CAPITAL Flashcards

(61 cards)

1
Q

2.1 CAPITAL

What is in Category 1 - 0%? (GLF FCGC)

A
  • Gold bullion
  • Local currency claims on or unconditionally guaranteed by non-OECD central governments
  • FRB Balances
  • Federal Reserve Bank stock
  • Cash
  • Guaranteed by US Gov’t Agencies (GNMA, VA, FHA, FMHA, ExIm Bank, OPIC, CCC, SBA) or OECD Central Governments
  • Central banks of OECD countries balances
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2
Q

2.1 CAPITAL

What is Category 2 - 20%? (SPPS GLI SCCR)

A
  • Secured by cash in a segregated account at a bank
  • Portions of loans and other claims conditionally guaranteed by US Treasury, US government agencies or OECD central banks
  • Portions of conditionally guaranteed claims by non-OECD central governments
  • Securities and claims gty’s on Gov’t sponsored agencies (FHLMC, FNMA, SLMA & FHLB)
  • General obligation securities of state or political subdivisions
  • Loans collateralized by securities issued/guaranteed by gov’t (agency, sponsored agency, OECD) securities
  • Investment in mutual funds which only permit holding of 0% and 20% risk weighted assets
  • Short-term claims on and portions gty’d by non-OECD banks
  • Correspondent bank balances and portions gty’d by banks
  • Cash items in process of collection
  • Recourse obligations, direct credit substitutes, residual interests, and asset/mortgage backed securities (Rated in the top two categories (AAA or AA) or the highest rating category for short term ratings (A-1 or P-1))
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3
Q

2.1 CAPITAL

What is in Category 3 - 50%? (LLL RR)

A
  • Loans fully secured by first liens on a residential property made on prudent basis and not PD 90 days or more or nonaccrual
  • Loans to builders with substantial project equity for construction of residences that have been pre-sold under firm contracts
  • Loans secured by first liens on multifamily residential properties <=80% LTV, 1.20 DSC, Amortization less than 30 years, payments made on time for minimum of 1 year, loan is not 90 days or more past due
  • Recourse obligations, direct credit substitutes, residual interests, and asset/mortgage backed securities (Rated in the third-highest categories (A) or the second highest rating category for short term ratings (A-2 or P-2))
  • Revenue bonds
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4
Q

2.1 CAPITAL

What is in Category 4 - 100-%? (RICCI SCAFA CC)

A
  • Recourse obligations, direct credit substitutes, etc. rated in the lowest investment grade (BBB) or A-3 or P-3
  • Industrial development bonds
  • Claims on commercial firms owned by the public sector
  • Customer liabilities to the bank on acceptances outstanding involving standard risk claims
  • Investments in unconsolidated companies, joint ventures; instruments that qualify as capital issued by other banks; deferred tax assets; MSAs, NMSAs, and PCCRs
  • Stripped MBS and others (IO strips that are not credit-enhancing and principal-only strips)
  • Common and preferred stock of corporations• All obligations of states or political S/D of countries that do not belong to the OECD
  • All claims on foreign and domestic private-sector obligors (including loans to non-depository banks and BHC)
  • FA, premises, and OREO
  • Commercial and consumer loans (except those assigned to lower risk categories)
  • Claims representing capital of a qualifying securities firm
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5
Q

2.1 CAPITAL

What is in Category 5 – 200% (Special treatment in Call Report b/c no column)?

A
  • Externally rated recourse obligations, direct credit substitutes, residual interests (other than a credit-enhancing interest only strip) ABS and MBS that are rated one category below investment grade (e.g. BB)
  • A position in a securitization or structured finance program that is not rated by an NRSRO
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6
Q

2.1 CAPITAL
What are the ratings of recourse obligations, direct credit substitutes, residual interest, and asset/mortgage backed securities? 1-4 Investment Grade. 5 and up Sub-investment grade.

