Alert November 26, 2013

Federal Banking Regulators Provide Community Banks with Regulatory Capital Estimation Tool

The FDIC, FRB and OCC (the “Agencies”) each made available a regulatory capital estimation tool (the “Estimation Tool”) that is designed to help community banks evaluate the potential impact on their capital ratios of the Agencies’ recently issued interim final capital rule (the “Capital Rule”).  An earlier version of the Estimation Tool, based upon the proposed version of the Capital Rule, was made available by the Agencies in 2012.  The Agencies noted that the Estimation Tool is intended to be useful for smaller, non-complex banks.  In addition, the Agencies cautioned banks that the Estimation Tool requires manual input that could have significant effects on their calculations.  Moreover, in a separate Financial Institution Letter, the FDIC stressed that the calculations arrived at after use of the Estimation Tool are “not a substitute for a bank’s analysis of the impact of the [Capital Rule] on its financial operations for regulatory reporting and capital planning purposes.”