Common use of INTERNAL LOAN REVIEW Clause in Contracts

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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (5) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analysts. (7) 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). (8) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association to collect or strengthen assets identified as problem credits, shall be preserved in the Association.

INTERNAL LOAN REVIEW. (1) The Within sixty (60) days, the Board shall within thirty (30employ or designate a sufficiently experienced and qualified person(s) days or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty ninety (6090) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 QualityRating Credit Risk” section and “Allowance for Loan and Lease Losses” booklets of the OTS Examination 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 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 AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for the self-identification and risk rating of borrowers experiencing credit deterioration. Within ninety (4) Within sixty (6090) days, the Board shall develop, implement, and thereafter ensure Association Bank adherence to a written program providing for independent review of problem loans and leases in the Association’s 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 AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (54) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (65) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (76) 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). (8) 7) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within 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 a new effective, independent and on-going ongoing loan review system to review, at least quarterly, the AssociationBank’s loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 Section 215 of the OTS Examination Handbook. Such reports shall include, at a minimum, conclusions Comptroller’s 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 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 (shareholders, and their related interests) interests of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (52) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (63) The Board shall ensure that the Association Bank has processes, personnel, and control systems systems, including a qualified and accountable Bank officer responsible for oversight of the system, to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (74) 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). (8) 5) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

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 Bank adherence to systems which provide for effective monitoring of early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions. (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 AssociationBank’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 AssociationBank’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 AssociationBank’s lending policies and laws, rules, and regulations pertaining to the AssociationBank’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (53) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (64) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (75) 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). (8) 6) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within Within thirty (30) days days, the Board shall employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty forty-five (6045) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 Loan Portfolio Management and Rating Credit Risk booklets of the OTS Examination 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; (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, the loan officer’s most recent rating of the loan, and the date of that rating; (g) concentrations of credit; (h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the Association’s Bank'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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (5) A written description of the program system called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (64) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (75) 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). (8) 6) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall shall, within thirty sixty (3060) days days, employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty ninety (60120) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, periodically review the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 Loan Portfolio Management booklet, A-LPM, of the OTS Examination 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; (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 AssociationBank; and (i) loans and leases not in conformance with the AssociationBank’s lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for the self-identification and risk rating of borrowers experiencing credit deterioration. Within ninety (4) Within sixty (6090) days, the Board shall develop, implement, and thereafter ensure Association Bank adherence to a written program providing for independent review of problem loans and leases in the Association’s Bank's loan and lease portfolios for the purpose of periodically monitoring portfolio trends, on at least a quarterly basis. The program shall require a quarterly written report to the Board. At a minimum the program shall provide for an independent reviewer’s assessment of the AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (4) Within sixty (60) days, the board shall review a monthly report reflecting the level and trend of major credit and collateral exceptions. The report should track exceptions at the officer level as well as at the bank level. The amount of exceptions should be expressed as a percentage of the dollar amount of each portfolio as well as a percentage of the number of loans in the portfolios. The report should also include the age of each exception. The Board should use this report to ensure that critical documentation is being received in a timely manner to make informed credit decisions and that the number of exceptions remains at a manageable level. (5) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (7) 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). (8) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

