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U.S. Bank Ratings And Capital Ratios Should Hold Firm Under The Collins Amendment

Publication date: 29-Aug-2012 11:23:01 EDT

(Editor's Note: In the original version of this article, published on June 27, 2012, figures for KeyCorp, New York Community Bancorp, and BOK Financial were incorrect in the table. A corrected version follows.)

U.S. banks have recently obtained further clarity on the Collins Amendment--one of the late and more controversial additions to the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Federal Reserve recently issued three notices of proposed rulemaking (NPRs) addressing in detail the capital requirements under the Dodd-Frank Act, including the Collins Amendment (see "For U.S. Banks, It's Finally Time For The Full Basel Rules," published June 18, 2012). The amendment imposes more stringent regulatory capital requirements on financial institutions and equalizes bank and thrift holding companies' capital requirements with the bank and thrift operating company capital requirements. It also disqualifies certain securities, including trust preferred securities (TruPS) and cumulative perpetual preferred stock, from Tier 1 capital. The Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corp. (FDIC) determined that these securities aren't able to absorb losses as effectively as other forms of Tier 1 capital. (Watch the related CreditMatters TV segment titled, "What The Collins Amendment's Capital Requirements Mean For U.S. Banks," dated July 9, 2012.)

We don't expect the implementation of the Collins Amendment, in itself, to have an impact on our issuer credit ratings on U.S. banks. Bank holding companies will need to build capital largely based on higher-quality and more permanent sources, particularly common stock, which should benefit banks' credit quality. But we believe that the market for hybrid instruments is likely to change considerably. The presence of TruPS in regulatory capital will likely decline substantially, although these securities could become cost-efficient Tier 2 instruments to the extent that they qualify, while contingent capital securities may gain ground.

An Overview Of The Collins Amendment

The Collins Amendment (Section 171, Leverage and Risk-Based Capital Requirements) made the leverage and risk-based capital requirements applicable to insured depository institutions that were in place when Dodd-Frank was enacted the new minimum standard for leverage and risk-based capital requirements for insured depository institutions, depository institution holding companies, and systemically important nonbank financial companies.

Although the Dodd-Frank Act required banking regulators to implement the Collins Amendment's provisions by January 2012, the Fed only recently addressed certain items such as the phase out of hybrid capital securities currently included in bank holding companies' Tier 1 capital. On June 7, 2012, the Fed issued three NPRs addressing the implementation of the Basel III regulatory capital reforms as well as the capital requirements under the Dodd-Frank Act, including the Collins Amendment. The NPR "Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, and Transition Provisions" directly addresses the Collins Amendment. The NPR identifies its proposed regulatory capital requirements as the "generally applicable" capital requirements for purposes of the Collins Amendment. The NPR also details the securities that will no longer qualify for Tier 1 capital treatment for bank holding companies and systemically important nonbank financial institutions: TruPS, cumulative perpetual preferred stock, and minority interest relating to cumulative perpetual preferred stock issued by a subsidiary.

One of the key clarifications relative to the Collins Amendment is the phase-out period, which will run from 2013 to 2016. The Fed's NPR stipulates that for banks with assets greater than $15 billion, by Jan. 1, 2013, 75% of outstanding nonqualifying securities will be included in regulatory capital. This will decline by 25% each year to 0% by Jan. 1, 2016. This phase-out period differs from Basel III, under which there is no differentiation by bank size and the phase-out period runs over 10 years. This considerably shorter phase-out period under the Collins Amendment could place U.S. banks subject to these provisions at a competitive disadvantage relative to foreign peers, in our view.

The Financial Stability Oversight Council (FSOC), which Congress created to enhance prudential supervision and capital requirements for systemically important financial institutions, has yet to determine which nonbank financial companies should be supervised by the Fed and subject to prudential standards. We expect these companies to be subject to the same provisions of the Collins Amendment. (see "New Regulatory Rules Likely Will Have A Limited Impact On U.S. Nonbank Financial Company Ratings," published May 9, 2012).

The Collins Amendment Is Unlikely To Have A Rating Impact For U.S. Banks

In our analysis of capital and earnings under our bank rating methodology, we first assess how a bank performs against its regulatory requirements. We then use our projected risk-adjusted capital (RAC) ratio--total adjusted capital to risk-weighted assets--to form an opinion of a bank's future capital. According to the Fed, the vast majority of banks would meet the fully phased-in minimum capital requirements as outlined in the NPRs as of March 31, 2012, and would otherwise be able to comply with the new regulatory requirements outlined by 2019 through retained earnings. Given the Fed's expectation, we focused our analysis on the Collins Amendment's potential impact on our RAC ratios for rated banks with total consolidated assets of more than $15 billion.

