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More and more frequently, Mark Kanaly sees examiners requesting to see a bank’s capital plan in addition to its strategic plan in advance of a regulatory exam. “Most banks will reach on the shelf and pull down what I would call a capital policy,” says Kanaly, a partner at the law firm Alston & Bird. But the two documents are distinctly different. A capital policy serves more as a guideline for decision-making. If capital falls below a certain level, how will a bank respond? A capital plan goes deeper, communicating a bank’s priorities and detailing how a bank plans to…
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