Common use of CONCENTRATIONS OF CREDIT Clause in Contracts

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 Bulletin 2006-46 Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. 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, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), 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 demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward a copy of an analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. 1F (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank Association adherence to a written asset diversification program consistent with OCC Bulletin 2006-46 the guidance set forth in OTS CEO Memo 2522 and the “Concentrations in CRE Lendingof Credit” booklet of the Comptrollers’ Handbook (December 13, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout2011). 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, credit including, but not limited to, establishing prudent concentrations of credit : (i) comprehensive and reasonable loan concentration limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., expressed as a percentage of total risk-based capital for all commercial real estate (CRE) loans in the aggregate and as a percentage of Tier One Capital plus the Allowance for Loan each primary and Lease Losses. The Board approved limits and identifiable sub-limits shall be based on the written analysis required in subparagraph category of CRE loans (bi.e., construction, multi-family, hotel, land, nonresidential, and nonmortgage commercial loans), and; (d) an 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 approved by the Board plan, including specific time frames, to reduce the risk of any concentration deemed imprudent in the above analysisanalysis 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 HandbookCEO Memo 252. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b1)(b) of this Article and that the analysis demonstrates that the concentration will not subject the Bank Association to undue credit or interest rate risk. (4) The Board shall forward a copy of an 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 Association has adequate 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 Bulletin 2006-46 Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. 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, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), 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 '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 demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward a copy of an analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. (1) Within sixty thirty (6030) daysdays of the date of this Agreement, the Board Bank shall adopt, implement, submit to the Assistant Deputy Comptroller for review and thereafter ensure Bank adherence to a prior written asset diversification program consistent with OCC Bulletin 2006-46 Concentrations in CRE Lending, Sound determination of no supervisory objection an acceptable written Concentration Risk Management Practices: Interagency Guidance on CRE Program (“Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan WorkoutProgram”). The program shall include, but not necessarily be limited to, Refer to the following: (a) a review “Concentrations of Credit” booklet 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, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease LossesComptroller’s Handbook. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), 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 ManagementConcentrations of Credit” booklet of the Comptroller’s Handbook. (32) The Board Concentration Program shall ensure that future include, at a minimum: (a) identification of the Bank’s known and potential concentrations of credit are subjected including, but not limited to, the concentrations identified in the most recent examination of the Bank; (b) the establishment of safe and sound, formal limits and sub-limits for all concentrations of credit including, but not limited to, the concentrations identified in the most recent examination of the Bank, based on a percentage of Tier 1 capital plus the allowance for credit losses, stratified by loan type, locality of the borrower and/or collateral, and other meaningful measures; (c) development and implementation of action plans, approved by the Board, to reduce concentrations to conform to the analysis required by established limits set in subparagraph (b) of this Article, including strategies and procedures when concentrations approach or exceed Board-approved limits; (d) prohibit the origination of new unsecured or under-secured credit commitments and prohibit the renewal of under-secured credit commitments (not including overdrafts made in ordinary course by customers that the analysis demonstrates do not include borrowers that the concentration will not subject already have unsecured or under secured advances or borrowers to whom or which the Bank already has a concentration of credit) until unsecured and under-secured levels are within reasonable, Board-approved limits; (e) management information systems that ensure timely and accurate reporting of concentrations to undue the Board including concentration reports that stratify the loan portfolio by type, locality, and other meaningful measures and procedures for monitoring concentration reports monthly based upon total committed amounts relative to Board-approved limits; and (f) annual re-evaluation and approval of concentration limits by the Board, and a Board policy that requires detailed analysis and written support of any proposed changes demonstrating the credit or interest rate riskrisk that will result from the change. (43) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the Concentration Program or to any subsequent amendment to the Concentration Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the Concentration Program. The Board shall forward a copy review the effectiveness of an analysis performed on existing the Concentration Program at least annually, and more frequently if necessary or potential concentrations of credit if required by the OCC in writing, and amend the Concentration Program as needed or directed by the OCC. Any amendment to the Concentration Program must be submitted to the Assistant Deputy Comptroller immediately following the reviewfor review and prior written determination of no supervisory objection.

CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification concentration management program consistent with OCC Bulletin 2006-46 46: Concentrations in CRE Commercial Real Estate Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. 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, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), and; (d) procedures to track and analyze concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Bank's loan and lease portfolios; (e) periodic portfolio-level stress tests or sensitivity analysis to quantify the impact on changing economic conditions on asset quality, earnings, and capital; (f) ongoing market analysis for the various property types represented in the loan portfolio; and (g) 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 's Handbook. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by paragraph (1), subparagraph (b) of this Article, and that the analysis demonstrates that the concentration will not subject the Bank to undue credit credit, liquidity, or interest rate risk. (4) The Board shall develop and implement a written strategy designed to ensure that the Bank's high level of commercial real estate concentrations are reduced to manageable levels. (5) The Board shall forward a copy of an 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 sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Bulletin 2006-46 “Concentrations in CRE Commercial Real Estate Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, ,” and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan WorkoutBanking 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, including, but not limited to, establishing prudent ; (d) identification of industry concentrations using a minimum second level NAIC code; (e) the formation of credit limits for commercial real estate exposure limits addressing non- owner occupied properties, owner-occupied properties, property type and other exposuresgeographic location; (f) maintenance of systems and reports which identify and analyze real estate portfolio concentrations, as well as sub-limits including commitments, by property type, industrycollateral, geographic areas, etc., and location; (g) maintenance of a system to calculate each concentration as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), andcapital; (dh) development of a system to identify, monitor and limit the amount of real estate loans that exceed supervisory loan-to-value limits as set forth in Appendix A to Subpart D of 12 C.F.R Part 34 “Interagency Guidelines for Real Estate Lending,” and (i) 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 '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 demonstrates demonstrate that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward a copy of an 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) daysdays of the date of this agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Bulletin 2006-46 “Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workoutof Credit (Section 216)” of the Comptroller’s Handbook. The program shall include, but not necessarily be limited to, the following: (a) an action plan for the reduction of the Bank’s concentration in commercial real estate (CRE) that includes, at a minimum: (i) a reduction strategy that includes CRE concentration limits stratified by type, locality and other meaningful measures supported by written analysis; (ii) monthly monitoring of concentration reports that stratify the CRE portfolio by product type, locality and other meaningful measures; (iii) strategies and procedures to manage and reduce CRE concentrations to conform with established limits set in Subparagraph (a)(i) of this Article; and (iv) target dates for the reduction of the Bank’s CRE concentration to levels below the limits established in subparagraph (a)(i) of this Article. (b) a review of the balance sheet to identify any additional concentrations of credit; (bc) a written analysis of any additional concentration of credit identified above in subparagraph (b) in order to identify and assess the inherent credit, liquidity, and interest rate risk; (cd) the establishment of safe and sound formal risk limits for all existing and future concentrations of credit based upon a percentage of the Bank’s capital; (e) policies and procedures to control and monitor concentrations of credit, including, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), ; and; (df) 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 's Handbook. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) this Article and that the analysis demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward a copy of an any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. (1) Within sixty (60) daysOn or before April 30, 2016, the Board shall adoptrevise and adopt written policies and procedures designed to identify, implementmeasure, monitor, and thereafter ensure Bank adherence to a written asset diversification program control concentrations of credit consistent with the “Concentrations of Credit” booklet of the Comptroller’s Handbook and OCC Bulletin 2006-46 Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout46. The program policies and procedures shall include, but not necessarily be limited to, the following: (a) a review establishment of the balance sheet to identify any specific roles and responsibilities for determining and managing concentrations of credit; (b) a written analysis an identification of any concentration of credit identified above in order to identify the Bank’s known and assess the inherent credit, liquidity, and interest rate risk; (c) policies and procedures to control and monitor potential concentrations of credit, including, but not limited to, establishing prudent the Bank’s concentrations identified in XXX; (c) an analysis of the risk that the Bank’s known and potential concentrations of credit limits for commercial real estate pose to the Bank’s earnings, capital, and other exposuresoperating strategy under stressed market conditions, economic downturns, and periods of general market illiquidity as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), andnormal market conditions; (d) an 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 plan plans, approved by the Board Board, to reduce the risk of any concentration deemed imprudent in that exceeds the above analysislimitations 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 “Loan Portfolio ManagementConcentrations 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 (b) and that the analysis demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk.; (4) The Board shall forward a A copy of an analysis performed on existing the program, or potential concentrations of credit any subsequent amendments or changes to the program, shall be forwarded to the Assistant Deputy Comptroller immediately following for review and determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the reviewAssistant Deputy Comptroller, the Board shall promptly implement and thereafter ensure adherence to the program.

