XML 42 R23.htm IDEA: XBRL DOCUMENT v3.25.0.1
Regulatory & Capital Matters
12 Months Ended
Dec. 31, 2024
Regulatory & Capital Matters  
Regulatory & Capital Matters

Note 15: Regulatory & Capital Matters

The Bank is subject to the risk-based capital regulatory guidelines, which include the methodology for calculating the risk-weighted Bank assets, developed by the Office of the Comptroller of the Currency (the “OCC”) and the other bank regulatory agencies.  In connection with the current economic environment, the Bank’s current level of nonperforming assets and the risk-based capital guidelines, the Bank’s board of directors’ guidelines are for the Bank to maintain a Tier 1 leverage capital ratio at or above eight percent (8%) and a total risk-based capital ratio at or above twelve percent (12%).  The Bank currently exceeds those thresholds.

Bank holding companies are required to maintain minimum levels of capital in accordance with capital guidelines implemented by the Board of Governors of the Federal Reserve System.  The general bank and holding company capital adequacy guidelines in force as of the periods reported are shown in the accompanying table, as are the capital ratios of the Company and the Bank, as of December 31, 2024, and December 31, 2023.

In July 2013, the U.S. federal banking authorities issued final rules (the “Basel III Rules”) establishing more stringent regulatory capital requirements for U.S. banking institutions, which went into effect on January 1, 2015.  A detailed discussion of the Basel III Rules is included in Part I, Item 1 of the annual report under the heading “Supervision and Regulation.”

The Company and the Bank are subject to regulatory capital requirements administered by federal banking agencies.  The capital ratios below are calculated pursuant to the capital requirements in effect for the periods reported below.

Capital levels and industry defined regulatory minimum required levels at December 31, were as follows:

Minimum Capital

Well Capitalized

Adequacy with Capital

Under Prompt Corrective

Actual

Conservation Buffer, if applicable1

Action Provisions2

    

Amount

    

Ratio

    

Amount

    

Ratio

    

Amount

    

Ratio

2024

Common equity tier 1 capital to risk weighted assets

Consolidated

$

607,294

12.82

%

$

331,596

7.00

%

N/A

N/A

Old Second Bank

610,285

12.89

331,419

7.00

$

307,747

6.50

%

Total capital to risk weighted assets

Consolidated

736,492

15.54

497,630

10.50

N/A

N/A

Old Second Bank

654,484

13.82

497,256

10.50

473,577

10.00

Tier 1 capital to risk weighted assets

Consolidated

632,294

13.34

402,886

8.50

N/A

N/A

Old Second Bank

610,285

12.89

402,438

8.50

378,765

8.00

Tier 1 capital to average assets

Consolidated

632,294

11.30

223,821

4.00

N/A

N/A

Old Second Bank

610,285

10.90

223,958

4.00

279,947

5.00

2023

Common equity tier 1 capital to risk weighted assets

Consolidated

$

547,721

11.37

%

$

337,207

7.00

%

N/A

N/A

Old Second Bank

592,413

12.32

336,598

7.00

$

312,556

6.50

%

Total capital to risk weighted assets

Consolidated

677,076

14.06

505,640

10.50

N/A

N/A

Old Second Bank

636,768

13.24

504,990

10.50

480,943

10.00

Tier 1 capital to risk weighted assets

Consolidated

572,721

11.89

409,430

8.50

N/A

N/A

Old Second Bank

592,413

12.32

408,727

8.50

384,684

8.00

Tier 1 capital to average assets

Consolidated

572,721

10.06

227,722

4.00

N/A

N/A

Old Second Bank

592,413

10.41

227,632

4.00

284,540

5.00

1 Amounts are shown inclusive of a capital conservation buffer of 2.50%.

2 The prompt corrective action provisions are only applicable at the Bank level. The Bank exceeded the general minimum regulatory requirements to be considered “well capitalized.”

As part of its response to the impact of the COVID-19 pandemic, in the first quarter of 2020, U.S. federal regulatory authorities issued an interim final rule that provided banking organizations that adopted CECL during the 2020 calendar year with the option to delay for two years the estimated impact of CECL on regulatory capital relative to regulatory capital determined under the prior incurred loss methodology, followed by a three-year transition period to phase out the aggregate amount of the capital benefit provided during the initial two-year delay (i.e., a five-year transition in total). In connection with our adoption of CECL on January 1, 2020, we elected to utilize the five-year CECL transition.  The cumulative amount that is not recognized in regulatory capital, in addition to the $3.8 million Day 1 impact of CECL adoption, has been phased in at 25% per year beginning January 1, 2022. As of December 31, 2024, the capital measures of the Company above include $951,000, which is the Day 1 impact to retained earnings and 25% of the increase in the allowance for credit losses during 2020 and 2021, excluding PCD loans and acquisition related adjustments.

Dividend Restrictions

In addition to the above requirements, banking regulations and capital guidelines generally limit the amount of dividends that may be paid by a Bank without prior regulatory approval.  Under these regulations, the amount of dividends that may be paid in any calendar year is limited to the current year’s profits, combined with the retained profit of the previous two years, subject to the capital requirements described above.  As of December 31, 2024, the Company had total dividend availability of $107.8 million from the Bank, per regulatory guidelines.  Pursuant to the Basel III rules that were fully phased-in at January 1, 2019, the Bank must keep a capital conservation buffer of 2.5% on all risk-based capital requirements in order to avoid additional limitations on capital distributions.