Common use of CREDIT RISK IDENTIFICATION AND LOAN REVIEW Clause in Contracts

CREDIT RISK IDENTIFICATION AND LOAN REVIEW. (1) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve the Bank’s credit risk identification process. The program shall include, but not be limited to: (a) credit risk rating definitions consistent with applicable regulatory guidance, including income accrual status; (b) procedures to ensure accurate and timely risk grades, including loss recognition and identification of nonaccrual loans; (c) procedures for early problem loan identification; (d) establishing loan officer and credit administration accountability for failure to assign accurate and timely risk grades on loans, including recognition of nonaccrual status, under their respective supervision; and (e) implementation of an effective training program for all lending staff. (2) Within sixty (60) days, the Board shall employ an independent external loan review firm and that firm shall complete, at least twice a year, a sufficient review relative to the Bank’s risk profile, of the Bank's loan portfolio(s), particularly loan participations, to assure the timely identification and categorization of problem credits. The external loan review firm shall use a loan grading system consistent with the requirements of 12 C.F.R. § 160.160 (Asset Classification) and the guidelines set forth in the “Rating Credit Risk” booklet of the Comptroller’s Handbook. The findings and recommendations of the external loan review shall be set forth in a written report to the Board. Such reports shall include, at a minimum, conclusions regarding: (a) the overall quality of the loan and lease portfolios; (b) the appropriateness and accuracy of risk grades and accrual decisions; (c) the identification, type, rating, and amount of problem loans and leases; (d) the identification and amount of delinquent loans and leases; (e) credit and collateral documentation exceptions; (f) the identification and status of credit related violations of law, rule or regulation; (g) loans not in conformance with the Bank's lending policies, and exceptions to the Bank’s lending policies; (h) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (g) of this Article; and

CREDIT RISK IDENTIFICATION AND LOAN REVIEW. (1) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve the Bank’s credit risk identification process. The program shall include, but not be limited to: (a) credit risk rating definitions consistent with applicable regulatory guidance, including income accrual status; (b) implementation of an effective training program for all lending staff; (c) procedures for early problem loan identification; (d) procedures to ensure accurate and timely risk grades, including loss recognition and identification of nonaccrual loans;; and (ce) procedures for early problem loan identification; (d) establishing establish loan officer and credit administration accountability for failure to assign accurate and timely risk grades on loans, including recognition of nonaccrual status, loans under their respective supervision; and (e) implementation of an effective training program for all lending staff. (2) Within sixty (60) days, the Board shall employ establish an effective independent external loan review firm and that firm shall complete, at least twice a year, a sufficient system to review relative to the Bank’s risk profile, of the Bank's loan portfolio(s), particularly loan participations, and lease portfolios to assure the timely identification and categorization of problem credits. The external loan system shall provide for a written report to be filed with the Board after each review firm and shall use a loan and lease grading system consistent with the requirements of 12 C.F.R. § 160.160 (Asset Classification) and the guidelines set forth in the “Rating Credit Risk” booklet and “Allowance for Loan and Lease Losses” booklets of the Comptroller’s Handbook. The findings and recommendations of the external loan review shall be set forth in a written report to the Board. Such reports shall include, at a minimum, conclusions regarding: (a) the overall quality of the loan and lease portfolios; (b) the appropriateness and accuracy of risk grades and accrual decisions; (c) the identification, type, rating, and amount of problem loans and leases; (dc) the identification and amount of delinquent loans and leases; (ed) credit and collateral documentation exceptions; (fe) the identification and status of credit related violations of law, rule or regulation; (g) loans not in conformance with the Bank's lending policies, and exceptions to the Bank’s lending policies; (hf) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (g) concentrations of credit; and (h) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (3) The Board shall evaluate the Bank’s external loan review firm to ensure objectives are met, and the scope, quality, and timelines are adequate. (4) The Board shall evaluate loan review report(s) and ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s). (5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the programs developed pursuant to this Article. (6) A written description of the programs required by paragraphs (1) and (2) of this Article; andArticle shall be forwarded to the Assistant Deputy Comptroller upon implementation. (7) The Board shall submit a copy of loan review reports to the Assistant Deputy Comptroller upon receipt.

