Common use of Credit Risk Management Clause in Contracts

Credit Risk Management. (1) Within ninety (90) days, the Board shall develop implement, and thereafter ensure Bank adherence to a written credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination (“XXX”). The program shall include but not be limited to: (a) a revision and/or development of the Bank’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification to include non-accrual loans; (b) ensure the bank’s credit policy aligns risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual status; (c) a revision and/or development of the Bank’s procedures to ensure current financial data is obtained on borrowers and guarantors; (d) ensure management performs and documents comprehensive analyses to support decisions on the accrual treatment of troubled borrowers, including troubled debt restructurings; (e) a revision and/or development of the Bank’s procedures to ensure quality financial analysis and documentation for new and renewed credits; (f) a revision and/or development of the Bank’s procedures to ensure ongoing guarantor analysis, to include a review of the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilities; (g) a system to track and analyze exceptions; (h) a revision and/or development of the Bank’s procedures to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; and (i) At least quarterly, the Board shall prepare a written assessment of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment to the Assistant Deputy Comptroller. (2) Prior to adoption by the Board, a copy of the credit risk management program shall be submitted to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt and the Bank shall immediately implement and adhere to the credit risk management program.

Credit Risk Management. (1) Within ninety The Board of the Bank shall continue to maintain a Credit Policy Committee that is comprised of at least five (905) daysexecutive officers from key functional areas (e.g. marketing, the Board operations, compliance, legal, etc), which shall develop implement, and thereafter ensure be responsible for ensuring Bank adherence to a written the Bank's credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination policy (“XXX”"Credit Policy Committee"). The program shall include but not be limited to:. (a) a revision and/or development of the Bank’s procedures to ensure accuracy of risk ratings The Credit Policy Committee shall meet at least monthly and proper review and timely problem loan identification to include non-accrual loansapprove: (i) new account acquisition solicitations and marketing campaigns; (ii) account management strategies; (iii) collection strategies; and (iv) key credit portfolio indicators and performance results. (b) ensure The Credit Policy Committee shall maintain complete written minutes of each meeting, and present a monthly report of its actions to the bank’s credit policy aligns risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual status; (c) a revision and/or development Board of the Bank’s procedures to ensure current financial data is obtained on borrowers Bank for the Board's review and guarantors; (d) ensure management performs and documents comprehensive analyses to support decisions on the accrual treatment of troubled borrowers, including troubled debt restructurings; (e) a revision and/or development of the Bank’s procedures to ensure quality financial analysis and documentation for new and renewed credits; (f) a revision and/or development of the Bank’s procedures to ensure ongoing guarantor analysis, to include a review of the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilities; (g) a system to track and analyze exceptions; (h) a revision and/or development of the Bank’s procedures to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; and (i) At least quarterly, the Board shall prepare a written assessment of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment to the Assistant Deputy Comptrollerapproval at its next regularly scheduled meeting. (2) Prior to adoption by the Board, a copy The Board of the Bank shall ensure credit risk management program maintains a disciplined test and control environment in adherence to the Board-approved Test and Control Policies. (3) The Board of the Bank shall be ensure credit risk management personnel, policies, processes and control functions are adequate for the Bank's size, complexity, and risk profile, in accordance with a written action plan adopted by the Board of the Bank and submitted to the Assistant Deputy Comptroller for a prior written determination of no supervisory objectionreview. Upon receiving a written determination of no supervisory objection from the Assistant Deputy ComptrollerOn at least an annual basis, as appropriate, management shall review with the Board shall adopt of the Bank the goals and objectives of the written action plan, and the Bank shall immediately implement and adhere make changes, as warranted, to address any deficiencies noted during this review. The Bank shall provide a copy of any such changes to the Comptroller for determination of supervisory non-objection. (4) The Board of the Bank shall ensure that risks identified in the evaluation of issues that impact borrowers' ability to make progress on reducing debt and possible causes for negative amortization are resolved in accordance with a written action plan adopted by the Board of the Bank and submitted to the Comptroller for review. On at least an annual basis, as appropriate, management shall review with the Board of the Bank the goals and objectives of the written action plan, and the Bank shall make changes, as warranted, to address any deficiencies noted during this review. The Bank shall provide a copy of any such changes to the Comptroller for determination of supervisory non-objection. (5) The Board of the Bank shall ensure credit risk lines are managed appropriately and in conformance with the Federal Financial Institutions Examination Council's Interagency Account Management and Loss Allowance Guidance, OCC Bulletin 2003-1, dated January 8, 2003, using proven credit criteria and