Common use of LOAN PORTFOLIO MANAGEMENT Clause in Contracts

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's loan portfolio management. The credit policy shall include (but not be limited to): (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (b) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (c) procedures and controls to periodically verify the existence and lien position of collateral; (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (f) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthly; (g) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies; (h) a system to effectively monitor previously charged-off assets and their recovery potential; and (i) a requirement to identify, track and report real estate loans that exceed the supervisory loan-to-value limits. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) On a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's lending and leasing policies, and exceptions to the Association’s lending and leasing policies. (7) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, the Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's ’s loan portfolio management. The credit policy shall include (but not be limited to): (a) revision and/or development of Association procedures to ensure adherence to the Association’s internal lending policies and concentration limits, including, but not limited to, the Association’s commercial lending activities; (b) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (bc) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (cd) procedures and controls to periodically verify the existence and lien position of collateral; (de) procedures that appropriate internal controls to ensure the utilization of interest reserves is appraisals and/or evaluations consistent with established controls the requirements of 12 C.F.R. Part 164 are obtained and clearly defined parameters for projected costs.reviewed on a timely basis prior to consummation of credit facilities: (ef) credit risk rating definitions consistent with applicable regulatory guidance; (fg) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthly; (g) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policiesquarterly; (h) a system to effectively monitor previously charged-off assets and their recovery potential; and; (i) a requirement to identify, track and report all loans approved as exceptions to the lending policy, including real estate loans that exceed the supervisory loan-to-value limits; and (j) procedures to track and analyze concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysisBeginning September 30, particularly analysis using information from tax returns2012, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) On on a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's ’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies. (73) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, the Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's loan portfolio management. The credit policy shall include (but not be limited to):be (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (b) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (c) procedures and controls to periodically verify the existence and lien position of collateral; (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (fe) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthlyquarterly; (gf) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies; (hg) a system to effectively monitor previously charged-off assets and their recovery potential; and; (ih) a requirement to identify, track and report all loans approved as exceptions to the lending policy, including real estate loans that exceed the supervisory loan-to-value limits; and (i) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates rates, concentration risks and appropriate economic factors. (54) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (65) On a quarterly basis management will provide Within sixty (60) days, the Board with written reports includingshall adopt, at a minimum, the following information: (a) the identification, type, ratingimplement, and amount of problem loans and leases; thereafter ensure Association adherence to a policy to ensure that Other Real Estate Owned (b“OREO”) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported is managed in accordance with subparagraphs OTS Examination Handbook Section 251 (a) through Real Estate Owned and Repossessed Assets), the Interagency Guidance on Accounting for Dispositions of Other Real Estate Owned (d) of this Article and Paragraph; (f) an analysis of concentrations of creditJuly 16, significant economic factors1993), and general conditions 12 C.F.R. Part 160. The policy shall include, but not be limited to, procedures to require timely appraisals pursuant to 12 C.F.R. § 160.172 and their impact on the credit quality of the Association’s loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's lending and leasing policies, and exceptions to the Association’s lending and leasing policies12 C.F.R. Part 164. (76) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, the Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's ’s loan portfolio management. The credit policy shall include (but not be limited to): (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (b) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (c) procedures and controls to periodically verify the existence and lien position of collateral; (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (fe) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthlyquarterly; (gf) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies; (hg) a system to effectively monitor previously charged-off assets and their recovery potential; and; (ih) a requirement to identify, track and report all loans approved as exceptions to the lending policy, including real estate loans that exceed the supervisory loan-to-value limits; and (i) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates rates, concentration risks and appropriate economic factors. (54) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (65) On a quarterly basis management will provide Within sixty (60) days, the Board with written reports includingshall adopt, at a minimum, the following information: (a) the identification, type, ratingimplement, and amount of problem loans and leases; thereafter ensure Association adherence to a policy to ensure that Other Real Estate Owned (b“OREO”) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported is managed in accordance with subparagraphs OTS Examination Handbook Section 251 (a) through Real Estate Owned and Repossessed Assets), the Interagency Guidance on Accounting for Dispositions of Other Real Estate Owned (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factorsJuly 16,1993), and general conditions 12 C.F.R. Part 160. The policy shall include, but not be limited to, procedures to require timely appraisals pursuant to 12C.F.R, § 160.172 and their impact on the credit quality of the Association’s loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's lending and leasing policies, and exceptions to the Association’s lending and leasing policies12 C.F.R. Part 164. (76) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing sodays of the date of this Agreement, the Board shall develop, adopt, implement, and thereafter ensure Bank adherence to a written program to ensure effective and safe and sound management of the Bank’s loan portfolio. The program shall include, but not be limited to: (a) procedures to ensure consistent application of the Bank’s underwriting criteria; (b) procedures to ensure accurate and timely risk rating of credits; (c) procedures to accurately and timely identify and control risk throughout the credit process; (d) procedures to ensure satisfactory and perfect collateral documentation; (e) procedures to document and monitor action