CONCENTRATIONS OF CREDIT. (1) Within sixty ninety (6090) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with the “Loan Portfolio Management” booklet of the Comptroller's Handbook. The program shall be consistent with OCC Bulletin 2006-46 46, Interagency Guidance on Concentrations in CRE Commercial Real Estate Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. The program shall include, but not necessarily be limited to, the following:, (a) a review of the balance sheet to identify any an ongoing process for identifying concentrations of credit; (b) a written analysis of any concentration the Bank’s concentrations of credit identified above in order to identify credit, which identifies and assess assesses the inherent credit, liquidity, and interest rate riskrisks; (c) policies and procedures to control and monitor concentrations of credit, including, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), and; (d) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis; (d) the establishment of Board-approved concentration limits relative to capital; (e) a process for reporting all concentrations to the Board on a periodic basis; (f) procedures requiring notification to the Board when the Bank’s concentrations of credit exceed Board-approved limits; (g) procedures for periodic portfolio-level stress tests or sensitivity analyses of the Bank’s concentrations to quantify the impact of changing economic conditions on asset quality, earnings, and capital; and (h) contingency plans to reduce or mitigate concentrations in the event of adverse market conditions. (2) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller’s 's Handbook. (3) Upon completion, the Board shall forward a copy of the program to the Assistant Deputy Comptroller for a written determination of no supervisory objection. (4) The Board shall ensure that future all concentrations of credit are subjected to the analysis required by subparagraph paragraph (b1) and of this Article at least annually, and, if that the analysis demonstrates that the concentration will not subject subjects the Bank to undue credit or interest rate risk, the Board shall take appropriate steps to mitigate such risk. (4) The Board shall forward a copy of an analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. (1) Within sixty ninety (6090) daysdays of this Agreement, the Board shall adoptprepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, implement, and thereafter ensure Bank adherence to a written asset diversification program (including appropriate revisions to policies and procedures) designed to diversify the Bank’s assets consistent with OCC Bulletin 2006-46 Banking Circular 255 and the “Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workoutof Credit” booklet of the Comptroller’s Handbook (Section 216). 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 creditcredit that include at a minimum, includingmonthly monitoring by the Board of concentration reports that stratify the loan portfolio by product type, but not limited to, establishing prudent concentrations of credit limits for commercial real estate locality and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), andmeaningful measures; (d) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis; and (e) a Board policy that requires a detailed analysis and written support to conclude that any concentration limit increase will not subject the Bank to undue credit or interest rate risk before the Board may approve such increase. (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 Subparagraph (b) and that the analysis demonstrates that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward Upon receiving a copy written determination of an analysis performed on existing or potential concentrations of credit to no supervisory objection from the Assistant Deputy Comptroller Comptroller, the Board shall immediately following implement and thereafter ensure adherence to the reviewprogram, policies and procedures required by this Article.

CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank Association adherence to a written asset diversification program consistent with guidance set forth in OCC Bulletin 2006-46 (Concentrations in CRE Commercial Real Estate Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management) and the “Concentrations of Credit” booklet of the Comptrollers’ Handbook (December 13, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout2011). 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, but not limited to, establishing prudent including policies and procedures to control and monitor concentrations of credit including comprehensive and reasonable loan concentration limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., expressed as a percentage of total risk-based capital for all commercial real estate (CRE) loans in the aggregate and as a percentage of Tier One Capital plus the Allowance for Loan each primary and Lease Losses. The Board approved limits and identifiable sub-limits shall be based on the written analysis required in subparagraph category of CRE loans (bi.e., construction, multi-family, hotel, land, nonresidential, and nonmortgage commercial loans), andsuch as such as the Association’s non-owner occupied residential/investor loan portfolio; (d) an 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 approved by the Board plan, including specific time frames, to reduce the risk of any concentration deemed imprudent in the above analysisanalysis 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 's Handbook. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b1)(b) and that the analysis demonstrates demonstrate that the concentration will not subject the Bank Association to undue credit or interest rate risk. (4) The Board shall forward a copy of an 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 Association 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 forty-five (6045) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written asset diversification program consistent with OCC Bulletin 2006-46 Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk “Loan Portfolio Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout” booklet of the Comptroller's Handbook. The program shall include, but not necessarily be limited to, the following: (a) a review of the balance sheet including loans, investment securities, and other assets 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 including specific concentration ranges or limits (as a percentage of Bank capital) by industry, type of collateral, type of investment, by employer, and/or by any other common characteristic as deemed appropriate by the Board, to control and monitor concentrations of credit, including, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), and; (d) a requirement for sufficient monthly Board reports indicating the actual Bank concentrations as compared to the range or limits imposed by policy limitations outlined in (c) such that the Board of Directors can determine the Bank’s adherence or non-compliance with such limits; and, (e) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in upon completion of 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 's Handbook. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b1)(b) and and, if that the analysis demonstrates that the concentration will not subject subjects the Bank to undue credit or interest rate risk, it takes appropriate steps to mitigate such risk. (4) The Board shall forward a copy of an any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. (1) The Bank shall take immediate and ongoing action to significantly reduce its concentrations of credit risk in the following asset classes: (a) commercial real estate (CRE) lending; and (b) construction and development lending. (2) Within sixty (60) daysdays of the date of this Agreement, the Board shall adopt, implement, adopt and thereafter ensure that the Bank adherence implements and adheres to a written asset diversification program consistent with OCC Bulletin 2006-46 Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workoutprogram. The program shall include, but not necessarily be limited to, the following: (a) A detailed description of the actions it is taking to comply with Paragraph (1) of this Article; (b) a review of the balance sheet to identify any other concentrations of creditcredit risk not identified in Paragraph (1) of this article, which shall include a review of the lending operations conducted by the Bank’s operating subsidiaries; (bc) a written analysis of any concentration of credit risk identified above in order to identify and assess the inherent credit, liquidity, and interest rate risk;. (cd) policies and procedures to control and monitor concentrations of creditcredit risk, includingthat include, but not limited toat a minimum: (i) a concentrations management system(s) that aggregates exposures across the consolidated bank, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), andincluding all operating subsidiaries; (dii) concentration limits and actionable thresholds by capital and the total portfolio; and (iii) the establishment of limits for direct and indirect exposures to industries. (e) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis. This analysis must include consideration of the Bank’s need to reduce reliance on brokered deposits as required by Article XII of this Agreement. (23) For purposes of this Article, a concentration of credit risk is as defined in the “Loan Portfolio Management” booklet of the Comptroller’s 's Handbook. (34) The Board shall ensure that future concentrations of credit risk are subjected to the analysis required by subparagraph (b) and that the analysis demonstrates demonstrate that the concentration will not subject the Bank to undue credit credit, liquidity, or interest rate risk. (45) The Board shall forward a copy of an any analysis performed on existing or potential concentrations of credit risk to the Assistant Deputy Comptroller immediately following the review.

CONCENTRATIONS OF CREDIT. (1) Within sixty (60) daysdays from the date of this Agreement, the Board shall adopt, implement, revise and thereafter ensure Bank adherence to a its written asset diversification program consistent with OCC Bulletin 2006-46 Concentrations safe and sound banking practices and the risk diversification guidelines set forth in CRE Lending, Sound Risk the Loan Portfolio Management Practices: Interagency Guidance on CRE and Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workoutof Credits booklets of the Comptroller’s Handbook. The revised program shall include, but not necessarily be limited to, the following: (a) a review of the balance sheet, and off balance sheet obligations, to identify any related concentrations of credit; (b) a written analysis of any concentration concentrations 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, but not limited to, establishing prudent including limits on concentrations and policies requiring notification to the Board when concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), exceed policy limits; 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 ManagementConcentration of Credits” booklet of the Comptroller’s 's Handbook. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) of this Article and if that the analysis demonstrates that the concentration will not subject subjects the Bank to undue credit or interest rate risk, the Board shall take appropriate steps to mitigate such risk. (4) The Board shall forward a copy of an any analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately within thirty (30) 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 revised pursuant to this Article.

