Common use of INDEPENDENT LOAN REVIEW Clause in Contracts

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) The Board shall, within ninety Within sixty (9060) days, submit the resume and qualifications days of the person(s) or firm selected by date of this Agreement, the Board shall establish and adopt, and the Bank (subject to conduct an independent Board review and identification of the Bank's problem loans on-going monitoring) shall implement and leases (the "Independent Reviewer")thereafter ensure adherence to a written loan review program that requires an effective, independent and on-going loan review system consistent with OCC Bulletin 2006-47, including the proposed scope of their loan review engagement Interagency Policy Statement on the Allowance for Loan and Lease Losses attached thereto, 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 review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem creditsportfolios. The engagement program shall address all corrective actions related to independent loan review as identified in the most recent XXX. In addition, the program shall provide for a written report to be filed with the Board after each review, review and the Independent Reviewer shall use a loan and lease grading system consistent with the guidelines set forth in “Rating Credit Risk” and “12 C.F.R. § 160.160 (Asset Classification), OCC Bulletin 2006-47, Interagency Policy Statement on the Allowance for Loan and Lease Losses, (December 13, 2006), OCC Bulletin 2000-20, Uniform Retail Credit Classification and Account Management Policy, (June 20, 2000) and the “Rating Credit Risk” booklets booklet of the Comptroller’s Handbook. Such . (2) The written reports required by paragraph (1) of this Article shall include, at a minimumbut not be limited to, conclusions regarding: (a) the identificationoverall quality of the loan and lease portfolios, typeincluding but not limited to information sufficient to determine the level of risk within the portfolio arising from portfolio composition, ratingunderwriting trends, industry or economic conditions, geographic location, loan types, the volume and nature of exceptions, and amount of problem loans and leasesconcentrations; (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 rule, regulation, or regulationregulatory guidance, as well as an affirmative declaration that specific laws, rules, regulations and regulatory guidance were tested; (ec) the identity identification and status 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) and exceptions to the Bank’s lending and leasing policies., as well as an affirmative declaration that policy compliance was tested; (2d) The Board shall ensure that the Bank has processesidentification of any deficient credit risk management practices and an analysis of their root cause; and (e) the status of corrective actions for any previously identified exceptions, personnelviolations of law, and control systems to ensure implementation of and adherence to the program developed pursuant to this Articlerule, regulation, or regulatory guidance, credit risk management deficiencies, or any loan officer identified as having inaccurate risk ratings. (3) The written loan review program required by paragraph (1) of this Article shall be forwarded to the Assistant Deputy Comptroller upon adoption. (4) The Board shall evaluate the independent internal 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). (45) 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 ninety Within thirty (9030) days, submit the resume and qualifications of the person(s) or firm selected by the Board to conduct shall establish an independent review effective, independent, and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on-going loan review engagement program 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 review, at least quarterly, the Bank's loan and lease portfolios portfolios, to assure the timely identification and categorization of problem credits. The engagement program shall provide for a written report to be filed with the Board promptly after each review, review and the Independent Reviewer shall use employ a loan and lease grading rating system consistent with the guidelines set forth in “"Rating Credit Risk” " and “"Allowance for Loan and Lease Losses” booklets ," Booklets A-RCR and A-ALLL, respectively, of the Comptroller’s 's Handbook. Such reports shall include, at a minimum, conclusions regarding: (a) conclusions regarding the overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) loans meeting the identification and status of credit related violations of law, rule or regulationcriteria for non-accrual status; (ef) the identity of the loan officer who originated officer(s) of each loan reported in accordance with subparagraphs (b) through (e) of the Article); (fg) the identification and status of credit-related violations of law, rule, or regulation; (h) concentrations of credit; (gi) loans and leases to the directors, executive officers, directors, and principal shareholders (of the Bank and to their related interests) of the Bank;; and (hj) loans and leases not in conformance nonconformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s '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 as appropriate, is taken upon all findings noted in the report(s). (4) A copy of the reports submitted to the Board, as well as and that documentation of the action taken by the Bank to collect or strengthen assets identified as problem credits, shall be is preserved in the Bank.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within Within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board to conduct shall adopt an effective, independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on-going loan review engagement system 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 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 categorization of problem creditspolicy exceptions. The engagement system 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, written conclusions regarding: (a) the identification, type, rating, and amount of problem loans and leases; (b) reasons for the identification and amount risk rating of delinquent loans and leasesindividual credits; (c) the accrual status and amount of impairment reserves, if necessary; (d) credit information and collateral documentation exceptions; (de) 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;; and (hg) loans and leases not in conformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (2) The Upon adoption, the Board shall ensure that submit a written description of the Bank has processes, personnelsystem required by this Article, and control systems any subsequent amendments or changes to that system, to the Assistant Deputy Comptroller for determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure implementation of and adherence to the program developed pursuant to this Articlesystem. (3) The Board shall evaluate the independent internal loan and lease review report(s) reports and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s)report. (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 by the Bank.