plans to work out problem assets, which shall include timely and targeted dates for disposition; (f) procedures to ensure that extensions of credit are granted, by renewal or otherwise, to any borrower only after obtaining and analyzing current and satisfactory credit information; (g) procedures to ensure conformance with loan approval requirements; (h) a system to track and analyze exceptions; (i) procedures to ensure conformance with Call Report Instructions; (j) procedures to ensure the accuracy of internal management information systems; and (k) procedures to track and analyze concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Bank’s loan and lease portfolios. (2) Upon completion, a copy of the program shall be submitted to the Assistant Deputy Comptroller. (3) Within ninety (90) days of the date of this Agreement, the Board shall develop and adopt and the Association Bank (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve systems that provide for the Association's effective monitoring of the Bank’s loan portfolio management. The credit policy shall include (but not be limited to):portfolio, including: (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely early problem loan identification, including non-accrual loansidentification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) procedures statistical records that require ongoing monitoring will serve as a basis for identifying sources of borrower ability to repay the loan through receipt problem loans and documented review of current borrowerleases by industry, principal size, collateral, division, group, indirect dealer, and guarantor financial informationindividual lending officer; (c) procedures loan portfolio concentration limits that are measured and controls monitored in relation to periodically verify the existence Bank’s Tier 1 capital (as defined in 12 C.F.R. Part 3) and lien position of collateralAllowance for Loan and Lease Losses (“Allowance”); (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (f) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthly; (g) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies; (h) a system to effectively monitor previously charged-off assets and their recovery potential; and; (ie) compliance with the Bank’s lending policies and laws, rules, and regulations pertaining to the Bank’s lending function; (f) a requirement policy for administering the Allowance that, at a minimum, complies with OCC Bulletin 2006-47 (Guidance and Frequently Asked Questions on the ALLL) (December 13, 2006) addresses the necessary controls for supporting the appropriateness of the Allowance level and documentation of the factors used to identify, track estimate credit losses and report real estate loans that exceed the supervisory loan-to-value limits. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profileimpairments. (4) Within sixty (60) days the Board shall adoptBeginning March 31, implement 2015 and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) On on a quarterly basis management will shall provide the Board with written reports including, at a minimum, minimum the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (4) (a) through (d) of this Article and ParagraphArticle; (f) the identity of the loan officer responsible for the ongoing administration of each loan maintained within the Bank’s loan portfolio; (g) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the AssociationBank’s loan and lease portfolios; (gh) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the AssociationBank; and (hi) the identification of 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. (7) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's loan portfolio management. The credit policy shall include (but not be limited to): (a) revision and/or development of the Association’s 's procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (b) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (c) procedures and controls to periodically verify the existence and lien position of collateral; (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (f) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthly; (g) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s 's lending and leasing policies, and exceptions to the Association’s 's lending and leasing policies; (h) a system to effectively monitor previously charged-off assets and their recovery potential; and (i) a requirement to identify, track and report real estate loans that exceed the supervisory loan-to-value limits. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s 's risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Association adherence to written policies and procedures governing management of matured loans. The policy shall include, among other things, procedures for active and material reduction in the Association's level of matured loans, and timely collection and possession of collateral. The policy shall be consistent with OCC Bulletin 2009-32 (Policy Statement on Prudent Commercial Loan Workouts) and other applicable regulatory guidance. (7) On a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s 's loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's lending and leasing policies, and exceptions to the Association’s 's lending and leasing policies. (7) 8) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty (60) days, Board shall establish credit risk management practices that ensure effective credit administration, portfolio management and monitoring, and risk mitigation. In doing so, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure adherence to a written credit policy to improve the Association's loan portfolio management. The credit policy shall include (but not be limited to): (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings and proper and timely problem loan identification, including non-accrual loans; (b) procedures that require ongoing monitoring of borrower ability to repay the loan through receipt and documented review of current borrower, principal and guarantor financial information; (c) procedures and controls to periodically verify the existence and lien position of collateral; (d) procedures that ensure the utilization of interest reserves is consistent with established controls and clearly defined parameters for projected costs. (e) credit risk rating definitions consistent with applicable regulatory guidance; (f) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthly; (g) written reports, regularly submitted to the Board, identifying the aggregate loans and leases not in conformance with the Association’s lending and leasing policies, and exceptions to the Association’s lending and leasing policies; (h) a system to effectively monitor previously charged-off assets and their recovery potential; and (i) a requirement to identify, track and report real estate loans that exceed the supervisory loan-to-value limits. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Association adherence to written policies and procedures governing management of matured loans. The policy shall include, among other things, procedures for active and material reduction in the Association’s level of matured loans, and timely collection and possession of collateral. The policy shall be consistent with OCC Bulletin 2009-32 (Policy Statement on Prudent Commercial Loan Workouts) and other applicable regulatory guidance. (7) On a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the Association’s loan and lease portfolios; (g) the identification and amount of loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Association; and (h) the identification of loans and leases not in conformance with the Association's lending and leasing policies, and exceptions to the Association’s lending and leasing policies. (7) 8) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the program and systems developed pursuant to this Article.

