Common use of CRA, Anti-money Laundering and Customer Information Security Clause in Contracts

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVB: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC Board has adopted and HVBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Buyer’s Knowledge, none of Buyer and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Buyer Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212022, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to Appendix B to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act. Buyer Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and 31 C.F.R. § 1010 et seq. Buyer Bank has, and at all times during the past three (3) years has had, a Community Reinvestment Act and the regulations thereunderrating no lower than “Satisfactory”.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Company’s Knowledge, none of Company and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, Community Reinvestment Act and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to Appendix B to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act Act. Company Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and the regulations thereunder31 C.F.R. § 1010 et seq.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Other than investments to satisfy regulatory requirements, neither BNC nor HVB Bank of NC is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge ofand, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31its knowledge, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, which would cause HVBC or HVBBank of NC: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Bank of NC pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. except where the failure to be in such compliance would not reasonably be expected to have a Material Adverse Effect on BNC. Furthermore, the HVBC Board board of directors of Bank of NC has adopted and HVBC Bank of NC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority governmental agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Company is not aware of, nor and none of Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Company Bank’s Home Mortgage Disclosure Act data for the year ended December March 31, 20212011, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has any no Knowledge of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212011, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Company is not aware of, nor and none of Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31September 30, 20212013, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Buyer’s Knowledge, none of Buyer and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Buyer Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212020, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the XxxxxGramx-Xxxxx-Xxxxxx Act Xxx of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act Act. Buyer Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and the regulations thereunder31 C.F.R. § 1010 et seq.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC NBT nor HVB NBT Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC NBT nor HVB NBT Bank has any Knowledge of, nor has HVBC NBT or HVB NBT Bank been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC NBT or HVBNBT Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC NBT pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC NBT Board has adopted adopted, and HVBC NBT has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Xxxxxx nor HVB Xxxxxx Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBXxxxxx Bank: (ai) to be deemed not to be in satisfactory compliance in any material respect with the Community Reinvestment Act of 1977, as amended (the “CRA, ”) and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; ,” or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, amended and its implementing regulations (31 C.F.R. Chapter XCFR part 103), the USA PATRIOT Patriot Act of 2001, Public Law 107-56 (the “USA Patriot Act, ”) and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, thereunder as well as the provisions of the information security program Information Security Program adopted by HVBC OFSLA pursuant to 12 C.F.R. CFR Part 000364. The Board of Directors of Xxxxxx Bank has adopted, Xxxxxxx Xand Xxxxxx Bank has implemented, Xxxxxxxx D. Furthermore, the HVBC Board has adopted and HVBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge the Company is not aware of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212006, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act of 2001, Public Law 107-56 (the “USA PATRIOT Act”), and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder; or (iv) to be deemed not to be in compliance with the Fair and Accurate Credit Transactions Act of 2003 (“FACTA”) and the regulations promulgated thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Company’s Knowledge, none of Company and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212020, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, Community Reinvestment Act and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the XxxxxGramx-Xxxxx-Xxxxxx Act Xxx of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to Appendix B to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act Act. Company Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and the regulations thereunder31 C.F.R. § 1010 et seq.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB the Company has any no Knowledge of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s because of the Company Bank's Home Mortgage Disclosure Act data for the year ended December 31, 20212010, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”"; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Patriot Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB Buyer has any no Knowledge of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Buyer Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212011, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Buyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or and data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 570. Furthermore, the HVBC Board of Directors of the Buyer Bank has adopted and HVBC the Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Exxxx nor HVB Exxxx Bank is a party to any agreement with any individual or group regarding CRA matters and and, except as