Deputy Seminar, Denver, CO

PROPOSED REGULATION ON CAPITAL PHASE-IN • Replaces ALLL terminology with ACL • Day 1 beginning retained earnings effect of CECL phased in over 3 years for regulatory capital purposes  Retained earnings, ACL and deferred tax asset • Includes loans, HTM debt securities and off-balance sheet commitments

http://www.bkd.com/articles/2018/proposed-regulation- on-cecl-regulatory-capital-phase-in.htm

CECL WHERE ARE BANKS TODAY & LESSONS LEARNED