EXTERNAL LOAN REVIEW. (1) Within sixty (60) days of this Agreement, the Board shall employ a qualified consultant to perform periodic (at least semi-annually) asset quality reviews of the Bank’s loan portfolio. The scope of the external loan review shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk, A-RCR, of the Comptroller’s Handbook. Such reports shall, at a minimum, include comments and conclusions regarding:
(a) the identification, type, rating, and amount of problem loans and leases;
(b) the identification and amount of delinquent and nonaccrual loans;
(c) the identification/status of credit related violations of law or regulation;
(d) loans not in conformance with the Bank’s lending policies;
(e) credit underwriting and documentation exceptions;
(f) credit analysis and documentation of such;
(g) accuracy of internal risk ratings;
(h) overall credit administration practices; and
(i) completeness and effectiveness of problem loan workout plans.
(2) Prior to the appointment or employment of any individual as loan review consultant or entering into any contract with any consultant, the Board shall submit the name and qualifications of the proposed consultant and the proposed scope and terms of employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. After the OCC has advised the Bank that it does not take supervisory objection to the loan review consultant or the scope of the review, the Board shall immediately engage the loan review consultant pursuant to the proposed terms of the engagement.
(3) The Board or a designated committee shall review the independent loan review reports and ensure that, if appropriate, immediate, adequate, and continuing remedial action, is taken upon the findings noted in the reports.
(4) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Bank to collect or strengthen assets identified as problem credits, shall be maintained in the books and records of the Bank.
(5) The Bank shall not terminate the consultant’s asset quality review services without a prior written determination of no supervisory objection from the Assistant Deputy Comptroller.
EXTERNAL LOAN REVIEW. (1) Effective immediately, the Board shall continue to employ a qualified consultant to perform semi-annual asset quality reviews of the Bank. The external loan review shall provide for a written report to be filed with the Board and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk of the Comptroller’s Handbook. Such reports shall, at a minimum, include comments and conclusions regarding:
(a) the loan review scope and coverage parameters;
(b) the overall quality of the loan and lease portfolios;
(c) the identification, type, rating, and amount of problem loans and leases including grading differences;
(d) the identification and amount of delinquent loans and leases;
(e) the number and type of credit and collateral documentation exceptions;
(f) the identification and status of credit related violations of law, rule or regulation;
(g) the identity of the loan officer who originated each loan reported in accordance with Subparagraphs (b) through (f) of the Article;
(h) the adequacy of the Allowance balance and methodology and reserve for unfunded commitments, including compliance with GAAP and applicable regulatory guidance;
(i) the adequacy of the Bank’s identification of and review of troubled debt restructues;
(j) concentrations of credit;
(k) loans and leases to affiliates and related parties;
(l) loans and leases not in conformance with the Bank’s Loan Policy, and exceptions to the Bank’s Loan Policy;
(m) the Bank’s compliance with BC-181; and
(n) any recommendations for improvements.
(2) Prior to the change in the appointment or employment of any individual to perform the required loan reviews or entering into any contract with a consulting firm for such services, the Board shall submit the name and qualifications of the proposed individual or firm and the proposed scope and terms of employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection.
EXTERNAL LOAN REVIEW. (1) Within thirty (30) days of the date of this Agreement, the Board shall employ a qualified consultant to perform an asset quality review of the Bank. The external loan review shall provide for a written report to be filed with the Board and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk of the Comptroller’s Handbook. Such report shall, at a minimum, include comments and conclusions regarding:
(a) the loan review scope and coverage parameters;
(b) the overall quality of the loan and lease portfolios;
(c) the identification, type, rating, and amount of problem loans and leases including grading differences;
(d) the identification and amount of delinquent loans and leases;
(e) credit and collateral documentation exceptions;
(f) the identification and status of credit related violations of law, rule or regulation;
(g) the identity of the loan officer who originated each loan reported in accordance with Subparagraphs (b) through (e) of the Article;
(h) concentrations of credit;
(i) loans and leases to affiliates and related parties;
(j) loans and leases not in conformance with the Bank’s Loan Policy, and exceptions to the Bank’s Loan Policy; and
(k) any recommendations for improvements.
(2) Prior to the appointment or employment of any individual to this loan review consultant or entering into any contract with a consultant, the Board shall submit the name and qualifications of the proposed consultant and the proposed scope and terms of employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection.
EXTERNAL LOAN REVIEW. (1) Within thirty (30) days of this Agreement, the Board shall employ a qualified consultant to perform periodic independent reviews of the Bank’s loan portfolio to assure the timely identification and categorization of problem credits. The consultant shall be utilized until such time as an ongoing internal asset quality review system is developed by the Board, implemented, and demonstrated to be effective.
(2) The scope of the engagement with the loan review consultant shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk, A- RCR, of the Comptroller’s Handbook. Such reports shall, at a minimum, include comments and conclusions regarding:
(a) the loan review scope and coverage parameters;
(b) the overall quality of the loan and lease portfolios;
(c) the adequacy of the Bank’s credit risk management systems;
(d) the identification, type, rating, and amount of problem loans and leases including grading differences;
(e) the identification and amount of delinquent loans and leases;
(f) credit and collateral documentation exceptions;
(g) loans and leases not in conformance with the Bank’s Loan Policy, and exceptions to the Bank’s Loan Policy;
(h) the identification and status of credit related violations of law, rule or regulation;
(i) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (d) through (h) of the Article;
(j) concentrations of credit;
(k) loans and leases to affiliates and related parties; and
(l) any recommendations for improvements.