set forth in Exxxx Disclosure Schedule 3.30, neither HVBC Exxxx nor HVB Exxxx Bank has any Knowledge of, nor has HVBC Exxxx or HVB Exxxx Bank been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC Exxxx or HVBExxxx Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Exxxx pursuant to 12 C.F.R. Part 000208, Xxxxxxx XSubpart J, Xxxxxxxx Appendix D. Furthermore, the HVBC Exxxx Board has adopted adopted, and HVBC Exxxx has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Except as set forth in Company Disclosure Schedule 3.29, neither Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Company’s Knowledge, none of Company and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212022, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, Community Reinvestment Act and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to Appendix B to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act. Company Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and 31 C.F.R. § 1010 et seq. Company Bank has, and at all times during the past three (3) years has had, a Community Reinvestment Act and the regulations thereunderrating no lower than “Satisfactory”.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Company is not aware of, nor and none of Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year transition period ended December March 31, 20212012, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC HPBC nor HVB the Bank is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, which would cause HVBC or HVBthe Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Bank pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. except where the failure to be in such compliance would not reasonably be expected to have a Material Adverse Effect. Furthermore, the HVBC Board board of directors of the Bank has adopted and HVBC the Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority governmental agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC NBT nor HVB NBT Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC NBT nor HVB NBT Bank has any Knowledge of, nor has HVBC NBT or HVB NBT Bank been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC NBT or HVBNBT Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC NBT pursuant to 12 C.F.R. Part 000208, Xxxxxxx XSubpart J, Xxxxxxxx Appendix D. Furthermore, the HVBC NBT Board has adopted adopted, and HVBC NBT has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Salisbury nor HVB Salisbury Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC Salisbury nor HVB Salisbury Bank has any Knowledge of, nor has HVBC Salisbury or HVB Salisbury Bank been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC Salisbury or HVBSalisbury Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Salisbury pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC Salisbury Board has adopted adopted, and HVBC Xxxxxxxxx has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Buyer is not aware of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s because Buyer Bank Home Mortgage Disclosure Act data for the year ended December 31, 20212006, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of each bank of Buyer has adopted and HVBC each such bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder; (iv) to be deemed not to be in compliance with FACTA and the regulations promulgated thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB Buyer has any no Knowledge of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s because of the Buyer Banks' Home Mortgage Disclosure Act data for the year ended December 31, 20212010, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Buyer Banks: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”"; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Patriot Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Buyer Banks pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 570. Furthermore, the HVBC Board of Directors of each of the Buyer Banks has adopted and HVBC each of the Buyer Banks has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB CBBC is not a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB CBBC has any no Knowledge of, nor has HVBC or HVB CBBC been advised in writing of of, or has any reason to believe (based on HVBCCBBC’s Home Mortgage Disclosure Act data for the year ended December 31, 20212016, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCBBC: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. . Furthermore, the HVBC Board of Directors of CBBC has adopted and HVBC CBBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC NBT nor HVB NBT Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC NBT nor HVB NBT Bank has any Knowledge of, nor has HVBC NBT or HVB NBT Bank been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC NBT or HVBNBT Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC NBT pursuant to 12 C.F.R. Part 000208, Xxxxxxx XSubpart J, Xxxxxxxx Appendix D. Furthermore, the HVBC NBT Board has adopted adopted, and HVBC NBT has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC ------------------------------------------------------------- CBSI nor HVB Community Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBCommunity Bank: (ai) to be deemed not to be in satisfactory compliance in any material respect with the Community Reinvestment Act of 1977, as amended (the "CRA, ") and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”; ," or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, amended and its implementing regulations (31 C.F.R. Chapter XCFR part 103), the USA PATRIOT Patriot Act of 2001, Public Law 107-56 (the "USA Patriot Act, ") and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGramm-XxxxxLeach-Xxxxxx Bliley Act of 1999 and regulations 0000 xxx xxxxxxxxxns promulgated thereunder, thereunder as well as the provisions of the information security program Information Security Program adopted by HVBC Community Bank pursuant to 12 C.F.R. CFR Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Community Bank has adopted adopted, and HVBC Community Bank has implemented implemented, an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB Cambridge is not a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has Cambridge does not have any Knowledge of, nor has HVBC or HVB Cambridge been advised in writing of of, or has any reason to believe (based on HVBCCambridge’s Home Mortgage Disclosure Act data for the