Regulatory Capital

6 Months Ended

Jun. 30, 2011

NOTE 9 — REGULATORY CAPITAL

The Company and CIT Bank are each subject to various regulatory capital requirements administered by the Federal Reserve Bank of New York ("FRBNY") and the Federal Deposit Insurance Corporation ("FDIC").

Quantitative measures established by regulation to ensure capital adequacy require that the Company and CIT Bank each maintain minimum ratios of Total and Tier 1 capital to risk-weighted assets, and of Tier 1 capital to average assets, subject to any agreement with regulators to maintain higher capital levels. In connection with becoming a bank holding company in December 2008, the Company committed to maintaining a minimum Total Risk Based Capital Ratio of 13%. In connection with converting to a Utah state bank in December 2008, CIT Bank committed to maintaining for at least three years a Tier 1 Leverage Ratio of at least 15%.

The calculation of the Company's regulatory capital ratios are subject to review and consultation with the FRBNY, which may result in refinements to amounts reported at June 30, 2011.


Tier 1 Capital and Total Capital Components (dollars in millions)
			CIT Group Inc.					CIT Bank
			June 30,		December 31,		June 30,				December 31,
Tier 1 Capital			2011		2010		2011			2010
Total stockholders' equity			$ 8,941.5		$ 8,916.0		$ 1,913.5			$ 1,832.2
Effect of certain items in accumulated other comprehensive loss excluded from Tier 1 Capital			(9.5)		(3.3)		(0.1)			(0.1)
Adjusted total equity			8,932.0		8,912.7		1,913.4			1,832.1
Less: Goodwill			(264.5)		(277.4)		0			0
Disallowed intangible assets			(84.1)		(119.2)		0			0
Investment in certain subsidiaries			(35.3)		(33.4)		0			0
Other Tier 1 components⁽¹⁾			(62.7)		(65.2)		(80.7)			(97.8)
Total Tier 1 Capital			8,485.4		8,417.5		1,832.7			1,734.3
Tier 2 Capital
Qualifying reserve for credit losses			439.3		416.2		23.2			10.7
Less: Investment in certain subsidiaries			(35.3)		(33.4)		0			0
Other Tier 2 components⁽²⁾			2.6		0.2		0.1			0.1
Total Tier 2 Capital			406.6		383.0		23.3			10.8
Total Capital (Tier 1 and Tier 2 Capital)			$ 8,892.0		$ 8,800.5		$ 1,856.0			$ 1,745.1
Risk-weighted assets⁽⁴⁾			$ 44,037.0		$ 44,176.7		$ 3,854.7			$ 3,022.0
Total Capital (to risk-weighted assets):
Actual			20.2%		19.9%		48.1%			57.7%
Required Ratio for Capital Adequacy Purposes			13.0%	⁽³⁾	13.0%	⁽³⁾	8.0%			8.0%
Tier 1 Capital (to risk-weighted assets):
Actual			19.3%		19.1%		47.5%			57.4%
Required Ratio for Capital Adequacy Purposes			4.0%		4.0%		4.0%			4.0%
Tier 1 Capital Leverage Ratio:
Actual			17.1%		16.2%		27.4%			24.2%
Required Ratio for Capital Adequacy Purposes			4.0%		4.0%		15.0%		⁽³⁾	15.0%		⁽³⁾
	(1)	Includes the portion of net deferred tax assets that does not qualify for inclusion in Tier 1 capital based on the capital guidelines and the Tier 1 capital charge for nonfinancial equity investments.
	(2)	Banking organizations are permitted to include in Tier 2 Capital up to 45% of net unrealized pretax gains on available-for-sale equity securities with readily determinable fair values.
	(3)	The Company and CIT Bank each committed to maintaining certain capital ratios above regulatory minimum levels.
	(4)	Risk-weighted assets include purchase commitments for aircraft to be purchased under a June 2011 Memorandum of Understanding.

- Definition

This element may be used to capture the complete disclosure for banks, savings institutions, and credit unions, for regulatory capital requirements imposed by the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of Thrift Supervision (OTS) or for any state imposed capital requirements, as applicable. The disclosure may include (1) a description of regulatory capital requirements (a) for capital adequacy purposes and (b) established by the prompt corrective action provisions of Section 38 of the Federal Depository Insurance Act; (2) the actual or possible material effects of noncompliance with such requirements; (3) whether the entity is in compliance with the regulatory capital requirements including (a) required and actual ratios and amounts of Tier 1 leverage, Tier 1 risk-based, and total risk-based capital, tangible capital (for savings institutions), and Tier 3 capital for market risk (for certain banks and bank holding companies), (b) factors that may significantly affect capital adequacy; (4) the prompt corrective action category in which the entity was classified as of its most recent notification; (5) whether management believes any conditions or events since notification have changed the entity's category. Also may include additional information that might be disclosed in situations where substantial doubt about the entity's ability to continue as a going concern for a reasonable period of time.

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