Did you know the Fed has released new tougher guidance for banks paying dividends or receiving TARP, including a stress test of future earnings?
	Have you performed a gap analysis comparing your current practices to the guidance outlined in SR 09-4 and informed your board of the remediation steps required?
	The Federal Reserve Board recently elevated its scrutiny of bank capital adequacy with Supervisory Letter SR 09-4 ("Applying Supervisory Guidance and Regulations on the Payment of Dividends, Stock Redemptions, and Stock Repurchases at Bank Holding Companies," 2/24/2009 revised March).  SR 09-4 clarifies regulatory expectations that all BHCs -- whether or not recipients of TARP/CPP funds -- provide their examiner with comprehensive documentation and analysis prior to the declaration of any dividend, redemption, or repurchase.  While not providing explicit safe harbor, SR 09-4 provides a list of critical capital management capabilities that regulators expect of banks your size and complexity before declaring a dividend.  Second Pillar Consulting would like to clarify these requirements and discuss our ability to help assess and fill any gaps you might have.  Our SR 09-4 Overview provides additional clarity on the new guidance.

	Exclusive Standardized Basel II focus. We do one thing and we do it well, ensuring the highest quality and lowest cost.
	Low overhead. We do not carry – and you do not pay for – the bloated partnership and support structure of traditional consulting firms.
	No “scope creep”. Unlike other bank consultants, we are not looking to up-sell or cross-sell larger “enterprise solutions.”
	No sales people. You work directly with compliance experts that want to help solve problems, not sell more business.

You want the capital benefits that come with Basel II compliance. We can help get you there efficiently and effectively.

Contact us for a free report to determine the potential Standardized Basel II capital savings for your bank.