LOAN PORTFOLIO MANAGEMENT. (1) Within sixty The Board shall, within ninety (6090) days, Board shall establish credit risk management practices that ensure effective credit administrationdevelop, portfolio management and monitoringadopt, and risk mitigation. In doing soimplement, the Board shall adopt and the Association (subject to Board review and ongoing monitoring) shall implement and thereafter ensure Bank adherence to a written credit policy program to improve the AssociationBank's loan portfolio management. The credit policy written program shall include (include, but not be limited to):: (a) revision and/or development of the Association’s procedures to ensure accuracy of risk ratings satisfactory and proper and timely problem loan identification, including non-accrual loansperfected collateral documentation; (b) procedures to ensure that require ongoing monitoring extensions of credit are granted, by renewal or otherwise, to any borrower ability to repay the loan through receipt only after obtaining and documented review of analyzing current borrower, principal and guarantor financial satisfactory credit information; (c) procedures and controls to periodically verify the existence and lien position of collateralensure conformance with loan approval requirements; (d) procedures that ensure the utilization of interest reserves is consistent with established controls a system to track and clearly defined parameters for projected costs.analyze exceptions; (e) credit risk rating definitions consistent procedures to ensure conformance with applicable regulatory guidanceCall Report instructions, including the identification and proper accounting treatment of nonaccrual loans; (f) procedures for early problem loan identification, to ensure that credits are accurately risk rated at least monthlythe accuracy of internal management information systems; (g) written reportsa formal, regularly submitted ongoing training program designed to ensure that officers and employees who are, or will be, involved in lending or loan administration are adequately trained to carry out their responsibilities. At a minimum, such a training program shall address: (i) loan structuring, credit analysis, underwriting standards and credit administration; and (ii) identified weaknesses in the Board, identifying skills and abilities of the aggregate loans and leases not in conformance with the AssociationBank’s lending and leasing policies, and exceptions to the Association’s lending and leasing policieslenders; (h) a system performance appraisal process, including performance appraisals, job descriptions, and incentive programs for loan officers, which adequately considers their performance relative to effectively monitor previously charged-off assets policy compliance, documentation standards, accuracy in credit grading, and their recovery potential; andother loan administration matters; (i) a requirement procedures to identify, track and report real estate loans that exceed the supervisory loan-to-value limits. (2) The Board shall ensure that Association personnel performing credit analyses are adequately trained in cash flow analysis, particularly analysis using information from tax returns, and that processes are in place to ensure that additional training is provided as needed. (3) The Board shall ensure that management adequately staffs the Credit Department with personnel who possess the appropriate expertise relative to the Association’s risk profile. (4) Within sixty (60) days the Board shall adopt, implement and ensure Association adherence to a written portfolio stress testing policy that considers changes in interest rates and appropriate economic factors. (5) A written report of the stress test results shall be provided to the Board by Association management at least quarterly. (6) On a quarterly basis management will provide the Board with written reports including, at a minimum, the following information: (a) the identification, type, rating, and amount of problem loans and leases; (b) the identification and amount of delinquent loans and leases; (c) credit and collateral documentation exceptions; (d) the identification and status of credit related violations of law, rule or regulation; (e) the identity of the loan officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and Paragraph; (f) an analysis of analyze concentrations of credit, significant economic factors, and general conditions and their impact on the credit quality of the AssociationBank’s loan and lease portfolios; (gj) a program designed to assure the timely identification and amount rating of criticized loans and leases to executive officers, directors, principal shareholders (and their related interests) of the Associationleases; and (hk) the identification of loans and leases not in conformance procedures to ensure compliance with the AssociationBank's lending policies and leasing policieslaws, rules, and exceptions regulations pertaining to the Association’s Bank's lending and leasing policiesfunction. (72) The Board Upon completion, a copy of the written program shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence be forwarded to the program and systems developed pursuant to this ArticleAssistant Deputy Comptroller.