, we've not gotten the full effect of the third quarter average rates noted on the slide.
Given that and more increases in fourth quarter, we anticipate fourth quarter yields will be up 75 to 90 basis points or so. As we sit here at the end of September, our loan yields are around 5%. We've also talked about loan floors over the last several quarters, but we're essentially through those, so we should capture a larger share of rate increases moving forward. The bottom left chart summarizes our loan betas for 2022. We've tracked each rate hike and what the beta results were for each hike. The green bars are estimates as we don't have the full effect of the September rate hike yet, and we won't until we get to the November FOMC meeting when we will put a stake in the ground and remeasure the September hike. Of course, November, December are based on our current planning assumptions, but we feel somewhere around 60% loan beta is a reasonable target for us.
Now on to deposits. Really pleased to report call it 10% linked-quarter annualized growth in deposits for the third quarter. At present, our relationship managers are active deposit book protectors as well as outbound deposit seekers.
So it's likely we've always said it's about shoe leather at Pinnacle. It's about being in the community and finding the funding at a reasonable price. We, like others, did experience some mix shift during the quarter as EOP DDA balances are down from prior quarter, but average DDA balances were actually up for the quarter. We will keep our fingers crossed that this will hold.
We are actively building out deposit gathering franchises around HSA, Community Housing Associations, non-profits and others, where we target specific types of organizations that are net providers of funding, and we believe we are making strong headway with these special deposit initiatives. More to come as these initiatives continue to grow. Everybody wants to know about deposit betas. The top right chart attempts to show what we're currently thinking. This chart is constructed similar to the loan chart shown previously. Our planning assumption is that we think we can hold with a 40% total deposit beta that we've been talking about since earlier in the year.
For the first 20-plus years of our existence, our #1 objective was developing strategies and tactics around funding our growth. We continue to like our chances given the significant investment we've made in both relationship managers and new markets over the last few years. We believe many other banks around the country are reassessing their beta assumption as liquidity has gotten more difficult. As to Pinnacle, we have been steadily investing in our deposit book all year long and believe that our clients appreciate a pricing discipline that is more fair in an upgrade environment in comparison to what we hear from others.
Hopefully, you'll not hear this bank's leadership ever talk about having too many deposits. Depositors are just as, if not significantly more important than borrowers. Our belief is that we can and will fund our growth effectively and prudently maintaining the appropriate balance between profitability and growth, something we believe we have a track record of accomplishing.
Now the liquidity. Our liquid assets decreased slightly this quarter, but we continue to believe we have ample liquidity to fund our near-term growth. As to investment securities, our allocation to bonds is anticipated to be flattish in the fourth quarter. As the top left chart reflects with the rate up cycle, our GAAP NIM increased by 30 basis points compared to 28 basis points last quarter. So we're pleased with this going into the fourth quarter.
Our planning assumption is that our NIM will likely top off in the first half of next year, assuming rate hikes stall or are minimal in the first half of next year. In summary, our belief is that we should see another quarter of NIM expansion, along with increased net interest income in the fourth quarter. Accordingly, we are upping our guidance for net interest income growth to the low 20 percentage growth for the full year 2022 over last year.
As to credit, we are again presenting our traditional credit metrics, Pinnacle's loan portfolio continues to perform very well. As Terry mentioned earlier, late in the quarter and into October, we had on pre-CECL classified C&I credit weekend due primarily to an alleged failure of a supplier's defective part that had been installed in the homes of our clients' customers. We don't believe this was the result of all the economic headwinds that we are all paying so much attention to. We recorded a partial charge-off effective September 30, placed the loan on non-accrual, pending more credit work. In spite of this 1 credit, we are pleased with where classified assets ended as evidenced by the almost 3-year downward trend in our classified loan totals as well as our past dues, which are again at very conservative levels at quarter end.
Our current ACL is 1.04%, which again compares to a pre-CECL precoded reserve of 48 basis points at the end of 2019. We previously thought our ACL for the quarter would have been less than 1.04%, but given the events over the last month or so, we believe keeping the ACL flattish for us is appropriate right now. All of this culminates in a larger provision expense than we anticipated at $27.5 million.
We continue to have conversations with borrowers about supply chains, labor inflation and how it's impacting their businesses. We have been in an all about sustainable credit diligence effort with the intent to actively identify any weaknesses in our borrowing base. We get many questions about what changes we are implementing as a result of the inflationary economy.
A few things worth mentioning here. We have substantially limited our appetite for new construction, whether it be residential or commercial. We believe our book is very healthy with strong sponsors, but the macro environment gives us a pause as to increasing our asset allocations to this segment. Our credit officers have increased our due diligence in stress testing, particularly around supply chain impact, rates and profitability. We're also increasing our diligence around the traditional metrics of loan-to-value debt coverage, so on and so forth.
