EAST WEST BANCORP, INC.
Basel III Regulatory Capital Disclosures
December 31, 2023
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TABLE OF CONTENTS | |
Page | |
General Disclosure for Counterparty Credit Risk-Related Exposures | 13 |
Credit Risk Mitigation | 15 |
Securitization | 15 |
Equities Not Subject to the Market Risk Rule | 16 |
Interest Rate Risk for Non-trading Activities | 17 |
Appendix 1 - References to the Company's SEC Filings | 19 |
Appendix 2 - Forward-looking statements | 24 |
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SCOPE OF APPLICATION
Organization
East West Bancorp, Inc. (referred to herein on an unconsolidated basis as "East West" and on a consolidated basis as the "Company") is a registered bank holding company that offers a full range of banking services to individuals and businesses through its subsidiary bank, East West Bank and its subsidiaries ("East West Bank" or the "Bank"). The Bank is the Company's principal asset and provides a full range of consumer and commercial products and services through the Consumer and Business Banking, and Commercial Banking segments, with the remaining functions included in the Other segment. As of December 31, 2023, the Company operated in the United States ("U.S.") and Asia. In the U.S., the Bank's corporate headquarters and main administrative offices are located in California, and its branches and offices are located in California, Texas, New York, Washington, Georgia, Massachusetts, Illinois, and Nevada. In Asia, the Company's presence includes full- service branches in Hong Kong, Shanghai, Shantou and Shenzhen, representative offices in Beijing, Chongqing, Guangzhou, Xiamen, and Singapore, and administrative support offices in Beijing and Shanghai. The Bank has a banking subsidiary based in China - East West Bank (China) Limited. As of December 31, 2023, the Company and the Bank were classified as "well capitalized" and not subject to any capital distribution restrictions. For additional information on dividend restrictions and transfers of funds, refer to Item 1. Business - Supervision and Regulation - Dividends and Other Transfers of Funds in the Company's Annual Report on Form 10-K for the year ended December 31, 2023, filed with the SEC (the "Company's 2023 Form 10-K").
Regulation
As a bank holding company, East West is subject to regulation, supervision, and examination by the Board of Governors of the Federal Reserve System ("Federal Reserve") under the BHC Act. The Company is also subject to the disclosure and regulatory requirements under the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and the rules and regulations adopted by the U.S. Securities and Exchange Commission ("SEC") thereunder.
East West Bank is a California state-chartered bank and a member of the Federal Reserve System, and its deposits are insured by the Federal Deposit Insurance Corporation ("FDIC"). The Bank's operations in the U.S. are primarily regulated and supervised by the Federal Reserve and the California Department of Financial Protection and Innovation ("DFPI"), and its activities outside the U.S. are regulated and supervised by its U.S. regulators and the applicable regulatory authority in the host country in which each overseas office is located.
The Bank's foreign subsidiary, East West Bank (China) Limited, is subject to applicable foreign laws and regulations, such as those implemented by the People's Bank of China ("PBOC") and China's National Administration of Financial Regulation ("NAFR"). East West Bank's Hong Kong branch is subject to applicable foreign laws and regulations, such as those implemented by the Hong Kong Monetary Authority ("HKMA") and the Hong Kong Securities and Futures Commission ("HKSFC"). The Bank's Singapore representative office is subject to applicable foreign laws and regulations, such as those implemented by the Monetary Authority of Singapore ("MAS").
In addition to its banking operations, East West has a wholly-owned nonbank subsidiary, East West Markets, LLC ("East West Markets"), which is an SEC-registeredbroker-dealer and a member of the Financial Industry Regulatory Authority, Inc. ("FINRA"). East West Markets is subject to regulatory requirements from several regulatory bodies, including the SEC, FINRA, and state securities regulators.
