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Regulatory Matters
 12 Months Ended
Dec. 31, 2017
Banking and Thrift [Abstract]  
Regulatory Matters
Regulatory Matters

We are subject to various regulatory capital requirements administered by the federal banking agencies. Failure to meet minimum capital requirements as set forth in the tables below can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a material effect on our consolidated financial statements. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, we must meet specific capital guidelines that involve quantitative measures of our assets, liabilities, and certain off-balance sheet items as calculated under regulatory accounting practices. The capital amounts and the Bank’s prompt corrective action classification are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors.
 
Capital ratios are reviewed by Management on a regular basis to ensure that capital exceeds the prescribed regulatory minimums and is adequate to meet our anticipated future needs.  For all periods presented, the Bank’s ratios exceed the regulatory definition of “well capitalized” under the regulatory framework for prompt corrective action and Bancorp’s ratios exceed the required minimum ratios to be considered a well capitalized bank holding company. In addition, the most recent notification from the FDIC categorized the Bank as well capitalized under the regulatory framework for prompt corrective action as of December 31, 2017. There are no conditions or events since that notification that Management believes have changed the Bank’s categories and we expect the Bank to remain well capitalized for prompt corrective action purposes.

In July 2013, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency ("Agencies") finalized regulatory capital rules known as “Basel III.” The rules became effective beginning January 2015, and will be fully phased-in by January 2019. The guidelines, among other things, changed the minimum capital requirements of banks and bank holding companies, by increasing the Tier 1 capital to risk-weighted assets ratio to 6%, and introduced a new requirement to maintain a minimum ratio of common equity Tier 1 capital to risk-weighted assets of 4.5%. By 2019, when fully phased in, the rules will require further increases to certain minimum capital requirements and a capital conservation buffer of an additional 2.5% of risk-weighted assets.

In August 2017, the Agencies published a final rule ("transitions NPR") halting the phase-in of certain Basel III capital rules for banks not using the Basel advanced approaches. The rule extends the regulatory capital treatment applicable during 2017 under the regulatory capital rules for certain items. These items include regulatory capital deductions, risk weights, and certain minority interest limitations. This effectively pauses the full transition to the Basel III treatment of mortgage servicing assets, certain deferred tax assets, investments in the capital of unconsolidated financial institutions and minority interests while the Agencies pursue more extensive rulemaking to simplify the treatment of assets. The transitions NPR that was effective January 1, 2018 does not apply to Bank of Marin.

We have modeled our ratios under fully phased-in Basel III rules and, based on present facts, we do not expect that we will be required to raise additional capital as a result of the fully phased-in rules.

The Bancorp’s and Bank's capital adequacy ratios as of December 31, 2017 and 2016 are presented in the following tables. Bancorp's Tier 1 capital includes the subordinated debentures, which are not included at the Bank level. We continued to build capital in 2017 through stock issued in the Bank of Napa acquisition and the accumulation of net income.
Capital Ratios for Bancorp
(dollars in thousands)
Actual Ratio
 
Adequately Capitalized Threshold 1
 
Ratio to be a Well Capitalized Bank Holding Company
December 31, 2017
Amount

Ratio

 
Amount

Ratio

 
Amount

Ratio

Total Capital (to risk-weighted assets)
$
287,435

14.91
%
 
≥ $
178,323

≥ 9.250
%
 
≥ $
192,782

≥ 10.000
%
Tier 1 Capital (to risk-weighted assets)
$
270,710

14.04
%
 
≥ $
139,767

≥ 7.250
%
 
≥ $
154,225

≥ 8.000
%
Tier 1 Capital (to average assets)
$
270,710

12.13
%
 
≥ $
89,285

≥ 4.000
%
 
≥ $
111,607

≥ 5.000
%
Common Equity Tier 1 (to risk-weighted assets)
$
265,119

13.75
%
 
≥ $
110,849

≥ 5.750
%
 
≥ $
125,308

≥ 6.500
%
December 31, 2016
 

 

 
 

 

 
 

 

Total Capital (to risk-weighted assets)
$
247,453

14.32
%
 
≥ $
149,039

≥ 8.625
%
 
≥ $
172,799

≥ 10.000
%
Tier 1 Capital (to risk-weighted assets)
$
231,111

13.37
%
 
≥ $
114,479

≥ 6.625
%
 
≥ $
138,239

≥ 8.000
%
Tier 1 Capital (to average assets)
$
231,111

11.39
%
 
≥ $
81,189

≥ 4.000
%
 
≥ $
101,486

≥ 5.000
%
Common Equity Tier 1 (to risk-weighted assets)
$
225,925

13.07
%
 
≥ $
88,559

≥ 5.125
%
 
≥ $
112,319

≥ 6.500
%
1 The 2017 and 2016 adequately capitalized thresholds include the capital conservation buffer that was effective January 1, 2016 and January 1, 2017, respectively. These ratios are not reflected on a fully phased-in basis.
Capital Ratios for the Bank  (dollars in thousands)
Actual Ratio
 
Adequately Capitalized Threshold 1
 
Ratio to be Well Capitalized under Prompt Corrective Action Provisions
December 31, 2017
Amount

Ratio

 
Amount

Ratio

 
Amount

Ratio

Total Capital (to risk-weighted assets)
$
283,885

14.73
%
 
≥ $
178,281

≥ 9.250
%
 
≥ $
192,737

≥ 10.000
%
Tier 1 Capital (to risk-weighted assets)
$
267,160

13.86
%
 
≥ $
139,734

≥ 7.250
%
 
≥ $
154,189

≥ 8.000
%
Tier 1 Capital (to average assets)
$
267,160

11.97
%
 
≥ $
89,275

≥ 4.000
%
 
≥ $
111,593

≥ 5.000
%
Common Equity Tier 1 (to risk-weighted assets)
$
267,160

13.86
%
 
≥ $
110,824

≥ 5.750
%
 
≥ $
125,279

≥ 6.500
%
December 31, 2016
 

 

 
 

 

 
 

 

Total Capital (to risk-weighted assets)
$
243,468

14.09
%
 
≥ $
149,016

≥ 8.625
%
 
≥ $
172,772

≥ 10.000
%
Tier 1 Capital (to risk-weighted assets)
$
222,127

13.15
%
 
≥ $
114,462

≥ 6.625
%
 
≥ $
138,218

≥ 8.000
%
Tier 1 Capital (to average assets)
$
222,127

11.19
%
 
≥ $
81,176

≥ 4.000
%
 
≥ $
101,469

≥ 5.000
%
Common Equity Tier 1 (to risk-weighted assets)
$
222,127

13.15
%
 
≥ $
88,546

≥ 5.125
%
 
≥ $
112,302

≥ 6.500
%
1 The 2017 and 2016 adequately capitalized thresholds include the capital conservation buffer that was effective January 1, 2016 and January 1, 2017, respectively. These ratios are not reflected on a fully phased-in basis.