(3) Before terminating the consultant’s asset quality review services, the Board shall both certify the effectiveness of the internal asset quality review system, and receive a prior written determination of no supervisory objection from the Assistant Deputy Comptroller.
EXTERNAL LOAN REVIEW. (1) Within sixty (60) days of the date of this Agreement, the Board shall employ a qualified consultant to perform semi-annual asset quality reviews of the Bank's loan portfolio. The scope of the external loan review shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in. Such reports shall, at a minimum, include comments and conclusions regarding:
(a) the identification, type, rating, and amount of problem loans and leases;
(b) the identification and amount of delinquent and nonaccrual loans;
(c) the identification/status of credit related violations of law or regulation;
(d) loans not in conformance with the Bank's lending policies;
(e) credit underwriting and documentation exceptions; credit analysis and documentation of such;
(g) accuracy of internal risk ratings;
EXTERNAL LOAN REVIEW. (1) Within thirty (30) days of this Agreement, the Board shall employ a qualified consultant to perform an asset quality review of the Bank. The external loan review shall provide for a written report to be filed with the Board and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk of the Comptroller’s Handbook. Such report shall, at a minimum, include comments and conclusions regarding:
(a) the loan review scope and coverage parameters;
(b) the overall quality of the loan and lease portfolios;
(c) the identification, type, rating, and amount of problem loans and leases including grading differences;
(d) the identification and amount of delinquent loans and leases;
(e) credit and collateral documentation exceptions;
(f) loans and leases not in conformance with the Bank’s Loan Policy, and exceptions to the Bank’s Loan Policy;
(g) the identification and status of credit related violations of law, rule or regulation;
(h) the identity of the loan officer who originated each loan reported in accordance with Subparagraphs (c) through (g) above;
(i) concentrations of credit;
(j) loans and leases to affiliates, insiders, and related interests; and
(k) any recommendations for improvements.
(2) Prior to the appointment or employment of any individual to this loan review consultant or entering into any contract with a consultant, the Board shall submit the name and qualifications of the proposed consultant and the proposed scope and terms of employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection.
EXTERNAL LOAN REVIEW. (1) By December 31, 2007, the Board shall implement and ensure an effective, independent and on-going external loan review system to review the Bank's loan and lease portfolios designed to timely identify and categorize problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in the Rating Credit Risk booklet, A- RCR, of the Comptroller’s Handbook. Such reports shall, at a minimum, include conclusions regarding:
(a) the identification, type, rating, and amount of problem loans and leases;
(b) the identification and amount of delinquent and nonaccrual loans and leases;
(c) credit and collateral documentation exceptions;
(d) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (c) of the Article;
(e) concentrations of credit; and
(f) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
(2) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation.
(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.
(4) The Board shall evaluate the loan and lease review report(s) and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s).
(5) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Bank to collect or strengthen assets identified as problem credits, shall be preserved in the Bank.
EXTERNAL LOAN REVIEW. (1) The Board shall continue to employ a qualified consultant to perform independent reviews of the Bank’s loan portfolio at least semi-annually to ensure the timely identification and categorization of problem credits.
(2) The scope of the engagement with the loan review consultant shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk, A-RCR, of the Comptroller’s Handbook.
EXTERNAL LOAN REVIEW. (1) The Board shall within sixty (60) days identify and contract with a sufficiently experienced and qualified individual or firm to ensure a timely and independent review of the Bank’s loan portfolio.
(2) Within one hundred twenty (120) days, the Board shall ensure that the above- referenced individual or firm conducts such review to assure the identification and categorization of problem credits. The contract shall provide for a written report to be filed with the Board after the review, which shall use a loan grading system consistent with the guidelines set forth in Rating Credit Risk, A-RCR, of the Comptroller’s Handbook. Such report shall, at a minimum, include conclusions regarding:
(a) the overall quality of the loan and lease portfolios;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation; and
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
EXTERNAL LOAN REVIEW. (1) Within ninety (90) days and annually thereafter, the Board shall obtain an individual or firm to conduct an external loan review of at least thirty (30) percent of the Bank’s commercial and agricultural loan and lease portfolios (beginning with the portfolios existing as of December 31, 2016), and provide a written report addressing the timeliness and accuracy of risk rating of credits and credit information, accrual status, collateral documentation, and policy exceptions. The Board and management shall review the written report upon receipt. Such reports shall include, at a minimum, conclusions regarding:
(a) the overall quality of the loan portfolio;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the accrual status and amount of impairment reserves, if necessary;
(d) credit information and collateral documentation exceptions;
(e) loans and leases to executive officers, directors, and principal shareholders (and their related interests) of the Bank; and
(f) loans and leases not in conformance with the Bank’s lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
(2) Within thirty (30) days of receipt, the Board shall evaluate the external loan and lease review reports and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report.
(3) A copy of the final reports submitted to the Board, including documentation of the action(s) taken by the Bank to address concerns pursuant to Paragraph (2) of this Article, shall be forwarded to the Assistant Deputy Comptroller within 30 days of receipt.