a sound process that includes testing, analysis, and controls, in accordance with a written action plan adopted by the Board of the Bank and to which the Comptroller has provided a determination of supervisory non-objection. On at least an annual basis, as appropriate, management programshall review with the Board of the Bank the goals and objectives of the written action plan, and the Bank shall make changes, as warranted, to address any deficiencies noted during this review. The Bank shall provide a copy of any such changes to the Comptroller for determination of supervisory non-objection. (6) The Board of the Bank shall ensure debt management/workout and reage programs are properly managed, analyzed, and controlled, in accordance with a written action plan adopted by the Board of the Bank and to which the Comptroller has provided a determination of supervisory non-objection. On at least an annual basis, as appropriate, management shall review with the Board of the Bank the goals and objectives of the written action plan, and the Bank shall make changes, as warranted, to address any deficiencies noted during the review. The Bank shall provide a copy of any such changes to the Comptroller for determination of supervisory non-objection. (7) The Board of the Bank shall ensure that the Bank's Allowance for Loan and Lease Losses ("ALLL") is adequate at all times for on-balance sheet assets, in accordance with the ALLL methodology and policy as adopted by the Board of the Bank and which the Comptroller has provided a determination of supervisory non-objection.

Credit Risk Management. (1) Within ninety (90) daysEffective as of the date of this Agreement, the Board shall develop ensure that all lending officers comply with all laws, rules, regulations, Bank policies and procedures, safe and sound banking practices, and fiduciary duties. (2) Within thirty (30) days of the date of this Agreement, the Board shall develop, implement, and thereafter ensure Bank bank adherence to a written program to reduce the high level of credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination (“XXX”)Bank. The program shall include include, but not be limited to: (a) a revision and/or development of the Bank’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification to include non-accrual loansstrengthen credit underwriting, particularly in the CRE portfolio; (b) ensure the bank’s credit policy aligns risk ratingprocedures to strengthen management of loan workout operations and to maintain adequate, accrual and non-accrual status definitions with regulatory definitions and ensures that qualified staff in all appropriate personnel are trained on risk ratings and accrual/non-accrual statuslending areas; (c) a revision and/or development procedures for strengthening collections; and (3) Within sixty (60) days of the Bank’s procedures date of this Agreement, the Bank shall revise its loan policy to ensure current financial data is obtained on borrowers and guarantorsrequire, at a minimum, that the Bank may not grant, extend, renew, alter or restructure any loan or other extension of credit above $100,000 without: (a) documenting the specific reason or purpose for the extension of credit; (b) identifying the expected source of repayment in writing; (c) structuring the repayment terms to coincide with the expected source of repayment; (d) ensure management performs obtaining current and documents comprehensive analyses to support decisions on the accrual treatment of troubled borrowerssatisfactory borrower financial information, including troubled analysis and documentation of global cash flow and global debt restructuringsservice ability; (e) a revision and/or development of determining and documenting whether the loan complies with the Bank’s procedures Loan Policy and if it does not comply, providing identification of the exception and ample justification to ensure quality financial analysis and documentation for new and renewed creditssupport waiving the policy exception; (f) a revision and/or development of making and documenting the Bankdeterminations made regarding the customer’s procedures ability to ensure ongoing guarantor analysis, to include a review of repay the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilitiescredit on the proposed repayment terms; (g) a system analyzing loan to track and analyze exceptionsvalue ratios based on collateral type; (h) a revision and/or development independent appraisal ordering and review procedures that ensure assumptions and valuations are properly supported and documented to include expanded documentation of appraisal deficiencies and mitigating factors. (i) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank’s procedures lien on it where applicable; (j) ensuring that, when required, credit approval presentations contain all appropriate information required to ensure MIS is developed allow the Bank to track completion of annual reviews and financial statement exceptionsmake an informed decision; and (ik) At least quarterly, ensuring that all participations purchased meet the Board shall prepare a written assessment requirements of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment to the Assistant Deputy Comptrollerprudent lending policies and Banking Circular 181. (24) Prior to adoption by the Board, a copy Within sixty (60) days of the credit risk management program shall be submitted to the Assistant Deputy Comptroller for a prior written determination date of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptrollerthis agreement, the Board shall adopt and the Bank shall immediately implement revise its loan policy to strengthen on-going monitoring and adhere documenting the status of its borrowers. These revisions shall include, at a minimum procedures designed to require: (a) the credit risk management programmaintenance of up to date borrower financial information, to include at a minimum timely analysis of tax returns, financial statements, global cash flow, contingent liabilities, and other indicators of possible problems; (b) periodic transaction level stress testing throughout the duration of the credit.