Regulatory Capital Standards and Disclosures
The federal banking agencies have imposed capital adequacy requirements, known as the Basel III Capital Rules, intended to ensure that banking organizations maintain capital that is commensurate with the degree of risk associated with their operations. The Basel III Capital Rules define the components of regulatory capital, including Common Equity Tier 1 ("CET1"), Tier 1 and Tier 2 capital, and set forth minimum capital adequacy ratios of capital to risk-weighted assets and total assets. The Basel III Capital Rules also prescribe a standardized approach for risk-weighting assets and include a number of risk-weighting categories that affect the denominator in banking organizations' regulatory capital ratios.
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The Company applies the Basel III Capital Rules as a standardized approach banking organization and is not currently subject to the market risk rules, which apply only to banking organizations with significant trading activities. To be considered adequately capitalized, standardized approach banking organizations are required to maintain minimum capital ratios of at least 4.5% CET1 capital to risk-weighted assets, 6.0% Tier 1 capital to risk-weighted assets, 8.0% total risk-based capital (i.e., Tier 1 plus Tier 2 capital) to risk-weighted assets and a 4.0% Tier 1 leverage ratio of Tier 1 capital to average total consolidated assets. The Company produces the Pillar 3 Regulatory Disclosures quarterly to update market participants regarding the Company's risk management practices and regulatory capital ratios as required under the U.S. Basel III rules. This report provides information on the Company's capital structure, risk exposures, risk assessment processes, risk-weighted assets ("RWA") and overall capital adequacy, including information on the methodologies used to calculate RWA.
The Company's 2023 Form 10-K contains management's discussion and analysis of the overall risk profile of the Company and related management strategies. The information presented herein should be read in conjunction with the Company's 2023 Form 10-K, as well as the Consolidated Financial Statements for Holding Companies - FR Y-9C ("FR Y-9C") and Consolidated Reports of Condition and Income for a Bank with Domestic and Foreign Offices - FFIEC 031 ("Call Report") dated December 31, 2023. A disclosure index is provided in Appendix 1 of this report, which specifies all disclosures required by the Basel III Capital Rules. These Basel III regulatory capital disclosures have not been audited by our external auditors. This report may contain forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Any statement that does not describe historical or current facts is a forward-looking statement, as discussed further in Appendix 2 of this report.
Consolidation
The principles of consolidation used for the Company's 2023 Form 10-K and for regulatory reporting conform with U.S. Generally Accepted Accounting Principles ("GAAP") and include the accounts of East West and its subsidiaries. The Basel III Regulatory Capital Disclosures and East West's regulatory capital ratio calculations are prepared on a fully consolidated basis. All intercompany transactions and balances have been eliminated in consolidation.
CAPITAL STRUCTURE
The Company's qualifying regulatory capital instruments primarily consist of common shareholders' equity and qualifying junior subordinated debt. For additional information on the Company's shareholders' equity, see the Company's "Consolidated Balance Sheets" in the Company's 2023 Form 10-K. The junior subordinated debt issued in connection with East West's trust preferred securities qualifies as Tier 2 capital under the Basel III Capital Rules. For additional information regarding the terms of East West's outstanding junior subordinated debt, see Note 10 - Short-TermBorrowings and Long- Term Debt - Long-TermDebt - Junior Subordinated Debt and Item 7. Management's Discussion & Analysis ("MD&A") - Balance Sheet Analysis - Deposits and Other Sources of Funding in the Company's 2023 Form 10-K.
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The following table presents the Company's capital composition as of December 31, 2023.
