Common use of Interest Rate Risk Management Clause in Contracts

Interest Rate Risk Management. (1) Within ninety (90) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) determinations of how the Bank will measure the quality of IRR management; and (iii) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (e) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (g) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (i) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (j) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreement, the Bank Board shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable adopt a revised written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and the “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include and shall, at a minimum: (a) provide specific assigned accountability for the establishment of formal policiesdevelopment, proceduresexecution, and governance commensurate with oversight of interest rate management, including oversight by both the Bank’s complexity Board, or committee thereof, and business activitiesmanagement; (b) include appropriate policies and procedures for identifying, to includemeasuring, monitoring, and controlling IRR exposures, that include at a minimum: (i) the establishment of Board-approved, reasonable limits on short-term and long-term IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRRexposures; (ii) determinations of how standards for measuring and monitoring the Bank will measure the quality of Bank’s short-term and long-term IRR management; andexposures; (iii) the frequency of IRR measurement; (iv) procedures to monitor, escalate, and address any breaches of established Board-approved IRR limits; (bv) the responsibility and frequency for periodic evaluations of IRR model assumptions; (vi) sound change management practices that require model assumption changes to be approved by the Board, or committee thereof, prior to implementation; and (vii) standards and responsibility for the frequency of independent IRR model validation, backtesting, and IRR audit; (c) include accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from quantify both an earnings earnings-at-risk and economic value perspective with recognition and consideration of all risks IRRs (repricing, basis, yield-curve, and options), to includeinclude at a minimum: (i) limits or triggers on IRR exposures that consider the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. (1) the level and trends of aggregate Bank short-term and long-term IRR exposureexposures; b. (2) whether management’s strategies are within the BankBoard’s established risk appetite and Bank policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major (3) as needed, actions management must take to bring interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movementexposures back within Board-approved tolerance limits; (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (e) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (g) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (i) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (je) an annual review include requirements for retention of qualified personnel with sufficient knowledge and authority to monitor and manage IRR and understand the Bank’s adherence to key model assumptions, model backtesting, and model validation requirements, which may include additional training or the IRR Programaddition of qualified staff. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objectionADC in writing.

Interest Rate Risk Management. (1) Within ninety thirty (9030) days of the date of this Agreementdays, the Bank shall submit Board shall: (a) hire a qualified outside vendor to provide an interim interest rate risk measurement system to quantify the Assistant Deputy Comptroller Bank's level of interest rate risk and provide monthly management and Board reports; (b) develop, implement, and ensure adherence to written and prudent investment strategies for review the actual and prior potential principal returned on the Bank's mortgage-backed securities and municipal bonds; and (c) develop, implement, and ensure adherence to written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbookcontingencies plans for interest rate risk scenarios with trigger points for specific action. (2) The IRR Program Within sixty (60) days, the Board shall include risk management systems to identifydevelop, measure, monitorimplement, and control thereafter ensure Bank adherence to a written interest rate risk management program. In formulating this program, the Board shall refer to the Interest Rate Risk booklet of the Comptroller's Handbook. The program shall include, at a minimum, the following: (“IRR”)a) appropriate technical and human resources to ensure effective risk management, to include audit and internal controls; (b) written policies and procedures that reflect the Board's goals, objectives, and risk tolerances; and include, at a minimum: (ai) the establishment and guidance of formal policies, procedures, and governance commensurate with the Bank’s complexity strategic direction and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies tolerance for managing IRRinterest rate risk; (ii) determinations prudent limits on the nature and amount of how the Bank will measure the quality of IRR managementinterest rate risk that can be taken; and (iii) procedures periodic review of the Bank's adherence to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR;policy. (c) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings responsibility and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital authority for its level of IRR; and e. whether management’s major identifying potential interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movementarising from new or existing products and activities; (d) requirements for retention establishing and maintaining an interest rate risk measurement system that can identify and quantify the Bank's major sources of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staffinterest rate risk in a timely manner; (e) periodic validation of the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenariosrisk measurement system; (f) adequate and documented support for the reasonableness of assumptions used in reports on the Bank’s IRR model;'s interest rate risk profile