Based on our analysis, we do not anticipate that the Collins Amendment, in itself, will lead to any rating changes for U.S. banks. Our RAC ratio currently includes TruPS--up to 33% of adjusted common equity--in the numerator (see "Bank Hybrid Capital Methodology And Assumptions," published Nov. 1, 2011). We will exclude TruPS from the numerator in line with the regulatory phase out. To assess the impact of the Collins Amendment on our RAC ratios, we have applied a general set of assumptions to all rated U.S. banks to arrive at forecasts for capital and risk-weighted assets. These assumptions are illustrative and not necessarily consistent with bank-specific assumptions we use in forecasting earnings and capital in our ratings process.

Our analysis includes the following assumptions:

  • Phased-out securities are not substituted for other securities qualifying as Tier 1 capital under the proposed rules.
  • Dividends are 30% of net income, based on the maximum the Fed allows for banks with total assets greater than $50 billion. We did not incorporate any share buybacks.
  • Net income growth of -0.6% in 2013, 0.5% in 2014, and 3.5% in 2015, based on our forecast for all FDIC banks.
  • Risk-weighted assets growth of 2.1% in 2013, 1.9% in 2014, and 1.9% in 2015.

In addition, although TruPS, cumulative perpetual preferred securities, and minority interest relating to cumulative perpetual preferred stock issued by a subsidiary would no longer qualify as Tier 1 capital under the proposed rules, we based our capital impact estimate only on TruPS since these instruments represent the overwhelming majority of outstanding hybrids that would be phased out for our rated banks.

In our analysis, we found that most banks would retain their current capital and earnings scores (see table). Note that for an "adequate" capital and earnings score, we would look for a RAC ratio of at least 7%, and for a "strong" score, we would look for a RAC ratio of at least 10%.

We expect that the few banks that do not quite reach the minimum thresholds for their current capital and earnings scores (bolded in table), based on our broad assumptions, will be able to bridge the gap by replacing phased-out securities with qualifying Tier 1 securities, retaining more earnings, or attempting to reduce risk-weighted assets. (We note that these banks could also have stronger earnings performance than what our general assumptions outline, which could help build capital.) With the exception of Susquehanna, which has one of the largest proportions of TruPS, the banks that fall below the required minimum to maintain their current capital and earnings score are only slightly below the minimum thresholds.

The Estimated Impact Of The Collins Amendment On Standard & Poor's RAC Ratio
Capital and earnings scores TruPS as percent of 2011 total adjusted capital (TAC) Standard & Poor's RAC ratio as of Dec. 31, 2011 (%) Standard & Poor's RAC ratio without TruPS as of Dec. 31, 2011 (%) Estimated Standard & Poor's RAC ratio as of Dec. 31, 2015 (%) Increase/decrease in the RAC ratio 2015-2011 (%)
BB&T Corp. Adequate (0) 21.8 8.0 6.3 7.7 (0.4)

Susquehanna Bancshares Inc.

Strong (+1) 21.0 11.0 8.7 9.2 (1.9)
Capital One Financial Corp. Adequate (0) 19.1 7.1 5.7 8.4 1.3
Fifth Third Bancorp Adequate (0) 18.0 8.9 7.3 9.1 0.2
M&T Bank Corp. Adequate (0) 16.4 6.7 5.6 7.8 1.1
Webster Financial Corp. Adequate (0) 13.7 10.6 9.1 11.1 0.5
Popular Inc. Adequate (0) 13.4 8.1 7.0 7.5 (0.6)

JPMorgan Chase & Co.

Adequate (0) 13.4 6.1 5.2 6.8 0.8

Citigroup Inc.

Adequate (0) 11.4 6.6 5.9 6.9 0.3
SunTrust Banks Inc. Adequate (0) 11.2 7.8 6.9 7.4 (0.4)

Bank of America Corp.

Adequate (0) 10.8 7.8 6.9 6.7 (1.1)
KeyCorp Strong (+1) 11.0 10.1 9.0 10.8 0.7
Huntington Bancshares Inc. Adequate (0) 10.5 9.9 8.9 10.9 1.0
Associated Banc Corp. Strong (+1) 10.1 10.3 9.3 10.4 0.1
Regions Financial Corp.§ Adequate (0) 9.8 7.7 7.0 7.6 (0.2)
U.S. Bancorp Adequate (0) 9.4 9.1 8.2 11.6 2.5
Zions Bancorporation Adequate (0) 8.4 9.8 9.0 9.8 0.0
Morgan Stanley Adequate (0) 8.4 8.9 8.2 9.2 0.3
Cullen/Frost Bankers Inc. Strong (+1) 7.6 11.7 10.8 14.0 2.4

First Horizon National Corp.

