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REGULATORY MATTERS

3 Months Ended

Mar. 31, 2021

NOTE 16 – REGULATORY MATTERS

The ability of the Company to pay dividends to its stockholders is dependent upon the ability of the Bank to pay dividends to the Company.

The Company (on a consolidated basis) and the Bank are each subject to various regulatory capital requirements administered by the federal and state banking agencies. Failure to meet minimum capital requirements can initiate certain mandatory, and possibly additional discretionary, actions by the regulators that, if undertaken, could have a direct material effect on the consolidated financial statements of the Company and the Bank.

Under capital adequacy guidelines and the regulatory framework for prompt corrective action, the Company and the Bank must meet specific capital guidelines that involve quantitative measures of the assets, liabilities, and certain off-balance-sheet items as calculated under regulatory accounting practices. The capital amounts and classification are also subject to qualitative judgments by the regulators about components, risk weightings, and other factors. As allowed under the regulations, the Company and the Bank elected to exclude accumulated other comprehensive income, including unrealized gains and losses on securities, in the computation of regulatory capital. Prompt corrective action provisions are not applicable to bank holding companies.

Additionally, the Company and the Bank must maintain a “capital conservation buffer” to avoid becoming subject to restrictions on capital distributions and certain discretionary bonus payments to management. As of March 31, 2021 and December 31, 2020, the capital conservation buffer was 2.5%.

As of March 31, 2021, the Company and the Bank each met all capital adequacy requirements to which they were subject.

The actual and required capital amounts and ratios of HBT Financial, Inc. (on a consolidated basis) and the Bank are as follows:


	Actual				For Capital Adequacy Purposes				To Be Well Capitalized Under Prompt Corrective Action Provisions
March 31, 2021	Amount		Ratio		Amount		Ratio		Amount		Ratio

		(dollars in thousands)
Total Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	434,408	17.37	%	$	200,018	8.00	%		N/A	N/A
Heartland Bank and Trust Company		397,098	15.90			199,847	8.00		$	249,809	10.00	%

Tier 1 Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	366,392	14.65	%	$	150,014	6.00	%		N/A	N/A
Heartland Bank and Trust Company		368,339	14.74			149,885	6.00		$	199,847	8.00	%

Common Equity Tier 1 Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	329,892	13.19	%	$	112,510	4.50	%		N/A	N/A
Heartland Bank and Trust Company		368,339	14.74			112,414	4.50		$	162,376	6.50	%

Tier 1 Capital (to Average Assets)
Consolidated HBT Financial, Inc.	$	366,392	9.85	%	$	148,768	4.00	%		N/A	N/A
Heartland Bank and Trust Company		368,339	9.91			148,616	4.00		$	185,770	5.00	%


	Actual				For Capital Adequacy Purposes				To Be Well Capitalized Under Prompt Corrective Action Provisions
December 31, 2020	Amount		Ratio		Amount		Ratio		Amount		Ratio

		(dollars in thousands)
Total Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	426,283	17.40	%	$	195,970	8.00	%		N/A	N/A
Heartland Bank and Trust Company		382,511	15.63			195,787	8.00		$	244,733	10.00	%

Tier 1 Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	356,410	14.55	%	$	146,977	6.00	%		N/A	N/A
Heartland Bank and Trust Company		351,904	14.38			146,840	6.00		$	195,787	8.00	%

Common Equity Tier 1 Capital (to Risk Weighted Assets)
Consolidated HBT Financial, Inc.	$	319,927	13.06	%	$	110,233	4.50	%		N/A	N/A
Heartland Bank and Trust Company		351,904	14.38			110,130	4.50		$	159,077	6.50	%

Tier 1 Capital (to Average Assets)
Consolidated HBT Financial, Inc.	$	356,410	9.94	%	$	143,454	4.00	%		N/A	N/A
Heartland Bank and Trust Company		351,904	9.82			143,296	4.00		$	179,120	5.00	%

- Definition

The entire disclosure for regulatory capital requirement for depository and lending institutions. Institutions include, but not are not limited to, finance company, insured depository institution, bank holding company, savings and loan association holding company, bank and savings institution not federally insured, mortgage company, foreign financial institution and credit union.

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