($ in thousands) | December 31, 2023 | ||
CET1 capital | |||
Common stock and related surplus | $ | 1,106,200 | |
Effect of current expected credit losses ("CECL") transition on retained earnings (1) | 56,988 | ||
Retained earnings | 6,465,230 | ||
Accumulated other comprehensive loss | (620,596) | ||
CET1 capital before adjustments and deductions | 7,007,822 | ||
Adjustments and deductions from CET1 capital | |||
Less: Goodwill, net of related deferred taxes | 465,697 | ||
Intangible assets, net of related deferred taxes | 394 | ||
Deferred tax assets | 210 | ||
Net unrealized losses on available-for-sale and held-to-maturity securities, net of deferred taxes | (601,882) | ||
Accumulated gains on cash flow hedges, net of deferred taxes | 2,625 | ||
Total CET1 capital | 7,140,778 | ||
Tier 1 capital | |||
Total Tier 1 capital | 7,140,778 | ||
Tier 2 capital | |||
Tier 2 capital instruments and related surplus | 148,000 | ||
Adjusted allowance for credit losses | 630,629 | ||
Total Tier 2 capital | 778,629 | ||
Total risk-based capital | $ | 7,919,407 | |
- For additional discussion regarding the CECL transition provision, see Item 7. MD&A - Balance Sheet Analysis - Regulatory Capital and Ratios in the Company's 2023 Form 10-K.
CAPITAL ADEQUACY
The Company's Board of Directors provides the ultimate oversight responsibility and accountability over capital planning. The Board and a Board-level committee, the Risk Oversight Committee ("ROC"), meet at least quarterly to review the Company's material risks and exposures and to ensure the adequacy of capital under both normal and stressed operating environments.
The Company's senior management and the Board are committed to achieving its capital targets in order to reach its capital goals, which include meeting or exceeding regulatory requirements. To achieve these capital goals, the Company has established policies and procedures to continuously monitor its capital levels and to maintain contingency plans. Monitoring activities include the evaluation of the Company's on-going capital needs, stress testing, and the assessment of the impact of stressed conditions under multiple scenarios; those activities also include the maintenance of capital buffers in consideration of other factors, such as the current credit and interest rate environment. The combination of these policies and procedures, and monitoring activities enables the Company to maintain adequate capital composition and levels to absorb losses, promote public confidence, provide protection to depositors, and meet regulatory requirements. The Company is committed to remaining above the "Well Capitalized" thresholds under Prompt Corrective Action regulations.
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The following table presents the Company's standardized approach risk-weighted assets as of December 31, 2023. For more information on the Company's risk-weighted assets, see Schedule HC-R, "Regulatory Capital" in the Company's FR Y-9C dated December 31, 2023:
($ in thousands) | December 31, 2023 | ||
Risk-Weighted Assets | |||
On-balance sheet | |||
Exposures to depository institutions, foreign banks, and credit unions | $ | 665,191 | |
Exposures to sovereign entities | 1,109,592 | ||
Exposures to public-sector entities | 124,077 | ||
Corporate exposures | 33,571,613 | ||
Residential mortgage exposures | 8,820,713 | ||
Statutory multifamily mortgages | 570,926 | ||
Cleared transactions | 548 | ||
High volatility commercial real estate | 68,131 | ||
Past due loans | 84,428 | ||
Other assets | 1,276,022 | ||
Securitization exposures | 375,205 | ||
Equity exposures | 1,032,155 | ||
Total on-balance sheet exposures | 47,698,601 | ||
Off-balance sheet | |||
Unused commitments with an original maturity of one year or less | 39,664 | ||
Unused commitments with an original maturity of more than one year | 4,350,667 | ||
Derivatives | 310,029 | ||
Letters of credit | 1,231,256 | ||
All other off-balance sheet liabilities | 33,175 | ||
Total off-balance sheet | 5,964,791 | ||
Total risk-weighted assets | $ | 53,663,392 | |
CAPITAL CONSERVATION BUFFER
The Basel III Capital Rules require the Company to maintain a minimum 2.5% "capital conservation buffer" on top of each of the minimum risk-based capital ratios for the purpose of absorbing losses during periods of economic stress. This effectively results in minimum ratios of (1) CET1 to risk-weighted assets of at least 7.0%, (2) Tier 1 capital to risk-weighted assets of at least 8.5%, and (3) Total capital to risk-weighted assets of at least 10.5%. Banking organizations with risk-based capital ratios that meet or exceed the minimum requirements but do not exceed the capital conservation buffer will face constraints on dividends, equity repurchases and discretionary bonus payments based on the amount of the shortfall. The severity of the constraint depends on the amount of the shortfall and the institution's "eligible retained income," which is defined as the greater of (1) the reporting institution's net income for the four preceding calendar quarters, net of any distributions and associated tax effects not already reflected in net income or (2) the average of the reporting institution's net income over the four preceding calendar quarters. As of December 31, 2023, the Company's eligible retained income was $890 million. The Company and Bank have capital ratios exceeding the 2.5% minimum capital conservation buffer and are not subject to any such limitations as of December 31, 2023. For additional discussion and disclosure, see the Company's December 31, 2023 FR Y-9C Schedule HC-R and Call Report Schedule RC-R,Item 7. MD&A - Balance Sheet Analysis - Regulatory Capital and Ratios and Note 16 - Regulatory Requirements and Matters in the Company's 2023 Form 10-K.