Strong (+1) 7.5 9.9 9.2 9.8 (0.2)
Wells Fargo & Co. Adequate (0) 6.8 7.4 6.9 9.1 1.7
PNC Financial Services Group Adequate (0) 6.2 7.9 7.4 8.9 1.0
First Citizens BancShares, Inc. Strong (+1) 5.0 10.4 9.9 11.8 1.4
The Goldman Sachs Group Inc. Adequate (0) 4.0 7.3 7.0 7.7 0.4
First Niagara Financial Group Inc. Adequate (0) 3.8 11.0 10.6 11.5 0.5
Santander Holdings U.S.A Inc. Strong (+1) 3.7 12.2 11.8 14.6 2.3
SVB Financial Group Strong (+1) 2.3 11.5 11.3 12.7 1.2
BBVA USA Bancshares Inc.† Adequate (0) 1.8 9.0 8.8 10.2 1.2
Synovus Financial Corp.* Moderate (-1) 0.5 7.0 6.9 6.5 (0.5)
Comerica Inc. Adequate (0) 0.4 9.1 9.1 9.9 0.8
City National Corp. Adequate (0) 0.3 8.8 8.7 10.6 1.8
New York Community Bancorp Inc. Adequate (0) 10.0 10.2 9.2 12.1 1.9
TCF Financial Corp. Adequate (0) 0.0 10.0 10.0 11.0 1.0
BOK Financial Corp. Strong (+1) 0.0 10.0 10.0 12.3 2.4
UnionBanCal Corp. Strong (+1) 0.0 10.0 10.0 11.4 1.4
Commerce Bancshares Inc. Adequate (0) 0.0 8.6 8.6 10.9 2.3
Astoria Financial Corp. Strong (+1) 0.0 9.7 9.7 10.6 0.9
BancWest Corp. Moderate (-1) 0.0 5.1 5.1 6.9 1.8
BMO Financial Corp. Moderate (-1) 0.0 6.8 6.8 7.2 0.4
First Republic Bank Strong (+1) 0.0 11.5 11.5 15.0 3.4
Hancock Holding Co. Strong (+1) 0.0 9.4 9.4 10.0 0.6
HSBC USA Inc. Adequate (0) 0.0 8.4 8.4 9.2 0.8
People's United Financial Inc. Strong (+1) 0.0 12.5 12.5 13.6 1.1
*Synovus has reported losses for the past three years. This analysis assumes break-even in 2012. §Regions reported a loss in 2011. We have assumed profits in 2012 of roughly $460 million based on repayment of TARP and the sale of Morgan Keegan. †BBVA reported a loss in 2011, largely because of a $2 billion impairment. We forecast profits of about $450 million in 2012. Sources: Y9-C and Standard & Poor's research.

We expect many U.S. banks to redeem TruPS for two reasons--as a way to manage down the cost of liabilities and because the Fed's NPRs should effectively act as a catalyst for redemptions. The continued low interest rates have resulted in net interest margin (NIM) compression for U.S. banks. Therefore, some banks have been redeeming TruPS that were eligible to be retired prior to the NPRs. Retiring TruPS that had higher coupons can help to boost the NIM. For example, PNC Financial has been redeeming hybrids for about a year, likely with Fed approval, which has increased the bank's NIM. Other institutions had also been evaluating the potential cost benefits of retiring callable nonqualifying securities before the Jan. 1, 2013, start date. However, because the Fed's NPRs propose that TruPS no longer qualify as Tier 1 capital, the NPRs are likely to spur redemptions of TruPS before year-end because, under a large number of TruPS indentures, such proposal would likely trigger a regulatory capital event. The regulatory capital event may expire after 90 days of the NPR, although this is not a legal certainty. As a result, JPMorgan, Citigroup, and SunTrust announced their plans to redeem $9 billion, $4.9 billion, and $1.2 billion respectively, of mostly higher-coupon TruPS, after the Fed released its NPRs. Other banks, such as BB&T, TCF Financial, and Webster Financial have subsequently announced TruPS redemptions as well.

