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Regulatory Matters (Notes)
12 Months Ended
Dec. 31, 2019
Banking and Thrift [Abstract]  
Regulatory Matters
REGULATORY MATTERS
The Company and the Bank are subject to various regulatory capital requirements administered by the federal and state banking agencies. Failure to meet minimum capital requirements can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a material and adverse effect on the Company’s and the Bank’s business, financial condition and results of operation, such as restrictions on growth or the payment of dividends or other capital distributions or management fees. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, the Company and the Bank must meet specific capital guidelines that involve quantitative measures of their assets, liabilities and certain off-balance-sheet items as calculated under regulatory accounting practices. The capital amounts and classification are also subject to qualitative judgments by the regulators about components, risk-weightings and other factors.
In July 2013, the federal bank regulatory agencies adopted final regulations, which revised their risk-based and leverage capital requirements for banking organizations to meet requirements of the Dodd-Frank Act and to implement the Basel III international agreements reached by the Basel Committee. The final rules began for the Company and the Bank on January 1, 2015 and were subject to a phase-in period through January 1, 2019. The final rules that had an impact on the Company and the Bank include:
An increase in the minimum Tier 1 capital ratio from 4.00% to 6.00% of risk-weighted assets;
A new category and a required 4.50% of risk-weighted assets ratio was established for “Common Equity Tier 1” as a subset of Tier 1 capital limited to common equity;
A minimum non-risk-based leverage ratio was set at 4.00%, eliminating a 3.00% exception for higher rated banks;
Changes in the permitted composition of Tier 1 capital to exclude trust preferred securities, mortgage servicing rights and certain deferred tax assets and include unrealized gains and losses on available for sale debt and equity securities;
The risk-weights of certain assets for purposes of calculating the risk-based capital ratios are changed for high volatility commercial real estate acquisition, development and construction loans, certain past due non-residential mortgage loans and certain mortgage-backed and other securities exposures; and
A new additional capital conservation buffer of 2.50% of risk-weighted assets over each of the required capital ratios was added and must be met to avoid limitations on the ability of the Bank to pay dividends, repurchase shares, or pay discretionary bonuses. The capital conservation buffer for the Company was initially 0.625% in 2016 and increased 0.625% annually until fully phased-in in 2019. As of December 31, 2019, the capital conservation buffer for the Company stood at 2.50%.
As of December 31, 2019, the ratios for the Company and the Bank were sufficient to meet the fully phased-in conservation buffer.
As of December 31, 2019 and 2018, the most recent regulatory notification categorized the Bank as “well-capitalized” under the regulatory framework for prompt corrective action. To generally be categorized as “well-capitalized”, the Bank must maintain minimum total risk-based, Tier 1 risk-based, common equity Tier 1, and Tier 1 leverage ratios as set forth in the following table. There are no conditions or events since the most recent notification from regulators that management believes has changed the institution’s category.
The Company’s and the Bank’s capital levels and regulatory capital ratios are presented in the tables below:
 
Actual
 
Required
For Capital
Adequacy Purposes
 
Minimum Capital Adequacy With Capital Conservation Buffer
 
Required To Be Well
Capitalized under
Prompt Corrective
Action Provisions
 
Amount
 
Ratio
 
Amount
 
Ratio
 
Amount
 
Ratio
 
Amount
 
Ratio
 
(Dollars in thousands)
December 31, 2019
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common equity tier 1 capital
(to risk-weighted assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,553,697

 
11.76
%
 
$
594,373

 
4.50
%
 
$
924,581

 
7.00
%
 
 N/A

 
 N/A

Bank
$
1,811,862

 
13.72
%
 
$
594,320

 
4.50
%
 
$
924,498

 
7.00
%
 
$
858,462

 
6.50
%
Total capital
(to risk-weighted assets):
 

 
 

 
 

 
 

 
 
 
 
 
 

 
 

Company
$
1,747,611

 
13.23
%
 
$
1,056,664

 
8.00
%
 
$
1,386,871

 
10.50
%
 
 N/A

 
 N/A

Bank
$
1,906,642

 
14.44
%
 
$
1,056,569

 
8.00
%
 
$
1,386,747

 
10.50
%
 
$
1,320,711

 
10.00
%
Tier I capital
(to risk-weighted assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,652,831

 
12.51
%
 
$
792,498

 
6.00
%
 
$
1,122,705

 
8.50
%
 
 N/A

 
 N/A

Bank
$
1,811,862

 
13.72
%
 
$
792,427

 
6.00
%
 
$
924,498

 
8.50
%
 
$
1,056,569

 
8.00
%
Tier I capital
(to average assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,652,831

 
11.22
%
 
$
589,367

 
4.00
%
 
N/A

 
N/A

 
 N/A

 
 N/A

Bank
$
1,811,862

 
12.29
%
 
$
589,604

 
4.00
%
 
N/A

 
N/A

 
$
737,005

 
5.00
%
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Actual
 
Required
For Capital
Adequacy Purposes
 
Minimum Capital Adequacy With Capital Conservation Buffer
 
Required To Be Well
Capitalized under
Prompt Corrective
Action Provisions
 
Amount
 
Ratio
 
Amount
 
Ratio
 
Amount
 
Ratio
 
Amount
 
Ratio
 
(Dollars in thousands)
December 31, 2018
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common equity tier 1 capital
(to risk-weighted assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,458,344

 
11.44
%
 
$
573,723

 
4.50
%
 
$
812,774

 
6.375
%
 
 N/A

 
N/A

Bank
$
1,737,092

 
13.63
%
 
$
573,699

 
4.50
%
 
$
812,740

 
6.375
%
 
$
828,677

 
6.50
%
Total capital
(to risk-weighted assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,649,664

 
12.94
%
 
$
1,019,952

 
8.00
%
 
$
1,259,004

 
9.875
%
 
 N/A

 
N/A

Bank
$
1,830,385

 
14.36
%
 
$
1,019,910

 
8.00
%
 
$
1,258,951

 
9.875
%
 
$
1,274,887

 
10.00
%
Tier I capital
(to risk-weighted assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,556,371

 
12.21
%
 
$
764,964

 
6.00
%
 
$
1,004,015

 
7.875
%
 
 N/A

 
N/A

Bank
$
1,737,092

 
13.63
%
 
$
764,932

 
6.00
%
 
$
812,740

 
7.875
%
 
$
1,019,910

 
8.00
%
Tier I capital
(to average assets):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company
$
1,556,371

 
10.55
%
 
$
590,176

 
4.00
%
 
N/A

 
N/A

 
N/A

 
N/A

Bank
$
1,737,092

 
11.76
%
 
$
590,639

 
4.00
%
 
N/A

 
N/A

 
$
738,299

 
5.00
%