INTERNAL LOAN REVIEW. (1) The Board shall within thirty (30) days ensure that the Association’s current loan review firm is timely and accurately identifying problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans.
(2) Within sixty (60) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Association’s loan and lease portfolios to assure the timely identification, categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in the “Asset Quality” section of the OTS Examination 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;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and
(i) loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies.
(3) The Board shall hold officers responsible for the self-identification and risk rating of borrowers experiencing credit deterioration.
(4) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Association adherence to a written program providing for independent review of problem loans and leases in the Association’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 Association’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 t...
INTERNAL LOAN REVIEW. ( 1 ) The Board shall within thirty (30) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure the timely and independent identification of problem loans and leases.
( 2 ) Within sixty (60) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in Section 215 of the Comptroller’s Handbook for National Bank Examiners. Such reports shall, at a minimum, include conclusions regarding:
(a) the overall quality of the loan and lease portfolios;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) the identity of the loan officer and/or participating financial institution who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank; and
(i) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
( 3 ) The Board shall evaluate the 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.
INTERNAL LOAN REVIEW. (1) The Board shall within ninety (90) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure the timely and independent identification of problem loans and leases.
(2) Within ninety (90) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in Rating Credit Risk, A-RCR, of the Comptroller’s Handbook. Such reports shall, at a minimum, include conclusions regarding:
(a) the overall quality of the loan and lease portfolios;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of this Article;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank; and
(i) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
(3) 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 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, division, group, indirect dealer, and individual lending officer (the requirement to collect data to support the requirements of this subparagraph is for loans and leases originated, renewed, or restruc...
INTERNAL LOAN REVIEW. (1) Within sixty (60) days, the Board shall establish an effective, independent and ongoing loan review system to review the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in “Rating Credit Risk” 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;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) concentrations of credit;
(f) follow up on previously noted deficiencies listed in either regulatory examination reports or internal loan review reports;
(g) the identification and status of credit related violations of law, rule or regulation; and
(h) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
(2) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program providing for independent review of problem loans and leases in the Bank’s loan and lease portfolios for the purpose of monitoring portfolio trends, on at least a quarterly basis. The program shall require a 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, division, group, 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 imple...
INTERNAL LOAN REVIEW. (1) Within thirty days of the date of this FA, the Board shall establish, implement, and thereafter ensure Bank adherence to an effective, independent and on- going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to validate the grades assigned by the lending staff and assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in “Rating Credit Risk” booklet 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;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article;
(g) loans and leases not in conformance with the Bank's lending and leasing policies;
(h) concentrations of credit; and
(i) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank.
(2) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation.
(3) The Board shall evaluate the internal loan and lease review report(s) and shall ensure that appropriate remedial action 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.
INTERNAL LOAN REVIEW. (1) The Board shall within thirty (30) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure the timely and independent identification of problem loans and leases. A copy of the Bank's proposed "Engagement Letter" with this independent loan review person or firm, and any amendments thereto, shall be submitted to the ADC for review and determination of no supervisory objection.
(2) Within sixty (60) days, the Board shall establish an effective, independent and on- going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in the Rating Credit Risk booklet, A- RCR, of the Comptroller's Handbook issued April 2001 (you may also want to refer to Loan Portfolio Management booklet, A-LPM, of the Comptroller's Handbook). Such reports shall, at a minimum, include conclusions regarding:
(a) the overall quality of the loan and lease portfolios;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of this Article and paragraph;
(g) concentrations of credit;
(h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank;
(i) the adequacy of the Allowance for Loan and Lease Losses; and
(j) loans and leases not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank's lending and leasing policies.
(3) A written description of the program called for in this Article shall be forwarded to the ADC 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.
(5) The Board shall evaluate the 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).
(6) A copy of...
INTERNAL LOAN REVIEW. (1) The Board shall 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.