year ended December 31, 20212018, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCambridge: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Cambridge pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC Cambridge Board has adopted and HVBC Cambridge has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Buyer is not aware of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s because Buyer Bank's Home Mortgage Disclosure Act data for the year ended December 31, 20212008, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”"; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Patriot Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC ------------------------------------------------------------ PBI nor HVB OFSLA is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBOFSLA: (ai) to be deemed not to be in satisfactory compliance in any material respect with the Community Reinvestment Act of 1977, as amended (the "CRA, ") and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”; ," or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, amended and its implementing regulations (31 C.F.R. Chapter XCFR part 103), the USA PATRIOT Patriot Act of 2001, Public Law 107-56 (the "USA Patriot Act, ") and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGramm-XxxxxLeach-Xxxxxx Bliley Act of 1999 and regulations 0000 xxx xxxxxxxxons promulgated thereunder, thereunder as well as the provisions of the information security program Information Security Program adopted by HVBC OFSLA pursuant to 12 C.F.R. CFR Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of OFSLA has adopted adopted, and HVBC OFSLA has implemented implemented, an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Seller nor HVB the Seller Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Seller Bank: (ai) to be deemed not to be in satisfactory compliance in any material respect with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”; ;" or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 20 103), the USA PATRIOT Act of 2001, Public Law 107-56 (the "USA PATRIOT Act"), ---------------- and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, including without limitation, in Title V of the XxxxxGramm-XxxxxLeach-Xxxxxx Bliley Act of 1999 and regulations promulgated thereundertherxxxxxx, as well xx xxxx as the provisions of the information security program adopted by HVBC the Seller Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 570. Furthermore, the HVBC Board of Directors of the Seller Bank has adopted and HVBC the Seller Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority comply with Section 326 of the USA Patriot Act and that such anti-money laundering program meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge the Company is not aware of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s due to the Company Bank's Home Mortgage Disclosure Act data for the year ended December 31, 20212008, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”"; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT ActUniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Public Law 107-56, and the regulations promulgated thereunderthereunder (the "USA Patriot Act"), any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Buyer’s Knowledge, none of Buyer and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Buyer Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act Act. Buyer Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and the regulations thereunder31 C.F.R. § 1010 et seq.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge the Company is not aware of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCthe Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212008, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT ActUniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Public Law 107-56, and the regulations promulgated thereunderthereunder (the “USA Patriot Act”), any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderPatriot Act.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Bank nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC none of Parent, the Bank nor HVB any of their Subsidiaries has any Knowledge of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBthe Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of the Bank has adopted and HVBC the Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC SBBX nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB SBBX has any no Knowledge of, nor and none of SBBX and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCSB One Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBSB One Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or and data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC SB One Bank pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. Appendix B. Furthermore, the HVBC Board of Directors of SB One Bank has adopted and HVBC SB One Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has no Knowledge of, and none of the Company and its Subsidiaries has been advised of, or has any Knowledge of, nor has HVBC or HVB been advised in writing (because of or has any reason to believe (based on HVBCthe Company’s Home Mortgage Disclosure Act data for the year ended December 31, 20212018, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Company Board has adopted and HVBC the Company has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets meets, in all material respects, the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has no Knowledge of, and none of the Company and its Subsidiaries has been advised of, or has any Knowledge of, nor has HVBC or HVB been advised in writing (because of or has any reason to believe (based on HVBCthe Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212012, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB Except as disclosed on Xxxxxx Disclosure Schedule 2.22, Xxxxxx is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge not aware of, nor has HVBC or HVB not been advised in writing of or of, and has any no reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31believe, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVB: FCNB (a) to be deemed not to be in satisfactory compliance in any respect with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; ,” or (b) to be deemed to be operating in material violation in any respect of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, the Bank