Credit Risk Management. (1) Within ninety (90) days, the Board shall develop implement, and thereafter ensure Bank adherence to a written an effective credit risk management program to improve that covers the bank’s loan and leasing portfolios. This program shall be designed in light of the comments for expectations of bank credit risk management processes rating systems, risk rating process controls, and address credit deficiencies noted risk evaluation process found in the Report “Rating Credit Risk” booklet of Examination (“XXX”)the Comptroller’s Handbook. The program shall include include, but not be limited to: (a) a revision and/or development establishment of prudent concentration risk limits that reflect the BankBoard’s procedures to ensure accuracy of risk ratings tolerance and proper and timely problem loan identification to include non-accrual loansassess whether concentrations are reasonable or excessive; (b) procedures to strengthen the risk rating process and ensure the bank’s credit policy aligns accuracy & timeliness of ratings that address: (i) ratings changes when risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel changes; and (ii) split ratings are trained on risk ratings and accrual/non-accrual status;effectively used. (c) establishment of a revision and/or development risk rating review process, conducted at least quarterly and prior to the filing of the Bank’s procedures Call Report, to ensure current financial data is obtained on borrowers and guarantorsthe accuracy of ratings; (d) ensure management performs review of and documents comprehensive analyses amendment to support decisions on the accrual treatment credit policies to outline: (i) when re-appraisals are needed; and (ii) clear criteria for re-appraisals of troubled borrowers, including troubled debt restructurings;impaired loans identified under FAS 114. (e) a revision and/or development procedures to strengthen management of the Bank’s procedures to ensure quality loan portfolio including: (i) periodic monitoring and interim financial analysis and documentation for new and renewed of credits; (ii) documentation of periodic monitoring and interim financial analysis of credits; (iii) establishment of monitoring procedures specific to watch rated credits and the inherent risk of those credits; (iv) establishment of a process for updating financial information; and (v) appropriate distribution of loan officer workload to ensure adequate monitoring of classified loans. (f) a revision and/or development of the Bank’s procedures to ensure ongoing guarantor analysis, to include a review the strengthening of the borrower’s or guarantor’s financial analysis on both existing and new customers subject to annual reviews including: (i) preparing global cash flow analysis of borrowers and analysis of guarantors as well as assessing their contingent liabilities;. (g2) Upon completion, a system copy of the program shall be forwarded to track and analyze exceptions;the Assistant Deputy Comptroller. (h) a revision and/or development of the Bank’s procedures to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; and (i3) At least quarterly, the Board shall prepare a written assessment of the Bankbank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment to the Assistant Deputy Comptroller. (2) Prior . The Board shall ensure that the Bank has processes, personnel, and control systems to adoption by the Board, a copy ensure implementation of the credit risk management program shall be submitted and adherence to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt and the Bank shall immediately implement and adhere program developed pursuant to the credit risk management programthis Article.

