Common use of Credit Risk Management Clause in Contracts

Credit Risk Management. (1) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve credit risk management at the Bank. The program shall include, but not be limited to: (a) procedures to ensure accuracy of risk ratings and proper and timely problem loan identification; (b) procedures governing the supervision and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral values; (c) procedures to ensure an independent appraisal review process is in place; (d) procedures to ensure risk ratings are appropriately reflected on internal MIS; (e) procedures to ensure current financial statements are obtained and reviewed, including a global analysis of the borrower, in a timely manner; (f) procedures to ensure appraisals and re-appraisals are obtained in a timely manner; and, (g) procedures to ensure that appraisal dates are appropriately reflected on internal MIS. (2) The Board shall submit a copy of the program to the Assistant Deputy Comptroller. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

Credit Risk Management. (1) Within sixty (60) days, the Board shall developadopt, implement, and thereafter ensure Bank adherence to a written program to improve strengthen credit risk management at the Banksystems. The program shall include, but not necessarily be limited to, the following: (a) procedures a review of the balance sheet to ensure accuracy identify any concentrations of risk ratings and proper and timely problem loan identificationcredit; (b) procedures governing a written analysis of any concentration of credit identified above in order to identify and assess the supervision inherent credit, liquidity, and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valuesrate risk; (c) policies and procedures to ensure an independent appraisal review process is in placecontrol and monitor concentrations of credit; (d) procedures to ensure re-evaluating the bank’s commercial real estate concentration risk ratings are appropriately reflected on internal MISlimits; (e) procedures to ensure current financial statements are obtained and reviewed, including a global analysis better defining sub categories of the borrower, in a timely mannercommercial real estate; (f) procedures to ensure appraisals and re-appraisals are obtained in a timely manner; and,establishing concentration risk limits for these sub categories; (g) developing a reporting system that shows actual concentration levels against Board approved risk limits; (h) an action plan approved by the Board to reduce the risk of any concentration deemed imprudent in the above analysis; (i) policies, procedures and risk limits for the three new credit programs (Mezzanine, Capital Markets and Franchise Lending) identified in the 2001 strategic plan; (j) policies, procedures and risk limits for any new loan product or program prior to ensure that appraisal dates are appropriately reflected on internal MISentering into the new product or program; (k) systems and controls to reduce the level of financial and documentation exceptions; and (l) systems and controls to strengthen the tracking, aggregating, analyzing, and reporting of credit policy and underwriting exceptions. (2) For purposes of this Article, a concentration of credit is as defined in Section 216 of the Comptroller's Handbook for National Bank Examiners. (3) The Board shall submit ensure that future concentrations of credit are subjected to the analysis required by subparagraph (b) and that the analysis demonstrate that the concentration will not subject the Bank to undue credit or interest rate risk. (4) The Board shall forward a copy of the program any analysis performed on existing or potential concentrations of credit to the Assistant Deputy ComptrollerComptroller immediately following the review. (35) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

Credit Risk Management. (1) Within sixty thirty (6030) days, the Board shall develop, implement, and thereafter continue to ensure Bank adherence to a written program to improve the Bank’s credit risk management at the Bankmanagement. The program shall include, but not be limited to: (a) procedures to ensure accuracy of risk ratings satisfactory and proper and timely problem loan identificationperfected collateral documentation; (b) procedures governing the supervision to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valuesanalyzing current and satisfactory credit information; (c) procedures to ensure an independent appraisal review process is in placeconformance with loan approval requirements; (d) procedures a system to ensure risk ratings are appropriately reflected on internal MIStrack and analyze exceptions; (e) procedures to ensure current financial statements are obtained and reviewed, including a global analysis of the borrower, in a timely mannerperiodic post-funding analysis; (f) procedures to ensure appraisals and re-appraisals are obtained in a timely manner; and,the accuracy of internal management information systems; (g) a performance appraisal process, including performance appraisals, job descriptions, and incentive programs for loan officers, which adequately consider their performance relative to policy compliance, documentation standards, accuracy in credit grading, and other loan administration matters; and (h) procedures to ensure that appraisal dates are appropriately reflected track and analyze concentrations of credit, significant economic factors, and general conditions and their impact on internal MISthe credit quality of the Bank’s loan and lease portfolios. (2) The Board shall submit Upon completion of the revisions to the Bank’s written program, a copy of the program shall be forwarded to the Assistant Deputy