new calculator—which is an Excel spreadsheet—has been pre-populated
with bank data from the June 30 call reports. Once the preparer fills in
the bank’s FDIC certificate number, data specific to that bank will
automatically appear on the spreadsheet. The calculator also will
identify the information banks need to submit to obtain an estimate of
their regulatory capital ratios under the proposal. Bankers will also
need to refer to the Basel III proposal to complete the calculator.
the calculator is completed, ICBA strongly urges every bank to write a
comment letter by the Oct. 22 comment deadline describing how the Basel
III proposal will affect the bank’s risk-based capital ratios. Guidelines for drafting a comment letter, including a template and insertable talking points, can be found on the ICBA website.
bank should examine the impact to its risk-based capital ratios of the
proposed new risk weights on mortgages—particularly balloon mortgages
where risk weights will double—as well as the proposed inclusion of
accumulated other comprehensive income as part of regulatory capital. The
more personalized comment letters that ICBA members send to the
regulators, the greater the chance of significant changes to the
ICBA also continues to call on community bankers to
sign its petition calling on regulators to exempt community banks from
the Basel III proposals. More information, including a summary of the
proposal, talking points, a link to the FDIC’s Power Point presentation,
an ICBA Basel III audio presentation and ICBA news coverage, is
available on ICBA’s comprehensive Basel III webpage.