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) 90 days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterlysemi-annually, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 rating system consistent with the guidelines set forth in the “Asset QualityRating Credit Risk” section and “Allowance for Loan and Lease Losses” booklets of the OTS Examination 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; (cb) the identification and amount of delinquent loans and leases; (dc) credit and collateral documentation exceptions; (ed) the identification and status of credit related violations of law, rule or regulation; (fe) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (ba) through (ed) 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 (if) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (52) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (63) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (74) 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). (8) 5) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Within ninety (90) days of this Amendment, the Board shall within thirty (30employ or designate a sufficiently experienced and qualified person(s) days or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty one hundred and twenty (60120) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the AssociationBank’s loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 QualityRating Credit Risk” section and “Allowance for Loan and Lease Losses” booklets of the OTS Examination 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) concentrations of credit; (h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for the self-identification Within one hundred and risk rating of borrowers experiencing credit deterioration. twenty (4) Within sixty (60120) days, the Board shall develop, implement, and thereafter ensure Association Bank adherence to a written program providing for independent review of problem loans and leases in the AssociationBank’s loan and lease portfolios for the purpose of monitoring portfolio trends, on at least a quarterly basis. The program shall require a quarterly semi-annual report to the Board. At a minimum the program shall provide for an independent reviewer’s assessment of the AssociationBank’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 AssociationBank’s lending policies and laws, rules, and regulations pertaining to the AssociationBank’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (54) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementationfor a prior determination of no supervisory objection. (65) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (76) 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). (8) 7) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within thirty Within ninety (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 (6090) days, the Board shall establish an effective, independent and on-going loan review system to review, on at least quarterlya semiannual basis, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 QualityRating Credit Risk” section and “Allowance for Loan and Lease Losses” booklets of the OTS Examination 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) concentrations of credit; (h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for the self-identification and risk rating of borrowers experiencing credit deterioration. (42) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Association Bank adherence to a written program providing for independent review of problem loans and leases in the Association’s 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 AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (53) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (64) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (75) 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). (8) 6) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within thirty sixty (3060) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of 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 effective and on-going loan review system to review, at least quarterly, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 Rating Credit Risk, A-RCR, of the OTS Examination Handbook. Such reports shall include, at a minimum, conclusions regarding:Comptroller’s (a) the overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (c) the identification and amount of delinquent loans and leases; (d) credit and collateral documentation exceptions; (e) the identification and status of credit related violations of law, rule or regulation; (f) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (b) through (e) of the Article; (g) concentrations of credit; (h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (5) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) . The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analysts. (7) Article. 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). (8) . A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1( 1 ) The Board shall within thirty (30) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2( 2 ) Within sixty forty-five (6045) days, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, periodically review the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160and provide an assessment of the overall condition of the loan and lease portfolios. 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 Rating Credit Risk booklet, A-RCR, of the OTS Examination Comptroller’s Handbook. Such These 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; (c) the identification and amount of delinquent loans and leases; (db) credit and collateral documentation exceptions; (ec) the identification and status of credit related violations of law, rule or regulation; (fd) the identity of the loan officer and/or participating financial institution who originated each loan reported in accordance with subparagraphs (ba) through (ec) of the ArticleArticle as well as the adequacy of loan officer credit analyses; (g) concentrations of credit; (he) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; andBank; (if) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies.; (3g) The Board shall hold officers responsible the adequacy of allowance 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 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 Association’s lending policies and laws, rules, and regulations pertaining to the Association’s lending functionloss allocations; and (eh) system for monitoring the adequacy of credit and collateral documentationwritten action plans for criticized borrowers as outlined in Article VII. (5) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analysts. (7) 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). (8) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association to collect or strengthen assets identified as problem credits, shall be preserved in the Association.

