The purpose of this study is to analyze the determinants of capital buffer in the Turkish Banking system and to estimate the cyclicality of capital buffer using a panel data of 87 banks covering the period 1988-2009. The data is based on the reports published by the Banks Association of Turkey. Two-step Generalized Method of Moments is implemented by using Arellano–Bond linear dynamic panel-data estimator. The study is focused on: i)economic growth, ii) asset size, iii) return on equity and iv) non-performing loans as the determinants of capital buffer. It is observed that commercial banks, including the banks under the control of Savings Deposit and Insurance Fund, move procyclically, where commercial banks, excluding the banks under Savings Deposit and Insurance Fund, fluctuate countercyclically. This finding is noteworthy since it is parallel to BASEL III, where structuring a countercyclical capital framework is emphasized.