Credit Risk Management. (1) Within ninety sixty (9060) daysdays of the date of this Agreement, the Board shall develop implementsubmit to the ADC for review and prior written determination of no supervisory objection a credit underwriting and administration program (the “Credit Risk Management Program”) designed to ensure the Bank obtains and analyzes credit and collateral information sufficient to identify, monitor, and thereafter ensure Bank adherence to report the Bank’s credit risk, properly account for loans, and assign accurate risk ratings in a written credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination (“XXX”)timely manner. The program Credit Risk Management Program shall include but not be limited toconsistent with safe and sound banking practices and at a minimum shall include: (a) a revision and/or development of the Bank’s procedures to ensure accuracy of risk ratings policies that address acceptable loan types, terms, covenants, concentration limits, and proper collateral requirements and timely problem loan identification to include non-accrual loansexceptions; (b) ensure a description of the bank’s types of credit policy aligns risk ratinginformation required from borrowers and guarantors prior to making a loan determination, accrual including, annual audited statements, interim financial statements, personal financial statements, and non-accrual status definitions tax returns with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual statussupporting schedule; (c) a revision and/or development procedures that require any extensions of credit are granted, by renewal or otherwise, only after obtaining the required credit information and adequately analyzing and documenting the borrower’s and guarantor’s cash flow, debt service requirements, contingent liabilities, global liquidity condition, and sensitivity analysis in support of the Bank’s procedures to ensure current financial data is obtained on borrowers and guarantorscredit decision; (d) procedures to identify and track all exceptions and efforts to mitigate or cure exceptions, including but not limited to financial exceptions, collateral exceptions, policy exceptions, and underwriting exceptions; (e) policies regarding the appropriateness of the capitalization of interest, which shall be prohibited unless doing so is conducted in a safe and sound manner. Refer to OCC Examining Circular 229 – Guidelines for Capitalization of Interest on Loans, and OCC Bank Accounting Advisory Series for related safe and sound principles; (f) procedures for the identification of, and accounting treatment for, nonaccrual loans that are consistent with the accounting requirements contained in the appropriate FFIEC’s Instructions for Preparation of Consolidated Reports of Condition and Income; (g) specific assignment of responsibility and accountability over the credit administration process to ensure management performs the Credit Underwriting and documents comprehensive analyses Administration Program developed pursuant to this Article is effectively implemented; (h) the Bank must review the experience level of lending staff, on an annual basis, to ensure employees have the requisite knowledge to perform their duties, and must implement a plan to hire additional staff and/or provide periodic training where staffing or knowledge gaps exist; (i) risk-based reviews of commercial lending relationships to support decisions or revise current risk ratings on at least an annual basis; (j) an independent loan review process reporting directly to the Board; and (k) generate reports that aggregate loans, both commercial and retail, that exceed the supervisory loan-to-value limits (“SLTV”) in 12 C.F.R 34, Subpart D, Appendix A. (2) Effective as of the date of this Agreement, the Bank may not grant, extend, renew, alter or restructure any loan or other extension of credit without: (a) documenting the specific reason or purpose for the extension of credit; (b) identifying the expected source of repayment in writing; (c) structuring the repayment terms to coincide with the expected source of repayment; (d) obtaining current and satisfactory credit information, including performing and documenting analysis of credit information, a detailed cash flow analysis of all expected repayment sources, and verification of liquid assets that the Bank is relying on as a source of repayment; (e) determining and documenting whether the loan complies with the Bank's loan policy and if it does not comply, providing identification of the exception and ample justification to support waiving the policy exception; (f) determining and documenting the customer’s ability to repay the credit on the accrual treatment of troubled borrowersproposed repayment terms, including troubled an evaluation of both primary and secondary sources of repayment, as well as global cash flow analysis that considers all customer debt restructuringsservice requirements; (g) providing an accurate risk assessment grade and proper accrual status for each credit; (h) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank's lien on it where applicable; (i) ongoing requirements for obtaining and analyzing financial statements and periodic collateral inspections as appropriate; and (j) obtaining the written approval of the Bank's loan committee or Board for any extension of credit greater than $500,000. (3) Within sixty (60) days of the date of this Agreement, the