CONCENTRATIONS OF CREDIT. Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank an acceptable written plan to strengthen the Bank’s management of commercial real estate (“CRE”) concentrations, including steps to reduce the risk of concentrations. The plan shall, at a minimum, include:
CONCENTRATIONS OF CREDIT. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Banking Circular 255. The program shall include, but not necessarily be limited to, the following:
(a) a review of the balance sheet to identify any concentrations of credit;
(b) a written analysis of any concentration of credit identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;
(c) policies and procedures to control and monitor concentrations of credit; and
(d) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis.
(2) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller's Handbook.
(3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) and that the analysis demonstrate that the concentration will not subject the Bank to undue credit or interest rate risk.
(4) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.
(5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Association adherence to a written asset diversification program consistent with guidance set forth in OCC Bulletin 2006-46 (Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices) and the “Concentrations of Credit” booklet of the Comptrollers’ Handbook (December 13, 2011). The program shall include, but not necessarily be limited to, the following:
(a) a review of the balance sheet to identify any concentrations of credit;
(b) a written analysis of any concentration of credit identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;
(c) policies and procedures to control and monitor concentrations of credit, including policies and procedures to control and monitor concentrations of credit including comprehensive and reasonable loan concentration limits expressed as a percentage of total risk-based capital for all commercial real estate (CRE) loans in the aggregate and for each primary and identifiable sub-category of CRE loans (i.e., construction, multi-family, hotel, land, nonresidential, and nonmortgage commercial loans), such as such as the Association’s non-owner occupied residential/investor loan portfolio;
(d) specific review procedures and reporting requirements, including written reports to the Board, to identify, monitor, and control the risks associated with concentrations of credit and periodic market analysis for the various property types and geographic markets represented in the portfolio; and
(e) a written action plan, including specific time frames, to reduce the risk of any concentration deemed imprudent in the analysis conducted pursuant to paragraph (1)(b) of this Article and to bring the Association into compliance with its concentration of credit limits established pursuant to paragraph (1)(c) of this Article.
(2) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller's Handbook.
(3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (1)(b) and that the analysis demonstrate that the concentration will not subject the Association to undue credit or interest rate risk.
(4) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the revi...
CONCENTRATIONS OF CREDIT. (1) On or before April 30, 2016, the Board shall revise and adopt written policies and procedures designed to identify, measure, monitor, and control concentrations of credit consistent with the “Concentrations of Credit” booklet of the Comptroller’s Handbook and OCC Bulletin 2006-46. The policies and procedures shall include, but not necessarily be limited to, the following:
(a) establishment of specific roles and responsibilities for determining and managing concentrations of credit;
(b) an identification of the Bank’s known and potential concentrations of credit, including, but not limited to, the Bank’s concentrations identified in XXX;
(c) an analysis of the risk that the Bank’s known and potential concentrations of credit pose to the Bank’s earnings, capital, and operating strategy under stressed market conditions, economic downturns, and periods of general market illiquidity as well as normal market conditions;
(d) establishment of specific limits for each of the Bank’s known and potential concentrations relative to capital based on the analysis performed under subparagraph (1)(b) of this Article;
(e) development and implementation of action plans, approved by the Board, to reduce the risk of any concentration that exceeds the limitations established pursuant to subparagraph (1)(d) of this Article;
(f) establishment of a process for setting concentration limits, and approving changes and exceptions to those limits; and
(g) management information systems designed to ensure timely and accurate reporting of concentrations to the Board.
(2) The Board shall ensure that all concentrations of credit are subjected to the analysis required by subparagraph (1)(c) of this Article at least annually, and, if that analysis demonstrates that the concentration subjects the Bank to undue risk, the Board shall take appropriate steps to mitigate such risk.
(3) For purposes of this Article, a concentration of credit is as defined in the “Concentrations of Credit” booklet of the Comptroller’s Handbook;
(4) A copy of the 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 promptly implement and thereafter ensure adherence to the program.
CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with the “Concentrations of Credit” booklet of the Comptroller's Handbook. The program shall include, but not necessarily be limited to, the following:
(a) a written analysis of any concentration of credit identified in order to identify and assess the inherent risk; and
(b) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis.