Now on the fees and expenses. I won't spend a lot of time on fees or expenses. And as always, I will speak to BHG in a few minutes. Third quarter fees are coming off of a record setting quarter, so the optics are difficult. And as a reminder, we did note last quarter that we thought we would see decreases in fees in the third quarter. All that said, we are pleased with the effort of our fee generating units are putting forward. service charges are impacted by a change in how we charge NSF and overdraft fees, which we announced in early July. We have some reason to believe we will see a rebound in wealth management in the fourth quarter as a result of recent hires.
Excluding BHG and barring any additional downdraft from our other equity investments, we are believing that we are near [floral] fees this quarter and that we should see a stronger fourth quarter fee result. Excluding BHG and the impact of these other equity investments, we continue to believe that high single-digit growth for 2022 over 2021 is still in play. As to expenses, we're increasing our overall total expense run rate to a high teens percentage growth in 2022. This increase is attributable to headcount growth in the new markets. Market disruption across our markets, which has led to strong recruiting opportunities and the addition of JB&B. In addition, we continue to believe that we should achieved maximum payouts of 125% of target awards for our annual cash incentive plan, but it's all about recruiting and our success in attracting the best bankers to our franchise, which seems to be operating at peak capacity. Our third quarter non-compensation expense was fairly flat with the second quarter, and we believe that the fourth quarter won't be that different from the prior 2 quarters.
In conclusion, we had a strong hiring quarter in the third quarter, which was the reason for the increased salary expense. We're anticipating another strong quarter of hiring in fourth quarter, although we don't anticipate the increase will be as great in the fourth quarter as it was in the third quarter. As to capital tangible book value increased to $42.44 at quarter end, up slightly from last quarter. Our capital ratios remain above well-capitalized levels. We like our tangible common equity ratio that stands at 8.3% currently. We are mindful of our Tier 2 capital levels, particularly at Pinnacle Bank in light of our exceptional growth. and we'll be monitoring these levels in the debt markets as we head into the fourth quarter and into 2023. Aside from that, we believe the action we've taken to preserve tangible book value and our tangible capital ratio have served us well and have no plans to alter our Tier 1 capital stack via any sort of common or preferred offering.
Now a few comments about BHG before we look at the outlook for the rest of the year. BHG had a great quarter in our opinion, slightly better than we had anticipated. We're booking more than $41 million in fee revenues this quarter and have increased our outlook for 2022 growth over 2021 to more than 25% from a projection of 15% last quarter.
As the slide indicates, BHG had another record quarter on originations. Spreads have come in slightly lower than last quarter from 9.8% to 9.7% as the chart on the bottom left indicates. That's more than the amounts BHG anticipated at the beginning of the quarter. BHG does anticipate that auction platform spreads will come in slightly as rates on the short end continue to rise. They anticipate that borrower rates should be approaching 17% by the end of the year with bank buy rates moving into the 7% range.
As a result, we anticipate that spreads will fluctuate within the historical ranges of 9% to 10% or so. That said, we're really pleased with BHG's third quarter as the third quarter again highlights their flexibility as to how they can pivot between the bank network and securitizations to fund their loan growth.
Formerly titled as the recourse obligation accrual, this slide now titled the accrual for loan substitutions and prepayments, which stood at 5.28% BHG's sold loan portfolio at September 30, which is more than the accrual at June quarter end as BSG increased this accrual from $235 million to $270 million at September 30.
As the blue bars in the bottom right chart show the credit loss portion of recourse losses for the second quarter remain at some of the lowest levels in the past 10 years. Additionally, given the macro environment, BHG also increased its on-balance sheet reserve for loan losses to $101 million or 3.53% of on-balance sheet loans from 3% last quarter. Given the macro environment, we believe BHG will likely increase reserves again going into the fourth quarter and into 2023. The quality of BHG's borrowing base, in our opinion, remains impressive, and we believe 1 of their strongest attributes.
BHG refreshes its credit score monthly always looking for weaknesses in its borrowing base. Credit scores were at the consistent levels with previous quarters, so their borrowers have remained resilient through the cycle thus far. As to past due trends, past dues greater than 30 days were at 1.52% at September 30 compared to 1.37% at June 30 and 1.39% from a year ago. Past dues were at 1.77% at the end of December 2020. BHG's consistent monitoring of its portfolio allows it to adjust its origination approvals quickly. They have, over the past few months, adjusted their commercial allocations away from non-medical practices and on consumer, which is about 20% of their business, they have adjusted their risk tolerance to the higher credit score borrowers.
National and regional unemployment forecasts give BHG more confidence that their borrowers should be able to withstand forecasted inflationary increases in a way that allows BHG to better weather this environment than others in their space. In comparison to other consumers, we believe BHG's borrowers are well paid with average borrower earnings being approximately $287,000 annually. We are comfortable in their credit models and their credit experience bears this out.