A
  • Long-Term
    • Highest or second highest - (AAA, AA, Aaa, Aa) - 20% investment grade
    • Third highest investment - (A) - 50% Investment grade
    • Lowest Investment grade - (BBB) - 100% Investment grade
    • Category below investment (BB) 200% Sub-investment grade
  • Short-Term
    • Highest investment grade - (A-1 or P-1) - 20%
    • Investment grade
    • Second Highest grade - (A-2 or P-2) - 50%
    • Investment grade
    • Lowest investment grade - (A-3 or P-3) - 100% Investment grade
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7
Q

2.1 CAPITAL

Risk-based capital - what are the 100% Conversion factors for off balance sheet items?

A
  • Financial Standby Letters of Credit
  • Forward agreements
  • Participations sold with recourse
  • Sale and repurchase agreements (Repo)
  • Securities, indemnifies the customer against loss
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8
Q

2.1 CAPITAL

What is deducted from the denominator when calculating the RBC ratio? AKA - TRWA

A

All assets that are deducted from capital in the numerator (Only items that are risk-weighted and deducted from Total Capital)- Intangibles other than allowed portion of MSRs, NMSAs, and PCCRs
• Investments in unconsolidated majority owned banking and finance subsidiaries
• Investments in securities subsidiaries (12 CFR 337.4)
• Reciprocal holdings of capital instruments banks
• Deferred tax assets disallowed for Tier 1
• The disallowed portion of the allowance.

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9
Q

2.1 CAPITAL

What are some ways that a bank could increase its RBC ratios?

A
  • Adjust portfolio to include lower risk weighted assets
  • Less loans or more cash secured or 1-4 family 1st liens
  • More USTs and GOs, rather than revenue obligations
  • GNMAs instead of other government sponsored agency issues
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10
Q

2.1 CAPITAL

Risk-based capital - what are the 50% Conversion factors for off balance sheet items?

A
  • Performance standby letters of credit
  • Unused portions of commitments with an original maturity exceeding one year
    * (Ex. Commercial LINE of Credit with an original maturity exceeding 1 year)
  • Revolving Underwriting Facilities (RUFs - Contingent I Liabilities)
  • Note Issuance Facilities (NIFs - Contingent I Liabilities)
    * • Note: If bank is subject to market risk rules in appendix C: ABCP liquidity facilities (not eligible, considered recourse obligations or direct credit subs)
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11
Q

2.1 CAPITAL

Risk-based capital - what are the 20% Conversion factors for off balance sheet items?

A

• Commercial letters of credit (contingencies that arise from the movement of goods, ST, self-liquidating, trade-related contingencies) (Ex. Commercial LETTER of Credit)

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12
Q

2.1 CAPITAL

Risk-based capital - what are the 10% Conversion factors for off balance sheet items?

A

10% Conversion Factor

• ABCP liquidity facilities (unused portions)

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13
Q

2.1 CAPITAL

Risk-based capital - what are the 0% Conversion factors for off balance sheet items?

A

0% Conversion Factor
• Unused portions of commitments with an original maturity of one year or less
• Unused portions of retail credit card lines and related if unconditional

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14
Q

2.1 CAPITAL

What are the 5 Capital Categories pursuant to Section 38 of the act?

A
  • Well capitalized
  • Adequately capitalized
  • Undercapitalized
  • Significantly undercapitalized
  • Critically undercapitalized
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15
Q

2.1 CAPITAL

What are the capital levels for a bank categorized as Well capitalized?

A
  • Total risk-based capital ratio of 10.0% or greater; and
  • Tier 1 risk-based capital ratio of 6.0% or greater; and
  • Tier 1 Leverage capital ratio of 5.0% or greater; and
  • Is not subject to any written agreement, order, capital directive, or prompt corrective action directive issued by the FDIC pursuant to section 8 of the FDI Act, the International Lending Supervision Act of 1983, or section 38 of the FDI Act, or any regulation thereunder, to meet and maintain specific capital levels for any capital measure.
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16
Q

2.1 CAPITAL

What are the capital levels for a bank categorized as Adequately capitalized?

