December 21, 2018

On November 21, 2018, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Agencies”) jointly issued a proposed rule to simplify the regulatory capital requirements for eligible community banks and holding companies, as required by Section 201 of the Economic Growth, Regulatory Relief and Consumer Protection Act.

Under the proposed rule, community banks and holding companies that have less than $10 billion in consolidated assets, that meet risk-based qualifying criteria and have a tangible equity ratio (referred to as the “community bank leverage ratio”) greater than 9% would be eligible to opt into a community bank leverage ratio framework. If this election is made, the qualifying community bank or holding company would satisfy its regulatory capital standards by calculating and reporting the community bank leverage ratio instead of the risk-weighted capital ratios and minimum leverage ratio currently required, and would be deemed “well capitalized” under the Federal Agencies’ prompt corrective action framework.

For more information, including a summary of the proposed rule, please see the attached News Alert.

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