Lastly, BHG had another great operating quarter in the third quarter. As I mentioned during the 2 earnings calls this -- 2 previous earnings calls this year, we believe earnings in the first half of 2022 would likely be stronger than the second half as they sent more loans to the bank auction platform in the first half of the year rather than hold loans on their balance sheet. As you know, the bank auction platform delivers immediate gain on sale income, while our securitization network delivers interest income over the life of the loans.
Additionally, BHG did accomplish during September a $412 million securitization at an acceptable rate of 7% when as it appears to us, other fintech lenders are -- were having to reevaluate their business models given the operating environment. BHG was very pleased to be able to get this securitization done. Just a side note, Kroll has now rerated BHG's first 2 issuances such that all tranches for all 6 prior securitizations are now investment grade and the senior Class A tranche and all issuances is AAA rated.
We do want to highlight BHG's flexibility as to funding. Securitization platform spreads have compressed in 2022 with the weighted average rate for the most recent set compared to 5.5% in June and 2.5% in the first quarter. This compression motivates BHG to reconsider selling more loans through its auction platform as it spreads have held up better this year than anticipated. The key point is that they have the flexibility to do it. In the end, overall profitability and balance sheet soundness are the key drivers for BHG. As I mentioned earlier, BHG has updated their 2022 earnings guidance and now estimate about 25% earnings growth over 2021.
Again, looking forward, some key points I'd like to reemphasize. Credit remains consistent with previous quarters, but BHG is and will be increasing reserves based on macroeconomic data at least over the next few quarters. BHG has been modifying their credit models towards originating less risky assets. Spread shrinkage may occur with more historical levels as we head into the fourth quarter and 2023. Production volumes are very strong, and we believe they will continue to have strong production going into the fourth quarter and 2023. Of note is that BHG anticipates at least 2 to 4 new funding alternatives to open up in the near term as they seek to broaden their already strong liquidity platform, which we also believe is one of their strongest attributes.
Quickly, here's an outlook for the remainder of 2022. For loans, we've increased our outlook to low 20% growth for 2022, we have adjusted our rate forecast to now consider a 4.5% Fed funds rate by year-end.
We like you will continue to monitor and modify as necessary but we don't believe any reasonable changes to our current planning assumption will impact our current outlook for 2022 materially. Given that, we believe we should see continued improvement in net interest income this year which should result in net interest income growth in the low 20 percentage range. We still believe increases in hires and other factors should result in expense growth being in the high teens. All of this is about '20 to '22.
We'll provide more information as to our 2023 outlook next quarter. Last year at this time, our concerns were trying to figure out how to put together a 2022 plan just to grow earnings. We were looking at low single-digit earnings growth rate for 2022, and it got no better by the end of the year. Based on sell-side research at the time, 80% of our peer group was anticipating negative EPS growth in 2022. So we're pleased with our 2022 financial performance thus far as we believe we will solidly beat our loan deposit revenue, PPNR and earnings targets for this year.
Trust us, as I'm primarily speaking to my Pinnacle teammates who are listening in, we have started building plans for next year, and our goal remains the same. Top quartile earnings performance, no matter what gets thrown at us.
Paul, with that, I'll stop and see if there are any questions.
Operator
(Operator Instructions) The first question is coming from Steven Alexopoulos from JPMorgan.
Steven A. Alexopoulos - MD and Head of Mid-Cap & Small-Cap Banks
I want to start, so Harold first, on the non-interest-bearing deposits, right? These went from 24% of total before the pandemic, which is before QE to 33% today. Do you think you can hold that mix at about that level? Or do you see it migrating back, right, where in QT migrating back as you continue to fund strong loan growth?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Well, no, we don't think it's going to go back to pre-COVID levels. We've had a lot of initiatives around operating accounts, and we've gathered a lot of clients. So we don't think we'll get back down there. We did see the mix shift that we noted previously.
But so far in October and [not granted] we're only 18 days in we're feeling pretty good about where this deposit book is hanging in there on -- particularly on non-interest-bearing.
Steven A. Alexopoulos - MD and Head of Mid-Cap & Small-Cap Banks
So there's enough sources when you look at sources of funding and maybe we could hold the mix about where it is?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes, I think so. We may drift down a couple of notches, but I don't think it's going to be that dramatic.
Steven A. Alexopoulos - MD and Head of Mid-Cap & Small-Cap Banks
Got it. Okay. And then as we think about expenses, I appreciate next quarter, it will give us 2023, but when we think about the ramp in hiring through 2022, could you just give us some framework about 2023? I mean should we at least be at a similar level of expense growth next year, just given the hiring that took place through 2022.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Well, I'll give you some data points, and then I'll let Terry talk about momentum. I think we should see at least high teens, mid- to high teens kind of expense growth next year. That's what we're kind of looking at currently. Terry?