with appropriate frequency and complexity commensurate with the Bank's risk; and (g) periodic review and adjustment, when there are material changes to risk limits based on the Bank’s balance sheet 's strategies and otherwiseactivities, as neededits past performance, the level of the assumptions earnings and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) procedures capital available to test the Bank’s IRR model to compare, reconcileabsorb potential losses, and report actual performance to simulated results; (i) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (j) an annual review of the Bank’s adherence to the IRR ProgramBoard's tolerance for risk. (3) Within thirty (30) days following receipt Upon adoption, a copy of the Assistant Deputy Comptroller’s written determination description of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt this program and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness a copy of the IRR Program at least annually, but no later than January 31 of each year, interest rate risk policy and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must procedures shall be promptly submitted to the Assistant Deputy Comptroller for review review. (4) The Board shall ensure that the Bank has processes, personnel, and prior written determination control systems to ensure implementation of no supervisory objectionand adherence to the program developed pursuant to this Article. If necessary, the Board shall employ an outside consultant to ensure that the requirements of this Article are met within the agreed upon timeframes.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) standards for measuring and monitoring IRR; (iii) the frequency of IRR measurement; (iv) determinations of how the Bank will measure the quality of IRR management; and (iiiv) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider considers the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (e) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (g) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) independent validation of the Bank’s IRR model and processes when there are material changes to the Bank’s balance sheet and otherwise, as needed, but in no event, less than on an annual basis; (i) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (ij) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (jk) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller ADC for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and the “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) standards for measuring and monitoring IRR; (iii) the frequency of IRR measurement; (iv) determinations of how the Bank will measure the quality of IRR management; and (iiiv) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) IRR measurement systems that are not dependent on just one measurement system for estimating the Bank’s IRR exposure that, at a minimum, estimates the Bank’s short-term and long-term IRR exposure; (d) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider considers the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (de) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (ef) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (fg) an immediate evaluation and corrective action (as well as ongoing procedures) to ensure the Bank properly operates its IRR model; (h) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (gi) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (hj) independent validation of the Bank’s IRR model and processes when there are material changes to the Bank’s balance sheet and otherwise, as needed, but in no event less than once in every eighteen (18) month period following the date of this Agreement; (k) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (il) procedures that require the Board to review and discuss, on at least a quarterly basis, discuss the model test results required by this ArticleArticle as they become available but in no event less than on an annual basis; and (jm) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy ComptrollerADC’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller ADC for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller ADC for review and prior written determination of no supervisory objection an acceptable revised written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) determinations of how the Bank will measure the quality of IRR management; and (iii) include procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) include IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. (i) whether management’s strategies are within the Bank’s established risk appetite and policy; c. (ii) the sensitivity of any key assumptions; d. (iii) whether the Bank holds sufficient capital for its level of IRR; and e. (iv) whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement;. (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (e) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (ge) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (hf) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (ig) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (jh) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy ComptrollerADC’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC ADC in writing, and amend the IRR Program as needed or directed by the OCCADC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller ADC for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety (90) days of the date of this AgreementBy May 31, 2024, the Bank Board shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable adopt a revised, written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of revisions to formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite appetite, and risk management objectives objectives, commensurate with the Bank’s size, complexity, and risk profile for all interest rate environments, with specific approved and prohibited strategies for managing IRR; (ii) standards for measuring and monitoring IRR; (iii) the frequency of IRR measurement; (iv) determinations of how the Bank will measure the quality of IRR management; and (iiiv) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) a strategy to reduce the level of balance sheet sensitivity to changing interest rates that is consistent with the Bank’s Strategic Plan and Asset Liability Management