(2) Within sixty (60) days, the Board shall establish an effective, independent and on- going loan review system that is consistent with the guidelines set forth in Section 215 of the Comptroller’s
INTERNAL LOAN REVIEW. (1) By June 30, 2002, the Board shall establish an effective, independent and on- going loan review system to review, at least quarterly, the Bank's loan and lease portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan and lease grading system consistent with the guidelines set forth in the Rating Credit Risk booklet, A- RCR, of the Comptroller’s Handbook. Such reports shall, at a minimum, include conclusions regarding:
(a) the overall quality of the loan and lease portfolios;
(b) the identification, type, rating, and amount of problem loans and leases;
(c) the identification and amount of delinquent loans and leases;
(d) credit and collateral documentation exceptions;
(e) the 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 not in conformance with the Bank's lending and leasing policies, and exceptions to the Bank’s lending and leasing policies.
(2) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
(4) The Board shall evaluate the 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).
(5) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Bank to collect or strengthen assets identified as problem credits, shall be preserved in the Bank.
INTERNAL LOAN REVIEW. (1) Within sixty (60) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Bank's loan portfolios to assure the timely identification and categorization of problem credits. The system shall provide for a written report to be filed with the Board after each review and shall use a loan grading system consistent with the guidelines set forth in Section 215 of the minimum, include conclusions regarding:
(a) the overall quality of the loan portfolio;
(b) the identification, type, rating, and amount of problem loans;
(c) the identification and amount of delinquent loans;
(d) credit and collateral documentation exceptions;
(e) the identification and status of credit related violations of law, rule or regulation;
(f) loans not in conformance with the Bank's lending policies, and exceptions to the Bank’s lending policies;
(g) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (f) of this Paragraph;
(h) concentrations of credit and significant economic facts and their impact on the credit quality of the Bank’s loan portfolio; and
(i) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Bank.
(2) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the loan review system developed pursuant to this Article.
(3) The Board shall evaluate the internal loan 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 forwarded to the assistant Deputy Comptroller.
INTERNAL LOAN REVIEW. (1) The Board shall, within thirty (30) days, retain a qualified external consultant to review the Bank’s commercial loan portfolio of credits of $100,000 and over. The appointment of the consultant shall be subject to review by the Assistant Deputy Comptroller, who shall have veto authority over the appointment.
(2) Upon receipt of no supervisory objection to the appointment, the consultant shall, within sixty (60) days, report to the Board on the following:
(a) the identification, type, rating, and amount of problem loans;
(b) reasonableness of action plans to resolve basis of concerns on problem credits and timeliness of plan execution and/or collections;
(c) loans not in conformance with the Bank’s lending policies and the volume trends and quality of these non-conforming loans;
(d) credit and collateral documentation exceptions found and timeframe that the exception has existed;
(e) loans and the credit quality of loans to executive officers, directors, and principal shareholders (and their related interests) of the Bank;
(f) the identification and status of credit related violations of law, rule or regulation;
(g) compliance with generally accepted accounting standards and regulatory guidance;
(h) the quality of the consumer, indirect auto dealer, and credit card portfolios; and
(i) effectiveness of management identification, reporting, and management of existing concentrations.
(3) Within thirty (30) days of receipt of the external consultant’s review, the Board shall develop an action plan to address all issues found in the review. Upon completion, the Bank shall forward the consultant’s report and Board’s action plan to the Assistant Deputy Comptroller for review. The Office of the Comptroller of the Currency retains authority to assess the sufficiency of the Board’s action plan.
(4) Within one-hundred fifty days (150) days and with the aid of the consultant required by paragraph (1) of this Article, the Board shall develop, implement, and thereafter ensure Bank adherence to a program which provides for:
(a) timely and comprehensive ongoing financial analysis of borrowers and guarantors to assure accurate risk rating of commercial loan;
(b) compliance with the Bank’s lending policies and laws, rules, and regulations pertaining to the Bank’s lending function;
(c) adequacy of credit and collateral documentation; and
(d) identification and management of concentrations of credit.
(5) Management shall, thereafter, on a quarterly basis, provide the Boar...