Secrecy Act and any regulations or rules promulgated under either of the regulations promulgated thereunderforegoing statutes, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; , or (c) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Xxxxxx pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of FCNB has adopted and HVBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification certification procedures that has not been deemed ineffective in any material respect by any Governmental Regulatory Authority and that meets the requirements in all material respects of Sections 352 and 326 and all other applicable provisions Section 353 of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has any no Knowledge of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212015, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (cb) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Gxxxx- Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB Wellesley or Wellesley Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC Wellesley nor HVB Wellesley Bank has any Knowledge of, nor has HVBC Wellesley or HVB Wellesley Bank been advised in writing of of, or has any reason to believe (based on HVBCWellesley’s Home Mortgage Disclosure Act data for the year ended December 31, 20212018, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC Wellesley or HVBWellesley Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Wellesley pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC Wellesley Board has adopted and HVBC Wellesley has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Wxxxxx nor HVB Wxxxxx Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBWxxxxx Bank: (ai) to be deemed not to be in satisfactory compliance in any material respect with the Community Reinvestment Act of 1977, as amended (the “CRA, ”) and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; ,” or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, amended and its implementing regulations (31 C.F.R. Chapter XCFR part 103), the USA PATRIOT Patriot Act of 2001, Public Law 107-56 (the “USA Patriot Act, ”) and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, thereunder as well as the provisions of the information security program Information Security Program adopted by HVBC OFSLA pursuant to 12 C.F.R. CFR Part 000364. The Board of Directors of Wxxxxx Bank has adopted, Xxxxxxx Xand Wxxxxx Bank has implemented, Xxxxxxxx D. Furthermore, the HVBC Board has adopted and HVBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB the Company Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has any no Knowledge of, and neither the Company nor the Company Bank has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212012, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB Buyer has no Knowledge of, and none of Buyer and its Subsidiaries has been advised of, or has any Knowledge of, nor has HVBC or HVB been advised in writing (because of or has any reason to believe (based on HVBCthe Buyer Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212012, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBBuyer Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB Buyer has any no Knowledge of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of Buyer Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212012, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or and data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 170. Furthermore, the HVBC Board of Directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Seller nor HVB the Seller Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Seller Bank: (a) to be deemed not to be in satisfactory compliance in any material respect with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”; ;" or (b) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act of 2001, Public Law 107-56 (the "USA PATRIOT Act"), and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, including without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Seller Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of the Seller Bank has adopted and HVBC the Seller Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB Except as disclosed on Xxxxxx Disclosure Schedule 2.22, Xxxxxx is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge not aware of, nor has HVBC or HVB not been advised in writing of or of, and has any no reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31believe, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVB: FCNB (a) to be deemed not to be in satisfactory compliance in any respect with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; ,” or (b) to be deemed to be operating in material violation in any respect of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, the Bank Secrecy Act and any regulations or rules promulgated under either of the regulations promulgated thereunderforegoing statutes, any order issued with respect to anti-anti- money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; , or (c) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Xxxxxx pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of FCNB has adopted and HVBC has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification certification procedures that has not been deemed ineffective in any material respect by any Governmental Regulatory Authority and that meets the requirements in all material respects of Sections 352 and 326 and all other applicable provisions Section 353 of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Company is not aware of, nor and none of Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212015, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, Community Reinvestment Act and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC SBBX nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB SBBX has any no Knowledge of, nor and none of SBBX and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCSussex Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212016, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBSussex Bank: (ai) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or and data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. . Furthermore, the HVBC Board of Directors of Sussex Bank has adopted and HVBC Sussex Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB Optima is not a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB Optima has any no Knowledge of, nor