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

CRA, Anti-money Laundering and Customer Information Security. Optima is not a party to any agreement with any individual or group regarding CRA matters and Optima has no Knowledge of, nor has Optima been advised of, or has any reason to believe (based on Optima’s Home Mortgage Disclosure Act data for the year ended December 31, 2017, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause Optima: (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 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 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 Gxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by Optima pursuant to 12 C.F.R. Part 364, Appendix B. Furthermore, the Board of Directors of Optima has adopted and 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. Optima Neither Company nor any of its Subsidiaries is not a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and Optima has no Knowledge of, neither Company nor has Optima been advised of, any of its Subsidiaries is aware of or has any reason to believe Knowledge (based on Optimabecause of Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20172013, filed with the FDIC, or otherwise) ), that any facts or circumstances exist, which would cause OptimaCompany 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 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 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 GxxxxXxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by Optima Company Bank pursuant to 12 C.F.R. Part 364, Appendix B. . Furthermore, the Board board of Directors directors of Optima Company Bank has adopted and Optima 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. Optima Neither Company nor any of its Subsidiaries is not a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and Optima has no Knowledge of, neither Company nor has Optima been advised of, any of its Subsidiaries is aware of or has any reason to believe Knowledge (based on Optimabecause of Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20172013, filed with the FDIC, or otherwise) ), that any facts or circumstances exist, which would cause OptimaCompany or 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 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 satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws Laws and regulations, including, without limitation, in Title V of the GxxxxXxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by Optima Company Bank pursuant to 12 C.F.R. Part 364, Appendix B. . Furthermore, the Board board of Directors directors of Optima Company Bank has adopted and Optima 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. Optima Neither Company nor any of its Subsidiaries is not a party to any agreement with any individual or group regarding CRA Community Reinvestment Act matters and Optima has no Knowledge of, neither Company nor has Optima been advised of, any of its Subsidiaries is aware of or has any reason to believe Knowledge (based on Optimabecause of Company Bank’s Home Mortgage Disclosure Act data for the year ended December 31, 20172014, filed with the FDIC, or otherwise) ), that any facts or circumstances exist, which would cause OptimaCompany or 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 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 satisfactory compliance with the applicable privacy of customer information requirements contained in any federal and state privacy or data security laws Laws and regulations, including, without limitation, in Title V of the GxxxxXxxxx-Xxxxx-Xxxxxx Act of 1999 and regulations promulgated thereunder, as well as the provisions of the information security program adopted by Optima Company Bank pursuant to 12 C.F.R. Part 364, Appendix B. . Furthermore, the Board board of Directors directors of Optima Company Bank has adopted and Optima 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. Optima Northmark is not a party to any agreement with any individual or group regarding CRA matters and Optima Northmark has no Knowledge of, nor has Optima Northmark been advised of, or has any reason to believe (based on OptimaNorthmark’s Home Mortgage Disclosure Act data for the year ended December 31, 20172021, filed with the FDIC, or otherwise) that any facts or circumstances exist, which would cause OptimaNorthmark: (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 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 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 GxxxxXxxxx-Xxxxx-Xxxxxx Act of 1999 and the regulations promulgated thereunder, as well as the provisions of the information security program adopted by Optima Northmark pursuant to 12 C.F.R. Part 364, Appendix B. Furthermore, the Northmark Board of Directors of Optima has adopted and Optima Northmark 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 promulgated thereunder.