A

• Total risk-based capital ratio of 8.0% or greater; and
• Tier 1 risk-based capital ratio of 4.0% or greater; and
• Tier 1 Leverage capital ratio of 4.0% or greater; or
• Tier 1 Leverage capital ratio of 3.0% or greater if:
&raquo_space; The bank is rated composite 1 at the most recent
examination, and
&raquo_space; Is not experiencing or anticipating significant
growth; and
&raquo_space; Does not meet the definition of a well capitalized
bank

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17
Q

2.1 CAPITAL

What are the capital levels for a bank categorized as Undercapitalized?

A

• Total risk-based capital ratio that is less than 8.0%; or
• Tier 1 risk-based capital ratio that is less than 4.0%; or
• Tier 1 Leverage capital ratio that is less than 4.0%; or
• Tier 1 Leverage capital ratio that less than 3.0%; if:
&raquo_space; The bank is rated composite 1 at the most recent
examination, and
&raquo_space; Is not experiencing or anticipating significant
growth

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18
Q

2.1 CAPITAL

What are the capital levels for a bank categorized as Significantly undercapitalized?

A
  • Total risk-based capital ratio that is less than 6.0%; or
  • Tier 1 risk-based capital ratio that is less than 3.0%; or
  • Tier 1 Leverage capital ratio that is less than 3.0%; or
  • Tier 1 Leverage capital ratio that less than 3.0%
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19
Q

2.1 CAPITAL

What are the capital levels for a bank categorized as Critically undercapitalized?

A

• Tangible Equity to total assets equal to or less than 2.0%

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20
Q

2.1 CAPITAL

Can a bank reveal its capital category marketing and promotional materials?

A

Unless permitted by the FDIC or otherwise required by law, no bank may state in any advertisement or promotional material its capital category under this subpart or that the FDIC or any other federal banking agency has assigned the bank to a particular capital category.

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21
Q

2.1 CAPITAL

What are the capital and exposure limits for a bank to be in compliance with the provisions of Regulation F?

A

Limits on credit exposure (1) The policies and procedures on exposure established by a bank under FRB § 206.3(c) shall limit a bank’s interday credit exposure to an individual correspondent to not more than 25% of the bank’s total capital, unless the bank can demonstrate that its correspondent is at least adequately capitalized, as defined in FRB § 206.5(a).

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22
Q

2.1 CAPITAL

What are some types of letter of credit?

A
  • Travelers Letter of Credit - Addressed by bank to correspondents authorizing draft by person named meeting specified terms
  • Sold for Cash Letter of Credit - Sold, and bank receives funds from account party at issuance (not a continent liability, but DDA)
  • Commercial Letter of Credit - Drafts drawn upon when underlying transaction consummated. Facilitates trade and commerce. (20% conversion factor)
  • Standby Letter of Credit – an irrevocable commitment by bank to make payment to a designated beneficiary and obligates the bank to guarantee or stand as surety for the benefit of a third party.
    • SBLCs can be:
      • Financial - where account party is to make payment to the beneficiary (100% conversion factor)
      • Performance - where a service is to be performed by account party (50% conversion factor
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23
Q

2.1 CAPITAL

What are the primary risk associated with standby letters of credit?

A

Credit risk and funding risk (liquidity)

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24
Q

2.1 CAPITAL

What is a material adverse change clause in a line of credit?

A

Allows the bank to terminate the commitment or line of credit arrangement if the customers financial condition deteriorates.

