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Proposal: 1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck Protection Program Loans Description: Comment ID: 137217 From: Clear Lake Bank & Trust Co., Matthew Ritter 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: Date:Apr 22, 2020 Proposal:Regulatory Capital Rule: Paycheck Protection Program Lending Facility and Paycheck [R1712] Document ID:R-1712 Revision:1 First name:Matthew Middle initial:J Last name:Ritter Affiliation (if any):Clear Lake Bank & Trust Co Affiliation Type: () Address line 1:322 Main Avenue Address line 2: City:Clear Lake State:Iowa Zip:50428 Country:UNITED STATES Postal (if outside the U.S.): Your comment:While PPP loans are excluded from risk-based capital ratio calculations, they are not excluded from average assets for the tier 1 leverage capital ratio calculation unless the PPP loans are pledged to the PPP liquidity facility and an advance is extended to the bank. The interim rule seems to place more of a burden on banks that have adequate liquidity to fund PPP loans without using advances from the PPPLF. It could also discourage banks with their adequate liquidity from continued participation in PPP lending or lending to customers outside of the PPP program if it would further decrease a bank's tier 1 leverage ratio.