policy; (d) requirements for identification and retention of Asset-Liability Committee members with sufficient knowledge and independence to manage and monitor the Bank’s IRR; (e) IRR measurement systems that are not dependent on just one measurement system for estimating the Bank’s IRR exposure that, at a minimum, estimates the Bank’s short-term and long-term IRR exposure; (f) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider considers the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. (a) the level and trends of aggregate Bank IRR exposure; b. (b) whether management’s strategies are within the Bank’s established risk appetite and policy; c. (c) the sensitivity of any key assumptions; d. (d) whether the Bank holds sufficient capital for its level of IRR; and e. (e) whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (dg) requirements for retention of qualified personnel with sufficient authority procedures that require the Board to review and responsibility to manage and monitor IRRdiscuss, which may include additional training or on at least an annual basis, the addition of qualified staff;model test results required by this Article; and (eh) an annual review of the establishment of controls over Bank’s adherence to the impact of changes in IRR Program. (3) By June 30, 2024, the Board shall ensure that management developments bank- specific assumptions for interest rates on liquid asset valuationsrate risk model simulations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios;minimum this includes: (fa) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (gb) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes;. (h4) By July 31, 2024, the Board shall an independent validation of the Bank’s IRR model and annually thereafter; including procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (i5) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (j) an annual review Upon adoption of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR ProgramProgram and any amendments thereto. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, annually and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety (90) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; , OCC Bulletin 2010-1, 1 (“Interagency Advisory on Interest Rate Risk Management,” ”) (Jan. 2010); OCC Bulletin 2012-5, 5 (“Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” ”) (Jan. 2012); and OCC Bulletin 2011-12 (“Sound Practices for Model Risk Management,” booklet of the Comptroller’s Handbook: Supervisory Guidance on Model Risk Management”) (Apr. 2011). (2) The IRR Program shall include risk management systems to identifyinclude, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity strategic direction and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies tolerance for managing IRR; (ii) determinations of how the Bank will measure the quality of IRR management; and (iii) procedures to monitor, escalate, and address any breaches of established IRR limitsinterest rate risk; (b) accurate establishment of prudent short- and timely long-term limits on the nature and amount of interest rate risk identification which identify the Board is willing to accept in relation to earnings and quantify the major sources and types of IRRcapital; (c) implementation of effective tools to measure and monitor the Bank’s performance and overall interest rate risk profile; (d) strategies and procedures to manage and reduce interest rate risk to conform with the established limits set in subparagraph (2)(b) of this Article; (e) employment of competent personnel or outside consultants to manage and monitor interest rate risk, which may include additional training or addition of knowledgeable staff; (f) establishment of risk monitoring processes management reports, including comparison of actual exposures to provide set limits, providing sufficient information on which to base sound IRR interest rate risk management decisions from for both an earnings short- and economic perspective with recognition and consideration of all risks long- term risks; (repricingg) enhancements to the Bank’s Model Risk Management program, basis, yield-curve, and options), to includeincluding at minimum: (i) limits develop and implement effective internal model validation procedures for back-testing; (ii) back-testing must compare actual modeled results to the modeled scenario that most closely reflects actual rate movements over the testing period; and (iii) differences between modeled and actual outcomes must be reviewed to determine if the variance is due to model development errors, including omission of material factors from the model or triggers on IRR exposures that consider inaccurate assumptions, or external factors; (h) enhancements to the Bank’s model stress testing process, including at minimum: (i) review and adjust all model assumptions, including beta and growth assumptions, to accurately reflect the changes in liability mix and the Board must review and approve the adjustments; (ii) sensitivity testing around the growth and beta assumptions to identify earnings at risk appetite(EAR) and economic value of equity (EVE) implications; and (iii) incorporation of off-balance sheet items into the IRR model and develop corresponding assumptions for unused commitments. ALCO and the Board must review and approve the new assumptions; (i) The Board must ensure that the Bank and its ALCO have the resources they need to effectively measure, complexity of operationsmonitor and control the IRR exposure, earnings performance, liquidity positionincluding non-parallel shifts in the yield curve, and capital adequacybasis risk; (j) enhancements to the Bank’s IRR policy development and approval process, including at minimum: (i) ALCO must develop, and the Board must approve, updates to the IRR policy to include procedures and practices for measuring and monitoring yield curve risk and effective back testing; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established must establish risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital limits for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (e) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (g) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (i) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Articleyield curve risk; and (jk) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety one hundred and twenty (90120) days of the date of this Agreement, the Bank shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite and risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) standards for measuring and monitoring IRR; (iii) the frequency of IRR measurement; (iv) determinations of how the Bank will measure the quality of IRR management; and (iiiv) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) establishment of effective asset liability management (ALM) policy, procedures, and governance that includes: (i) bank-specific key model assumptions, including non-maturity deposit decay rates, (ii) periodic reassessment of model assumptions, at least every two years, to ensure timely and supported depositor behavior is reflected in assumption measurements; (iii) requirements to ensure periodic independent evaluation of model assumptions consistent with Bank policy; (iv) enhanced management reporting to the Bank’s asset/liability committee (ALCO) that includes all changes to key model assumptions, any impact to projected IRR exposures, and sufficient narrative support; and (v) enhanced ALM policy that clearly defines day-to-day oversight and model risk management responsibilities of senior management, provides for clear description of how key model assumptions are developed and maintained, and provides for periodic ALCO review, documentation, and affirmation of assumption reasonableness; (d) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider considers the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (de) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (ef) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (fg) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (gh) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (hi) independent validation of the Bank’s IRR model and processes when there are material changes to the Bank’s balance sheet and otherwise, as needed, but in no event, less than on an annual basis; (j) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (ik) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; (l) oversight by a senior manager who is sufficiently trained and knowledgeable about managing interest rate risk; and (jm) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must be submitted to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreement, the Bank Board shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection adopt an acceptable revised written Interest Rate Risk Management Program (“IRR Program”)) for the Bank. Refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) The IRR Program shall include risk management systems to identify, measure, monitor, and control interest rate risk (“IRR”), to include at a minimum: (a) the establishment of revisions to formal policies, procedures, and governance commensurate with the Bank’s complexity and business activities, to include: (i) the establishment of IRR appetite appetite, and risk management objectives objectives, commensurate with the Bank’s size, complexity, and risk profile for all interest rate environments, with specific approved and prohibited strategies for managing IRR; (ii) standards for measuring and monitoring IRR; (iii) the frequency of IRR measurement; (iv) determinations of how the Bank will measure the quality of IRR management; and (iiiv) procedures to monitor, escalate, and address any breaches of established IRR limits; (b) accurate and timely risk identification which identify and quantify the major sources and types of IRR; (c) a strategy to reduce the level of balance sheet sensitivity to changing interest rates that is consistent with the Bank’s Strategic Plan; (d) IRR measurement systems that are not dependent on just one measurement system for estimating the Bank’s IRR exposure that, at a minimum, estimates the Bank’s short-term and long-term IRR exposure; (e) the establishment of risk monitoring processes to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider considers the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movement; (df) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or the addition of qualified staff; (eg) enhancements to the establishment of controls over the impact of changes in interest rates on liquid asset valuationsBank’s Model Risk Management program, including but not limited to, thresholds or triggers in asset valuation declines with specific action(sat the minimum: (i) to be taken by the Bank to ensure it maintains sufficient access to assetdevelop and implement effective internal model validation procedures for back-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenariostesting; (fii) back-testing must compare actual modeled results to the modeled scenario that most closely reflects actual rate movements over the testing period; and (iii) differences between modeled and actual outcomes must be reviewed to determine if the variance is due to model development errors, including omission of material factors from the model or inaccurate assumptions or external factors; (h) enhancements to the Bank’s model stress testing process, including at minimum: (i) review and adjust all model assumptions, including beta assumptions, to accurately reflect the changes in liability mix and Board must review and approve the adjustments; and (ii) sensitivity testing around the beta assumptions to identify earnings at risk and economic value of equity implications; (i) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (gj) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (hk) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (il) procedures that require the Board to review and discuss, on at least a quarterly basis, the model test results required by this Article; and (jm) an annual review of the Bank’s adherence to the IRR Program. (3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR ProgramUpon adoption, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR ProgramProgram and any amendments thereto. The Board shall review the effectiveness of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to The Board shall forward a copy of the adopted IRR Program must be submitted Program, and any subsequent amendments thereto, to the Assistant Deputy Comptroller for review and prior written determination within thirty (30) days of no supervisory objectionadoption.