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25
2.1 CAPITAL | What is a 1 rating?
• Strong capital levels relative to the institution's risk | profile.
26
2.1 CAPITAL | What is a 2 rating?
• Satisfactory capital levels relative to the financial | institution's risk profile.
27
2.1 CAPITAL | What is a 3 rating?
• Less than satisfactory levels of capital that do not fully support the institution's risk profile; • Capital needs for improvement, despite capital level exceeding the minimum regulatory and statutory requirements.
28
2.1 CAPITAL | What is a 4 rating?
• Deficient level of capital; • Based on the institutions risk profile, viability of the institution may be threatened; • May require assistance from shareholders or other external sources of financial support.
29
2.1 CAPITAL | What is a 5 rating?
• Critically deficient levels of capital; • Viability of the institution is threatened; • Requires immediate assistance from shareholders or other external sources of financial support.
30
2.1 CAPITAL | What is the purpose of Capital?
* Absorb losses * Promote Public Confidence * Restrict Excessive Asset Growth * Provide Protection to Depositors and the DIF
31
2.1 CAPITAL | How do you calculate Part 1 of Tier 1 Capital?
• Common stockholders’ equity + • Noncumulative perpetual preferred stock + • Minority interests in equity capital accounts of consolidated subsidiaries MINUS • Disallowed goodwill and other intangibles besides MSAs, NMSAs, and PCCRs • Cumulative change in FV of liabilities accounted for under FV option • Non-eligible cred-enhancing interest-only strips (AFS Securities gains/losses)
32
2.1 CAPITAL | How do you calculate Part 2 of Tier 1 Capital?
PART 1 OF TIER 1 MINUS • Non-eligible credit-enhancing I/O strips - limited to 25% of Part 1 • Disallowed MSAs, NMSAs, and PCCRs - Allowable is the lesser of 90% of FV or 100% of remaining amortized BV - Limited in aggregate to 100% of Part 1 - Sublimit on MSA, NMSA, PCCR is 25% of Part 1 • Identified losses (other than loans) • Investments securities subsidiaries subject to 12 CFR Part 362 • Investments in financial subsidiaries • Ineligible deferred tax assets - Allowable is the lesser of 10% of Part 1 or amount expected to be realized within one year
33
2.1 CAPITAL | How do you calculate Tier 2 Capital?
• ALLL up to 1.25% of gross RWA • Cumulative perpetual preferred stock, Long-term preferred stock (orig. mat. at least 20 years) + related surplus - Discounted 20% per year after mat. falls below five years • Perpetual preferred stock where dividend is reset periodically based in whole or part on bank's credit rating • Hybrid capital instruments including mandatory convertible debt • Term sub. debt & Intermediate-term preferred stock (orig. mat. 5-20 years and not redeemable at option of holder prior to mat., except prior approval of FDIC) - Discounted 20% per year after mat. falls below five years - Limited to 50% of Tier 1 Capital • 45% pre tax net unrealized holding gains on AFS equity securities
34
2.1 CAPITAL | What is the maximum of Tier 2 Capital that may be recognized for risk-based capital purposes?
Limited to 100% of Tier 1 capital
35
2.1 CAPITAL | What is Total Capital for risk-based purposes?
• Tier 1 + Tier 2, • MINUS investments in banking and finance subsidiaries that are not consolidated for regulatory purposes
36
2.1 CAPITAL | What is included in Common Stockholders Equity?
* Common Stock and related surplus * Surplus * Retained Earnings (undivided profits) * Disclosed capital reserves (rarely seen) * AOCI Other Equity Capital Components
37
2.1 CAPITAL | How would preferred stock with an original maturity of 10 years fit into Tier 2 Capital?
• Intermediate-term preferred stock & qualifying term subordinated are limited to 50% of Tier 1 • Aggregated amount of items above (excluding convertibles) and (including related surplus) includable in Tier 2 is limited to 50% of Tier 1
38
2.1 CAPITAL | What limit is placed on Tier 2?
• Max amount of Tier 2 capital is limited | to 100% of Tier 1 Capital
39
2.1 CAPITAL | What is the method for making adjustments for an unfunded ALLL?
• Deduct amount of Loss for items other than loans and leases from Tier 1 Capital • Deduct the amount of Loss on loans and leases from the ALLL in the calculation of Tier 2 Capital • If the ALLL is inadequate, estimate the amount of provision expense needed (after loan losses are deducted) to make the ALLL adequately funded • Subtract the needed provision expense from Tier 1 Capital and add to Tier 2 Capital • An adjustment from Tier 1 to Tier 2 for an inadequate ALLL should be made only when the amount is considered significant
