The federal banking agencies are issuing a statement to provide information and guidance on the use of the two-quarter grace period under the optional community bank leverage ratio (CBLR) framework when the temporary relief measures affecting the framework expire on December 31, 2021.
The interagency statement on the community bank leverage ratio framework can be found here.
Statement of Applicability: This Financial Institution Letter (FIL) is applicable to institutions reporting under the community bank leverage ratio framework.
- A banking organization that elects the CBLR framework when submitting its March 31, 2022 Call Report will be subject to the greater than 9 percent CBLR requirement and must use total consolidated assets as of the report date to determine eligibility.
- Importantly, the CBLR framework includes a two-quarter grace period that generally allows banking organizations additional time to build capital and manage their balance sheets to either remain in the framework or prepare to comply with the generally applicable risk-based and leverage capital requirements.
- Depending on whether a banking organization is currently in its grace period and when that grace period began, a banking organization may not be required to report a greater than 9 percent CBLR until the June 30, 2022 or September 30, 2022 regulatory filings. Banking organizations will not be viewed negatively in the examination process due to use of the grace period.
- Starting on January 1, 2022, a banking organization in the CBLR framework must report a leverage ratio greater than 8 percent to use the two-quarter grace period. At the end of the two-quarter grace period, the banking organization must satisfy all qualifying criteria to remain in the CBLR framework.
12 CFR 324