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Proposal: 1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck Protection Program Loans Description: Comment ID: 137202 From: Alpine Bank, Eric Gardey Proposal: 1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck Protection Program Loans Subject: Regulatory Capital Rule: Paycheck Protection Program Lending Facility and Paycheck Protection Progra Comments: NONCONFIDENTIAL // EXTERNAL Regulatory Capital Rule: Paycheck Protection Program Lending Facility and Paycheck Protection Program Loans My understanding of the Interim final rule is that PPP loans a bank makes must be pledged to the new PPPL Facility in order to be excluded from the calculation of Average Total Consolidated Assets or Total Leverage Exposure. Our organization has sufficient on balance sheet liquidity to fund the expected volume of PPP loans we originate. At this time, we do not anticipate having to access the PPPL Facility. The interim final rule as written puts us at a disadvantage in terms of calculating our Leverage Capital Ratio. We will need to include all PPP loans on our books in the Average Total Consolidated Assets calculation. I would suggest that all PPP loans carried on the books of a bank, whether pledged to the PPPL Facility or not, be excluded from the calculation of total leverage exposure, average total consolidated assets, advanced approaches-total risk weighted assets, and standardized total risk-weighted assets. [div] [/div] [div] [/div] Eric Gardey Chief Financial Officer Tel: +19703843257 2200 Grand Ave. Glenwood Springs, CO 81601 [https://www.alpinebank.com