Board shall adopt an appropriate written exception tracking and monitoring system that establishes that financial, collateral, underwriting, documentation, credit administration, and policy exceptions are tracked and reported to the Board in a timely manner (“Exception Tracking Program”). Refer to the “Loan Portfolio Management” booklet of the Comptroller’s Handbook for guidance. The Exception Tracking Program, at a minimum, shall include: (a) Board-established limits for financial, collateral, and policy exceptions. All exceptions must be vetted, and mitigating factors sufficiently supported; (b) a requirement that the Bank maintains, on an ongoing basis, a detailed listing of all loans not in conformance with the Bank’s lending policies, with a notation as to whether the exceptions were properly granted in accordance with the Bank’s loan policy; (c) identification of the loan officer who originated each loan or other extension of credit reported in accordance with subparagraphs (3)(a) and (3)(b) of this Article; (d) consideration of each loan officer’s exceptions in conducting periodic performance reviews and compensation decisions; (e) a revision and/or development requirement for quarterly reports to the Board that, at a minimum, include: (i) the current listings described in subparagraph (3)(b) of this Article; (ii) the Bank’s procedures aggregate dollar amount of all loans with outstanding exceptions compared as a percentage to ensure quality the dollar amount of total loans; (iii) the aggregate dollar amount of all loans with outstanding exceptions compared to board approved limits; (iv) the number of credit documentation exceptions by type such as borrower financial analysis and documentation for new and renewed creditsstatements, guarantor tax returns, or rent rolls; and (v) identify actionable items if/when exception levels exceed board- approved limits; (f) a revision and/or development reporting structure for measuring exceptions against the Board-approved limits, quarterly Board monitoring of exception reports, and accountability by lending staff for such exceptions. (4) Upon adoption of the Bank’s procedures Exception Tracking Program, Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure ongoing guarantor analysis, adherence to include a review of the borrower’s or guarantor’s global cash flow analysis Exception Tracking Program and analysis of contingent liabilities; (g) a system to track and analyze exceptions; (h) a revision and/or development of the Bank’s procedures to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; and (i) At least quarterly, the Board shall prepare a written assessment of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned programany amendments thereto. The Board shall submit a copy review the effectiveness of this assessment to the Assistant Deputy Comptroller. (2) Prior to adoption Exception Tracking Program at least annually, and more frequently if necessary or if required by the BoardOCC in writing, and amend the Exception Tracking Program as needed or directed by the OCC. The Board shall forward a copy of the credit risk management program shall be submitted adopted Exception Tracking Program, and any subsequent amendments thereto, to the Assistant Deputy Comptroller for a prior written determination ADC within thirty (30) days of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt and the Bank shall immediately implement and adhere to the credit risk management programadoption.

Credit Risk Management. (1) Within ninety one hundred-twenty (90120) days, the Board shall develop develop, implement, and thereafter ensure Bank adherence to a written program to reduce the high level of credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination (“XXX”)Bank. The program shall include but not be limited toinclude: (a) a revision and/or development of revising the Bank’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification lending policy to include non-accrual loansprudent underwriting standards and risk limits for each type of lending in which the Bank engages or intends to engage, including working capital loans in the Bank’s Turkish loan portfolio. Underwriting standards shall specify: (i) permissible structure and terms, including tenor of maturities; principal and interest payment requirements, collateral and collateral documentation requirements; financial statement requirements, guarantor requirements; and required convenants, (ii) the requirement to identify loan purpose, (iii) the requirement to identify the primary and secondary sources of repayment; (b) ensure developing and implementing a formal approval procedure for the bank’s credit granting of any loan not in conformance with the policy aligns risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual status;revisions required in (a). (c) developing and implementing a revision and/or development of policy exception tracking system, including appropriate management reports, which enables the Bank’s Board and management to determine the extent to which the Bank has extended credit not in conformance with the policy revisions or exception approval procedures to ensure current financial data is obtained on borrowers required in (a) and guarantors(b), respectively; (d) ensure identifying actions the Board will require management performs and documents comprehensive analyses to support decisions on the accrual treatment of troubled