Common use of Allowance for Loan and Lease Losses Clause in Contracts

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall adoptrevise, implement, and thereafter continue to ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent, and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall continue to provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty ninety (6090) days, the Board shall adoptadopt or revise, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006, (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to incorporate annualized year-to-date credit losses into each quarterly analysis and document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adoptadopt or revise, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles Generally Accepted Accounting Principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP Accounting Standards Codification 450 (including formerly known FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adoptrevise, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) ALLL in accordance with U.S. generally accepted accounting principles (“GAAP”)Generally Accepted Accounting Principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) ), and shall at a minimum include, but not be limited to: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP FASB Statement of Financial Accounting Standards No. 5, Accounting for Contingencies; (including FASB ASC 450-20, Loss Contingencies). These c) procedures shall require to ensure that the Bank to document its estimation of credit losses considers the relevant qualitative and its analysis of environmental factors, with particular focus on the nine qualitative factors set forth following: (i) trends in the Interagency StatementBank’s internal risk ratings, delinquent and nonaccrual loans; (cii) results of the Bank’s external loan review, conducted pursuant to Article VI of this Agreement; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (d) procedures for validating the ALLL methodology; and; (d2) The ALLL program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days . Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedALLL.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” (OCC Bulletin 2006-47) (“Interagency Statement”) ), dated December 13, 2006, and shall at a minimum shall include: (a) procedures for determining whether a consideration of the Bank’s loan is impaired loss experience, concentrations of credit in the Bank, and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment)present and prospective economic conditions; (b) procedures detailing the selection process for loans considered impaired and procedures detailing how the amount of impairment for those loans will be measured, consistent with FASB Statement of Financial Accounting Standards Number 114, Accounting by Creditors for Impairment of a Loan; (c) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards Number 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement;; and (cd) procedures for validating the ALLL methodology; and. (d2) The revised policies and procedures shall address specific actions needed to improve the methodology outlined in the “as of” September 30, 2008, Report of Examination and in any subsequent Report of Examination. (3) The revised policies and procedures shall provide for a process for summarizing and documenting, for the Board’s prior review and approvalapproval of the Allowance by the Board at least once each calendar quarter. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the amount filing of the Consolidated Reports of Condition and Income, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (4) The Board shall ensure that the Bank has processes, personnel, and control systems to be reported in ensure implementation of and adherence to the policies and procedures developed pursuant to this Article and shall ensure the accuracy of the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLLin accordance with 12 USC 161. (2) Within sixty (60) days the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”)Generally Accepted Accounting Principles. The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement;; and (c) procedures for validating to ensure that the ALLL methodologyestimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (dv) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of the date of this Agreement, the Board shall adopt, implement, review the adequacy of the Bank’s Allowance for Loan and thereafter ensure adherence to Lease Losses (“Allowance”) and shall revise the Bank’s written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles Generally Accepted Accounting Principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (), and the “Interagency Statement”) Allowance for Loan and Lease Losses” booklet of the Comptroller’s Handbook, and shall at focus particular attention on directional consistency between portfolio risk and the reserve balance. At a minimum includeminimum, the following factors shall be considered and included in the revised methodology: (a) procedures Procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment);Accounting by Creditors for Impairment of a Loan; and (b) procedures Procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c2) procedures The program shall provide for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Consolidated Reports of Condition and Income, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) ), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a revision and/or development of the Bank’s procedures on ALLL methodology, including incorporating external factors that could impact the ALLL and costs to sell; (e) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of the Call Reports, through additional provision expense. (2) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty one hundred and twenty (60120) days, the Board shall adopt, implement, and thereafter ensure adherence to adopt revised written policies and procedures for maintaining that ensure it maintains an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for measuring the amount of impairment for loans that have undergone troubled debt restructurings. If impairment is measured using an estimate of the expected future cash flows, the interest rate used to calculate the present value of the cash flows must be based on the original effective interest rate on the loan, and not the rate specified in the restructuring agreement; (c) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of at least the nine qualitative factors set forth in the Interagency Statement; (cd) incorporate a process to ensure loss is recognized in a timely manner in accordance with interagency guidance; (e) procedures for validating the ALLL methodology; andmethodology and reporting the findings to the Board; (df) a process procedures for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL; and (g) a requirement that the Board review and approve the ALLL policies and procedures at least annually. (2) Within sixty one hundred and twenty (60120) days days, the Board shall adopt, implement, and thereafter ensure adherence to adopt revised written policies and procedures to that ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports. (3) Upon adoption, the Board shall submit a copy of the revised policies and procedures required by this Article, or any subsequent amendments or changes to those policies and procedures, to the Assistant Deputy Comptroller for review and determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure adherence to the policies and procedures.