INTERNAL LOAN REVIEW. (1) The Board Bank shall within thirty ninety (3090) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty The Board shall cause, within ninety (6090) days, the Board Bank's internal loan review system to be revised. The revised system shall establish include an effective, independent and on-going loan review system to reviewwhich reviews, at least quarterly, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 Loan Portfolio Management booklet, A-LPM, of the OTS Examination Handbook. Such reports shall include, at a minimum, conclusions regarding:Comptroller’s (a) the overall quality of the loan and lease portfolios; (b) the identification, type, rating, and amount of problem loans and leases; (c) the identification and amount of delinquent loans and leases; (d) credit and collateral documentation exceptions; (e) the identification and status of credit 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 creditcredit within the loan portfolio being reviewed and, in aggregate, annually; (h) loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for the self-identification cause to be developed and risk rating of borrowers experiencing credit deterioration. implemented within ninety (490) Within sixty (60) days, the Board shall develop, implement, and thereafter ensure Association adherence to days a written program providing for independent review of problem loans and leases in the Association’s 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 AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (54) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller Director upon implementation. (65) The Board shall ensure that cause the Association has Bank to have the processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (76) The Board shall evaluate review the internal loan and lease review report(s) and shall ensure direct that immediate, adequate, and continuing remedial action, if appropriate, is taken upon all findings noted in the report(s). (8) 7) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within thirty sixty (3060) days employ or designate a sufficiently experienced and qualified person(s) or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of 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-on- going loan review system to review, at least quarterly, the Association’s Bank's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 12 C.F.R. § 160.160, Section 260 of the OTS Examination Handbook. Handbook(“Classification of Assets”), OCC Bulletin 2006-47 (“Interagency Policy Statement on the Allowance for Loan and Lease Losses”), and all subsequently issued OCC regulations and guidance.. 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 AssociationBank; and (i) loans and leases not in conformance with the Association’s Bank's lending and leasing policies, and exceptions to the AssociationBank’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 Bank adherence to a written program providing for independent review of problem loans and leases in the Association’s 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 AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (54) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (6) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analysts. (75) 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). (8) 6) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Within ninety (90) days of the date of this Agreement, the Board shall within thirty (30employ or designate a sufficiently experienced and qualified person(s) days or firm to ensure that the Association’s current loan review firm is timely and accurately identifying independent identification of problem loans and leases; as well as develop and implement effective strategies to reduce the Association’s level of problem loans. (2) Within sixty ninety (6090) daysdays of the date of this Agreement, the Board shall establish an effective, independent and on-going loan review system to review, at least quarterly, the AssociationBank’s loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. 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 QualityRating Credit Risk” section and “Allowance for Loan and Lease Losses” booklets of the OTS Examination 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 Articlethis paragraph; (g) concentrations of credit; (h) loans and leases to the Bank’s executive officers, directors, principal shareholders (shareholders, and their related interests) of the Association; and (i) loans and leases not in conformance with the AssociationBank’s lending and leasing policies, and exceptions to the AssociationBank’s lending and leasing policies. (3) The Board shall hold officers responsible for Within ninety (90) days of the self-identification and risk rating date of borrowers experiencing credit deterioration. (4) Within sixty (60) daysthis Agreement, the Board shall develop, implement, and thereafter ensure Association Bank adherence to a written program providing for independent review of problem loans and leases in the AssociationBank’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 AssociationBank’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 AssociationBank’s lending policies and laws, rules, and regulations pertaining to the AssociationBank’s lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (54) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (65) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (76) 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). (8) 7) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

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 Bank adherence to systems which provide for effective monitoring of early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions. (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 Association’s 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 AssociationBank’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 Association’s Bank's lending policies and laws, rules, and regulations pertaining to the Association’s Bank's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (53) A written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementation. (64) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analystsArticle. (75) 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). (8) 6) A copy of the reports submitted to the Board, as well as documentation of the action taken by the Association Bank to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBank.

INTERNAL LOAN REVIEW. (1) The Board shall within Within thirty (30) days days, the General Manager shall ensure that the AssociationBranch’s current loan review firm system is timely effective 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 that the on-going loan review system to reviewreviews, at least quarterly, the Association’s Branch's loan and lease portfolios to assure the timely identification, identification and categorization and classification of problem credits in accordance with 12 C.F.R. § 160.160credits. The system shall provide for a written report to be filed with the Board General Manager 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 HandbookComptroller’s Handbook for Rating Credit Risk dated April 2001. 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; (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 officers of the Branch (and their related interests) of the Association); and (i) loans and leases not in conformance with the Association’s Branch's lending and leasing policies, and including where exceptions to the AssociationBranch’s lending and leasing policiespolicies have been approved. (3) The Board shall hold officers responsible for the self-identification and risk rating of borrowers experiencing credit deterioration. (42) Within sixty ninety (6090) days, the Board General Manager shall develop, implement, and thereafter ensure Association Branch adherence to a written program providing for independent review of problem loans and leases in the Association’s Branch's loan and lease portfolios portfolios, on at least a quarterly basis, for the purpose of monitoring portfolio trends, on at least a quarterly basis. The program shall require a quarterly report to the BoardGeneral Manager. At a minimum minimum, the program shall provide for an independent reviewer’s assessment of the AssociationBranch’s: (a) monitoring systems for early problem loan identification to assure ensure 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 Association’s Branch's lending policies and laws, rules, and regulations pertaining to the Association’s Branch's lending function; and (e) system for monitoring the adequacy of credit and collateral documentation. (53) A Upon implementation, the General Manager shall submit the written description of the program called for in this Article shall be forwarded to the Assistant Deputy Comptroller upon implementationDirector. (64) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article including but not limited to ensuring that additional internal and/or external problem loan identification training is provided for loan officers, loan committee members, credit officers, and credit analysts. (7) The Board General Manager 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). (8) 5) A copy of the reports submitted to the BoardGeneral Manager, as well as documentation of the action taken by the Association Branch to collect or strengthen assets identified as problem credits, shall be preserved in the AssociationBranch.