Michael Terry Turner - President, CEO & Director
Yes. Steve, I think on hiring momentum. As you saw, third quarter was a record quarter for us, I don't look forward to stay at 53 revenue producers a quarter, but I expect it to remain high going forward. And so I think your idea is correct that the hiring more or less occurs on a straight line, and I would expect it to continue for the foreseeable future. And so how that bears on the expense growth is just exactly what you say. I mean, it will be elevated because we have hired throughout the year, and frankly, we intend to continue hiring at a similar rate in 2023.
Steven A. Alexopoulos - MD and Head of Mid-Cap & Small-Cap Banks
Okay. That's helpful. And then finally, there are many investors on the sidelines who are nervous to own your stock here, not because of Pinnacle's credit quality, but they're concerned on the credit outlook for most of the fintech lenders out there, including BHG, particularly given that BHG expanded these newer verticals. Can you just share with people on the sidelines, how worried are you on the credit outlook at BHG given the macro environment. Just any additional color you could provide would be really helpful.
Michael Terry Turner - President, CEO & Director
Harold, do you want to go first and maybe I'll add some color after? Yes.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Sure. We've had a lot of conversations with the leadership at Bankers Healthcare Group over the last several quarters about their confidence with their book, their confidence in their credit models they think -- or they believe currently that their models are sound. If there is a significant kind of uptick in inflationary pressure, no doubt their charge-offs could tweak up, but they are very confident with respect to their ability to find the best borrowers in this environment and continue to monitor their book for, call it, cracks or weaknesses.
Michael Terry Turner - President, CEO & Director
I think, Steve, I might add just a couple of other things. Obviously, for us as an investor, I always have been since we started and continue to try to understand really what all that credit risk is. I think some things that give me great comfort are, number 1, they've got a huge group of people in analytics. They work on all kinds of variables. You've heard us talk about that in the past. But the main variable, the foremost variable, obviously, is their credit scoring mechanism. We provide information to you on the FICO scores because that's a common thing that you and I and others can all understand it's a way to level set, but they don't underwrite their credit off that FICO score, they're using their own proprietary model. which they can demonstrate is 17% more predictive than the FICO score.
And so again, these are not credit (inaudible). They've been through it through a number of cycles. They went through the great recession without sustaining any losses, which not many of the banks they sell credit to could say that. And so again, I think they started as a credit scorecard analytical group. It's broadened out, but it still is their strength. And so I love the capability that they have, the fact that their model is a little more rich than a FICO score, which is sort of the industry standard.
I think that's one thing that gives me a lot of confidence. As I mentioned, I think the second thing I would say is, again, these guys have been through recessions in the past, and their performance was extraordinarily good. It was better than our banks' performance and better than most banks' performance. And so that's another item that gives me a great deal of confidence. I think the third thing is when so much of it is consumer credit.
So my -- even the business credit has a consumer underwriting orientation to it. And so I guess the idea for me here is that the average borrower has income of $287,000. When I think about various other fintechs, and I won't go through and name them all on what the credit products are and so forth, I don't know any of them that are underwriting borrowers with $287,000 in annual income. It's a different class bar. These are not people that are borrowing money for a washing machine or a small home improvement or something. I mean these are substantial people.
And so again, I think the mix of their borrower is different than what most of their fintech providers -- other fintech providers are doing for their borrowers. So anyway, I just rambled through those 3 things.
Operator
The next question is coming from Stephen Scouten from Piper Sandler.
Stephen Kendall Scouten - MD & Senior Research Analyst
I guess I wanted to dig down into the beta expectations you have that you laid out in the presentation, both on the loan and then especially on the deposit side. In 2021, growth and kind of historical growth is maybe...
(technical difficulty)
Michael Terry Turner - President, CEO & Director
Hello. Steve, are you there?
Stephen Kendall Scouten - MD & Senior Research Analyst
Spread and where you've been today -- Yes. Can you guys hear me?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
You kind of blanked out on me.
Stephen Kendall Scouten - MD & Senior Research Analyst
Okay. I guess I'm just trying to think about where loan growth -- what kind of loan growth expectations you have in '23 relative to those deposit beta expectations? Because it would seem with your expense guidance, if it's going to be high teens again, that we might be looking for high-teens growth again...
(technical difficulty)
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
I think I got the -- Steve, I think I got the gist of the question. You kind of blanked out on me. I'm not sure if the others on the call experienced the same thing or not. I think going into next year and the -- just looking at the net interest margin, if it -- historically, if it responds the way it has done in the past, we're anticipating that as the Fed stops raising rates, that the left side of the balance sheet, yields and rates will likely start topping off. and that the deposit lag will likely be in effect through that time.
I was looking at our net interest margin performance over the last 2 years. it stayed fairly consistent at around 2.95% to 3.05% range for the last 2 years during a fairly flat rate environment. So we'd anticipate that kind of performance with respect to our -- at least our margins once the Fed settles down on their rate increases. Is that helpful?