Although we expect redemptions, we don't anticipate that banks will retire all of their outstanding TruPS because a portion of them could become cost efficient Tier 2 capital instruments. Also, banks could choose not to retire a proportion of these securities to buy time to build capital ratios because a larger amount of outstanding TruPS would add more to Tier 1 capital until fully phased out. Separately, the Fed could require that banks replace the redeemed TruPS with qualifying Tier 1 capital instruments, which may not necessarily align with banks' goal of reducing their cost of capital. Thus, banks' decisions will likely depend on optimizing financing costs and regulatory capital requirements. We don't expect measured capital management actions to have a negative impact on U.S. bank ratings, though more aggressive capital management could lead to downgrades.

Foreign Banks Are Reorganizing Their U.S. Operations And Avoiding Collins-Related Costs

The Collins Amendment extends to the U.S. subsidiaries of foreign banks, eliminating the capital exemption that the Federal Reserve has provided since 2001 to foreign-owned intermediate holding companies (IHCs) that qualified as financial holding companies. (The capital exemption meant that qualifying foreign-owned IHCs did not have to comply with the Fed's capital requirements, as specified in Supervision and Regulation Letter 01-1.) U.S. bank holding companies of foreign banks have until July 2015 to meet capital requirements at the holding company level, as the Collins Amendment stipulates. We believe that the elimination of the capital exemption evens out the treatment of U.S. and foreign-owned holding companies by making them subject to the same capital requirements.

However, we believe some foreign banks have reorganized their U.S. operations to circumvent the capital adequacy requirements under the Collins Amendment and thus avoid the potential cost of having to inject billions of fresh capital into their U.S. holding companies. According to the January 2012 U.S. Government Accountability Office's (GAO) report on Bank Capital Requirements ("Potential Effects of New Changes on Foreign Holding Companies and U.S. Banks Abroad"), five foreign-owned IHCs relied on the capital exemption as of July 2010, when the Dodd-Frank Act was enacted. By the end of 2010, Barclays PLC deregistered its U.S. bank holding company. Similarly, in February 2012, Deutsche Bank AG reorganized its U.S. operations so that its banking activities in the U.S. are no longer subsidiaries of its U.S. intermediate holding company (Taunus). Like Barclays, Deutsche Bank has applied to deregister Taunus as a bank holding company.

Interestingly, for one of the unidentified four remaining exempt foreign banks the GAO study referred to, the estimated requirement to comply with "well-capitalized" standards was $12.2 billion in Tier 1 and $31.6 billion of total capital. For the other three banks, the collective estimated amounts are lower at $2.6 billion and $5.4 billion for Tier 1 and total capital, respectively. We expect other foreign banks to consider the potential benefits of restructuring their exempt holding companies, like Barclays and Deutsche Bank have. However, the Fed has taken a more active role in such reorganizations, which could limit or even eliminate banks' opportunities to restructure. Indeed, following Deutsche Bank's reorganization, the Fed said it intends to revise the regulation of foreign bank organizations. Therefore, foreign banks may need to consider other alternatives such as injecting capital, retaining earnings, reducing riskier assets, or exiting the U.S. market. We note that even if foreign banks manage to avoid these new higher capital requirements, they may still be subject to other provisions under the Dodd-Frank Act. For example, both Barclays and Deutsche Bank have investment banking operations that will need to comply with the Volcker Rule.

The Ultimate Impact? It's Too Early To Tell

The impact that the Collins Amendment will have on U.S. banks in the long run is unclear. A key issue remains coordinating the implementation of the Collins Amendment with the implementation of Basel III, which may be costly and challenging. It also remains to be seen to what extent this could result in a loss of competitiveness for U.S banks, particularly those under the Basel II "advanced approaches." The proposed implementation of Basel III in the U.S. in the context of the Collins Amendment, as presented in the NPRs, means that U.S. banks will be subject to more restrictive capital requirements than banks in other countries--including the much shorter phase-out period for nonqualifying securities. Moreover, the interplay between capital management and asset-liability management to optimize regulatory capital and financing costs will also be a factor in our ratings. Despite these uncertainties and potential issues, U.S. banks will be building up higher-quality capital, which we view as favorable for banks' creditworthiness.

Appendix: The Collins Amendment's Key Provisions And Timing

The Collins Amendment states that minimum leverage and capital requirements:

  • Cannot be less than the "generally applicable leverage and risk-based capital requirements" or "quantitatively lower than the generally applicable leverage capital requirements" that were in effect for insured depository institutions as of the date the Dodd-Frank Act was enacted.
  • The generally applicable leverage and risk-based capital requirements must serve as a "floor."