borrowers, including troubled debt restructuringsimplement to address exceptions to policy; (e) a revision and/or development strengthening management of the Bank’s procedures financial credit analysis function to ensure quality that each borrower's financial analysis condition is thoroughly reviewed and documentation for new analyzed before credit is extended and renewed creditsthat updated borrower financial information is reviewed and analyzed upon receipt; (f) a revision and/or development of ensuring the Bank’s procedures to ensure ongoing guarantor analysis, to include a review 's internal risk rating process complies with regulatory guidelines for proper and timely risk rating of the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilitiesall credit facilities; (g) a system to track ensuring future loan growth is well planned, controlled, supported by sufficient capital and analyze exceptionsconsistent with the Bank's strategic plan; (h) a revision and/or development establishing procedures to track and analyze concentrations of credit (as defined in the Loan Portfolio Management booklet, A-LPM of the Bank’s procedures to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; Comptroller's and (i) At least quarterlydeveloping actions plan, approved by the Board shall prepare Board, to reduce the risk of any concentration deemed imprudent as a written assessment result of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment to the Assistant Deputy Comptrolleranalysis required in (h). (2) Prior to adoption by the BoardUpon completion, a copy of the credit risk management program shall be submitted forwarded to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the review. (3) The Board shall adopt and ensure that the Bank shall immediately implement has processes, personnel, and adhere control systems to ensure implementation of and adherence to the credit risk management programprogram developed pursuant to this Article.

Credit Risk Management. (1) Within ninety thirty (9030) days, the Board shall develop implementtake necessary steps to ensure the Bank’s credit risk management systems are sufficient to ensure the Bank’s loan portfolio is managed in a safe and sound manner. (2) The Board shall revise, adopt, implement and thereafter ensure Bank adherence to a written credit program of policies and procedures designed to manage the risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination Bank’s commercial real estate (“XXXCRE”). The program shall ) loan portfolio, to include but not be limited toat a minimum: (a) a revision and/or development Procedures to strengthen credit underwriting in the CRE portfolio, including expanded loan presentations and analysis providing for: (i) More detailed project plans; (ii) Timeframes for project completion; (iii) More detailed market analysis; (iv) Stress testing of significant property and lending assumptions; and (v) More detailed analysis of the Bank’s procedures to ensure accuracy financial support of risk ratings and proper and timely problem loan identification to include non-accrual loanssignificant guarantors; (b) ensure the bank’s credit policy aligns risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual statusThe establishment of more diversified CRE concentration limits; (c) a revision and/or development of the Bank’s procedures Strategies and procedures, including appropriate CRE loan growth restrictions, to ensure current financial data is obtained on borrowers and guarantorsthat CRE concentrations conform with established limits; (d) ensure management performs Monthly monitoring of concentration reports that stratify the CRE portfolio by product type, locality and documents comprehensive analyses to support decisions on the accrual treatment of troubled borrowers, including troubled debt restructuringsother meaningful measures; (e) At a revision and/or development minimum, quarterly reports to senior management and the loan committee of the Bank’s procedures to ensure quality financial analysis and documentation for new and renewed creditsproject status, including: (i) Development status; (fii) a revision and/or Comparison of sales activity and development of the Bank’s procedures costs to ensure ongoing guarantor analysis, to include a review of the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilitiesbudget; (giii) a system to track Current market conditions and analyze exceptionsactivity; (hiv) a revision and/or development Level of the Bank’s procedures interest reserve and comparison to ensure MIS is developed to track completion of annual reviews and financial statement exceptionsbudget; and (iv) Any other significant comments on development. (3) Within sixty (60) days, the Board shall revise, adopt, implement and thereafter ensure Bank adherence to a written program of policies and procedures designed to aggregate and track exceptions to policy and underwriting guidelines for CRE, to include at a minimum, monthly Board monitoring of policy exception reports that track aggregate number and dollar amount of loans of material underwriting exceptions by type of loan, to include exceptions to the appraisal requirements described in Paragraph (4) below. (4) Within sixty (60) days, the Board shall revise, adopt, implement and thereafter ensure Bank adherence to a written program of policies and procedures designed to ensure the Bank obtains appraisals in compliance with the Uniform