Common use of Credit Risk Management Clause in Contracts

Credit Risk Management. (1) Within ninety (90) days of this Agreement, the Board shall prepare, adopt and thereafter adhere to revisions to the Bank’s loan policy, as well as any necessary procedures, to address weaknesses in the Bank’s credit risk management and underwriting, that, at a minimum, include: (a) policies and procedures designed to aggregate, track and eliminate exceptions to the Loan Policy, underwriting guidelines, and supervisory loan to value limits, for all loans to include, at a minimum: (i) monthly Board monitoring of policy exception reports that track the aggregate number and dollar amount of loans with material exceptions by type of loan and loan officer, and measured as a percentage of Tier I Capital plus the Allowance for Loans and Lease Losses; (ii) procedures to hold employees and officers accountable for non- compliance with the Bank’s loan policy and other underwriting requirements; and (iii) monthly reports to the Board of all exceptions that have been cured since the previous month’s report; and (b) procedures to ensure appropriate ongoing monitoring, including 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. (2) Effective as of the date of this Agreement, the Bank may not grant, extend, renew, modify or restructure any loan or other extension of credit, or purchase any loan participation, equal to or exceeding two hundred fifty thousand dollars ($250,000), 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) obtaining current and satisfactory credit information, including performing and documenting analysis of credit information and a detailed cash flow analysis of all expected repayment sources; (e) individual stress testing of all loans for changes in interest rates at origination; (f) 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 justification to support waiving the policy exception; (g) making and documenting the determinations made regarding the customer’s ability to repay the credit on the proposed repayment terms; (h) providing an accurate risk assessment grade and proper accrual status for each credit; (i) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank’s lien on it where applicable; (j) ensuring that any participations purchased are consistent with sound banking practices, guidelines set forth in Banking Circular 181 (Revised), dated August 2, 1984, and the requirements of 12 C.F.R. Part 34; and (k) obtaining the written approval of the Bank’s Loan Committee or Board, consistent with the policy developed in Article IV. (3) The Board shall take the necessary steps to ensure that current and satisfactory credit and proper collateral information is maintained on all loans. Within thirty (30) days of notification, the Board shall ensure that the Bank takes all necessary actions, and maintains appropriate documentation of the actions taken, to obtain any missing credit or collateral information described in the XXX, in any internal or external loan review, or in any listings of loans lacking such information provided to management by the National Bank Examiners at the conclusion of an examination.

Credit Risk Management. (1) Within ninety (90) days of this Agreement, the Board shall prepare, adopt and thereafter adhere submit to revisions the Assistant Deputy Comptroller for prior written determination of no supervisory objection a written program to improve the Bank’s loan policy, as well as any necessary procedures, to address weaknesses in the Bank’s credit administration and risk management and underwriting, thatpractices. The program shall include, at a minimum, include: (a) policies a requirement that lending officers analyze and procedures designed to aggregatedocument appropriate credit and collateral information on all extensions of credit, track and eliminate exceptions to the Loan Policy, underwriting guidelines, and supervisory loan to value limits, for all loans to include, at a minimum: (i) monthly Board monitoring of policy exception reports that track the aggregate number and dollar amount of loans with material exceptions by type of loan and loan officer, and measured as a percentage of Tier I Capital plus the Allowance for Loans and Lease Losses; (ii) procedures to hold employees and officers accountable for non- compliance with the Bank’s loan policy and other underwriting requirements; and (iii) monthly reports to the Board of all exceptions that have been cured since the previous month’s report; and (b) procedures to ensure appropriate ongoing monitoring, including 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. (2) Effective as of the date of this Agreement, the Bank may not grant, extend, renew, modify or restructure any loan or other extension of credit, or purchase any loan participation, equal to or exceeding two hundred fifty thousand dollars ($250,000), without: (a) documenting the specific reason or purpose for the extension of credit; (bii) identifying the expected source of repayment in writing; (ciii) 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 and a detailed cash flow analysis of all expected repayment sources; (e) individual stress testing of all loans for changes in interest rates at origination; (fiv) determining and documenting whether the loan complies with the Bank’s 's Loan Policy and if it does not comply, providing identification of the exception and ample justification to support waiving the policy exception; (gv) making and documenting the determinations made regarding the customer’s 's ability to repay the credit on the proposed repayment terms, including an evaluation of both primary and secondary sources of repayment, as well as a global cash flow analysis that considers all customer debt service requirements; (hvi) providing an accurate risk assessment grade and proper accrual status for each creditverification of liquid assets that the Bank is relying on as a source of repayment; (ivii) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank’s 's lien on it where applicable; (jviii) ensuring that any participations purchased are consistent with sound banking practices, guidelines set forth in Banking Circular 181 providing an accurate risk assessment grade; (Revised), dated August 2, 1984, ix) ongoing requirements for obtaining and the requirements of 12 C.F.R. Part 34analyzing financial statements; and (kx) ongoing requirements for obtaining the written approval of the Bank’s Loan Committee or Board, consistent with the policy developed in Article IVperiodic collateral inspections as appropriate. (32) The Board shall take the necessary steps to ensure that current and satisfactory credit and proper collateral information is maintained on all loans. Within thirty ninety (3090) days of notificationthis Agreement, the Board shall ensure develop 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. The exception tracking and monitoring system, 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 takes maintains, on an ongoing basis, a detailed listing of all necessary actionsloans not in conformance with the Bank’s lending policies, and maintains appropriate documentation with a notation as to whether the exceptions were properly granted in accordance with the Bank’s policy; (c) identification of the actions taken, to obtain any missing loan officer who originated each loan or other extension of credit or collateral information described reported in the XXX, in any internal or external loan review, or in any listings accordance with subparagraphs (a) and (b) of loans lacking such information provided to management by the National Bank Examiners at the conclusion Paragraph (2) of an examination.this Article;