40
2.1 CAPITAL | What is Noncumulative Perpetual Preferred Stock and Related Surplus? (CEND)
• Cannot be redeemed at the option of the holder (perpetual) • Entitles holders to preference or priority over owners of common stock for dividends or asset distribution in case of liquidation (preferred) • No stated maturity (perpetual) • Issuer must have ability and legal right to defer or eliminate dividends (noncumulative) • Dividends do not accumulate, if not paid out (noncumulative)
41
2.1 CAPITAL What is limit for the combined amount of term subordinated debt (excluding mandatory convertible debt securities) and intermediate-term preferred stock (including any related surplus) that may be treated as Tier 2 capital for risk-based capital purposes?
The allowable combined amount of term subordinated debt and intermediate-term preferred stock (including any related surplus) that can be treated as Tier 2 capital is limited to 50 percent of Tier 1 capital.
42
2.1 CAPITAL What if Term subordinated debt or intermediate-term preferred stock is less than 5 years - how much do you include in Tier 2?
• 1-2 years 20% • 2-3 years 40% • 3-4 years 60% • 4-5 years 80% • > 5 years 100% • The less than 5 year rule also applies to long-term preferred stock with an original maturity of 20 years or more. The entire amount is includible in Tier 2.
43
2.1 CAPITAL | What is the maximum amount of Credit Enhancing Interest Only Strips allowable to include in Tier 1?
The lesser of: • 25% of Tier 1 Capital existing prior to the deductions of any disallowed MSA's, PCCR's, NMSA's, CEIO's, DTA's, and any NFEI, or • Sum of face value of all CEIOS's
44
2.1 CAPITAL | When is Tier 3 Capital used?
• Tier 3 Capital is only used when the market risk risk-based capital rules apply; • Insured SNM banks whose trading activity (on a worldwide basis) equals 10% or more of total assets, or $1 billion or more
45
2.1 CAPITAL | A bank subject to the market risk rules must complete what items?
• Value-at-Risk Model to estimate the maximum amount the bank’s covered positions could decline during a fixed holding period. • Risk Management System which defines a risk control unit that reports directly to senior management and is independent from business trading units, and • Internal Risk Measurement Model - integrated into the daily management process, and must have policies and procedures that identify appropriate stress tests and back tests, which the bank must conduct.
46
2.1 CAPITAL | What is includible in Tier 3 Capital? (FOD IN
• Fully paid up; • Original maturity of at least two years; • Does not contain and is not covered by any covenants, terms, or restrictions that are inconsistent with safe and sound banking practices • Unsecured subordinated debt; • Includes a lock-in clause precluding payment of either interest or principal (even at maturity) if the payment would cause the issuing bank's risk-based capital ratio to fall or remain below the minimum required under appendix A of this part; • Not redeemable before maturity without prior approval by the FDIC.
47
2.1 CAPITAL | Are there additional capital adjustments necessary for calculating risk-based capital?
• ORE reserves are not a component of capital; but, they can be used to reduce the amount of loss on ORE that is deducted from Tier 1 Capital • Liabilities not shown on the banks books should be deducted from Tier 1 capital and include significant amounts of unpaid bills, material deferred tax liabilities, contingent liabilities classified Loss, losses from criminal violations, account shortages
48
2.1 CAPITAL | What is the minimum regulatory leverage capital requirements per Part 325 of the FDIC Rules and Regulations?
• If less than 3% if the bank has a composite 1 rating and is not anticipating or experiencing any significant growth, and has well diversified risk, including IRR, excellent AQ, high liquidity, and good earnings • All other banks must have Tier 1 Leverage Capital of at least 4%
49
2.1 CAPITAL | What is the minimum regulatory risk-based capital requirements per Part 325 of the FDIC Rules and Regulations?
• Qualifying total capital to risk-weighted assets must be at least 8%, at least half of which (4%) must be comprised of Tier 1 capital. • If TRB capital falls below 8%, a contravention of Appendix to Part 325 must be cited
