Regulatory Matters

3 Months Ended

Mar. 31, 2020

Banking and Thrift [Abstract]

Regulatory Matters

12.  Regulatory Matters

The Bank is subject to various regulatory capital requirements administered by the federal 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 direct material effect on the Company’s financial statements. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, the Bank must meet specific capital guidelines that involve quantitative measures of the Bank’s assets, liabilities and certain off-balance-sheet items, as calculated under regulatory accounting practices. The Bank’s capital amounts and classification are also subject to qualitative judgments by the regulators about components, risk weightings and other factors.

The final rules implementing the BASEL Committee on Banking Supervisor’s Capital Guidance for U.S. Banks (BASEL III) became effective for the Bank on January 1, 2016. Compliance with the requirements was phased in over a four year period with full compliance as of January 1, 2019. All presented capital ratios are calculated using BASEL III rules.

Pursuant to the Economic Growth, Regulatory Relief, and Consumer Protection Act, the federal banking agencies adopted, effective January 1, 2020, a final rule whereby financial institutions and financial 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 eligible to opt into a “Community Bank Leverage Ratio” framework.  The agencies reserved the authority to disallow the use of the Community Bank Leverage Ratio by a financial institution or holding company based on the risk profile of the organization.  More recently, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act and implementing rules temporarily reduced the community bank leverage ratio to 8%, to be gradually increased back to 9% by 2022. The CARES Act also provides that, during the same time period, if a qualifying community banking organization falls no more than 1% below the community bank leverage ratio, it will have a two-quarter grace period to satisfy the community bank leverage ratio.  The Bank has not elected to use the community bank leverage ratio framework.

Quantitative measures established by regulation to ensure capital adequacy require the Bank to maintain minimum amounts and ratios (set forth in the tables below) of total, common equity Tier 1 and Tier I capital (as defined in the regulations) to risk-weighted assets (as defined) and of Tier I capital (as defined) to average assets (as defined). Management believes, as of March 31, 2020 and December 31, 2019, that the Bank met all capital adequacy requirements to which they are subject.

The most recent notification from the Federal Deposit Insurance Corporation (“FDIC”) categorized the Bank as “well capitalized” under the regulatory framework. To be categorized as well capitalized, the Bank must maintain minimum total risk-based, common equity Tier 1, Tier I risk-based and Tier I leverage ratios as set forth in the table below. There are no conditions or events since then, which management believes have changed the Bank’s category.

The Bank’s actual capital amounts and ratios were:

									To be Well Capitalized under
					For Capital Adequacy				Prompt Corrective Action
	Actual				Purposes				Provisions
	Amount		Ratio		Amount		Ratio		Amount		Ratio
	March 31, 2020
Rhinebeck Bank
Total capital (to risk-weighted assets)	$	111,801	12.80	%	$	69,892	8.00	%	$	87,365	10.00	%
Tier 1 capital (to risk-weighted assets)		105,181	12.04	%		52,419	6.00	%		69,892	8.00	%
Common equity tier one capital (to risk weighted assets)		105,181	12.04	%		39,314	4.50	%		56,787	6.50	%
Tier 1 capital (to average assets)		105,181	10.68	%		39,391	4.00	%		49,238	5.00	%

	December 31, 2019
Rhinebeck Bank
Total capital (to risk-weighted assets)	$	109,799	12.83	%	$	68,481	8.00	%	$	85,602	10.00	%
Tier 1 capital (to risk-weighted assets)		103,845	12.13	%		51,361	6.00	%		68,481	8.00	%
Common equity tier one capital (to risk weighted assets)		103,845	12.13	%		38,521	4.50	%		55,641	6.50	%
Tier 1 capital (to average assets)		103,845	10.84	%		38,325	4.00	%		47,907	5.00	%