As the number of start-up banks continues to swell, the Federal Deposit Insurance Corp. is starting to worry about how an economic downturn would affect them.
The proliferation of unseasoned institutions could spell trouble, the FDIC's Atlanta and San Francisco regions said in the agency's quarterly Regional Outlook. 
During the recession of the early 1990s, the Atlanta region pointed out, banks that had not weathered one before were twice as likely as established banks to fail or have poor examination ratings.
In addition, the FDIC's Memphis office voiced concerns about banks' recent shift toward taking on more risk in their asset portfolios.
The FDIC is not advising against starting banks. In the conclusion of its report, it simply urged bank organizers and those running new banks to consider the risks "that are innate in the early life cycle of a start-up and how changes in the economy could affect their institutions."
T. Stephen Johnson, a banking consultant in Roswell, Ga., says the FDIC's worries are unfounded, because the current environment is far different from the last heyday of small-bank start-ups.
Many new banks have management teams that have been through downturns, Mr. Johnson said. "In the mid-'80s a lot of the people starting banks were not qualified to run them," he said. "What we are seeing now is some well-educated, experienced people forming banks."
Indeed, many people running start-ups are big-bank executives who lost their jobs when their banks were sold. But Jack Phelps, regional manager of the FDIC's Atlanta office, pointed out that such people often assume more responsibility in their new positions.
"They may have been through recessions," he said, "but it may not have been in these roles."
Moreover, recessions usually hit small banks harder than big ones, said Richard P. Hunt, chairman and chief executive officer of Kendrick, Pierce & Co., a Tampa consulting firm specializing in bank start-up. For a manager, he said, "going through a recession at a large institution is a lot easier than going through one at a small bank."
Even when recession experience is not a factor, new banks are just more vulnerable than established ones, according to a recent study by the Federal Reserve Bank of Chicago.
Banks are most likely to fail shortly after their third year of operation, the study concluded. If they weather that period the risk goes down, because regulatory capital requirements are reduced.
"Brand-new but unprofitable banks are typically protected from failure by large initial capital cushions," the report said. "However, equity cushions at de novo banks typically decline to established bank levels several years before their earnings justify these relatively low levels of capital."
If start-ups should be a worry, some regions should be more worried than others. The Atlanta region had 203 start-ups on Sept. 30 - 15.2% of all banks there - with $11.1 billion of assets. And the San Francisco region - which includes new-bank hotbeds such as Phoenix, Las Vegas, and Sacramento - had 114 banks less than four years old, the highest total since yearend 1990.
Asset mix is another worrisome area for the FDIC. The San Francisco region reported that its start-up banks had more exposure than established institutions to commercial real estate loans, and paid more for money. "In addition, start-ups depend slightly more on volatile funding sources than do established institutions."
Mr. Phelps observed that banks formed today are striving for higher returns than historically sought by start-ups, because more of them are publicly traded. "They need to reach to satisfy public investors, which leads to greater risk-taking in deploying their capital," he said.
Michael Clark, chief executive officer of Access Bank in Chantilly, Va., said he thinks the FDIC's worries are overblown. For one thing, he said, though regulators have expressed concern about commercial real estate lending, his bank and many other new ones focus on less-risky small-business lending.
"It is unfair to make a sweeping statement about one segment of the market," he said. "You have to take it on a case-by-case basis."
Carroll C. Markley, chairman of Millennium Bank in Reston, Va., agreed. It is the quality of the people running the bank that counts, he said.
But not everyone with big-bank experience can run a start-up well, Mr. Markley observed. It is a complicated job, he said. "Making the transition was & a lot harder than I thought."
John Reosti contributed to this article.
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