Standards of Professional Appraisal Practice, 12 C.F.R. Part 34, OCC Advisory Letter 2003-9, and OCC Bulletin 2005-6, to include at a minimum: (a) The required use of a standard appraisal form for ordering all appraisals; (b) The ordering of appraisals, independent of the lending function; (c) The use of Board approved appraisers only, except for specialized or out- of-area transactions, in which case the appraisal will be conducted by an MAI designated member; (d) The establishment of a policy requiring a meaningful, independent review of all appraisals to include analysis commensurate with the type, size and complexity of the property being appraised; and (e) The establishment of a consolidated tickler system for tracking appraisals ordered, received, returned, and reviewed. (5) The Board shall submit a copy of the revised policies and procedures required by this Article to the Assistant Deputy Comptroller. (6) At least quarterly, the Board shall prepare a written assessment of the Bank’s credit risk, which shall evaluate the Bank’s progress under in reaching compliance with the aforementioned programpolicies and procedures required by this Article. The Board shall submit a copy of this assessment to the Assistant Deputy Comptroller. (27) Prior The Board shall ensure that the Bank has processes, personnel, and control systems to adoption by the Board, a copy ensure implementation of the credit risk management program shall be submitted and adherence to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt policies and the Bank shall immediately implement and adhere procedures developed pursuant to the credit risk management programthis Article.

Credit Risk Management. (1) Within ninety sixty (9060) days, the Board shall develop develop, implement, and thereafter ensure Bank adherence to a written program designed to reduce the high level of credit risk management program to improve credit risk management processes and address credit deficiencies noted in the Report of Examination (“XXX”)Bank. The program shall include include, but not be limited to: (a) a revision and/or development of the Bank’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification to include non-accrual loansstrengthen credit underwriting; (b) ensure the bank’s credit policy aligns risk ratingprocedures to strengthen management of loan operations and to maintain an adequate, accrual and non-accrual status definitions with regulatory definitions and ensures that qualified staff in all appropriate personnel are trained on risk ratings and accrual/non-accrual statuslending areas; (c) a revision and/or development of the Bank’s procedures to ensure current financial data is obtained on borrowers and guarantorsfor strengthening collections; (d) ensure management performs a strengthened system that effectively tracks and documents comprehensive analyses analyzes exceptions to support decisions on the accrual treatment of troubled borrowers, including troubled debt restructuringsBank’s lending and leasing policies; (e) a revision and/or development of the Bank’s procedures to ensure quality financial analysis that, after extensions of credit are approved, the Bank will thereafter continue to timely secure and documentation for new analyze current and renewed creditssatisfactory credit information on its borrowers so as to be able to determine and appropriately respond to the borrowers’ respective on-going repayment capacities; (f) a revision and/or development of the Bank’s procedures an action plan to ensure ongoing guarantor analysis, to include a review of that the borrower’s or guarantor’s global cash flow analysis Bank will grow its loan portfolio only after ensuring that appropriate risk management policies and analysis of contingent liabilities;procedures are in place. (g) procedures to ensure you periodically stress test rental property for vacancy rates, shock for a system rise in interest rates and monitor on a more frequent basis to track and analyze exceptions;include obtaining quarterly rent rolls; and (h) improved procedures that detail when collateral valuations should be updated based on changing market conditions or deterioration in a revision and/or development borrower’s financial condition. (2) The Board shall submit a copy of the Bank’s procedures program to ensure MIS is developed to track completion of annual reviews and financial statement exceptions; andthe Assistant Deputy Comptroller. (i3) At least quarterly, the Board shall prepare a written assessment of the Bank’s progress in reducing its credit risk, which shall evaluate the Bank’s progress risk under the aforementioned program. To the extent that this assessment identifies deficiencies in the Bank’s program for reducing its credit risk, the Board shall also prepare a written analysis of the revisions to the program that will be needed in order to correct those deficiencies. The Board shall submit a copy of this assessment assessment, as well as any proposed revisions, to the Assistant Deputy Comptroller. (24) Prior The Board shall ensure that the Bank has processes, personnel, and control systems to adoption by the Board, a copy ensure implementation of the credit risk management program shall be submitted and adherence to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt and the Bank shall immediately implement and adhere program developed pursuant to the credit risk management programthis Article.