50
2.1 CAPITAL | What are the consequences if a bank falls below the regulatory 3% capital minimum requirements?
• Less than minimum will result in a violation of Part 325, Unsafe and Unsound Practice, unless entered into and in compliance with written agreement or submitted and in compliance with an FDIC-approved capital plan • Applications requiring FDIC approval will be automatically denied
51
2.1 CAPITAL | What does Appendix B of FDIC Rules & Regulations establish?
Prompt Corrective Action (PCA) pursuant to Section 38 of the FDI Act is used measure capital and in determining the supervisory actions authorized by Section 38
52
2.1 CAPITAL When does management have to submit a written capital restoration plan once receipt of notice that the bank is UC, SU, CU?
Management must file a written capital restoration plan with the FDIC within 45 days of the date the bank receives notice of UC, SU, or CU.
53
2.1 CAPITAL | What are the consequences if a bank falls below the regulatory 2% capital minimum requirements?
• Less than minimum 2% will result in a violation of Part 325, Unsafe and Unsound Condition • Subject to 8A proceedings unless bank has entered into and in compliance with written agreement with FDIC to increase Tier 1 to appropriate level
54
2.1 CAPITAL | What are the methods for increasing capital ratios?
``` • Increased earnings retention > Raise earnings or lower dividends/expenses • Sell additional capital stock > Shareholder dilution • Reduce asset growth ```
55
2.1 CAPITAL | How and when is a bank notified of the Capital Category?
A bank shall be deemed to have been notified of its capital levels and its capital category as of the most recent date of: • Consolidated Report of Condition and Income (Call Report); • Final report of examination is delivered to the bank; or • Written notice is provided by the FDIC to the bank of its capital category for purposes of section 38 of the FDI Act and this subpart or that the bank's capital category has changed as provided in § 325.103(d).
56
2.1 CAPITAL | What are the types of Category I Contingent Liabilities?
Category I Contingent Liabilities - will result in a concomitant increase in bank assets if converted to actual liabilities • Unfunded Commitments • Letters of credit Evaluated for credit risk - if assigned a Loss, then Tier 1 is adjusted "Assets Other than Loans Classified Loss"
57
2.1 CAPITAL | What are the types of Category II Contingent liabilities?
Category II Contingent Liabilities - a claim on assets that arises without an equivalent increase in assets • Lawsuits / litigation • Trust activities • Consigned items • Collection items • Reserve premium accounts Evaluated based on the probability that the contingency will become a direct liability
58
2.1 CAPITAL What type of Contingent Liability is "Loss Contingency," what does the term mean, and indicate whether it is included on the Capital Calculations page, and if so where?
• Refers to Category II • An existing condition, situation, or set of circumstances that involves uncertainty as to possible loss that will resolved when one or more future events occur or fail to occur • Included on Capital Calculations page as Contingent Liability with Type I's
59
2.1 CAPITAL What type of Contingent Liability is "Potential Loss," what does the term mean, and indicate whether it is included on the Capital Calculations page, and if so where?
• Refers to Category II • Contingent liability in which there is substantial and material risk of loss • Consists soles of Type II, • Listed separately on the Capital Calculations Page Memo Section
60
2.1 CAPITAL What type of Contingent Liability is "Estimated Loss," what does the term mean, and indicate whether it is included on the Capital Calculations page, and if so where?
• Refers to Category II • Should be recognized if it is probable that an asset has been impaired or a liability incurred as of the exam date & the loss can be reasonably estimated • Deducted from capital in the line "Other Adjustments to from) Tier 1 on Capital Calculations page • Amount of estimated Loss is not deducted from assets
61
2.1 CAPITAL | What is a Capital Directive?
• A final order issued to a SNM bank that fails to maintain capital at or above the minimum leverage capital requirement. • Equivalent to a C&D order (enforceable in the same manner and context) • Are issued by the FDIC's Board or Directors (designee)