The Changing Capital Landscape for Community Banks

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The federal bank regulatory agencies have jointly issued notices of proposed rulemaking which would introduce sweeping new capital regulations affecting all community banks. Banks and their directors would be well advised to evaluate the proposed changes and calculate pro forma risk-based capital ratios “as if in effect today” to determine how these enhanced capital ratios will impact their institution and to begin considering strategies to respond to the challenges ahead. Comments on the proposed rules are requested by September 7, 2012 ...

Phase-In of New Capital Rules -

The attached chart is intended to provide a summary of selected aspects of the proposed capital rules and which would be of particular relevance to our community bank clients. Readers should refer to specific provisions in the proposed rules for specific details and consult your advisors.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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