Regulatory Capital Requirements

12 Months Ended

Dec. 31, 2018

Regulatory Capital Requirements [Abstract]

Regulatory Capital Requirements

Regulatory Capital Requirements

TCF and TCF Bank are subject to minimum capital requirements administered by the federal banking regulators. Failure to meet minimum capital requirements can initiate certain mandatory, and possible additional discretionary, actions by the federal banking regulators that could have a material adverse effect on TCF. In general, TCF Bank may not declare or pay a dividend to TCF Financial in excess of 100% of its net retained earnings for the current year combined with its net retained earnings for the preceding two calendar years, which was $235.4 million at December 31, 2018, without prior approval of the Office of the Comptroller of the Currency (the "OCC"). The OCC also has the authority to prohibit the payment of dividends by a national bank when it determines such payments would constitute an unsafe and unsound banking practice. TCF Bank's ability to make capital distributions in the future may require regulatory approval and may be restricted by its federal banking regulators. TCF Bank's ability to make any such distributions will also depend on its earnings and ability to meet minimum regulatory capital requirements in effect during future periods. In the future, these capital adequacy standards may be higher than existing minimum regulatory capital requirements.

The Basel III capital standards allowed institutions not subject to the advanced approaches requirements to opt out of including components of accumulated other comprehensive income (loss) in common equity Tier 1 capital. TCF and TCF Bank made the one-time permanent election to not include accumulated other comprehensive income (loss) in regulatory capital. TCF and TCF Bank are subject to a capital conservation buffer. As of January 1, 2019, the Basel III capital standard requires TCF and TCF Bank to maintain a 2.5% capital conservation buffer, designed to absorb losses during periods of economic stress, composed entirely of common equity Tier 1 capital, on top of the minimum risk-weighted asset ratios, resulting in minimum ratios for TCF Bank of (i) a common equity Tier 1 capital ratio of at least 7.0%, (ii) a Tier 1 risk-based capital ratio of at least 8.5% and (iii) a total risk-based capital ratio of at least 10.5%.

Regulatory capital information for TCF and TCF Bank was as follows:

	TCF						TCF Bank
	At December 31,						At December 31,
(Dollars in thousands)	2018			2017			2018			2017			Well-capitalized Standard		Minimum Capital Requirement(1)
Regulatory Capital:
Common equity Tier 1 capital	$	2,224,183		$	2,242,410		$	2,282,013		$	2,409,027
Tier 1 capital	2,408,393			2,522,178			2,300,472			2,426,854
Total capital	2,750,581			2,889,323			2,675,347			2,837,374
Regulatory Capital Ratios:
Common equity Tier 1 capital ratio	10.82		%	10.79		%	11.10		%	11.59		%	6.50	%	4.50	%
Tier 1 risk-based capital ratio	11.72			12.14			11.19			11.68			8.00		6.00
Total risk-based capital ratio	13.38			13.90			13.01			13.65			10.00		8.00
Tier 1 leverage ratio	10.44			11.12			9.97			10.70			5.00		4.00

(1) Excludes capital conservation buffer of 1.875% and 1.25% at December 31, 2018 and 2017, respectively.