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within Within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board shall establish an effective, independent and on-going loan review program 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 ’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 program shall use a loan and lease grading system consistent with the guidelines set forth in the “Rating Credit Risk” and “Allowance for Loan and Lease Losses” booklets booklet of the Comptroller’s HandbookHandbook and shall consist of sampling of the retail and commercial loan and lease portfolio by an independent party. Such The Board shall submit the proposed scope of the loan review engagement to the Assistant Deputy Comptroller for review and a written determination of no supervisory objection. (2) All reports required for an effective and on-going credit risk rating program set forth in Paragraph (1) of this Article shall ensure timely identification and categorization of problem credits and shall include, at a minimum, conclusions regarding: (a) the overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) the identification of credit and collateral documentation exceptions; (de) the identification and status an analysis 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;concentrations; and (f) concentrations a listing 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 ensure that the loan review is conducted by a party who is independent of the decision making or approval process for the loans reviewed. (4) 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). (45) 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 at the Bank.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within ninety Within sixty (9060) days, submit the resume and qualifications days of the person(s) or firm selected by date of this Agreement, the Board to conduct shall establish an effective, independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on-going loan review engagement system to review, at least quarterly beginning in the Assistant Deputy Comptroller for review and determination second calendar quarter of no supervisory objection. The engagement shall provide for the periodic (and not less than annual) review of 2008, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) the identification and status of credit related violations of law, rule or regulation; (ef) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (fg) concentrations of credit; (gh) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;; and (hi) loans and leases not in conformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (2) Within ninety (90) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program providing for the 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 quarterly report to the Board. At a minimum the program shall provide for an independent reviewer’s assessment of the Bank’s: (a) monitoring systems for early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that serve as a basis for identifying sources of problem loans and leases by industry, size, collateral, concentration, indirect dealer, and individual lending officer; (c) system for monitoring previously charged-off assets and their recovery potential; (d) system for monitoring compliance with the Bank's lending policies and laws, rules, and regulations pertaining to the Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (3) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (4) 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. (35) The Board shall evaluate the independent internal 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). (46) 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 shallshall within sixty (60) 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. 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 terms of employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. (2) The requirement to submit information and the provisions for 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 his/her review and act on any such information or authority within ninety (90) days, submit the resume and qualifications . (3) Within sixty (60) days 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 receiving a written determination of no supervisory objection. The engagement objection from the Assistant Deputy Comptroller, the Board shall provide for the periodic (establish an effective, independent and not less than annual) on-going loan review of system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) the identification and status of credit related violations of law, rule or regulation; (ef) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (fg) concentrations of credit; (gh) loans and leases to executive officers, directors, principal shareholders shareholders, and employees (and their related interests) of the Bank;; and (hi) loans and leases not in conformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (24) The Within one hundred and twenty (120) days, the Board shall ensure that the Bank has processesdevelop, personnelimplement, and control systems to thereafter ensure implementation of and 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 quarterly report to the Board. At a minimum the program developed pursuant shall provide for an independent reviewer’s assessment of the Bank’s: (a) monitoring systems for early problem loan identification to this Articleassure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that 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) a system for monitoring previously charged-off assets and their recovery potential; (d) a system for monitoring compliance with the Bank's lending policies and laws, rules, and regulations pertaining to the Bank's lending function; and (e) a system for monitoring the adequacy of credit and collateral documentation. (35) The Board shall evaluate the independent internal 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. (6) A written description of the programs called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (7) 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) The Board shall, within ninety Within sixty (9060) days, submit the resume and qualifications days of the person(s) or firm selected by date of this Agreement, the Board shall establish an effective, independent and on-going loan review system to conduct an independent review and identification review, at least quarterly beginning in the second calendar quarter of 2008, 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 ’s loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) the identification and status of credit related violations of law, rule or regulation; (ef) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (fg) concentrations of credit; (gh) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;; and (hi) loans and leases not in conformance with the Bank's ’s lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (2) Within ninety (90) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program providing for the 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 quarterly report to the Board. At a minimum the program shall provide for an independent reviewer’s assessment of the Bank’s: (a) monitoring systems for early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that serve as a basis for identifying sources of problem loans and leases by industry, size, collateral, concentration, indirect dealer, and individual lending officer; (c) system for monitoring previously charged-off assets and their recovery potential; (d) system