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, the Board shall adoptrevise, implement, and thereafter ensure adherence to its written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in OCC Bulletin 2006-47 and the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” (OCC Bulletin 2006-47) (“Interagency Statement”) Losses dated December 13, 2006 and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring to ensure the amount of impairment, consistent with GAAP (including ALLL methodology conforms to accounting standards contained in FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment310-10 (Accounting by Creditors for Impairment of a Loan) and FASB ASC 450-20 (Loss Contingencies); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (dc) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of Condition and Income (“the Call Reports”, through additional provision expense. (2) for Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the ALLL. (23) Within sixty A copy of the Board’s program shall be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the program. (604) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written policies and procedures the program developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adoptdevelop, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and with "Allowance for Loan and Lease Losses," booklet A-ALLL of the Comptroller's Handbook, and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of the Call Reports, through additional provision expense. (2) Within sixty (60) days A copy of the Board Board's program shall adoptbe submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of shall implement and adhere to the date that such reports are submittedprogram.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall adoptprepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, implementa revised program, and thereafter ensure adherence to including written policies and procedures procedures, for maintaining an adequate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles Generally Accepted Accounting Principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written the program, policies and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures Procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures Procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures Procedures for validating the ALLL Allowance methodology; and (d) Procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) Trends in the Bank’s internal risk ratings, delinquent, and nonaccrual loans; (ii) Results of the Bank’s external loan review; (iii) Concentrations of credit in the Bank; (iv) Present and prospective economic conditions; and (v) Applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written policies the program, policies, and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance guidelines set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – Impairment);Receivables (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) a process to accurately measure historical loss calculations; (d) procedures for validating the ALLL methodology; and (de) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty thirty (6030) days the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, in the Board shall adoptdevelop, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with generally accepted accounting principles, the guidance set forth in OCC Bulletin 2006-47, the “Allowance for Loan and Lease Losses” booklet of the Comptroller’s Handbook, and the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” (OCC Bulletin dated December 13, 2006-47) (“Interagency Statement”) , and shall address the corrective actions prescribed in the XXX that are related to the ALLL, and shall at a minimum include: (a) results of the Bank’s internal and external loan reviews; (b) a standard method of adjusting and applying the Bank’s historical loan loss experience and also considering ratio analysis; (c) procedures for considering all relevant qualitative and environmental factors as outlined in relevant regulatory guidance; (d) qualitative factor adjustments in each homogeneous pool to reflect credit underwriting and management practices in place at the Bank; (e) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of Loans; (bf) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20, Accounting for Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (cg) procedures for validating the ALLL methodology; and (dh) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of Condition and Income (“the Call Reports”, through additional provision expense. (2) for Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the ALLL. (23) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written policies and procedures the program developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to updated written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and with "Allowance for Loan and Lease Losses," booklet A-ALLL of the Comptroller's Handbook, and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official this Article. (3) A copy of the Board’s program shall be submitted to the Assistant Deputy Comptroller for review and regulatory reports filed prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the program. (4) The program shall provide for a review of the Allowance by the Bank accurately reflect an adequate ALLL balance as Board at least once each calendar quarter. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the date that such reports are submittedConsolidated Reports of Condition and Income, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance.