Credit Risk Management. (1) Within ninety sixty (9060) days of this Agreement, the Board shall prepare, adopt and thereafter adhere to to, revisions to the Bank’s loan policy, as well as any necessary procedures, to address weaknesses in the Bank’s credit risk management and underwriting, that, at a minimum, include: (a) policies and procedures designed to aggregate, track and eliminate exceptions to the Loan Policy, underwriting guidelines, and supervisory loan to value limits, for all loans to include, at a minimum: (i) monthly Board monitoring of policy exception reports that track the aggregate number and dollar amount of loans with material exceptions by type of loan and loan officer, and measured as a percentage of Tier I Capital plus the Allowance for Loans and Lease Losses;; and (ii) procedures to hold employees and officers accountable for non- compliance with the Bank’s loan policy and other underwriting requirements; and (iii) monthly reports to the Board of all exceptions that have been cured since the previous month’s report; and; (b) procedures to ensure appropriate ongoing monitoring, including that 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 periodic (at least annually) cash flow analysis of income-producing collateral; and (c) procedures to ensure that insider loans are underwritten in accordance with applicable laws and regulations. (2) Effective as of the date of this Agreement, the Bank may not grant, extend, renew, modify or restructure any loan or other extension of creditcredit (including participations), or purchase any loan participation, equal to or exceeding two hundred fifty thousand dollars ($250,000), 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) obtaining current and satisfactory credit information, including ; (e) performing and documenting an analysis of the credit information and information, including but not limited to, a detailed cash flow analysis of all expected repayment sources; (e) individual stress testing of all loans for changes in interest rates at origination; (f) 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 justification to support waiving the policy exception; (g) making and documenting the determinations made regarding the customer’s ability to repay the credit on the proposed repayment terms; (h) providing an accurate risk assessment grade and proper accrual status for each credit; (i) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank’s lien on it where applicable; (j) ensuring that any participations purchased are consistent with sound banking practices, guidelines set forth in Banking Circular 181 (Revised), dated August 2, 1984, and the requirements of 12 C.F.R. Part 34; and (k) obtaining the written approval of the Bank’s Loan Committee or Board, consistent with the policy developed in Article IV. (3) The Board shall take the necessary steps to ensure that current and satisfactory credit and proper collateral information is maintained on all loans. Within thirty (30) days of notification, the Board shall ensure that the Bank takes all necessary actions, and maintains appropriate documentation of the actions taken, to obtain obtains any missing credit or collateral information described in the XXX, in any internal or external loan review, or in any listings of loans lacking such information provided to management by the National Bank Examiners at the conclusion of an examination.

Credit Risk Management. (1) Within ninety sixty (9060) days of this Agreement, the Board shall prepare, adopt and thereafter adhere to revisions to the Bank’s loan policy, as well as any necessary procedures, to address weaknesses in the Bank’s credit risk management and underwriting, that, at a minimum, include: (a) policies and procedures designed to aggregate, track and eliminate exceptions to the Loan Policy, underwriting guidelines, and supervisory loan to value limits, for all loans to include, at a minimum: (i) monthly Board monitoring of policy exception reports that track the aggregate number and dollar amount of loans with material exceptions by type of loan and loan officer, and measured as a percentage of Tier I Capital plus the Allowance for Loans and Lease Losses;; and (ii) procedures to hold employees and officers accountable for non- compliance with the Bank’s loan policy and other underwriting requirements; and (iii) monthly reports to the Board of all exceptions that have been cured since the previous month’s report; and; (b) procedures to ensure appropriate ongoing monitoring, including that 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 periodic (at least annually) cash flow analysis of income-producing collateral; and (c) procedures to ensure that insider loans are underwritten in accordance with applicable laws and regulations. (2) Effective as of the date of this Agreement, the Bank may not grant, extend, renew, modify or restructure any loan or other extension of credit, or purchase any loan participation, equal to or exceeding two five hundred fifty thousand dollars ($250,000500,000), 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) obtaining current and satisfactory credit information, including performing and documenting analysis of credit information and a detailed cash flow analysis of all expected repayment sources; (e) individual stress testing of all loans for changes in interest rates at origination; (f) 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 justification to support waiving the policy exception; (gf) making and documenting the determinations made regarding the customer’s ability to repay the credit on the proposed repayment terms; (hg) providing an accurate risk assessment grade and proper accrual status for each credit; (ih) documenting, with adequate supporting material, the value of collateral and properly perfecting the Bank’s lien on it where applicable; (ji) ensuring that any participations purchased are consistent with sound banking practices, guidelines set forth in Banking Circular 181 (Revised), dated August 2, 1984, and the requirements of 12 C.F.R. Part 34; and (kj) obtaining the written approval of the Bank’s Loan Committee or Board, consistent with the policy developed in Article IV. (3) The Board shall take the necessary steps to ensure that current and satisfactory credit and proper collateral information is maintained on all loans. Within thirty (30) days of notification, the Board shall ensure that the Bank takes all necessary actions, and maintains appropriate documentation of the actions taken, to obtain obtains any missing credit or collateral information described in the XXX, in any internal or external loan review, or in any listings of loans lacking such information provided to management by the National Bank Examiners at the conclusion of an examination.