for monitoring compliance with the Bank’s lending policies and laws, rules, and regulations pertaining to the Bank’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (3) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (4) 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. (35) The Board shall evaluate the independent internal 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). (46) 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 ninety sixty (9060) daysdays after receipt of no supervisory objection from the Assistant Deputy Comptroller pursuant to paragraph (2) of this Article, submit the resume and qualifications of the appoint or employ a capable person(s) or firm selected by the Board to conduct an independent review and identification of the Bank's ’s problem loans and leases (the "“Independent Reviewer"”). (2) Prior to appointing or employing the Independent Reviewer, the Board shall submit the resume and qualifications of 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. (23) 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. (34) 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). (45) 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, 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, submit the resume and qualifications of the person(s) or firm selected by the Board to conduct shall establish an effective, independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on- going loan review engagement system 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 review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 , A-RCR, of the Comptroller’s Handbook. Such reports shall includeshall, 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; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) the identification and status of credit related violations of law, rule or regulation; (ef) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (fg) concentrations the principal components of creditthe Bank’s loan portfolio; (gh) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;; and (hi) loans and leases not no longer in conformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (23) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (4) 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. (35) 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). (46) 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 Within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board shall establish, implement, and thereafter ensure Bank adherence to conduct an effective, independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on-going loan review engagement system 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 review, at least annually, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 and nonaccrual loans and leases; (c) the level of credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulationregulation pertaining to the Bank’s lending function; (e) the identity identification and analysis of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (f) concentrations of credit; (gf) loans and leases to executive officers, directors, principal shareholders (and their related interests) the accuracy of the Bank’s risk ratings; (hg) compliance with the Bank’s lending and leasing policies detailing the number and volume of loans and leases funded with exceptions or otherwise 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 A written description of the program called for in this Article shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence be forwarded to the program developed pursuant to this ArticleAssistant Deputy Comptroller for review and determination of no supervisory objection. (3) The Board or a committee designated by the Board shall evaluate the independent internal loan and lease review report(s) reports and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s)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 preserved in the Bank.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within Within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board shall adopt, implement, and ensure Bank adherence 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 program that is consistent with the Assistant Deputy Comptroller for review and determination of no supervisory objectionguidance provided in OCC Bulletin 2006-47. The engagement At a minimum, the program shall provide for the require: (a) a periodic (and not less than annual) independent 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 In conducting the Board after each review, and the Independent Reviewer independent reviewer shall use a loan and lease grading system that is consistent with the guidelines set forth in “Rating Credit Risk” and “Allowance for Loan and Lease Losses” booklets of the Comptroller’s Handbook; and (b) the submission of a written report to be filed with the Board within sixty (60) days after each review. Such reports shall include, at a minimum, conclusions regarding: (ai) the identification, type, rating, and amount of problem loans and leases; (bii) the identification and amount of delinquent loans and leases; (ciii) credit and collateral documentation exceptions; (div) the identification and status of credit related violations of law, rule or regulation; (ev) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (bii) through (eiv) of the this Article; (fvi) concentrations of credit; (gvii) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;principal (h) loans and leases not in conformance with the Bank's lending and leasing policies, and (iviii) 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 each 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). (43) 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. (4) Within ninety (90) days, the Board shall submit the proposed scope of the loan review engagement letter to the Assistant Deputy Comptroller for review and written determination of no supervisory objection. (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.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within 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 shall modify the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their ’s existing loan review engagement system, and shall implement, and thereafter ensure Bank adherence to the Assistant Deputy Comptroller for review and determination of no supervisory objectionmodified system. The engagement As modified, the system shall provide for require the periodic (and not less than annual) review of Bank to review, at least semi- annually, 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 HandbookHandbook as well as OCC Bulletin 2000-20“Uniform Retail Credit Classification and Account Management Policy.” The 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 identification and amount of delinquent and nonaccrual 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; (gf) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;; and (hg) loans and leases not in conformance with the Bank's lending and leasing policies, and (i) and 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 internal loan and lease review report(s) reports and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s)report. (43) 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 Within ninety (90) days, submit the resume Board shall employ a sufficiently experienced