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The following table summarizes capital conservation buffer-related information for both the Company and the Bank as of December 31, 2023:
Capital | Capital in Excess of | ||||||
Minimum Capital | |||||||
Minimum Capital | Conservation | Requirement Plus | |||||
Capital Ratio | Buffer | Capital Conservation | |||||
Requirement | Requirement | Buffer Requirement | |||||
East West Bancorp | |||||||
CET1 capital ratio | 13.3 % | 4.5 % | 2.5 % | 6.3 % | |||
Tier 1 risk-based capital ratio | 13.3 % | 6.0 % | 2.5 % | 4.8 % | |||
Total risk-based capital ratio | 14.8 % | 8.0 % | 2.5 % | 4.3 % | |||
East West Bank | |||||||
CET1 capital ratio | 12.6 % | 4.5 % | 2.5 % | 5.6 % | |||
Tier 1 risk-based capital ratio | 12.6 % | 6.0 % | 2.5 % | 4.1 % | |||
Total risk-based capital ratio | 13.8 % | 8.0 % | 2.5 % | 3.3 % | |||
RISK MANAGEMENT
The Company encounters risk as part of the normal course of its business activities. The enterprise risk management ("ERM") framework focuses on material risks including: credit, liquidity, capital, market, operational, compliance, legal, strategic, technology and reputational. The Company's ERM program is an ongoing process designed to identify, assess and manage such risks in light of its risk appetite to maintain safety and soundness, and to optimize shareholder value.
The Company operates under a Board-approved ERM framework, which outlines the company-wide approach to risk management and oversight, and describes the structures and practices employed to manage the current and emerging risks inherent to the Company. The Company's ERM program is executed along the three lines of defense model, which provides for a consistent and standardized risk management control environment across the enterprise. The first line of defense is comprised of production, operational and support units. The second line of defense is comprised of various risk management and control functions charged with monitoring and managing specific major risk categories and/or risk subcategories. The third line of defense is comprised of the Internal Audit and Independent Asset Review ("IAR") functions. Internal Audit reports to the Chief Audit Executive ("CAE") who reports to the Board's Audit Committee. Internal Audit provides assurance and evaluates the effectiveness of risk management, control and governance processes as established by the Company. IAR serves as an internal loan review and independent credit risk monitoring function within the Bank that works under the direction of the CAE and reports to the ROC. IAR provides management and the ROC with an objective and independent assessment of the Bank's credit profile and credit risk management process.
The Board of Directors' ROC monitors the ERM program through the identified risk categories and provides oversight of the Company's risk appetite and control environment. The ROC provides focused oversight of the Company's identified enterprise risk categories on behalf of the full Board of Directors. Under the direction of the ROC, management committees apply targeted strategies to manage the risks to which the Company's operations are exposed.
CREDIT RISK: GENERAL DISCLOSURES
Credit risk is the risk that a borrower or a counterparty will fail to perform according to the terms and conditions of a loan or investment and expose the Company to loss. Credit risk exists with many of the Company's assets and exposures such as loans, debt securities and certain derivatives. The majority of the Company's credit risk is associated with lending activities.
