This morning the FDIC published its Interagency Guidance on Correspondent Concentration Risks. The Guidance leaves Regulation F unchanged which means, per Regulation F, there are no interbank liability limitations with ACBB since we are ‘Well Capitalized.’ It should be noted because ACBB has continued its participation in the TAG program, these insured deposits do not count towards total exposure.
Practically speaking, anytime you exceed 25% of total capital, you should be thorough in documenting your due diligence. The guidance reaffirms this philosophy. We will read the FDIC's 27 page document thoroughly and send our communication next week. This communication will include a full recap of ACBB’s financial performance, capital and asset quality ratios (vs. just Capital ratios) as well as a trend line on some key metrics
(ie. NPAs). If you have any questions, please contact:
Janine Salisbury: salisbury@atlanticcentral.com or (717) 441-4605
Laura Gibboney: gibboney@atlanticcentral.com or (717) 441-4512