(2) For purposes of this Article, a concentration of credit is as defined in the “Concentrations of Credit” booklet of the Comptroller's Handbook.
(3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (a) of paragraph (1) and, if that analysis demonstrates that the concentration subjects the Bank to undue risk, it takes appropriate steps to mitigate such risk.
(4) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller within seven days following the review.
(5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Banking Circular 255 and OCC Bulletin 2006-46, “Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices.”
(2) The program shall include, but not necessarily be limited to, the following:
(a) a review of the balance sheet to identify any concentrations of credit;
(b) a written analysis of any concentration of credit identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;
(c) policies and procedures to control and monitor concentrations of credit;
(d) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis;
(e) a process to monitor the performance of large CRE projects against projected absorption rates;
(f) a process to ensure portfolio level stress tests or sensitivity analysis is performed to quantify the impact of changing economic conditions on asset quality, earnings, and capital;
(g) a process to establish, monitor and adjust CRE risk exposure limits and appropriate sub-limits;
(h) a process to establish, monitor, and adjust insider risk exposure limits; and
(i) establishment of Board reports that:
(i) aggregate insider borrowings and show the amount supported by cash collateral (as appropriately excluded in concurrence with regulations) for each insider; and
(ii) track individual aggregate insider exposure for compliance with Regulation O and the Legal Lending Limit.
(3) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller’s Handbook.
(4) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) of paragraph (2) of this Article and that the analysis demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk.
(5) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.
(6) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONCENTRATIONS OF CREDIT. (1) Within ninety (90) days of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with the "Concentrations of Credit" booklet of the Comptroller's Handbook (December, 2011). The program shall include, but not necessarily be limited to, the following:
(a) a review of current policies, processes and procedures to control and monitor concentrations of credit;
(b) a written analysis of all concentrations of credit that fully assesses inherent credit, liquidity, and interest rate risk;
(c) establishment of safe and sound, formal risk limits for all concentrations of credit based on a percentage of capital; and
(d) an action plan approved by the Board to reduce the risk of any concentration of credit deemed imprudent in the above analysis.
(2) The Board shall ensure that future concentrations of credit are subjected to the analysis required by paragraph (1)(b), and the limits established by paragraph (1)(c), of this Article and that the analysis demonstrates that the concentration will not subject the Bank to undue credit, liquidity, or interest rate risk.
(3) The Board shall forward a copy of the written asset diversification program, including the analysis of existing concentrations of credit, and the establishment of formal limits for all existing or future concentrations of credit, to the Assistant Deputy Comptroller for prior determination of no supervisory objection.
CONCENTRATIONS OF CREDIT. (1) Within thirty (30) days from the effective date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Banking Circular 255. The program shall include, but not necessarily be limited to, the following:
(a) a review of the balance sheet to identify any concentrations of credit with particular emphasis on real estate loans, commercial loans, out-of-area loans, and unfunded commitments to lend;
(b) a written analysis of any concentration of credit identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;
(c) policies and procedures to control and monitor concentrations of credit; and
(d) a written action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis.
(2) For purposes of this Article, a concentration of credit is as defined in the Loan Portfolio Management booklet of the Comptroller's Handbook.
(3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) of Paragraph (1) of this Article, and that the analysis demonstrates that the concentration will not subject the Bank to undue credit, liquidity, or interest rate risk.
(4) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.
(5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Banking Circular 255. The program shall include, but not necessarily be limited to, the following:
(a) a review of the balance sheet to identify any concentrations of credit;
(b) a written analysis of any concentration of credit identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;
(c) policies and procedures to control and monitor concentrations of credit in conformance with OCC Bulletin 2006-46; and
(d) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis, especially as it relates to land, land development and commercial real estate loans.
(2) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller's Handbook.
(3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) and that the analysis demonstrate that the concentration will not subject the Bank to undue credit or interest rate risk.
(4) The Board shall forward a copy of any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.
(5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONCENTRATIONS OF CREDIT. Within thirty (30) days, the Association shall revise its written program for identifying, monitoring, and controlling risks associated with concentrations of credit (Concentration Program) to ensure that it addresses all corrective actions set forth in the 2010 XXX relating to concentrations of credit. The Concentration Program shall comply with all applicable laws, regulations, and regulatory guidance and shall:
