Common use of CONCENTRATIONS OF CREDIT Clause in Contracts

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) On or before April Within thirty (30, 2016) days of the date of this Agreement, the Board Bank shall revise submit to the Assistant Deputy Comptroller for review and adopt prior written policies and procedures designed determination of no supervisory objection an acceptable written Concentration Risk Management Program (“Concentration Program”). Refer to identify, measure, monitor, and control concentrations of credit consistent with the “Concentrations of Credit” booklet of the Comptroller’s Handbook and OCC Bulletin 2006-46Handbook. 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. (2) The Concentration Program shall include, at a minimum: (a) identification of the Bank’s known and potential concentrations of credit including, but not limited to, the concentrations identified in the most recent examination of the Bank; (4b) A copy 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 programBank, 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 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 do not include borrowers that 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 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 risk that will result from the change. (3) 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 amendments or changes amendment to the programConcentration 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 review the effectiveness of the Concentration Program at least annually, and more frequently if necessary or 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 forwarded 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 Board shall promptly implement and thereafter ensure adherence to the program.

CONCENTRATIONS OF CREDIT. (1) On or before April 30, 2016Within forty-five (45) days, the Board shall revise and adopt written policies and procedures designed to identifyadopt, measure, monitorimplement, and control concentrations of credit thereafter ensure Bank adherence to a written asset diversification program consistent with the “Concentrations of CreditLoan Portfolio Management” booklet of the Comptroller’s Handbook and OCC Bulletin 2006-46's Handbook. The policies and procedures program shall include, but not necessarily be limited to, the following: (a) establishment a review of specific roles the balance sheet including loans, investment securities, and responsibilities for determining and managing other assets to identify any concentrations of credit; (b) an identification a written analysis of any concentration of credit identified above in order to identify and assess the Bank’s known and potential concentrations of inherent credit, includingliquidity, but not limited to, the Bank’s concentrations identified in XXXand interest rate risk; (c) an analysis 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 risk that the Bank’s known Board, to control and potential monitor 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 conditionscredit; (d) establishment 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 specific limits for each of Directors can determine the Bank’s known and potential concentrations relative to capital based on the analysis performed under subparagraph (1)(b) of this Article;adherence or non-compliance with such limits; and, (e) development and implementation of an action plans, plan approved by the Board, Board to reduce the risk of any concentration that exceeds deemed imprudent upon completion of 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 Boardabove analysis. (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 CreditLoan 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 (1)(b) and, if that analysis demonstrates that the concentration subjects the Bank to undue risk, it takes appropriate steps to mitigate such risk. (4) A The Board shall forward a copy of the program, any analysis performed on existing or any subsequent amendments or changes to the program, shall be forwarded potential concentrations of credit to the Assistant Deputy Comptroller for review and determination of no supervisory objection. Upon receiving a determination of no supervisory objection from immediately following the Assistant Deputy Comptroller, the Board shall promptly implement and thereafter ensure adherence to the programreview.

CONCENTRATIONS OF CREDIT. (1) On or before April 30, 2016Within ninety (90) days of this Agreement, the Board shall revise prepare and adopt submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program (including appropriate revisions to policies and procedures procedures) designed to identify, measure, monitor, and control concentrations of credit diversify the Bank’s assets consistent with OCC Banking Circular 255 and the “Concentrations of Credit” booklet of the Comptroller’s Handbook and OCC Bulletin 2006-46(Section 216). The policies and procedures program shall include, but not necessarily be limited to, the following: (a) establishment a review of specific roles and responsibilities for determining and managing the balance sheet to identify any concentrations of credit; (b) an identification a written analysis of any concentration of credit identified above to identify and assess the Bank’s known and potential concentrations of inherent credit, includingliquidity, but not limited to, the Bank’s concentrations identified in XXXand interest rate risk; (c) an analysis of the risk that the Bank’s known policies and potential procedures to control and monitor concentrations of credit pose to that include at a minimum, monthly monitoring by the Bank’s earningsBoard of concentration reports that stratify the loan portfolio by product type, capital, locality and operating strategy under stressed market conditions, economic downturns, and periods of general market illiquidity as well as normal market conditionsother meaningful measures; (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 an action plans, plan approved by the Board, Board to reduce the risk of any concentration that exceeds deemed imprudent in 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 limitsabove analysis; and (ge) management information systems designed a Board policy that requires a detailed analysis and written support to ensure timely and accurate reporting of concentrations conclude that any concentration limit increase will not subject the Bank to undue credit or interest rate risk before the BoardBoard may approve such increase. (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 CreditLoan 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) 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 written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall promptly immediately implement and thereafter ensure adherence to the program, policies and procedures required by this Article.

CONCENTRATIONS OF CREDIT. (1) On or before April 30, 2016Within sixty (60) days from the date of this Agreement, the Board shall revise and adopt thereafter ensure Bank adherence to its written policies and procedures designed to identify, measure, monitor, and control concentrations of credit asset diversification program consistent with safe and sound banking practices and the “Concentrations risk diversification guidelines set forth in the Loan Portfolio Management and Concentration of Credit” booklet Credits booklets of the Comptroller’s Handbook and OCC Bulletin 2006-46Handbook. The policies and procedures revised program shall include, but not necessarily be limited to, the following: (a) establishment a review of specific roles the balance sheet, and responsibilities for determining and managing off balance sheet obligations, to identify any related concentrations of credit; (b) an identification a written analysis of the Bank’s known and potential any concentrations of credit identified above in order to identify and assess the inherent credit, includingliquidity, but not limited to, the Bank’s concentrations identified in XXXand interest rate risk; (c) an analysis policies and procedures to control and monitor concentrations of credit, including limits on concentrations and policies requiring notification to the risk that the Bank’s known and potential Board when 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;exceed policy limits; and (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 an action plans, plan approved by the Board, Board to reduce the risk of any concentration that exceeds deemed imprudent in 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 Boardabove analysis. (2) For purposes of this Article, a concentration of credit is as defined in the “Concentration of Credits” booklet of the Comptroller's Handbook. (3) The Board shall ensure that all future concentrations of credit are subjected to the analysis required by subparagraph (1)(cb) of this Article at least annually, and, and if that analysis demonstrates that the concentration subjects the Bank to undue risk, the Board shall take appropriate steps to mitigate such risk. (34) For purposes The Board shall forward a copy of this Article, a concentration any analysis performed on existing or potential concentrations 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 within thirty (30) days following the Assistant Deputy Comptroller, the review. (5) The Board shall promptly implement ensure that the Bank has processes, personnel, and thereafter control systems to ensure implementation of and adherence to the programprogram revised pursuant to this Article.

CONCENTRATIONS OF CREDIT. (1) On or before April 30, 2016Within sixty (60) days, the Board shall revise and adopt develop a written policies and procedures program 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(December 2011, as revised). The Board shall forward a copy of the program to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. The program shall address the concentration risk management weaknesses identified in the most recent XXX, and require policies and procedures shall that include, but not necessarily be limited toat a minimum, the following: (a) establishment of specific roles a reasonable and responsibilities supportable overall concentration limit for determining HELOCs for both outstanding and managing concentrations of credittotal committed balances with sufficient consideration for the Bank’s capital and ALLL balances; (b) an identification of the Bank’s known and potential non-HELOC concentrations of credit, including, but not limited to, the Bank’s concentrations identified in XXXthe Report of Examination dated as of September 30, 2016; (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; (ed) development and implementation establishment of action plans, approved by concentration management information systems that incorporate the Board, to reduce the risk of any concentration that exceeds the limitations established data collected pursuant to subparagraph paragraph (1)(d1)(a) of Article II of this Articleagreement, including segmenting of concentrations by categories of similar risk and performance characteristics which must include, but are not limited to, segmenting, when possible, by: (i) vintage, particularly when underwriting was changed or new product features were introduced; (fii) establishment of a process for setting concentration limits, and approving changes and exceptions to those limitscredit scores; (iii) combined loan-to-value ratios; (iv) employer or industry; and (gv) management information systems designed geographical location; and (e) periodic monitoring and re-evaluation of concentration limits set by the Board to ensure timely the limits established pursuant to subparagraphs (a) and accurate reporting (c) of concentrations this paragraph remain safe and sound, responsive to changes in market conditions, and within the Board’s tolerance for risk. (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 written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall promptly immediately implement and thereafter ensure adherence to the concentration risk management program.