CONCENTRATIONS OF CREDIT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank Association adherence to a written asset diversification program consistent with OCC Bulletin 2006-46 the guidance set forth in OTS CEO Memo 2521F2 and the “Concentrations in CRE Lendingof Credit” booklet of the Comptrollers’ Handbook (December 13, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout2011). The program shall include, but not necessarily be limited to, the following:: 2 CEO Memo 252, issued December 14, 2006 provides guidance on “Commercial Real Estate Concentration Risks”. (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, credit including, but not limited to, establishing prudent concentrations of credit : (i) comprehensive and reasonable loan concentration limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., expressed as a percentage of total risk-based capital for all commercial real estate (CRE) loans in the aggregate and as a percentage of Tier One Capital plus the Allowance for Loan each primary and Lease Losses. The Board approved limits and identifiable sub-limits shall be based on the written analysis required in subparagraph category of CRE loans (bi.e., construction, multi-family, hotel, land, nonresidential, and nonmortgage commercial loans), and; (d) an 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 approved by the Board plan, including specific time frames, to reduce the risk of any concentration deemed imprudent in the above analysisanalysis 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 HandbookCEO Memo 252. (3) The Board shall ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b1)(b) of this Article and that the analysis demonstrates that the concentration will not subject the Bank Association to undue credit or interest rate risk. (4) The Board shall forward a copy of an 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 Association has adequate 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) daysdays of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to adopt a written asset diversification concentration risk management program consistent with OCC Bulletin 2006-46 (“Concentration Program”). Refer to the “Concentrations in CRE Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. The program shall include, but not necessarily be limited to, the following: (a) a review of Credit” booklet 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, but not limited to, establishing prudent concentrations of credit limits Comptroller’s Handbook for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Lossesguidance. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), 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 ManagementConcentrations of Credit” booklet of the Comptroller’s Handbook. (32) The Board Concentration Program shall ensure that future include, at a minimum: (a) identification of the Bank’s known and potential concentrations of credit are subjected to the analysis required by subparagraph including, but not limited to, commercial real estate, commercial and industrial, and construction and development concentrations; (b) a written analysis of all concentrations of credit that identifies and assesses inherent credit, liquidity, and interest rate risks and considers the impact of concentration levels on overall growth plans, financial targets, portfolio stress tests, and capital plan objectives; (c) the establishment of safe and sound, formal limits and sub-limits for all concentrations of credit based on a percentage of Tier 1 capital plus the allowance for loan and lease losses, stratified by loan type, locality of the borrower and/or collateral, and other meaningful measures; (d) development and implementation of action plans, approved by the Board, to reduce concentrations to conform to the established limits set in paragraph (2)(c) of this Article, including strategies and procedures when concentrations approach or exceed Board-approved limits; (e) management information systems that ensure timely and accurate reporting of concentrations to the Board, including concentration reports that stratify the loan portfolio by type, locality, and other meaningful measures, and procedures for monitoring concentration reports quarterly based upon total committed amounts relative to Board-approved limits; (f) portfolio-level stress tests to quantify the impact of changes to portfolio- specific characteristics and market conditions on earnings and capital, consistent with the size, complexity, and risk profile of the portfolio; (g) annual re-evaluation and approval of concentration limits by the Board, and a Board policy that requires detailed analysis demonstrates that and written support of any proposed changes demonstrating the concentration will not subject the Bank to undue credit or interest rate risk.risk that will result from the change; and (4h) The Board shall forward a copy detailed contingency plan to reduce concentration risk in the event of an analysis performed on existing or potential concentrations of credit to the Assistant Deputy Comptroller immediately following the reviewadverse market conditions, including reasonable action plans.

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 46, “Concentrations in CRE Commercial Real Estate Lending, Sound Risk Management Practices: Interagency Guidance on CRE Concentration Risk Management, and OCC Bulletin 2009-32 CRE Loans: guidance on Prudent CRE Loan Workout. .” (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, including, but not limited to, establishing prudent concentrations of credit limits for commercial real estate and other exposures, as well as sub-limits by property type, industry, geographic areas, etc., as a percentage of total loans and as a percentage of Tier One Capital plus the Allowance for Loan and Lease Losses. The Board approved limits and sub-limits shall be based on the written analysis required in subparagraph (b), and; (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. (23) For purposes of this Article, a concentration of credit is as defined in the “Loan Portfolio Management” booklet of the Comptroller’s Handbook. (34) 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. (45) The Board shall forward a copy of an 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.