Interest Rate Risk Management. (1) Within ninety sixty (9060) days of the date of this Agreementdays, the Board shall adopt, implement, and thereafter ensure Bank adherence to a comprehensive, written interest rate risk policy. In formulating this policy, the Board shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Interest Rate Risk Management Program (“IRR Program”). Refer refer to the “Interest Rate Risk,” booklet of the Comptroller’s Handbook; OCC Bulletin 2010-1, “Interagency Advisory on Interest Rate Risk Management,” (Jan. 2010); OCC Bulletin 2012-5, “Interest Rate Risk Management: FAQs on 2010 Interagency Advisory on Interest Rate Risk Management,” (Jan. 2012); and “Model Risk Management,” booklet of the Comptroller’s Handbook. (2) . The IRR Program policy shall include risk management systems to identify, measure, monitor, and control provide for a coordinated interest rate risk (“IRR”)strategy and, to include at a minimum, address: (a) the establishment of formal policiesadequate management reports on which to base sound interest rate risk management decisions; (2) Within ninety (90) days, procedures, the Board shall provide management with the following: (a) effective tools to measure and governance commensurate with monitor the Bank’s complexity performance and business activities, to include: (i) the establishment of IRR appetite and overall interest rate risk management objectives with specific approved and prohibited strategies for managing IRR; (ii) determinations of how the Bank will measure the quality of IRR management; and (iii) procedures to monitor, escalate, and address any breaches of established IRR limitsprofile; (b) accurate prudent limits on the nature and timely amount of interest rate risk identification which identify that can be taken; and (c) action plans for reducing exposure in the event that limits are exceeded. (3) Within ninety (90) days, management shall develop reasonable assumptions for all rate sensitive asset and quantify the major sources liability accounts especially for mortgage-backed securities, callable securities and types non-maturity deposits. (a) assumptions should be well-supported, formally documented and based on historically valid data; (b) assumptions should be developed for each type of IRRmodel – earnings-at-risk and economic value of equity; (c) the establishment of risk monitoring processes assumptions for all rate-sensitive accounts should be reported in detail to provide sufficient information on which to base sound IRR management decisions from both an earnings and economic perspective with recognition and consideration of all risks (repricing, basis, yield-curve, and options), to include: (i) limits or triggers on IRR exposures that consider the Bank’s risk appetite, complexity of operations, earnings performance, liquidity position, and capital adequacy; and (ii) IRR reporting standards and procedures that specify the frequency and types of reports senior management and the Board will use to monitor the Bank’s IRR that address: a. the level and trends of aggregate Bank IRR exposure; b. whether management’s strategies are within the Bank’s established risk appetite and policy; c. the sensitivity of any key assumptions; d. whether the Bank holds sufficient capital for its level of IRR; and e. whether management’s major interest rate strategies balance risk with reward, including at a minimum, an evaluation of a potential adverse rate movement against the potential rewards of a favorable rate movementleast annually; (d) requirements for retention of qualified personnel with sufficient authority and responsibility to manage and monitor IRR, which may include additional training or assumptions should be approved by the addition of qualified staff;Board at least annually. (e4) the establishment of controls over the impact of changes in interest rates on liquid asset valuations, including but not limited to, thresholds or triggers in asset valuation declines with specific action(s) to be taken by the Bank to ensure it maintains sufficient access to asset-based and liability-based liquidity to meet funding needs in both expected and adverse conditions, to include at a minimum, rapidly rising interest rate scenarios; (f) adequate and documented support for the reasonableness of assumptions used in the Bank’s IRR model; (g) periodic review and adjustment, when there are material changes to the Bank’s balance sheet and otherwise, as needed, of the assumptions and inputs used in the Bank’s IRR model, that includes sensitivity analysis and model stress testing, with appropriate documentation and governance that requires approval for changes; (h) procedures to test the Bank’s IRR model to compare, reconcile, and report actual performance to simulated results; (i) procedures that require the Board to review and discuss, on On at least a quarterly basis, the model test results required by this Article; and (j) an annual review of the Bank’s adherence management should provide reports to the IRR ProgramBoard detailing compliance with the approved limits and actions being taken to reduce exposure, if applicable. (35) Within one hundred eighty (180) days, the Board shall engage an independent firm to assess the reasonableness of the assumptions used in the earnings-at-risk and economic value of equity models. (a) The independent firm shall report to the Board their findings in writing. (b) Within thirty (30) days following receipt of issuance of the Assistant Deputy Comptrollerreport, management shall implement corrective action to remedy the firm’s written determination of no supervisory objection to the IRR Program or to any subsequent amendment to the IRR Programfindings. (6) Upon adoption, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the IRR Program. The Board shall review the effectiveness a copy of the IRR Program at least annually, but no later than January 31 of each year, and more frequently if necessary or if required by the OCC in writing, and amend the IRR Program as needed or directed by the OCC. Any amendment to the IRR Program must written policy shall be submitted forwarded to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objectionreview.