Comptroller. (3) Within sixty (60) days, the Board shall continue to ensure Bank adherence to systems that provide for effective monitoring of: (a) early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that will serve as a basis for identifying sources of problem loans and leases by industry, size, collateral, division, group, indirect dealer, and individual lending officer; (c) previously charged-off assets and their recovery potential; (d) compliance with the Bank’s lending policies and laws, rules, and regulations pertaining to the Bank’s lending function; (e) adequacy of credit and collateral documentation; and (f) concentrations of credit. (4) Beginning on June 30, 2009, and on a quarterly basis thereafter, management will continue to provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Bank’s loan and lease portfolios; and (g) the identification of loans and leases not in conformance with the Bank’s lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (5) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

Credit Risk Management. (1) Within thirty (30) days, the Board shall continue to ensure adherence to a written program to improve the Bank’s credit risk management. The program shall include, but not limited to: (a) procedures to ensure satisfactory and perfected collateral documentation; (b) procedures to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and analyzing current and satisfactory credit information; (c) procedures to ensure that loan participations purchased are underwritten and administered in accordance with Bank policy and the guidelines in Banking Circular 181 (Revised August 2, 1984); (d) procedures to ensure adherence to the guidance on commercial real estate lending outlined in OCC Bulletin 2006-46. (e) procedures to ensure that global cash flow analyses are prepared in support of all new nonagricultural loan requests of $500,000 or more; (f) procedures to ensure conformance with loan approval requirements; (g) a system to track and analyze credit, collateral, and policy exceptions; (h) procedures to ensure periodic post-funding analysis including preparation of annual global cash flow analyses supporting all non-agricultural credit relationships in excess of $500 thousand; (i) a definition of the Bank’s trade area, and guidelines and limitations on loans originating outside the bank’s trade area; (j) procedures to ensure the accuracy of internal management information systems; (k) a performance appraisal process, including performance appraisals, job descriptions, and incentive programs for loan officers, which adequately consider their performance relative to policy compliance, documentation standards, accuracy in credit grading, and other loan administration matters, and (l) procedures to track and analyze concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Bank’s loan and lease portfolios. (2) Upon completion of the revisions of the Bank’s written program, a copy of the program shall be forwarded to the Assistant Deputy Comptroller. (3) Within sixty (60) days, the Board shall develop, implement, and thereafter continue to ensure Bank adherence to a written program to improve credit risk management at the Bank. The program shall include, but not be limited tosystems that provide for effective monitoring of: (a) procedures to ensure accuracy of risk ratings and proper and timely early problem loan identificationidentification to assure the timely identification and ratings of loans and leases based on lending officer submissions; (b) procedures governing the supervision statistical records that will serve as a basis for identifying sources of problem loans and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans thatleases by industry, when combined with principalsize, is not protected by sound collateral valuescollateral, division, group, indirect dealer, and individual lending officer; (c) procedures to ensure an independent appraisal review process is in placepreviously charged-off assets and their recovery potential; (d) procedures compliance with Bank’s lending policies and laws, rules and regulations pertaining to ensure risk ratings are appropriately reflected on internal MISthe Bank’s lending function; (e) procedures to ensure current financial statements the bank’s ongoing post funding analysis program and assurance that annual global cash flow analyses are obtained and reviewed, including a global analysis prepared in support of the borrower, all nonagricultural credit relationships in a timely manner;excess of $1 million; and (f) procedures to ensure appraisals adequacy of credit and re-appraisals are obtained in a timely mannercollateral documentation; and, (g) procedures concentrations of credit.. (4) Beginning on October 31, 2009, and on a monthly basis, thereafter, management should continue to ensure that appraisal dates are appropriately reflected on internal MISprovide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph. (2f) The Board shall submit a copy an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the program Bank’s loan and lease portfolios; and (g) the identification of loans and leases not conforming to the Assistant Deputy ComptrollerBank’s lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (35) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

Credit Risk Management. (1) Within sixty ninety (6090) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to reduce the high level of credit risk in the Bank, and to improve credit risk management at the Bankpractices. The program shall include, but not be limited to: (a) procedures to strengthen credit underwriting, to ensure accuracy of risk ratings that proper consideration is given to borrower cash flow and proper profitability, liquidity, and timely problem loan identificationsolvency, and to prevent over reliance upon character and collateral; (b) procedures governing the supervision to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valuesanalyzing current and satisfactory credit information; (c) procedures to ensure an independent appraisal review process is in placesatisfactory and perfected collateral documentation; (d) procedures a system to ensure risk ratings are appropriately reflected on internal MIStrack and analyze exceptions; (e) procedures to ensure current financial statements are obtained a credit risk rating and reviewedclassification system that at a minimum incorporates the regulatory risk ratings as discussed in the Rating Credit Risk, including a global analysis A-RCR and Agricultural Lending, A-AL booklets of the borrower, in a timely mannerComptroller’s Handbook; (f) procedures to ensure appraisals early problem loan identification and re-appraisals are obtained in a timely manner; and,and accurate loan risk ratings based on lending officer submissions; (g) procedures for strengthening collections, to include follow-up efforts that are systematically and progressively stronger; (h) procedures that limit the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board; (i) procedures to ensure that appraisal dates are appropriately reflected on conformance with Call Report instructions; (j) procedures to ensure the accuracy of internal MISmanagement information systems; and (k) procedures to ensure compliance with the Bank's lending policies, and laws, rules, and regulations pertaining to the Bank's lending function. (2) The Board shall submit a copy of the program to the Assistant Deputy ComptrollerComptroller for review and prior determination of no supervisory objection. After the Assistant Deputy Comptroller has advised the Board in writing that there are no supervisory objections to the credit risk management program, the Bank shall implement and adhere to the credit risk management program. (3) 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 ensure that submit a copy of this assessment to the Bank has processesAssistant Deputy Comptroller. (4) Beginning April 30, personnel2004, on a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and control systems to ensure implementation amount of problem loans and adherence leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) the identification of loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the program developed pursuant to this ArticleBank’s lending and leasing policies.

Credit Risk Management. (1) Within sixty ninety (6090) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to improve reduce the high level of credit risk management at in the Bank. The program shall include, but not be limited to: (a) procedures to ensure accuracy of risk ratings and proper and timely problem loan identificationstrengthen credit underwriting; (b) procedures governing the supervision to strengthen management of loan operations and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained to maintain an adequate, qualified staff in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valueslending areas; (c) procedures to ensure an independent appraisal review process is in placefor strengthening collections; (d) procedures to ensure risk ratings that extensions of credit are appropriately reflected on internal MISgranted, by renewal or otherwise, to any borrower only after obtaining and analyzing current and satisfactory credit information; (e) procedures to ensure current financial statements are obtained and reviewed, including a global analysis of the borrower, in a timely mannerconformance with loan approval requirements; (f) procedures to ensure appraisals compliance with the Bank's lending policies and re-appraisals are obtained in a timely manner; and,requirements, as well as all laws, rules, and regulations pertaining to the Bank's lending function; (g) procedures to ensure that appraisal dates are appropriately reflected on internal MISthe identification and status of credit related violations of law, rule or regulation; (h) a system to timely identify, track, and analyze exceptions; (i) procedures to ensure the timely identification of loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies. (2j) procedures to ensure the timely identification and rating of problem loans and leases based on lending officer submissions; and (k) procedures to ensure that the Bank obtains and analyzes current and satisfactory credit information, including cash flow analysis, where loans are to be repaid from operations; (i) Failure to obtain the information in (1)(k) shall require a majority of the full Board (or a delegated committee thereof) to certify in writing the specific reasons why obtaining and analyzing the information in (1)(k) would be detrimental to the best interests of the Bank. (ii) A copy of the Board certification shall be maintained in the credit file of the affected borrower(s). The certification will be reviewed by this Office in subsequent examinations of the Bank; and (l) Procedures to ensure, with adequate supporting material, the value of collateral is properly evaluated, and where applicable, that the Bank's lien on collateral is properly perfected. (m) 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 the program this assessment to the Assistant Deputy Comptroller. (2) Upon completion, the Bank's credit risk management program shall be submitted to the Assistant Deputy Comptroller for prior written determination of no supervisory objection. Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the credit risk management program. (3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.

Credit Risk Management. (1) Within sixty ninety (6090) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program to reduce the high level of credit risk in the Bank, and to improve credit risk management at the Bankpractices. The program shall include, but not be limited to: (a) procedures to strengthen credit underwriting, to ensure accuracy of risk ratings that proper consideration is given to borrower cash flow and proper profitability, liquidity, and timely problem loan identificationsolvency, and to prevent over reliance upon character and collateral; (b) procedures governing the supervision to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and control of nonaccrual loans that, (i) are consistent with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valuesanalyzing current and satisfactory credit information; (c) procedures to ensure an independent appraisal review process is in placesatisfactory and perfected collateral documentation; (d) procedures a system to ensure risk ratings are appropriately reflected on internal MIStrack and analyze exceptions; (e) procedures to ensure current financial statements are obtained a credit risk rating and reviewedclassification system that at a minimum incorporates the regulatory risk ratings as discussed in the Rating Credit Risk, including a global analysis A-RCR and Agricultural Lending, A-AL booklets of the borrower, in a timely mannerComptroller’s Handbook; (f) procedures to ensure appraisals early problem loan identification and re-appraisals are obtained in a timely manner; and,and accurate loan risk ratings based on lending officer submissions; (g) procedures for strengthening collections, to include follow-up efforts that are systematically and progressively stronger; (h) procedures that limit the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board; (i) procedures to ensure that appraisal dates are appropriately reflected on conformance with Call Report instructions; (j) procedures to ensure the accuracy of internal MISmanagement information systems; and (k) procedures to ensure compliance with the Bank's lending policies, and laws, rules, and regulations pertaining to the Bank's lending function. (2) The Board shall submit a copy of the program to the Assistant Deputy ComptrollerComptroller for review and prior determination of no supervisory objection. After the Assistant Deputy Comptroller has advised the Board in writing that there are no supervisory objections to the credit risk management program, the Bank shall implement and adhere to the credit risk management program. (3) 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 ensure that submit a copy of this assessment to the Bank has processesAssistant Deputy Comptroller. (4) Beginning March 31, personnel2004, on a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and control systems amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) the identification and amount of loans and leases to ensure implementation executive officers, directors, principal shareholders (and their related interests) of the Bank; and (g) the identification of loans and adherence leases not in conformance with the Bank's lending and leasing policies, and exceptions to the program developed pursuant to this ArticleBank’s lending and leasing policies.

