INDEPENDENT LOAN REVIEW. (1) The Board shall, within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board to conduct an independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their loan review engagement to the Assistant Deputy Comptroller for review and determination of no supervisory objection. The engagement shall provide for the periodic (and not less than annual) review of the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement shall provide for a written report to be filed with the Board after each review, and the Independent Reviewer shall use a loan and lease grading system consistent with the guidelines set forth in “Rating Credit Risk” and “Allowance for Loan and Lease Losses” booklets of the Comptroller’s Handbook. Such reports shall include, at a minimum, conclusions regarding:
(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 (b) through (e) of the Article;
(f) concentrations of credit;
(g) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;
(h) loans and leases not in conformance with the Bank's lending and leasing policies, and
(i) exceptions to the Bank’s lending and leasing policies.
(2) 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.
(3) The Board shall evaluate the independent 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).
(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 preserved in the Bank.
INDEPENDENT LOAN REVIEW. (1) Within ninety (90) days, the Board shall establish an effective, independent and on-going 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) credit and collateral documentation exceptions;
(c) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies; and,
(d) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (c) of the Article.
(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.
INDEPENDENT LOAN REVIEW. (1) The Board shall within thirty (30) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure the timely and independent identification of problem loans and leases.
(2) Prior to the employment or designation of any person or entering into any contract with a firm, the Board shall submit the name and qualifications of the proposed person or firm and the proposed terms of employment or engagement in writing to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection.
(3) The requirement to submit information and the provision for a prior written determination of no supervisory objection in this Article are based on the authority of 12 U.S.C. § 1818(b) and do not require the Comptroller or the Assistant Deputy Comptroller to complete the review and act on any such information or authority within ninety (90) days.
(4) Within sixty (60) days, the Board shall establish an effective, independent and on- going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of 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 Rating Credit Risk, A-RCR, of the Comptroller’s
(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;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank; and
(i) 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) Within thirty (30) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program providing for independent review of problem loans and leases in the Bank's loan and lease portfolios for the purpose of monitoring portfolio trends, on at least a quarterly basis. The program shall require a quar...
INDEPENDENT LOAN REVIEW. (1) The Board shall within thirty (30) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure the timely and independent identification of problem loans and leases.
(2) Within ninety (90) days, the Board shall obtain an independent loan review report from its designated person/firm to identify credit risk, additional losses, or credit and collateral exceptions.
(3) The Board shall incorporate the findings of the independent loan review into its analysis of the Allowance for Loan & Lease Losses (ALLL).
(4) The Board shall establish an effective, independent and on-going loan review system to review, at least annually, the Bank's loan and lease portfolios to assure the timely identification and categorization of 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 Comptroller’s Handbook Rating Credit Risk. Such reports 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;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank; and
(i) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
INDEPENDENT LOAN REVIEW. (1) Within ninety (90) days, the Board shall establish, implement, and thereafter ensure Bank adherence to an effective, independent and on-going loan review program to review, at least semi-annually, the Bank’s loan and lease portfolios to assure the timely and accurate risk rating of credits and the identification of credit information, collateral documentation, and policy exceptions. The Bank’s program shall provide for a written report to be filed with the Board after each review. Such reports shall include, at a minimum, conclusions regarding:
(a) the identification, type, rating, and amount of problem loans and leases;
(b) the accrual status and amount of impairment reserves, if necessary;
(c) credit information and collateral documentation exceptions;
(d) the identification and status of credit related violations of law, rule, or regulation;
(e) loans, leases, or extensions of credit to executive officers, directors, principal shareholders (and their related interests) of the Bank; and
(f) loans, leases, or extensions of credit not in conformance with the Bank’s lending and leasing policies concerning underwriting standards, credit administration, problem loan identification, and risk ratings with a description of each exception.
(2) Within thirty (30) days of receipt, the Board shall evaluate the internal 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 reports submitted to the Board, as well as documentation of the Board’s review, decisions, and actions taken by the Bank to address concerns pursuant to this Article, shall be maintained at the Bank and available for review by the OCC upon request.
INDEPENDENT LOAN REVIEW. (1) Bank management, subject to Board review and ongoing monitoring, shall continue to implement and ensure adherence to the Bank’s written External Loan Review Policy.