and qualifications of the qualified person(s) or firm selected by (“Independent Reviewer”) to ensure the Board to conduct an timely and independent review and identification of the Bank's problem loans and leases leases. (2) Prior to the "employment of the Independent Reviewer"), including the Board shall submit the name and qualifications of the Independent Reviewer and the proposed scope terms of their loan review engagement employment to the Assistant Deputy Comptroller for review and a prior written determination of no supervisory objection. The engagement . (3) Within ninety (90) days, the Board shall provide for establish an effective, independent, and on-going loan review system which provides that the periodic (and not less than annual) review of Independent reviewer shall review, at least annually, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system 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 leaseslease losses; (c) the identification of credit and collateral documentation exceptions; (d) the identification of all loans and leases not in conformance with the Bank’s lending and leasing policies; (e) the identification of all loans and leases where exceptions were granted under the Bank’s lending and leasing policies; (f) concentrations of credit; and (g) 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. (34) The Board shall evaluate the independent loan and lease review report(s) it receives pursuant to paragraph (3) of this Article and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s). (45) 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 ninety (90) days, submit the resume and qualifications Effective as of the person(s) date of this Agreement, the Board shall continue to employ a qualified Association employee, consultant or firm selected by to perform periodic, independent loan reviews that are sufficient in scope and coverage to accurately identify the Board to conduct an independent review risk in the loan portfolio and identification make conclusions regarding the items listed in Paragraph (2) of this Article. (2) The scope and coverage 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 use 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 the “Rating Credit Risk” and “Allowance for Loan and Lease Losses” booklets booklet of the Comptroller’s Handbook, be performed at least annually and include appropriate coverage of the Association’s loan portfolio (in particular the church and investor loan portfolios) using a risk-based approach, and require a written report to be filed with the Board. Such reports shall includeThe loan review report 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 loans and leasesnonaccrual loans; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule rule, or regulation; (ed) loans not in conformance with the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through Association’s lending policies; (e) of the Articlecredit underwriting and documentation exceptions; (f) concentrations credit analysis and documentation of creditsuch; (g) loans and leases to executive officers, directors, principal shareholders (and their related interests) accuracy of the Bankinternal risk ratings; (h) loans and leases not in conformance with the Bank's lending and leasing policies, effectiveness of overall credit administration practices; and (i) exceptions to the Bank’s lending completeness and leasing policies. (2) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation effectiveness of and adherence to the program developed pursuant to this Articleproblem loan workout plans. (3) The Prior to the change in the appointment or employment of any individual or consulting firm to perform the required loan reviews or entering into any contract for such services, the Board shall evaluate submit the name and qualifications of the proposed individual or firm and the proposed scope and terms of employment (including the proposed engagement letter and any amendments thereto) to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. (4) Within thirty (30) days of the Association’s receipt of each independent loan and lease review report(s) and report, the Board or a designated committee shall review it and, if appropriate, ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all the findings noted in the report(s)report. (45) A Within forty-five (45) days of the Association’s receipt of each independent loan review report, a copy of the reports submitted to the Boardloan review report, as well as documentation of the action taken by the Bank Association to collect or strengthen assets identified as problem credits, shall be preserved maintained in the Bankbooks and records of the Association. (6) The Association shall not terminate the loan review services without submitting a written notice of said termination to the Assistant Deputy Comptroller at least thirty (30) days prior to the effective termination date and obtaining a prior written determination of no supervisory objection from the Assistant Deputy Comptroller.

INDEPENDENT LOAN REVIEW. (1) The Board shall, within Within ninety (90) days, submit the resume and qualifications of the person(s) or firm selected by the Board to conduct shall establish an effective, independent review and identification of the Bank's problem loans and leases (the "Independent Reviewer"), including the proposed scope of their on-going loan review engagement system 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 review, at least semi-annually, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The engagement system shall provide for a written report to be filed with the Board after each review, 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 overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (bc) the identification and amount of delinquent loans and leases; (cd) credit and collateral documentation exceptions; (de) the identification and status of credit related violations of law, rule or regulation; (ef) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (fg) concentrations of credit; (gh) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;; and (hi) loans and leases not in conformance with the Bank's lending and leasing policies, and (i) and exceptions to the Bank’s lending and leasing policies. (2) Within ninety (90) 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 semi-annual basis. The program shall require a semi-annual report to the Board. At a minimum the program shall provide for an independent reviewer’s assessment of the Bank’s: (a) monitoring systems for early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that serve as a basis for identifying sources of problem loans and leases by industry, size, collateral, indirect dealer, and individual lending officer; (c) system for monitoring previously charged-off assets and their recovery potential; (d) system for monitoring compliance with the Bank's lending policies and laws, rules, and regulations pertaining to the Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (3) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (4) 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. (35) The Board shall evaluate the independent internal loan and lease review report(s) reports and shall ensure that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s)reports. (46) 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.