Credit Risk Management. (1) Within sixty thirty (6030) daysdays of this Agreement, the Board shall developdevelop and submit for a prior written determination of no supervisory objection to the Assistant Deputy Comptroller, implement, and thereafter ensure Bank adherence to a written program to improve ensure appropriate credit risk management that includes, at the Bank. The program shall include, but not be limited toa minimum: (a) a written program designed to manage and reduce the Bank’s criticized assets that includes or addresses the following matters: (i) aggregate reporting of criticized asset levels by type to the Board or a designated committee thereof every month; (ii) specific plans for the reduction of criticized assets by asset type with target reductions by quarter; and (iii) procedures for the quarterly review and preparation of written determinations by the Board or a designated committee thereof regarding the effectiveness of the efforts to ensure accuracy eliminate the weaknesses in each criticized credit relationship or Other Real Estate Owned (“OREO”) with a net principal exposure of risk ratings and proper and timely problem loan identificationone hundred thousand dollars ($100,000) or more; (b) procedures governing the supervision to hold employees and control of nonaccrual loans that, (i) are consistent officers accountable for non- compliance with the accounting requirements contained in the Call Report Instructions; (ii) address the circumstances under which accrued interest due on a loan may be added to the outstanding principal amount when the loan is renewed or restructured; (iii) address circumstances under which restructured loans (TDRs) will be maintained on accruals status; (iv) require the monthly presentation to the Board of all loans meeting any of the nonaccrual criteria; and, (v) require the immediate reversal or charge off of that portion of the remaining accrued interest on such loans that, when combined with principal, is not protected by sound collateral valuesBank’s lending policies and other underwriting requirements; (c) procedures and staff to ensure an independent appraisal review process is in placethat loans are properly monitored to include periodic receipt, analysis and documentation of sufficient financial and operating information to measure and monitor the borrower’s and guarantor’s financial condition and repayment ability, to include at a minimum: (i) the collection of financial statements and operating and collateral information no less than annually; (dii) procedures the addition of staff as necessary to ensure risk ratings are the Bank appropriately reflected on internal MIScollects and obtains appropriate periodic financial statements, tax returns, rent rolls, and other financial information; (eiii) procedures to ensure current financial statements are obtained and reviewed, including a global appropriate analysis of operating, financial and collateral information that considers the borrower’s industry, in a timely mannerlocale, guarantor dependency, revenue sources, global cash flow and other relevant factors; (fiv) procedures immediate and ongoing training for the credit administration staff with respect to ensure appraisals and re-appraisals are obtained in a timely mannerthe application of Subparagraph (iii) of this Article; and, (gv) procedures to ensure that appraisal dates credit administration staff and management are appropriately reflected held accountable for accurate financial analysis; and (d) policies and procedures to monitor and reduce lending concentrations of credit that include at a minimum: (i) the establishment of safe and sound, formal risk limits (based upon the Bank’s tier 1 capital plus the Allowance) for aggregate total unguaranteed SBA/USDA loans, aggregate total CRE and additional CRE sub-limits by industry type (multi-purpose CRE buildings, gas stations/convenience stores, and hotels/motels) and geographic location, where aggregate total CRE is defined as construction and land development loans, multifamily loans, nonfarm nonresidential loans (including owner-occupied and nonowner-occupied), and loans to finance CRE, construction and development, but not secured by real estate; (ii) continuation of quarterly monitoring by the Board of the Bank’s concentrations; (iii) an action plan approved by the Board to reduce the Bank’s concentrations in total unguaranteed SBA/USDA, total CRE and sub-limits to the levels established above; and (iv) the performance of portfolio-level multi-factor stress testing and/or sensitivity analysis on internal MIShomogeneous pools of loans (unguaranteed SBA/USDA, multi-purpose CRE buildings, gas stations/convenience stores, and hotels/motels) to quantify the impact of changing economic conditions on asset quality, earnings, and capital. The sophistication of stress testing practices and sensitivity analysis should be consistent with the size, complexity, and risk characteristics of the CRE portfolio. (2) The Board shall submit Upon receiving a copy written determination of the program to no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to, and the effectiveness of, the program, policies and procedures required by this Article. (3) The Board shall take the necessary steps to ensure that the Bank has processesobtains any missing credit or collateral information described in any OCC correspondence or report, personnelin any internal or external loan review, and control systems or in any listings of loans lacking such information provided to ensure implementation management by the examiners within thirty (30) days of and adherence to the program developed pursuant to this Articleits receipt.