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Regulatory Capital and Reserve Requirements
12 Months Ended
Dec. 31, 2023
Broker-Dealer, Net Capital Requirement, SEC Regulation [Abstract]  
Regulatory Capital and Reserve Requirements REGULATORY CAPITAL
Banking regulations limit the transfer of assets in the form of dividends, loans or advances from the bank subsidiaries to the parent company. Under the most restrictive of these regulations, the aggregate amount of dividends which can be paid to the parent company, without prior approval from bank regulatory agencies, approximated $400 million at January 1, 2024, plus 2024 net profits. Substantially all the assets of the Corporation’s banking subsidiaries are restricted from transfer to the parent company of the Corporation in the form of loans or advances.
The Corporation’s subsidiary banks declared dividends of $675 million, $1.0 billion and $852 million in 2023, 2022 and 2021, respectively.
The Corporation and its U.S. banking subsidiaries are subject to various regulatory capital requirements administered by federal and state banking agencies under the Basel III regulatory framework (Basel III). This regulatory framework establishes comprehensive methodologies for calculating regulatory capital and risk-weighted assets (RWA). Basel III also set minimum capital ratios as well as overall capital adequacy standards.
Under Basel III, regulatory capital comprises Common Equity Tier 1 (CET1) capital, additional Tier 1 capital and Tier 2 capital. CET1 capital predominantly includes common shareholders' equity, less certain deductions for goodwill, intangible assets and deferred tax assets that arise from net operating losses and tax credit carry-forwards. Additionally, the Corporation has elected to permanently exclude capital in accumulated other comprehensive income (AOCI) related to debt securities classified as available-for-sale as well as for cash flow hedges and defined benefit postretirement plans from CET1, an option available to standardized approach entities under Basel III. Tier 1 capital incrementally includes noncumulative perpetual preferred stock. Tier 2 capital includes Tier 1 capital as well as subordinated debt qualifying as Tier 2 and qualifying allowance for credit losses. In addition to the minimum risk-based capital requirements, the Corporation and its Bank subsidiaries are required to maintain a minimum capital conservation buffer, in the form of common equity, of 2.5 percent in order to avoid restrictions on capital distributions and discretionary bonuses.
The Corporation computes RWA using the standardized approach. Under the standardized approach, RWA is generally based on supervisory risk-weightings which vary by counterparty type and asset class. Under the Basel III standardized approach, capital is required for credit risk RWA, to cover the risk of unexpected losses due to failure of a customer or counterparty to meet its financial obligations in accordance with contractual terms; and if trading assets and liabilities exceed certain thresholds, capital is also required for market risk RWA, to cover the risk of losses due to adverse market movements or from position-specific factors.
Quantitative measures established by regulation to ensure capital adequacy require the maintenance of minimum amounts and ratios of CET1, Tier 1 and total capital (as defined in the regulations) to average and/or risk-weighted assets. Failure to meet minimum capital requirements can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a direct material effect on the Corporation’s financial statements. At December 31, 2023 and 2022, the Corporation and its U.S. banking subsidiaries exceeded the ratios required for an institution to be considered “well capitalized”. For U.S. banking subsidiaries, those requirements were total risk-based capital, Tier 1 risk-based capital, CET1 risk-based capital and leverage ratios greater than 10 percent, 8 percent, 6.5 percent and 5 percent, respectively, at December 31, 2023 and 2022. For the Corporation, requirements to be considered "well capitalized" were total risk-based capital and Tier 1 risk-based capital ratios greater than 10 percent and 6 percent, respectively, at December 31, 2023 and 2022. There have been no conditions or events since December 31, 2023 that management believes have changed the capital adequacy classification of the Corporation or its U.S. banking subsidiaries.
The following is a summary of the capital position of the Corporation and Comerica Bank, its principal banking subsidiary.
(dollar amounts in millions)Comerica
Incorporated
(Consolidated)
Comerica
Bank
December 31, 2023
CET1 capital (minimum $3.4 billion (Consolidated))
$8,414 $8,007 
Tier 1 capital (minimum $4.6 billion (Consolidated))
8,808 8,007 
Total capital (minimum $6.1 billion (Consolidated))
10,263 9,362 
Risk-weighted assets75,901 75,783 
Average assets (fourth quarter)87,538 87,423 
CET1 capital to risk-weighted assets (minimum-4.5%)
11.09 %10.57 %
Tier 1 capital to risk-weighted assets (minimum-6.0%)
11.60 10.57 
Total capital to risk-weighted assets (minimum-8.0%)
13.52 12.35 
Tier 1 capital to average assets (minimum-4.0%)
10.06 9.16 
Capital conservation buffer (minimum-2.5%)
5.52 4.35 
December 31, 2022
CET1 capital (minimum $3.5 billion (Consolidated))
$7,884 $7,801 
Tier 1 capital (minimum $4.7 billion (Consolidated))
8,278 7,801 
Total capital (minimum $6.3 billion (Consolidated))
9,817 9,190 
Risk-weighted assets78,871 78,781 
Average assets (fourth quarter)86,726 86,608 
CET1 capital to risk-weighted assets (minimum-4.5%)
10.00 %9.90 %
Tier 1 capital to risk-weighted assets (minimum-6.0%)
10.50 9.90 
Total capital to risk-weighted assets (minimum-8.0%)
12.45 11.67 
Tier 1 capital to average assets (minimum-4.0%)
9.55 9.01 
Capital conservation buffer (minimum-2.5%)
4.45 3.67