CREDIT RISK IDENTIFICATION AND LOAN REVIEW. (1) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve the Bank’s credit risk identification process. The program shall include, but not be limited to: (a) credit risk rating definitions consistent with applicable regulatory guidance, including income accrual status; (b) implementation of an effective training program for all lending staff; (c) procedures for early problem loan identification; (d) procedures to ensure accurate and timely risk grades, including loss recognition and identification of nonaccrual loans;; and (ce) procedures for early problem loan identification; (d) establishing establish loan officer and credit administration accountability for failure to assign accurate and timely risk grades on loans, including recognition of nonaccrual status, loans under their respective supervision; and (e) implementation of an effective training program for all lending staff. (2) Within sixty (60) days, the Board shall employ establish an effective independent external loan review firm and that firm shall complete, at least twice a year, a sufficient system to review relative to the Bank’s risk profile, of the Bank's loan portfolio(s), particularly loan participations, and lease portfolios to assure the timely identification and categorization of problem credits. The external loan system shall provide for a written report to be filed with the Board after each review firm and shall use a loan and lease grading system consistent with the requirements of 12 C.F.R. § 160.160 (Asset Classification) and the guidelines set forth in the “Rating Credit Risk” booklet and “Allowance for Loan and Lease Losses” booklets of the Comptroller’s Handbook. The findings and recommendations of the external loan review shall be set forth in a written report to the Board. Such reports shall include, at a minimum, conclusions regarding: (a) the overall quality of the loan and lease portfolios; (b) the appropriateness and accuracy of risk grades and accrual decisions; (c) the identification, type, rating, and amount of problem loans and leases; (dc) the identification and amount of delinquent loans and leases; (ed) credit and collateral documentation exceptions; (fe) the identification and status of credit related violations of law, rule or regulation; (g) loans not in conformance with the Bank's lending policies, and exceptions to the Bank’s lending policies; (hf) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (g) concentrations of credit; and (h) loans and leases not in conformance with the Bank’s lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (3) The Board shall evaluate the Bank’s external loan review firm to ensure objectives are met, and the scope, quality, and timelines are adequate. (4) The Board shall evaluate loan review report(s) and ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s). (5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the programs developed pursuant to this Article. (6) A written description of the programs required by paragraphs (1) and (2) of this Article; andArticle shall be forwarded to the Assistant Deputy Comptroller upon implementation. (7) The Board shall submit a copy of loan review reports to the Assistant Deputy Comptroller upon receipt.

CREDIT RISK IDENTIFICATION AND LOAN REVIEW. (1) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve the Bank’s credit risk identification process. The program shall include, but not be limited to: (a) credit risk rating definitions consistent with applicable regulatory guidance, including income accrual status; (b) implementation of an effective training program for all lending staff; (c) procedures for early problem loan identification; (d) procedures to ensure accurate and timely risk grades, including loss recognition and identification of nonaccrual loans;; and (ce) procedures for early problem loan identification; (d) establishing to ensure loan officer and credit administration accountability for failure to assign accurate and timely risk grades on loans, including recognition of nonaccrual status, under their respective supervision; and (e) implementation of an effective training program for all lending staff. (2) Within sixty ninety (6090) days, the Board shall employ establish an effective independent external loan review firm and that firm shall complete, at least twice a year, a sufficient system to review relative to the Bank’s risk profile, of the Bank's loan portfolio(s), particularly loan participations, and lease portfolios to assure the timely identification and categorization classification of problem creditscredits in accordance with 12 C.F.R. § 160.160. The external loan system shall provide for a written report to be filed with the Board after each review firm and shall use a loan and lease grading system consistent with the requirements of 12 C.F.R. § 160.160 (Asset Classification) and the guidelines set forth in the “Rating Credit RiskAsset Quality” booklet section of the Comptroller’s OTS Examination Handbook. The findings and recommendations of the external loan review shall be set forth in a written report to the Board. Such reports shall include, at a minimum, conclusions regarding: (a) the overall quality of the loan and lease portfolios; (b) the appropriateness and accuracy of risk grades and accrual decisions; (c) the identification, type, rating, and amount of problem loans and leases; (dc) the identification and amount of delinquent loans and leases; (ed) credit and collateral documentation exceptions; (fe) the identification and status of credit related violations of law, rule or regulation; (g) loans not in conformance with the Bank's lending policies, and exceptions to the Bank’s lending policies; (hf) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (g) concentrations of credit; and (h) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (3) The Board shall evaluate the Bank’s external loan review firm to ensure objectives are met, and the scope, quality, and timelines are adequate. (4) The Board shall evaluate loan review report(s) and ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s). (5) A written description of the programs required by paragraphs (1) and (2) of this Article; andArticle shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) The Board shall submit a copy of loan review reports to the Assistant Deputy Comptroller upon receipt.