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The ROC has primary oversight responsibility for identified enterprise risk categories including credit risk. The ROC monitors management's assessment of asset quality, credit risk trends, credit quality administration, underwriting standards, and portfolio credit risk management strategies and processes, such as diversification and liquidity, all of which enable management to control credit risk. At the management level, the Credit Risk Management Committee has primary oversight responsibility for credit risk. The Senior Credit Supervision function manages credit policy for the line of business transactional credit risk, assuring that all exposure is risk-rated according to the requirements of the credit risk rating policy. The Senior Credit Supervision function evaluates and reports the overall credit risk exposure to senior management and the ROC. Reporting directly to the Board's ROC, the IAR function provides additional support to the Company's strong credit risk management culture by performing an independent and objective assessment of underwriting and documentation quality. A key focus of our credit risk management is adherence to a well-controlled underwriting and loan monitoring process.
For information on the Company's credit risk policies for nonaccrual loans and the allowance for loan losses, refer to "Loans Held-for-Investment" and "Allowance for Loan Losses" in Note 1 - Summary of Significant Accounting Policies and Note 6 - Loans Receivable and Allowance for Credit Losses in the Company's 2023 Form 10-K.
The Company's debt securities portfolio includes U.S. Treasury, U.S. government agency, U.S. government-sponsored agency, and U.S. government-sponsored enterprise debt and mortgage-backed securities that are issued, guaranteed, or otherwise supported by the U.S. government, for which a zero credit loss assumption is applied when determining any allowance for credit losses. For additional information on the Company's allowance for credit losses on debt securities, refer to "Allowance for Credit Losses on Available-for-SaleDebt Securities" and "Allowance for Credit Losses on Held-to-MaturityDebt Securities" in Note 1 - Summary of Significant Accounting Policies in the Company's 2023 Form 10-K. For additional information on debt securities, refer to Note 4 - Securities and Item 7. MD&A - Balance Sheet Analysis - Debt Securities in the Company's 2023 Form 10-K.
For the Company's credit risk policies on derivatives, refer to the "General Disclosure for Counterparty Credit Risk- Related Exposures" section of this report. For additional information on the derivatives portfolio, refer to Note 5 - Derivatives and Item 7. MD&A - Market Risk Management - Derivatives in the Company's 2023 Form 10-K.
The following table presents the Company's total exposure on loans held-for-investment by loan type, and an aging analysis of accruing and nonperforming loans as of December 31, 2023.
Accruing | Nonperforming | Nonperforming | |||||||||||||
Loans | Total | ||||||||||||||
Total | Loans | Loans | 90 Days and | ||||||||||||
($ in thousands) | 30-89 Days | 30-89 Days | Greater | Nonperforming | |||||||||||
Loans | Past Due | Past Due | Past Due | Loans | |||||||||||
Commercial: | |||||||||||||||
Commercial and industrial ("C&I") | $ | 16,581,079 | $ | 35,649 | $ | 16,063 | $ | 20,973 | $ | 37,036 | |||||
Commercial real estate ("CRE"): | |||||||||||||||
CRE | 14,777,081 | 3,517 | 23,249 | - | 23,249 | ||||||||||
Multifamily residential | 5,023,163 | 597 | 434 | 4,235 | 4,669 | ||||||||||
Construction and land | 663,868 | 13,251 | - | - | - | ||||||||||
Total CRE | 20,464,112 | 17,365 | 23,683 | 4,235 | 27,918 | ||||||||||
Total commercial | 37,045,191 | 53,014 | 39,746 | 25,208 | 64,954 | ||||||||||
Consumer: | |||||||||||||||
Residential mortgage: | |||||||||||||||
Single-family residential | 13,383,060 | 45,228 | 375 | 24,002 | 24,377 | ||||||||||
HELOCs | 1,722,204 | 21,492 | 192 | 13,219 | 13,411 | ||||||||||
Total residential mortgage | 15,105,264 | 66,720 | 567 | 37,221 | 37,788 | ||||||||||
Other consumer | 60,327 | 3,265 | - | 132 | 132 | ||||||||||
Total consumer | 15,165,591 | 69,985 | 567 | 37,353 | 37,920 | ||||||||||
Total loans (1) | $ | 52,210,782 | $ | 122,999 | $ | 40,313 | $ | 62,561 | $ | 102,874 | |||||
- There were no accruing loans 90 days and greater past due in any of the Company's loan categories.