Stephen Kendall Scouten - MD & Senior Research Analyst
Yes, that's helpful. And that sounds like I might be having technology issues so I'll let somebody else hop on.
Operator
The next question is coming from Michael Rose from Raymond James.
Michael Edward Rose - MD of Equity Research
Just you gave us a lot of color as usual on BHG. Very much appreciated. On the one hand, you continue to grow, you feel comfortable with that growth. But on the other hand, the recourse reserves the new terminology for it is expected to grow kind of as well. I hate to -- I know it's really hard to kind of forecast, but you had really good growth through the year in BHG better than expected. Can you give us a stab at kind of the puts and takes of how we should think about 2023 and the growth of that business just going into a slowdown?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. Steve, we've had -- I mean, Michael, we've had some preliminary conversations with BHG about their next year's outlook. They have -- they do believe their production platform will continue to deliver at a reasonable pace next year. And they think they have opportunities to continue to kind of pivot between the securitization platform and the gain on sale and the bank auction platform. .
I don't think it would be unreasonable to assume that next year's growth rate might be somewhere around a 15% number, something like that. I'm hesitant to get into too much detail because we need to have some more conversations with Bankers Healthcare Group.
Michael Edward Rose - MD of Equity Research
Certainly understood. Maybe just more broadly speaking, you guys have been obviously very active on the hiring front, and you talked about dislocations, maybe getting even more advantageous for you into next year just given the market dislocation. But it's been a while, I think, since you've kind of entertained the thoughts of maybe doing a whole bank transaction, I just wanted to see, given the dislocations that some banks are going to have and some of the credit issues that I think we're going to see. Is that an avenue that you could potentially open up again as we think about the next couple of years?
Michael Terry Turner - President, CEO & Director
Michael, I think on that front, you've heard my answer before, and it's really no different in our position. I don't think has changed. I'm never going to say never that we just absolutely won't to do it. I don't want to say that. But I do think it's fair to say you can see the hiring momentum that we have. I expect it to continue as long as we can sort of continue that market share play for the foreseeable future, which I think we can. You'd have to have a really compelling transaction to want to do it. And so if we find one of those, certainly, we would consider it. But again, I just think the bias is more towards organic growth and continuing our market share at play. We're really in a I think a luxury is positioned to have built a preferred bank standing for large bank employees who want to exit their large bank. And so again, I expect that will be our principal lever.
Michael Edward Rose - MD of Equity Research
I appreciate it. Maybe just one final quick one, just putting together some of the expectations you talked about initially for next year. Is the expectation that just given the rate outlook and beta assumptions and what you said on BHG and expenses that you could generate positive operating leverage next year? Or is that going to be more challenging?
Michael Terry Turner - President, CEO & Director
Harold, do you want to take that?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Sure. Yes, I don't think it's unreasonable. We're -- I believe, at our core, a sub-50% efficiency ratio kind of franchise. And I believe that we've got all the opportunities in the world to increase or better than that here in the near term.
Operator
And the next question is coming from Jared Shaw from Wells Fargo Securities.
Jared David Wesley Shaw - MD & Senior Equity Analyst
I guess going back to BHG, could you give an update, Harold, on maybe some of the steps that they're taking to utilize more CECL-friendly disposition avenues and what a day-1 potential estimate for BHG could look like right now?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. Sure. There's currently several different options, maybe a couple that I'll talk about. One is within the guidance, you can sell more of the cash flows and then avoid CECL. So call it similar to what they do with the gain on sale platform with the banks, they can do that with institutional investors. They can also sell part of the residual cash flows maybe carve out some of those future cash flows and sell those and then take those credits out of the CECL kind of domain. So there's a variety of different tactics they can deploy to try to avoid CECL. Right now, they're thinking their reserves, which are currently at 3.5%, could get into the 9% to 10% range with day-1 CECL impacts. So I don't know if that gets you all the way there, Jared, but that's what we've been talking about thus far.
Jared David Wesley Shaw - MD & Senior Equity Analyst
Okay. And then any update on how you're thinking about your ownership stake in that in the past, you said that you would -- I think you said you travel with the founders. And then over the last few quarters, it sounded like maybe you could forge your own path. How should we be thinking about BHG as a percentage of the Pinnacle balance sheet or earnings stream going forward?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Terry, I'll start and then let you finish. But the -- I don't think we've got any real strong change with our perspective on our ownership of BHG. We're definitely not interested in owning or buying a majority stake in the franchise. I think both Pinnacle and the 2 founders of the franchise, we're all on the same page. I think if there were a liquidity event, an opportunity for one, I think the founders and ourselves, we'd entertain it. and see where it goes from there. The market right now is not real supportive of any kind of transaction. But I believe that -- like I said, we're all on the same page if there were something to come down the pipe.