The Collins Amendment defines generally applicable leverage capital requirements as minimum ratios of Tier 1 capital to average total assets and generally applicable risk-based capital requirements as the risk-based capital requirements based on Basel I. The minimums apply to all insured depository institutions under the prompt corrective action (PCA) provisions of the Federal Deposit Insurance Act--regardless of total consolidated asset size or foreign financial exposure. The Collins Amendment allows federal banking agencies to set capital requirements that are higher than the "generally applicable" minimum capital requirements, but not lower. The NPR that addresses the Collins Amendment also proposes revising the PCA framework to include the proposed changes to the definitions of capital and regulatory minimums.

Under the Collins Amendment, the leverage and capital requirements serve as a permanent floor. This permanent floor is mandatory for U.S. banks using the "advanced approaches" under Basel II. For banks using the "advanced approaches," the Fed's NPRs identify their proposed regulatory capital requirements as the "generally applicable" capital requirements for purposes of the Collins Amendment. A U.S. depository institution or bank holding company operating under "advanced approaches" must calculate its capital based on both the proposed "generally applicable" rules and the "advanced approaches." The company must use the lower of the two Tier 1 capital ratios and the lower of the two total capital ratios to determine whether it meets capital requirements. The current minimums under the NPR--which would represent the floor--are 6% for the Tier 1 capital ratio (the NPR increased the minimum from 4%) and 8% for the total capital ratio.

One issue surrounding the floor is that it could place U.S. banks at a competitive disadvantage to their less stringently regulated global peers. This raises the question of whether the floor should apply to foreign banks while applying for approval to operate in the U.S. (Statutory approval standards require federal banking agencies to determine whether a foreign bank's capital would be equivalent to the capital a U.S. bank is required to hold.)

In addition, according to the Collins Amendment, holding companies and systemically important nonbanks will no longer have to deduct (from Tier 1 capital) their investments in subsidiaries that are engaged in financial activities, unless the Federal Reserve or the primary financial regulator determines otherwise. The NPR does not appear to address this specific point.

Timing and exceptions

The Collins Amendment will phase in any regulatory capital deductions for debt and equity hybrids (meaning they don't qualify as Tier 1 capital) issued before May 19, 2010, from Jan. 1, 2013, to Jan. 1, 2016. The amendment was retroactively effective for debt and equity hybrids issued on or after May 19, 2010, for all institutions--with some exceptions.

Exempted from the phase-in of the regulatory capital deductions for nonqualifying hybrids issued before May 19, 2010:

  • Organizations that were mutual holding companies on May 19, 2010
  • Thrift and bank holding companies with less than $15 billion in total consolidated assets

Allowed to permanently grandfather debt and equity hybrids issued before May 19, 2010:

  • Bank holding companies with total assets of $500 million to $15 billion
  • Thrift holding companies with total assets of less than $500 million

Organizations that will phase in the deductions over five years:

  • Depository institutions that were previously not supervised
  • Intermediate U.S. holding companies of foreign banks

The Fed's NPR outlines the phase-out schedule for the regulatory capital deductions as follows:

  • For institutions with more than $15 billion in total assets, 75% of nonqualifying securities will be included in regulatory capital by Jan. 1, 2013. This percentage steps down 25% each year to 0% by Jan. 1, 2016.
  • Institutions with less than $15 billion in total assets have a separate phase-out schedule that gradually reduces the percentage of the notional outstanding amount of nonqualifying securities issued before Sept. 12, 2010, that can continue to count as Tier 1 capital. By Jan. 1, 2013, 90% of securities will qualify. This will decline by 10% each year until fully phased out by Jan. 1, 2022. This is a change from what the Collins Amendment specified.

Unlike the Collins Amendment, under Basel III there is no differentiation by bank size and the phase-out period runs over 10 years. For banks with more than $15 billion in assets, the considerably shorter phase-out period under the Collins Amendment could also place U.S. banks at a disadvantage relative to foreign peers, in our view.

The Collins Amendment does not apply to Federal Home Loan Banks and small bank holding companies (total assets less than $500 million) subject to the Small Bank Holding Company Policy Statement of the Board of Governors as of May 19, 2010. The amendment also explicitly and permanently grandfathers all Troubled Asset Relief Program preferred issuances, regardless of the institution's size.

The NPR is also consistent with the Collins Amendment on the exceptions. The NPR does make the distinction between small savings and loan holding companies (which are not exempt from the Collins Amendment) and small bank holding companies, which are exempt.

Related Research

Primary Credit Analyst:Carmen Y Manoyan, New York (1) 212-438-6162;
Secondary Contact:Rodrigo Quintanilla, New York (1) 212-438-3090;
Research Contributor:Shameer Bandeally, CRISIL Global Analytical Center, an S&P affiliate, Mumbai

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