Old National’s affiliate bank is required to maintain reserve balances on hand and with the Federal Reserve Bank that are interest-bearing and unavailable for investment purposes. The reserve balances were $115.3 million at December 31, 2019 and $108.1 million at December 31, 2018. In addition, Old National had cash and due from banks which was held as collateral for collateralized swap positions of $6.9 million at December 31, 2019. Old National did not have any cash and due from banks held as collateral for collateralized swap positions at December 31, 2018.

Regulations limit the amount of dividends an affiliate bank can declare in any year without obtaining prior regulatory approval. Prior regulatory approval is required if dividends to be declared in any year would exceed net earnings of the current year plus retained net profits for the preceding two years. Prior regulatory approval to pay dividends was not required in 2017, 2018, or 2019 and is not currently required.

Old National has traditionally paid a quarterly dividend to common stockholders. The payment of dividends is subject to legal and regulatory restrictions. Any payment of dividends in the future will depend, in large part, on Old National’s earnings, capital requirements, financial condition, and other factors considered relevant by our Board of Directors.

Old National and Old National Bank are subject to various regulatory capital requirements administered by the federal banking agencies. Failure to meet minimum capital requirements can elicit certain mandatory actions by regulators that, if undertaken, could have a direct material effect on Old National’s financial statements. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, Old National and Old National Bank must meet specific capital guidelines that involve quantitative measures of assets, liabilities, and certain off-balance sheet items as calculated under regulatory accounting practices. The capital amounts and classifications are also subject to qualitative judgments by the regulators about components, risk weightings, and other factors. Prompt corrective action provisions are not applicable to bank holding companies. Quantitative measures established by regulation to ensure capital adequacy require Old National and Old National Bank to maintain minimum amounts and ratios as set forth in the following tables.

At December 31, 2019, Old National and Old National Bank exceeded the regulatory minimums and Old National Bank met the regulatory definition of well-capitalized based on the most recent regulatory notification. There have been no conditions or events since that notification that management believes have changed Old National Bank’s category.

The following table summarizes capital ratios for Old National and Old National Bank as of December 31:

						Fully Phased-In						Prompt Corrective Action
						Regulatory						"Well Capitalized"
	Actual					Guidelines Minimum (1)						Guidelines
(dollars in thousands)	Amount		Ratio			Amount		Ratio			Amount			Ratio
2019
Total capital to risk-weighted assets
Old National Bancorp	$	1,828,312		12.99	%	$	1,477,763		10.50	%	$	N/A		N/A		%
Old National Bank		1,891,612		13.50			1,471,122		10.50				1,401,069		10.00
Common equity Tier 1 capital to risk-weighted assets
Old National Bancorp		1,706,727		12.13			985,175		7.00			N/A		N/A
Old National Bank		1,822,337		13.01			980,748		7.00				910,695		6.50
Tier 1 capital to risk-weighted assets
Old National Bancorp		1,706,727		12.13			1,196,284		8.50			N/A		N/A
Old National Bank		1,822,737		13.01			1,190,909		8.50				1,120,855		8.00
Tier 1 capital to average assets
Old National Bancorp		1,706,727		8.88			768,537		4.00			N/A		N/A
Old National Bank		1,822,737		9.62			757,783		4.00				947,228		5.00
2018
Total capital to risk-weighted assets
Old National Bancorp	$	1,748,231		12.27	%	$	1,496,099		10.50	%	$	N/A		N/A		%
Old National Bank		1,769,930		12.47			1,489,938		10.50				1,418,989		10.00
Common equity Tier 1 capital to risk-weighted assets
Old National Bancorp		1,617,936		11.36			997,399		7.00			N/A		N/A
Old National Bank		1,699,945		11.98			993,292		7.00				922,343		6.50
Tier 1 capital to risk-weighted assets
Old National Bancorp		1,617,936		11.36			1,211,128		8.50			N/A		N/A
Old National Bank		1,699,945		11.98			1,206,141		8.50				1,135,191		8.00
Tier 1 capital to average assets
Old National Bancorp		1,617,936		9.17			705,681		4.00			N/A		N/A
Old National Bank		1,699,945		9.58			709,929		4.00				887,412		5.00

In December 2018, the OCC, the Board of Governors of the Federal Reserve System, and the FDIC approved a final rule to address changes to credit loss accounting under GAAP, including banking organizations’ implementation of CECL. The final rule provides banking organizations the option to phase in over a three-year period the day-one adverse effects on regulatory capital that may result from the adoption of the new accounting standard. Old National is planning on adopting the capital transition relief over the permissible three-year period.