Allowance for Loan and Lease Losses. (1) Within sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006, (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to adopt a written policies and procedures program for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance guidelines set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – Impairment);Receivables (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its losses, including but not limited to an analysis of the nine qualitative factors set forth in the Interagency Statement; (c) a process to accurately measure historical loss calculations; (d) a process to measure impairment for impaired collateral dependent loans, as required on pages 31-32 of the most recent XXX; (e) procedures to ensure that correct inputs, including modified repayment terms, are used to calculate net present value of future cash flows; (f) procedures for validating the ALLL methodology; and (dg) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) A copy of the ALLL program, or any subsequent amendments or changes to the program, shall be forwarded to the Assistant Deputy Comptroller for review and determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure adherence to the program. (3) Within sixty (60) days days, and thereafter on an ongoing basis, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006, (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. The Bank shall maintain written documentation indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (2) Within sixty (60) days the The Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any deficiency between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance, regardless of the amount of such deficiency, shall be remedied through additional provision expense in the quarter it is discovered, prior to the filing of the Call Reports. (3) Upon adoption, the Board shall submit a copy of the policies and procedures required by this Article to the Assistant Deputy Comptroller for determination of no supervisory objection.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of the effective date of this Agreement, the Board shall adoptrevise, implement, and thereafter ensure adherence to its written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) ALLL in accordance with U.S. generally accepted accounting principles (“GAAP”). The revised ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “OCC Bulletin 2006-47 – Interagency Policy Statement on the Allowance for Loan and Lease Losses” Losses (OCC Bulletin Dec. 13, 2006-47) (“Interagency Statement”) ), and shall include, at a minimum includeminimum: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss losses on groups of loans using historical loss data that are reflect current economic conditions and the current financial condition of the bank, consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its an appropriate analysis of the nine qualitative factors set forth in the Interagency StatementOCC Bulletin 2006-47; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to develop written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” Losses dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall shall, at a minimum minimum, include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – - Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating an independent review to validate the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Upon completion, the Board shall promptly submit a copy of the ALLL policies and procedures to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall promptly adopt, implement, and thereafter ensure Bank adherence to the ALLL policies and procedures. (3) Within sixty (60) days days, the Board shall adopt, implement, and thereafter ensure Bank adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”)Generally Accepted Accounting Principles. The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days the Board shall adoptUpon adoption, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as a copy of the date that such reports are submittedwritten policy shall be forwarded to the Assistant Deputy Comptroller for review.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including FASB ASC 310- 10formerly known as FAS Statement of Financial Accounting Standards No. 114) and Accounting Standards Codification 450-20 (formerly known as FAS Statement of Financial Accounting Standards No. 5, Receivables - Overall - Subsequent Measurement – ImpairmentAccounting for Contingencies); (b) procedures for segmenting the designation of loan portfolio and estimating loss on groups of pools containing loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statementsimilar risk characteristics; (c) procedures for validating the ALLL Allowance methodology; (d) procedures for the estimation of credit losses that consider the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (dv) the applicable experience of the Bank’s lending staff; (e) procedures to require that loans which have been designated impaired undergo impairment testing during each calendar quarter; and (f) immediate and periodic training for staff and management personnel responsible for calculating the Allowance. (2) The Allowance program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the appropriateness of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written policies the program, policies, and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (dv) applicable experience of the Bank’s lending staff. (2) The program shall provide a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006, (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written the program, policies and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) ), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of the Call Reports, through additional provision expense. (2) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official this Article. (3) A copy of the Board's program shall be submitted to the Assistant Deputy Comptroller for review and regulatory reports filed by prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank accurately reflect an adequate ALLL balance as of shall implement and adhere to the date that such reports are submittedprogram.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent, and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written policies the program, policies, and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006, (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the The Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Receivables, Overall - Subsequent Measurement – - Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating an independent review of the ALLL methodologymethodology to validate its appropriateness; and (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate appropriate ALLL balance. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the date that such reports are submittedCall Reports.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall adoptrevise, implement, and thereafter continue to ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLL”"Allowance") in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “'s "Interagency Policy Statement on the Allowance for Loan and Lease Losses” " dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310-10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank's internal risk ratings, delinquent, and nonaccrual loans; (ii) results of the Bank's external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank's lending staff. (2) The program shall continue to provide for a process for summarizing and documenting, for the Board’s prior 's review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) days, the Board shall adoptdevelop, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”)principles. The ALLL policies and procedures shall be consistent with the guidance set forth in OCC Bulletin 2006-47 and the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” (OCC Bulletin 2006-47) (“Interagency Statement”) dated December 13, 2006 and shall at a minimum include: (a) results of the Bank's internal and external loan reviews; (b) a standard method of adjusting and applying the Bank’s historical loan loss experience; (c) trends of delinquent and nonaccrual loans; (d) concentrations of credit in the Bank; (e) present and prospective economic conditions; (f) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 310-10, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of Loans; (bg) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20, Accounting for Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (ch) procedures for validating the ALLL methodology; and (di) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports for the ALLL. Any deficiency in the ALLL shall be remedied in the quarter it is discovered, prior to the filing of Condition and Income (“the Call Reports”, through additional provision expense. (2) for Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the ALLL. (23) Within sixty A copy of the Board's program shall be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the program. (604) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written policies and procedures the program developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles Generally Accepted Accounting Principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; and (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (v) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”)Generally Accepted Accounting Principles. The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – Impairment)Accounting by Creditors for Impairment of a Loan; (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC 450-20Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL Allowance methodology; (d) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (dv) applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days the The Board shall adoptensure that the Bank has processes, implementpersonnel, and thereafter control systems to ensure implementation of and adherence to written the policies and procedures developed pursuant to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall adoptrevise, implement, and thereafter continue to ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures for determining whether a loan is impaired and procedures for measuring the amount of impairment, impairment that are consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10Statement of Financial Accounting Standards No. 114, Receivables - Overall - Subsequent Measurement – ImpairmentAccounting by Creditors for Impairment of a Loan); (b) procedures for identifying a dollar amount for loans the Bank deems “material” for purposes of performing an impairment analysis pursuant to this Subparagraph (a); (c) procedures for determining the amount of impairment pursuant to ASC 000- 00-00-00 by using the present value of the expected future cash flows when the loans are not collateral dependent and for which there is no observable market price for the loan; (d) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (ce) procedures for validating the ALLL Allowance methodology; (f) procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) trends in the Bank’s internal risk ratings, delinquent, and nonaccrual loans; (ii) results of the Bank’s external loan review; (iii) concentrations of credit in the Bank; (iv) present and prospective economic conditions; and (dv) applicable experience of the Bank’s lending staff; and (g) procedures to ensure that the weight or percentages assigned to the relevant qualitative and environmental factors are validated for reasonableness. (2) The program shall continue to provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days Allowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by in determining the Bank accurately reflect an adequate ALLL balance as adequacy of the date that such reports are submittedAllowance.