Michael Terry Turner - President, CEO & Director
Jared, I think I might add to Harold's comments, Certainly, what he said is accurate. I think the case is that, as you know, the valuation whatever it is, it bounces around and has moved rapidly. If you look at what I would say the value of that company is or what it has been 12 months ago, 9 months ago, 6 months ago, 3 months ago, it's pretty dramatically different over that time period. And so all those things influence what can in fact be done.
When you talk about a liquidity event, obviously, what you got to get down to is a willing buyer and a willing seller. And so again, those -- there are people that are always circling and looking for valuations and so forth. I think we -- as Harold said, we and the other 2 owners are at this point at a really similar spot. We'd be willing to write valuations, reduce our stakes or sell the company. And so again, it's just about how the market moves and where you find that willing buyer and willing seller. I think I've indicated that if nobody had to be happy with me, I think some reduction in our stake in BHG to the extent people want a minority interest in the company, is a good idea. I love the income that it generates has provided extraordinary flexibility. It's been a tremendous strategic advantage in terms of funding extraordinary growth here and allowing us to maintain very high profitability. And so I don't want to completely give that a way to be candid. But if it became a lesser percent of our income that would probably, I think, add to investor perception, P/E multiples, all those kinds of things. So any rate, it's impossible to say exactly what is going to happen but we'd be willing to consider a reduction or a sale of the company. And so if that comes about, that will be fine. But we're very comfortable to continue in the current situation as well.
Jared David Wesley Shaw - MD & Senior Equity Analyst
Okay, right. And I guess shifting over to loan growth and the outlook as we go into next year, certainly, it sounds like you have good momentum with old hiring. If we're looking at a weaker maybe economic backdrop, and I look at Slide 7 and the different avenues of where that growth has come from, do you think that you can see a shift with a bigger dependence on the expansion markets or having a bigger relative impact from the hiring? Or do you think that we'll see sort of a broad-based equally diversified platform of growth going into '23?
Michael Terry Turner - President, CEO & Director
My own sense of it is that it ought to remain relatively similar. I think as the new markets take hold, their growth will be faster than in the legacy markets. But I think generally, that idea is that allocation of the growth is probably a pretty similar thing when you look at it 12 months from now.
Operator
And the next question is coming from Catherine Mealor from KBW.
Catherine Fitzhugh Summerson Mealor - MD & SVP
I want to go back up to the margin and the cumulative betas through '22, I thought was really helpful with the 60% loan beta and the 40% cumulative deposit beta, how do you think as we move into next year, I know you're not giving next year guidance yet, but just kind of generally and directionally between the 2, how do you think those 2 trend next year? And is that 50% cumulative loan beta is that a good number for next year? Are there dynamics that kind of pricing of new loans and all that, that may kind of change that as we look at it full cycle?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. I think -- well, first of all, I want to make sure that we emphasize more about where the margin is versus where the betas go. We provide the bet information to kind of help people get through it. But we're more interested in what we think the margin is going to do given where the rate cycle is. And like I was mentioning earlier, we think the margin once the rate -- once the Fed begins to kind of stop or ease or just stall that the margin will probably flatten out. And if -- and with deposit competition, we'd probably see some more increases in our deposit rates. But as far as a beta question itself, in all likelihood, the loan beta would probably once it stalls, would probably come down as with competitive pressure, but we think the lag on deposits would probably be the more -- be more influential on the longer-term margin.
Catherine Fitzhugh Summerson Mealor - MD & SVP
Got it. And on that, how are you thinking -- I mean, the margin substantial expansion this quarter, I expect we'll see it again next quarter. Any kind of near-term thoughts on where you think the margin may shake out next quarter and then...
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. We're not currently planning for another 30 basis point uptick, but it ought to be somewhere half, maybe a little more than half going into the fourth quarter.
Catherine Fitzhugh Summerson Mealor - MD & SVP
Half of the increase we saw this quarter. .
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
That's right.
Catherine Fitzhugh Summerson Mealor - MD & SVP
Got it. Okay. And so you probably peak early '23 and then start to flatten out to come down as you move through the rest of the year.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. Our planning assumption is next year that we ought to see 225 basis point rate decreases in the last half of the year, and so the margin pretty much flattens out in the second quarter.
Catherine Fitzhugh Summerson Mealor - MD & SVP
Got it. Okay. And then on the composition of deposit growth, just the balance growth was great to see. Is there just big picture, how are you strategically thinking about the composition of where that growth will come? I know you mentioned you still expect to grow non-interest-bearing. But then how much do you think comes from non-core versus core? And then also, you talked about some in different specialty deposit strategies that you've got. If you could kind of talk about how you think that factors in to the deposit growth outlook as well.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Terry, I'll start and let you go from there. Traditionally, our client base will provide 80% to 90% of the core funding that we need to fund our loan growth. And so we've always had to go to the wholesale market, call it brokered or Federal Home Loan Bank to try to fund the gap with respect to try to fund the gap.
