Daniel T. Henry
Analyst · CLSA
So initially, when we're coming out of the recession, we said we want to be at least 10% or 11%. I think over the course of the past couple of years, we've had good capital generation. And really, in 2011, we kind of increased from that 11% range up to the 12% range, because in our submission to the Fed in January of '11, we only asked for $2.3 billion of buybacks on the assumption that we were going to use half of the capital generated to do acquisitions, which would mean we'd do $2 billion in acquisitions. In fact, that year we only did $1 billion. So we effectively wound up as a result of that of retaining another $1 billion, and that took us from 11 up to 12%. I think we taken artificially high in the first quarter because we couldn't do share buybacks in the first quarter of '12 until our plan was approved. That was in the middle of March. So I'd expect to see us to trend back towards where we were at the beginning of this year, which was 12.3%. We think our submission was appropriate in terms of the levels of buybacks that we requested. And the fact that the Fed approved that level, I think, is a demonstration of our financial strength and flexibility. So this will evolve over time, and each year, we'll probably get better insight in terms of where we want to be. And as we move forward with the work that we're doing on Basel II, which we may not have better insights until we get to 2014, but when we get those better insights, we'll have a better sense of where we want just to settle in. Now the other thing, I think, that's important is not just a raw number that your Tier 1 common ratio is, but if you look at the stress test and see where your ratio is after that stress, may start to become even more important. And certainly, if you look at the data from this year, you can see that based on the stress test that the Fed decided the assumptions on, we had very limited drop in where the Tier 1 common was in that stress, which was different than many others. So I think people start to look at that. And that will be something we'll have to consider when we ultimately set where we decide to hold Tier 1 common ratio.