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The following table presents the Company's nonperforming loans with no related allowance and nonperforming loans with a related allowance as of December 31, 2023. Nonaccrual loans may not have an allowance for credit losses if the loan balances are well secured by the collateral value and there is no loss expectation.
Nonperforming | Nonperforming | Total | |||||||
Loans with No | Loans with | ||||||||
($ in thousands) | Related | Related | Nonperforming | ||||||
Allowance | Allowance | Loans | |||||||
Commercial: | |||||||||
C&I | $ | 33,089 | $ | 3,947 | $ | 37,036 | |||
CRE: | |||||||||
CRE | 22,653 | 596 | 23,249 | ||||||
Multifamily residential | 4,235 | 434 | 4,669 | ||||||
Total CRE | 26,888 | 1,030 | 27,918 | ||||||
Total commercial | 59,977 | 4,977 | 64,954 | ||||||
Consumer: | |||||||||
Residential mortgage: | |||||||||
Single-family residential | 4,852 | 19,525 | 24,377 | ||||||
HELOCs | 7,256 | 6,155 | 13,411 | ||||||
Total residential mortgage | 12,108 | 25,680 | 37,788 | ||||||
Other consumer | - | 132 | 132 | ||||||
Total consumer | 12,108 | 25,812 | 37,920 | ||||||
Total loans | $ | 72,085 | $ | 30,789 | $ | 102,874 | |||
The changes in the allowance for credit losses for the nine months ended December 31, 2023, are as follows:
($ in thousands) | Year Ended December 31, 2023 | ||
Allowance for loan losses, beginning of period | 595,645 | ||
Impact of ASU 2022-02 adoption (1) | 6,028 | ||
Allowance for loan losses, January 1, 2023 | 601,673 | ||
Provision for credit losses on loans | 113,571 | ||
Gross charge-offs | (54,372) | ||
Gross recoveries | 8,118 | ||
Total net charge-offs | (46,254) | ||
Foreign currency translation adjustment | (247) | ||
Allowance for loan losses, end of period | $ | 668,743 | |
Allowance for unfunded credit commitments, beginning of period | 26,264 | ||
Provision for credit losses on unfunded credit commitments | 11,429 | ||
Foreign currency translation adjustment | 6 | ||
Allowance for unfunded credit commitments, end of period | $ | 37,699 | |
Allowance for credit losses, end of period | $ | 706,442 | |
- Represents the change in the Company's allowance for loan losses as a result of the adoption of Accounting Standards Update ("ASU") 2022-02,Financial Instruments - Credit Losses (Topic 326): Troubled Debt Restructurings and the Vintage Disclosures on January 1, 2023. Refer to Note 1 - Summary of Significant Accounting Policies in the Company's 2023 Form 10-K for additional information.
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The following table presents the geographic distribution of the Company's C&I loan portfolio as of December 31,
2023:
($ in thousands) | C&I | ||
Geographic markets: | |||
Southern California | $ | 3,551,273 | |
Northern California | 846,865 | ||
California | 4,398,138 | ||
New York | 2,956,908 | ||
Texas | 1,354,789 | ||
China | 1,328,383 | ||
Hong Kong | 894,277 | ||
Georgia | 687,808 | ||
Florida | 489,892 | ||
Illinois | 468,444 | ||
North Carolina | 354,823 | ||
Other markets | 3,647,617 | ||
Total exposure | $ | 16,581,079 | |
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East West Bancorp Inc. published this content on 01 March 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 01 March 2024 16:43:06 UTC.