So here over the last couple of years, we've not had that problem. We've not had to go to the wholesale markets much at all. to get our liquidity to fund loan growth. So we do have capacity internally to go to the wholesale markets to fund loan growth, but there will be a stop gap before we had kind of a 20% wholesale funding kind of limitation. I don't see us getting anywhere near that.
But we will do it to fund some loan growth, but our -- like I said earlier, our belief is that our franchise, a lot of value of our franchise is built in our deposit book. And so we've got to make sure that we're looking under rocks for deposits. And I think our relationship managers are doing just that today. I think where this new deposit growth is going to come from, is from our new hires and our new markets. Terry?
Michael Terry Turner - President, CEO & Director
Yes, I think I would add to that, Harold commented, I think when he went over the slide, we have over the last year or 2, been building some specialty deposit funding around HSAs, around community associations, which is inclusive of homeowners associations and property managers, some non-profit specialties and so forth. Those have been built. They're all through breakeven. They are having success, and we believe will be a meaningful part of the funding as we get out through here as well. So in addition to new people in new markets. I think the new product specialties are important to us in terms of low-cost funding.
Operator
The next question is coming from Brian Martin from Janney Montgomery.
Brian Joseph Martin - Director of Banks and Thrifts
Just maybe circling back here. Just one clarification on the comments or just some questions on expense growth earlier. I know you're not giving the guidance, but just when you were talking about kind of that the high teens expense growth, was that more from the people you've already hired, was that really talking about the salary line? Or are you talking about total expenses there, just for clarity?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. Mid to teen -- mid- to high-teens would be for total expenses. Again, we're going through all of our planning for 2023 currently. We're pretty much maybe at the first few steps of a mini step journey, but that's probably where it's going to shake out at the end of the day. But that said, as Terry alluded to earlier in the call, our hiring plan when you put it in effect or you start executing it, what we're going to do is we're going to hire the people whenever we get an opportunity, we're going to be opportunistic hires. And so we may put in the plan that we're going to maybe hire 125 revenue producers next year or 130 or whatever the number might be. But if we have a chance to double that, we might just go after it.
Brian Joseph Martin - Director of Banks and Thrifts
Got you. Okay. No, it makes sense. How about just shifting gears to the BHG. I think your -- I guess, third quarter is obviously down, but strong here. I guess fourth quarter, as it shapes up right now, should -- is the expectation that it should drift a bit lower at BHG today?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
I don't know if I caught all your -- Brian, say that question -- go back to that one more time.
Brian Joseph Martin - Director of Banks and Thrifts
Yes, just the outlook for BHG in 4Q. I mean relative to third quarter. Third quarter was strong but down, but fourth quarter is also expected to be a bit lower given kind of your comments about the performance.
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. Yes, I think so. What could change our current perspective is if they send more loans to the auction platform, which is what they did this quarter. So now they believe they're going to warehouse more loans on their balance sheet, which could tamp down earnings in the fourth quarter.
Brian Joseph Martin - Director of Banks and Thrifts
Got you. Okay. And then just the -- maybe just looking at one line item on fee income, and that was just the I guess, the gain or loss on sale of other equity investments kind of the, I guess, a significant drop this quarter as you guys have talked about kind of that volatility there. But just as we think about that number going forward, I guess, just kind of take an average of the past quarters? Or just what's the best way to think about that given this quarter's mark relative to last quarter? .
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes. We're not anticipating much movement in that year-to-date number here today. We'll get more information through the quarter on all those investments and see where it shakes out. But right now, we're not planning on any kind of up or down movement with respect to anything in the fourth quarter.
Brian Joseph Martin - Director of Banks and Thrifts
Got you. Okay. And then new loan yields, Harold, where are they coming on today? I guess there be the month of September? Or just kind of whatever most recent data you have, where are they -- where are you putting on new loans today? .
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Well, I could flip down to the back of the -- in the supplemental information and look at that number. But at the end of September, we were at 5%. So that would imply that we're getting bigger.
Brian Joseph Martin - Director of Banks and Thrifts
If it's in the slides, I'll grab it, I missed that, if I did. So no problem on that.
Operator
And the next question is coming from Jennifer Demba from Truist Securities.
Jennifer Haskew Demba - MD
Terry, I wonder if you could just give us your thoughts on your -- the performance in your expansion markets and especially commercial lending. Just looking at Slide 8. And if you could just talk about where -- how things have gone in each market versus your expectations?
Michael Terry Turner - President, CEO & Director
Yes. I'll try to just throw out thoughts if I'm not addressing what you're interested in, just redirect me and I'll hit it. I would say that the Atlanta market is almost exactly on target for what we would have hoped. We probably a little ahead on hiring. I think volumes are generally right where we would expect them to be. And so we're excited about what's going on here in Atlanta.
