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REGULATORY CAPITAL MATTERS
 3 Months Ended
Mar. 31, 2020
Broker-Dealer, Net Capital Requirement, SEC Regulation [Abstract]  
REGULATORY CAPITAL MATTERS REGULATORY CAPITAL MATTERSBanks and bank holding companies are subject to regulatory capital requirements administered by federal banking agencies. Capital adequacy guidelines and, additionally for banks, prompt corrective action regulations, involve quantitative measures of assets, liabilities, and certain off-balance-sheet items calculated under regulatory accounting practices. Capital amounts and
classifications are also subject to qualitative judgments by regulators. Failure to meet capital requirements can initiate regulatory action.
The final rules implementing Basel Committee on Banking Supervision’s capital guidelines for U.S. Banks (Basel III rules) provide for counter cyclical capital requirements so that the required amount of capital increases in times of economic expansion and decreases in times of economic contraction, consistent with safety and soundness. Under the Basel III rules, banks must maintain a capital conservation buffer consisting of additional Common Equity Tier 1 Capital equal to 2.5% of risk-weighted assets above each of the required minimum capital levels in order to avoid limitations on paying dividends, engaging in share repurchases, and paying certain discretionary bonuses. This capital conservation buffer became fully effective for the Company as of January 1, 2019.
Prompt corrective action regulations provide five classifications: well capitalized, adequately capitalized, undercapitalized, significantly undercapitalized, and critically undercapitalized, although these terms are not used to represent overall financial condition. If adequately capitalized, regulatory approval is required to accept brokered deposits. If undercapitalized, capital distributions are limited, as is asset growth and expansion, and capital restoration plans are required. At March 31, 2020, the most recent regulatory notifications categorized the Bank as well capitalized under the regulatory framework for prompt corrective action. Management believes that, as of March 31, 2020, the Company and Bank met all capital adequacy requirements to which they are subject. There are no conditions or events since that notification that management believes have changed the institution’s category.
In October 2019, the federal bank regulatory agencies, or the Agencies, issued a final rule, the Community Bank Leverage Ratio Framework, the “Framework,” to simplify capital calculations for community banks. The Framework provides for a simple measure of capital adequacy for certain community banking organizations and is consistent with Section 201 of the Economic Growth, Regulatory Relief and Consumer Protection Act. The Framework is optional and is designed to reduce burden by removing requirements for calculating and reporting risk-based capital ratios. Depository institutions and depository institution holding companies that have less than $10 billion in total consolidated assets and meet other qualifying criteria, including a leverage ratio of greater than 9%, are considered qualifying community banking organizations and are eligible to opt into the Framework. The final rule became effective January 1, 2020, and organizations that opt into the Framework and meet the criteria established by the rule can use the Framework for regulatory reports for the quarter ended March 31, 2020. In April 2020, the Agencies announced two interim final rules to provide relief associated with Section 4012 of the CARES Act. For institutions that elect the Framework, the interim rules temporarily lower the leverage ratio requirement to 8% for the second quarter of 2020 through the end of calendar year 2020 and to 8.5% for the 2021 calendar year. An institution will have until January 1, 2022 before the 9% leverage ratio requirement is re-established. The Company and the Bank have elected to opt into the Framework and will file their regulatory capital reports in accordance with the Framework’s guidance.
For comparative purposes, the Company has included in the table below estimated regulatory capital ratios for the Company and for the Bank as of March 31, 2020, and December 31, 2019, based on the Basel III Capital Rules discussed above.
ActualRequired
For Capital
Adequacy Purposes		To Be Well
Capitalized Under
Prompt Corrective
Action Regulations
AmountRatioAmountRatioAmountRatio
March 31, 2020
Company-Level
Company common equity Tier 1 capital to RWA$388,222  12.0 %$146,134  4.5 %N/AN/A
Company Total Capital to RWA$485,625  15.0 %$259,793  8.0 %N/AN/A
Company Tier 1 (Core) Capital to RWA$388,222  12.0 %$194,845  6.0 %N/AN/A
Company Tier 1 (Core) Capital to average assets$388,222  10.1 %$154,131  4.0 %N/AN/A
Bank-Level
Bank common equity Tier 1 capital to RWA$442,454  13.6 %$146,039  4.5 %$210,946  6.5 %
Bank Total Capital to RWA$480,940  14.8 %$259,626  8.0 %$324,532  10.0 %
Bank Tier 1 (Core) Capital to RWA$442,454  13.6 %$194,719  6.0 %$259,626  8.0 %
Bank Tier 1 (Core) Capital to average assets$442,454  11.5 %$153,905  4.0 %$192,381  5.0 %
December 31, 2019
Company-Level
Company common equity Tier 1 capital to RWA$388,199  11.9 %$146,711  4.5 %N/AN/A
Company Total Capital to RWA$487,966  15.0 %$260,819  8.0 %N/AN/A
Company Tier 1 (Core) Capital to RWA$388,199  11.9 %$195,614  6.0 %N/AN/A
Company Tier 1 (Core) Capital to average assets$388,199  10.3 %$151,456  4.0 %N/AN/A
Bank-Level
Bank common equity Tier 1 capital to RWA$441,348  13.6 %$146,491  4.5 %$211,599  6.5 %
Bank Total Capital to RWA$482,183  14.8 %$260,429  8.0 %$325,536  10.0 %
Bank Tier 1 (Core) Capital to RWA$441,348  13.6 %$195,322  6.0 %$260,429  8.0 %
Bank Tier 1 (Core) Capital to average assets$441,348  11.7 %$151,255  4.0 %$189,069  5.0 %
Note: Minimum ratios presented exclude the capital conservation buffer
Dividend Restrictions: The Company’s principal source of funds for dividend payments is dividends received from the Bank. Banking regulations limit the amount of dividends that may be paid without prior approval of regulatory agencies. Under these regulations, the amount of dividends that may be paid in any calendar year is limited to the current year’s net profits, combined with the retained net profits of the preceding two years, subject to the capital requirements described above.