has HVBC or HVB Optima been advised in writing of of, or has any reason to believe (based on HVBCOptima’s Home Mortgage Disclosure Act data for the year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBOptima: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Optima pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. Appendix B. Furthermore, the HVBC Board of Directors of Optima has adopted and HVBC Optima has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB NUVO is not a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB NUVO has any no Knowledge of, nor has HVBC or HVB NUVO been advised in writing of of, or has any reason to believe (based on HVBCbecause of NUVO’s Home Mortgage Disclosure Act data for the year ended December 31, 20212014, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBNUVO: (ai) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amendedamended (“BSA”), and its implementing regulations (31 C.F.R. Chapter XParts 1000 et seq.), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC NUVO pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC 364. The Board of Directors of NUVO has adopted and HVBC NUVO has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge the Company is not aware of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212005, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT ActPatriot Act of 2001, Public Law 107-56, and the regulations promulgated thereunderthereunder (the “USA Patriot Act”), any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGramx-Xxxxx-Xxxxxx Act Xxx of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderPatriot Act.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge the Company is not aware of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCdue to the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212008, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT ActUniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Public Law 107-56, and the regulations promulgated thereunderthereunder (the “USA Patriot Act”), any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC the Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB the Company has any no Knowledge of, nor and none of the Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of the Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212015, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBthe Company Bank: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (cb) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx- Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 30. Furthermore, the HVBC Board of Directors of the Company Bank has adopted and HVBC the Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Buyer is not aware of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause Buyer Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212008, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, Patriot Act and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and, to Buyer’s Knowledge, none of Buyer and neither HVBC nor HVB its Subsidiaries has any Knowledge been advised of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCbecause of Buyer Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBBuyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunderits implementing regulations, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactorySatisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule rule, or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunderits implementing regulations, as well as the provisions of the information security program adopted by HVBC Buyer Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Buyer Bank has adopted and HVBC Buyer Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act Act. Buyer Bank has implemented a program with respect to the beneficial ownership requirements set forth in the final rule on Customer Due Diligence Requirements for Financial Institutions found in 81 Federal Register 29397 (July 11, 2016) and the regulations thereunder31 C.F.R. § 1010 et seq.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Other than investments to satisfy regulatory requirements, neither AEB nor HVB the Bank is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge of, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, which would cause HVBC or HVBthe Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-XxxxxGramm- Lxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Bank pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. except where the failure to be in such compliance would not reasonably be expected to have a Material Adverse Effect. Furthermore, the HVBC Board board of directors of the Bank has adopted and HVBC the Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority governmental agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Target nor HVB the Target Subsidiary is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge ofand, nor has HVBC or HVB been advised in writing of or has any reason to believe (based on HVBCTarget’s Home Mortgage Disclosure Act data for the year ended December 31knowledge, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, exist which would cause HVBC Target or HVBthe Target Subsidiary: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Target pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of the Target Subsidiary has adopted and HVBC the Target Subsidiary has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority Entity or Regulatory Agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Tidelands nor HVB Tidelands Bank is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge ofand, nor has HVBC or HVB been advised in writing to the knowledge of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31Tidelands, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, which would cause HVBC or HVBTidelands Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Tidelands Bank pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. except where the failure to be in such compliance would not reasonably be expected to have a Material Adverse Effect. Furthermore, the HVBC Board board of directors of Tidelands Bank has adopted and HVBC Tidelands Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority governmental agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC nor HVB EBNJ is not a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB EBNJ has any no Knowledge