Basel III: New Regulatory Capital Framework Survey

On June 7, 2012, the prudential regulators proposed a new regulatory capital framework for all banks including new minimum capital requirements and new risk weightings for certain exposures including residential real estate loans. Please click here for a summary of the proposal and its impact on community banks. ICBA would like to receive your feedback on this proposal with particular emphasis on how your bank would be impacted. Please complete the survey by August 31, 2012.

Feel free to contact James Kendrick or Chris Cole at 202-659-8111 if you have any questions or concerns.

Survey Questions

1. The proposal creates new minimum capital requirements for all banks with a focus on common equity. The minimum capital ratio of common equity to risk weighted assets would be 4.5%. For tier 1 capital the minimum would be 6%. For total capital the minimum would be 8%. Do you generally believe that these new minimum levels will impact community banks?

The proposal creates new minimum capital requirements for all banks with a focus on common equity. The minimum capital ratio of common equity to risk weighted assets would be 4.5%. For tier 1 capital the minimum would be 6%. For total capital the minimum would be 8%. Do you generally believe that these new minimum levels will impact community banks? Yes	No
Please explain.

2. How will the new minimum levels impact your bank? Please explain.

How will the new minimum levels impact your bank? Please explain.

3. In addition to minimum capital levels, the proposal would add new capital conservation buffers of 2.5% that would curb certain payments like dividends and executive bonuses if not met. Do you generally believe that these new capital conservation buffers are appropriate for community banks?

In addition to minimum capital levels, the proposal would add new capital conservation buffers of 2.5% that would curb certain payments like dividends and executive bonuses if not met. Do you generally believe that these new capital conservation buffers are appropriate for community banks? Yes	No
Why or why not?