(2) The Board shall review the effectiveness of the External Loan Review Policy at least annually, and more frequently if necessary or if required by the OCC in writing, and amend the External Loan Review Policy as needed or directed by the OCC. Any material amendment to the External Loan Review Policy must be submitted to the ADC for review and prior written determination of no supervisory objection. Any amendment to the External Loan Review policy shall at a minimum, include:
(a) appropriate review requirements to ensure the review is representative of the portfolio, reasonably assures that credit deterioration or other adverse trends are identified, and credit risk identification systems are effectively tested;
(b) ensure the loan review scope is representative of the loan portfolio. The scope of loan review must be commensurate with the Bank’s credit risk profile and based on, but not limited to, loans over a predetermined size, new loans and products, loans with higher risk indicators, concentrations of credit, growth, and adversely rated credits;
(c) ensure testing of credit administration and risk identification systems includes Bank management’s adherence to Board-approved policies and procedures, the accuracy of risk rating practices, compliance with applicable laws and regulations, and adherence to loan agreement covenants; and
(d) ensure external loan review follows agreed upon procedures as outlined in the engagement letter.
(3) Within thirty (30) days of receipt, 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) Within thirty (30) days following receipt of the ADC’s written determination of no supervisory objection to any subsequent amendment to the External Loan Review Policy, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the Credit Underwriting and Administration Program.
INDEPENDENT LOAN REVIEW. (1) Effective immediately, the Board shall ensure that the Bank has an independent loan review program that is sufficient in scope and coverage to accurately identify the risk in the loan portfolio and make conclusions regarding the items listed in Paragraph (2) of this Article.
(2) The scope and coverage of the loan review program shall provide for periodic written reports to be filed with the Board, 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, shall include appropriate coverage of the Bank’s loan portfolio (in particular, the Xxxxxxx loan portfolio) using a risk-based approach. The loan review 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) the effectiveness of overall credit administration practices; and
(i) completeness and effectiveness of problem loan workout plans.
(3) The independent loan review program adopted pursuant to this Article shall be conducted quarterly, and both the scope of the review and the firm or consultant conducting the review shall be submitted to the Assistant Deputy Comptroller for a prior, written determination of no supervisory objection.
(4) 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 to address the findings noted in the reports.
INDEPENDENT LOAN REVIEW. (1) Within ninety (90) days, the Board shall establish an effective, independent and on- going 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. The minimum content of independent loan reviews shall include:
(a) a summary for agreement or disagreement with the assigned risk rating by Bank management;
(b) credit and collateral documentation exceptions;
(c) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies;
(d) a summary of financial trends to support the risk rating assigned;
(e) amount of and support for the amount of loan impairment;
(f) evaluation and support for accrual or nonaccrual status; and
(g) identification of payment extensions, deferrals, and renewals along with a written conclusion regarding appropriateness.
(2) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller for review and determination of no supervisory objection.
(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.
INDEPENDENT LOAN REVIEW. (1) Within ninety (90) days, the Board shall establish, implement, and thereafter ensure Bank adherence to an effective, independent and on-going loan review system to review, at least semi-annually, the Bank's loan and lease portfolios to assure the timely and accurate risk ratings of credits and the identification of credit information, collateral documentation, and policy exceptions. The Bank’s system shall provide for a written report to be filed with the Board after each review. Such reports shall include, at a minimum, conclusions regarding:
(a) the identification, type, rating, and amount of problem loans and leases;
(b) the accrual status and amount of impairment reserves, if necessary;
(c) credit information 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 Paragraphs (1) (a), (1) (c), and (1) (d) of this Article; and
(f) loans, leases, and extensions of credit not in conformance with the Bank's lending and leasing policies regarding underwriting standards, credit administration, problem loan identification, and risk ratings. The report must include a description of each exception.
(2) Within thirty (30) days of receipt of each report described in Paragraph (1) of this Article, the Board shall evaluate the report and ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report.
INDEPENDENT LOAN REVIEW. (1) Within sixty (60) days, the Board shall revise the Bank’s independent loan review process to address the concerns identified in the XXX. Specifically, the loan review process shall be revised to, at a minimum:
(a) broaden the scope of the loan review coverage by increasing the number and dollar amount of loans that must be reviewed each quarter to a level adequate to assess the condition of the loan portfolio;
(b) implement a risk-based approach to selection of loans for review that targets loans posing higher risks, including but not limited to:
(i) unsecured loans,
(ii) commercial real estate loans,
(iii) larger loans and loan relationships, and
(iv) groups of affiliated borrowers; and
(c) ensure that internal loan review reports include a discussion of the specific reasons for the risk rating assigned and include the analysis in support of that risk rating.
(2) A copy of the revised process shall be forwarded to the Assistant Deputy Comptroller for review and determination of no supervisory objection.
(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.