Allowance for Loan and Lease Losses. (1) Within sixty (60) daysdays of this Agreement, the Board shall revise, adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate appropriate Allowance for Loan and Lease Losses (“ALLLAllowance”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL Allowance policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) ), and July 20, 2001 (“Interagency Statement”) OCC Bulletin 2001-37), and shall at a minimum include: (a) procedures Procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP Accounting Standards Codification 310-10 (including formerly known as FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – ImpairmentStatement of Financial Accounting Standards No. 114); (b) procedures Procedures for segmenting the loan portfolio and estimating loss on groups of loans that are loans, consistent with GAAP (including FASB ASC Accounting Standards Codification 310- 10 and 450-2020 (formerly known as FASB Statement of Financial Accounting Standards No. 5, Loss Accounting for Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures Procedures for validating the ALLL Allowance methodology; and (d) Procedures to ensure that the estimation of credit losses considers the relevant qualitative and environmental factors, with particular focus on the following: (i) Trends in the Bank’s internal risk ratings, delinquent, and nonaccrual loans; (ii) Results of the Bank’s external loan review; (iii) Concentrations of credit in the Bank; (iv) Present and prospective economic conditions; and (v) Applicable experience of the Bank’s lending staff. (2) The program shall provide for a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Call Reports of Condition and Income (“Call Reports”) for the ALLLAllowance. Any deficiency in the Allowance shall be remedied in the quarter it is discovered, prior to the filing of the Call Report, by additional provisions from earnings. Written documentation shall be maintained indicating the factors considered and conclusions reached by the Board in determining the adequacy of the Allowance. (23) Within sixty (60) days Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt, implement, immediately implement and thereafter ensure adherence to written policies the program, policies, and procedures to ensure that all official and regulatory reports filed required by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submittedthis Article.

Allowance for Loan and Lease Losses. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures for maintaining an adequate Allowance for Loan and Lease Losses (“ALLL”) in accordance with U.S. generally accepted accounting principles (“GAAP”). The ALLL policies and procedures shall be consistent with the guidance set forth in the Federal Financial Institutions Examination CouncilFFIEC’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47) (“Interagency Statement”) and shall at a minimum include: (a) procedures for determining whether a loan is impaired and measuring the amount of impairment, consistent with GAAP (including FASB ASC 310- 10, Receivables - Overall - Subsequent Measurement – Impairment); (b) procedures for segmenting the loan portfolio and estimating loss on groups of loans that are consistent with GAAP (including FASB ASC 450-20, Loss Contingencies). These procedures shall require the Bank to document its estimation of credit losses and its analysis of the nine qualitative factors set forth in the Interagency Statement; (c) procedures for validating the ALLL methodology; and; (d) a process for summarizing and documenting, for the Board’s prior review and approval, the amount to be reported in the Consolidated Reports of Condition and Income (“Call Reports”) for the ALLL. (2) Within sixty (60) days the Board shall adopt, implement, and thereafter ensure adherence to written policies and procedures to ensure that all official and regulatory reports filed by the Bank accurately reflect an adequate ALLL balance as of the date that such reports are submitted. Any difference between the ALLL balance as determined by the analysis required by this Article and the Bank’s actual ALLL balance shall be remedied through appropriate account adjustments in the quarter it is discovered, prior to the filing of the Call Reports.