I think in the case of Alabama, both Huntsville and Birmingham, I would say they have outperformed what our expectations were, both in terms of hiring and in terms of the balance sheet volumes that they generated early on both sides of the balance sheet. Loan and deposit volumes have been really attractive. And so I think we're going to do better in those markets than what we had said.
And then in the case of D.C., I would say just for me personally, that's probably the market I am most excited about, as you can see by the months in existence. We're still in the early stages, but their pipelines are building pretty dramatically. You can see they've had great success hiring people and again, both sides of the balance sheet for them, what's in the pipeline and what we expect to happen over the next 2 quarters, that will do better than what our original pro forma was as well. So anyway, that's how I look at those big markets. If I have not addressed what you're interested in, please redirect.
Jennifer Haskew Demba - MD
That's great color. And just a question, a lot of analysts and investors have asked about normalizing credit. And I just wonder what you think normal is? Is normal somewhere between where we have been at these historically low losses and problem asset levels and the historical median, or is it -- or is -- is it the historical median. What do you think normal is?
Michael Terry Turner - President, CEO & Director
Well, I think when you start using a term like normal, that obviously has to apply over a period of time to me or through the cycle, you get ups and downs. And so I don't think there's any thesis under which I would expect to operate our company at the levels of classified assets and non-performing assets and so forth, that we are currently at through an entire cycle.
So at any rate, I think those median numbers are -- they're a reasonable way to think about what ought to happen through the whole cycle. Again, I personally think we're ways away from that. But again, I think when I -- for me to say we expect things to normalize. I just want people to understand. I don't think we're going to be operating at the level of classified assets and nonperforming assets that we've been at over the last handful of quarters for the foreseeable future, surely, it will have to go up to some extent. Again, maybe the median number is a good plan and assumption.
Operator
And we had Catherine Mealor from KBW, coming with a follow-up.
Catherine Fitzhugh Summerson Mealor - MD & SVP
I just had a follow-up on expenses like your stack has (inaudible) underperformed since the call started when you mentioned a high teens expense growth rate. So I just wanted to circle back to that comment and maybe provide you the opportunity to remind us how nimble you can be on the expense side if the revenue growth is not going to come in as expected. If we see loan growth flow or the margin come in lower than expected, how nimble can you be on pulling back that high-teens expense guidance you gave.
Michael Terry Turner - President, CEO & Director
Harold, you want to go first?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
Yes, I'll go first. Thanks, Catherine, for the follow-up. Yes, I mean, we've always got the ability to take money out of the expense book -- but the big thing that we can -- that we always do around here is our incentive plans are all tied to earnings growth. And so if the earnings growth doesn't come around, then we've got opportunities to take quite a large sum of money out of our incentive plan to kind of fortify our P&L and make sure our earnings growth is reasonable under the circumstances. The other thing -- and we did this back during the financial crisis is we can always pull back on hiring that will impact our longer-term growth. So we're not really anxious to do that. But there's a lot of variability in our expense book that we can go after when it's absolutely necessary. Terry, I'll stop there.
Michael Terry Turner - President, CEO & Director
Yes. Catherine, I guess I had to hit two things. I mean, Harold said it, but just in case there are people who don't get it, the incentive, we have sacrificed 100% of our incentives if we don't produce our earnings targets and earnings targets are set to be top quartile performance.
And so that's the biggest expense lever that you have. We don't get paid unless shareholders do get paid. And I don't think there's a company that I'm cited with that we'll do that and protect shareholders to that extent. I think the second thing is, and I pound away on this for a reason, but I don't feel successful to get people to understand it.
The hiring that we do the -- because we do it on a straight line, it's a huge part of the expense base, and so we're paying expenses today for revenues that are yet to come. And so my only message in that is there's an immense amount of profitability that comes when we quit hiring people. All the revenue continues to roll in and the expenses cease to grow. And so there's huge profit leverage in just that single idea right there when you think about having hired 53 revenue producers this quarter, that revenue will come in. And so then if we have difficulties, we quit hiring people, and so the expenses stop growing, but the revenue continues to grow. So Anyway, that's my own view of it. That's the way we've operated over an extended period of time, and I'm not sure everybody understands how that works, but you can't quit hiring. And it does produce earnings growth even though it impacts the longer-term balance sheet and earnings growth in the short run, it accelerates earnings growth.
Catherine Fitzhugh Summerson Mealor - MD & SVP
Got it. That's helpful. And I mean, I just if you're going to put a high teens expense growth rate out there, then it's just fair to assume that the revenue growth rate is going to be above that, just given your business model, correct?
Harold R. Carpenter - Executive VP, CFO & Principal Accounting Officer
No doubt. No doubt.
Operator
Thank you, ladies and gentlemen, this does conclude today's conference. You may disconnect your lines at this time, and have a wonderful day. Thank you for your participation.