of, nor has HVBC or HVB EBNJ been advised in writing of of, or has any reason to believe (based on HVBCEBNJ’s Home Mortgage Disclosure Act data for the year ended December 31, 20212017, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBEBNJ: (a) to be deemed not to be in satisfactory compliance with the CRA, and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators of lower than “satisfactory”; (b) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (c) to be deemed not to be in material satisfactory compliance with the applicable requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC EBNJ pursuant to 12 C.F.R. Part 000200, Xxxxxxx X, Xxxxxxxx D. Furthermore, the HVBC Board of Directors of EBNJ has adopted and HVBC EBNJ has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC GNBC nor HVB Grange National Bank is a party to any agreement with any individual or group regarding CRA matters and neither HVBC nor HVB has any Knowledge aware of, nor has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31, 2021, filed with the FDIC, or otherwise) that any facts or circumstances exist, exist which would cause HVBC or HVBGrange National Bank: (ai) to be deemed not to be in satisfactory compliance in any material respect with the Community Reinvestment Act of 1977, as amended (the "CRA, ") and the regulations promulgated thereunder, or to be assigned a rating for CRA purposes by Bank Regulators federal or state bank regulators of lower than “"satisfactory”; ," or (bii) to be deemed to be operating in violation in any material violation respect of the federal Bank Secrecy Act, as amended, amended and its implementing regulations (31 C.F.R. Chapter XCFR part 103), the USA PATRIOT Patriot Act of 2001, Public Law 107-56 (the "USA Patriot Act, ") and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s 's Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in satisfactory compliance in any material compliance respect with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, thereunder as well as the provisions of the information security program Information Security Program adopted by HVBC Grange National Bank pursuant to 12 C.F.R. CFR Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of Grange National Bank has adopted adopted, and HVBC Grange National Bank has implemented implemented, an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements in all material respects of Sections Section 352 and 326 and all other applicable provisions of the USA PATRIOT Patriot Act and the regulations thereunder.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Company nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Company is not aware of, nor and none of Company and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBCbecause of Company Bank’s Home Mortgage Disclosure Act data for the fiscal year ended December 31, 20212014, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBCompany Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; or (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulationsLaws, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Company Bank pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board board of directors of Company Bank has adopted and HVBC Company Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Tidelands nor HVB Tidelands Bank is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge ofand, nor has HVBC or HVB been advised in writing to the knowledge of or has any reason to believe (based on HVBC’s Home Mortgage Disclosure Act data for the year ended December 31Tidelands, 2021, filed with the FDIC, or otherwise) that any no facts or circumstances exist, which would cause HVBC or HVBTidelands Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy Act, as amended, Act and its implementing regulations (31 C.F.R. Chapter XPart 103), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the Xxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC Tidelands Bank pursuant to 12 C.F.R. Part 000364, Xxxxxxx X, Xxxxxxxx D. except where the failure to be in such compliance would not reasonably be expected to have a Material Adverse Effect. Furthermore, the HVBC Board board of directors of Tidelands Bank has adopted and HVBC Tidelands Bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority governmental agency and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderAct.

CRA, Anti-money Laundering and Customer Information Security. Neither HVBC Buyer nor HVB any of its Subsidiaries is a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and neither HVBC nor HVB has any Knowledge Buyer is not aware of, nor and none of Buyer and its Subsidiaries has HVBC or HVB been advised in writing of of, or has any reason to believe (based on HVBC’s because the Buyer Banks’ Home Mortgage Disclosure Act data for the year ended December 31, 20212005, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause HVBC or HVBa Buyer Bank: (ai) to be deemed not to be in satisfactory compliance with the CRACommunity Reinvestment Act, and the regulations promulgated thereunder, or to be assigned a rating for CRA Community Reinvestment Act purposes by Bank Regulators federal or state bank regulators of lower than “satisfactory”; (bii) to be deemed to be operating in material violation of the federal Bank Secrecy USA Patriot Act, as amended, and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and the regulations promulgated thereunder, any order issued with respect to anti-money laundering by the U.S. Department of the Treasury’s Office of Foreign Assets Control, or any other applicable anti-money laundering statute, rule or regulation; or (ciii) to be deemed not to be in material satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws and regulations, including, without limitation, in Title V of the XxxxxGramx-Xxxxx-Xxxxxx Act Xxx of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by HVBC the Buyer Banks pursuant to 12 C.F.R. Part 000, Xxxxxxx X, Xxxxxxxx D. 364. Furthermore, the HVBC Board of Directors of each of the Buyer Banks has adopted and HVBC each such bank has implemented an anti-money laundering program that contains adequate and appropriate customer identification verification procedures that has not been deemed ineffective by any Governmental Authority and that meets the requirements of Sections 352 and 326 and all other applicable provisions of the USA PATRIOT Act and the regulations thereunderPatriot Act.