Credit Risk Management. (1) Within ninety (90) daysBy March 31, 2020, the Board shall develop implementsubmit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection, and thereafter ensure Bank adherence to a written credit risk management program to improve the Bank’s credit risk management processes management. The program shall include, at a minimum, provisions for the following: (a) ensuring that the Chief Credit Officer has the knowledge, skills, ability and address credit authority necessary to ensure appropriate oversight of the Bank’s loan portfolio; (b) requiring the Chief Credit Officer to develop a plan to improve and formalize oversight of the loan portfolio. This plan must include the following: (i) an evaluation of the number and expertise of current staff and whether additional staff is necessary to achieve compliance with this Agreement; (ii) an assessment of the actions needed to reach and maintain compliance with this Agreement; (iii) documentation on how the Chief Credit Officer will remediate the deficiencies noted detailed in the Bank’s most recent Report of Examination (“XXX”). The program shall include but not be limited to:; (aiv) a revision and/or development of documentation on changes required in the Bank’s procedures review processes and management information systems necessary to ensure accuracy of risk ratings and proper and timely problem improve the Bank’s loan identification to include non-accrual loans;portfolio management; and (bv) ensure a requirement for the bank’s credit policy aligns risk rating, accrual and non-accrual status definitions with regulatory definitions and ensures that all appropriate personnel are trained on risk ratings and accrual/non-accrual statusBoard to approve the plan developed by the Chief Credit Officer; (c) a revision and/or development of the Bank’s procedures to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and analyzing current financial data is obtained on borrowers and guarantorssatisfactory credit information; (d) procedures to ensure management performs pre- and documents post-funding analysis is comprehensive analyses and includes a complete analysis of the borrower’s background, primary source of repayment, guarantor support, and collateral value, including: (i) analysis that focuses on key financial indicators (i.e., cash flow/repayment capacity, income statement trends/ratios, balance sheet analysis), in addition to support other appropriate considerations for credit approval decisions on the accrual treatment and determining risk classification for loans; and (ii) analysis, assessment, and verification of troubled borrowers, including troubled debt restructuringscontingent liabilities and liquid assets when consideration of such is relevant to loan approval decisions; (e) a revision and/or development of the Bank’s procedures to ensure quality financial satisfactory and perfected collateral documentation including analysis of collateral inspections for construction and documentation for new and renewed creditscommercial loans; (f) a revision and/or development of the Bank’s procedures to ensure ongoing guarantor analysis, to include a review of the borrower’s or guarantor’s global cash flow analysis and analysis of contingent liabilitiesconformance with loan approval requirements; (g) a system to track track, aggregate, and analyze exceptionsexceptions by loan officer; (h) a revision and/or development of the Bank’s performance appraisal process, including performance appraisals, job descriptions, and incentive programs for loan officers, which adequately considers their performance relative to policy compliance, documentation standards, accuracy in credit grading, other loan administration matters; (i) procedures to ensure MIS is developed identify and track supervisory loan-to-value exceptions; (j) procedures to track completion and reduce the volume of annual reviews and financial statement exceptions; and (ik) At least quarterly, the Board shall prepare a written assessment of the Bank’s credit risk, which shall evaluate the Bank’s progress under the aforementioned program. The Board shall submit a copy of this assessment procedures to the Assistant Deputy Comptrollerensure proper accounting treatment for other real estate owned (“OREO”). (2) Prior to adoption by the Board, a copy Following receipt of the credit risk management program shall be submitted to the Assistant Deputy Comptroller for a prior Comptroller’s written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall adopt and the Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere ensure adherence to the written credit risk management programprogram and any amendments or revisions thereto.