Common use of LENDING POLICY Clause in Contracts

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions). This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period. (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (r) guidelines for periodic review of the Association’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s 's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending TransactionsLimitations). This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s 's trade area; (h) guidelines and limitations for loans originating outside of the Association’s 's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s 's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (r) guidelines for periodic review of the Association’s 's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within thirty (30) days, the Board shall review and revise the Bank’s written loan policy to strengthen underwriting and reduce credit risk by: (a) establishing strict financial requirements for unsecured lending; (b) establishing strict criteria for collateral concentration limits and delinquency cross-age rules for accounts receivable lending; (c) establishing strict analytical standards for loans secured by blanket liens on business assets, including treating such loans as unsecured when they lack adequate documentation, or reasonable assessment, of collateral values; (d) requiring the exclusion of capital gains income when calculating personal debt coverage ratios for individuals; (e) requiring lending officers and staff to obtain all necessary credit and financial information prior to the booking of new credits; and (f) requiring lending officers and staff to obtain and review all credit and financial statement information necessary to monitor existing credits. (2) Within sixty (60) days, the Board shall further review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ec) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fd) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (me) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nf) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (og) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iiiii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (ph) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (qi) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rj) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (23) Upon adoption, the policy shall be implemented, the The Board shall thereafter ensure Association adherence to adopt and implement the revised loan policy, and a copy of thereafter ensure Bank adherence to such policy. Upon adoption by the Board, the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) daysdays of the date of this Agreement, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the "Loan Portfolio Management" booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which that deviate from the AssociationBank’s normal course of business, including all credits which that deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall:Banking Circular 255 and OCC Bulletin 2000- (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. . (qr) charge-off guidelines, consistent with Generally Accepted Accounting Principles and OCC Bulletin 2000-20, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon completion, a copy of the program shall be immediately forwarded to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. Upon adoption, the policy shall be implemented, and the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that be responsible for the Association has Bank having the processes, personnel, and control systems in place necessary to ensure implementation of implement and adherence adhere to the policy program and systems developed pursuant to this Article.

LENDING POLICY. (1) Within sixty thirty-five (6035) daysday of this Amendment, the Board shall review and revise the AssociationBank’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) required loan officer expertise (including education, experience, knowledge, and skills) necessary to support the Bank’s description of acceptable types of loans; (c) a provision that current and satisfactory credit information will be obtained on each borrower; (cd) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (de) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ef) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fg) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (gh) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the AssociationBank’s trade area; (i) guidelines and limitations for originating loans outside of the Bank’s trade area and expertise; (j) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jk) distribution of loans by category; (kl) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (m) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (ln) guidelines and limitations on concentrations of credit; (mo) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (np) measures to correct the deficiencies in the AssociationBank’s lending procedures noted in any ▇▇▇; (oq) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic planRemedial Action Plan, receive the prior approval of the Board, or a committee thereof. (pr) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qs) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rt) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a A copy of the policy shall be forwarded to the Assistant Deputy Comptroller for reviewa prior written determination of no supervisory objection. Within ten (10) days of the receipt of the determination of no supervisory objection, the policy shall be adopted and implemented, and the Board shall thereafter ensure Bank adherence to the policy. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 181, setting forth the criteria under which renewals of extensions of credit may be approvedwhen purchasing loans and loan participations. At a minimum the policy shallminimum, guidelines should include: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; andwritten lending policies and procedures governing these transactions; (ii) an agreement by the obligor to make full credit information available to the selling bank; (iii) agreement by the selling bank to provide guidelines and limitations available information on the capitalization obligor to the purchase; and, (iv) written documentation of interestrecourse arrangements outlining the rights and obligations of each party. (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the AssociationBank’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively strongerminimum debt service coverage requirements for each acceptable loan type; (f) a pricing policy that takes into consideration costs, general overhead, loans eligible for interest only terms and probable loan losses, while providing maximum terms for a reasonable margin of profitinterest only structure; (g) maximum amortization requirements for each acceptable loan type; (h) a definition of the AssociationBank’s trade area; (hi) guidelines and limitations for loans originating outside of the AssociationBank’s trade area; (ij) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jk) distribution of loans by category; (kl) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (ip) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (iii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and; (iiiii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof, and. (pq) establish guidelines for independent appraisal ordering and review for new loan originations and renewals. (r) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)OCC Bulletin 2000-20, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and; (ii) provide guidelines and limitations on the capitalization of interest.; and (qs) charge-off guidelines, by type of loan or other asset, including Other Real Estate OwnedOwned and overdrafts, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (r) guidelines for periodic review of the Association’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policypolicy and construction underwriting standards. In revising this policythe loan policy and underwriting standards, the Board shall refer to 12 C.F.R. §§ 160.93 the Loan Portfolio Management and 160.170 Commercial Real Estate and Construction Lending booklets of the Comptroller’s Handbook. The loan policy (Lending Limitations letters a – o below) and Records for Lending Transactions). This policy construction underwriting standards (letters p – s below) shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (hg) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ih) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (ji) distribution of loans by category; (kj) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lk) guidelines and limitations on concentrations of credit; (ml) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nm) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (on) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (qo) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (p) cash flow analyses are performed on construction loan borrowers; (q) copies of original invoices are received and retained in file, scrutinized and compared to the construction budget to identify and resolve cost overruns; (r) guidelines periodic inspections are performed on all construction projects; and (s) all construction loans are either in conformity with the Bank's construction loan policies and procedures or in compliance with the Bank's written provisions for periodic review of the Association’s adherence exceptions to the revised lending policyloan policies and procedures. (2) Upon adoption, the loan policy and construction underwriting standards shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policypolicy and underwriting standards, and a copy of the policy and underwriting standards shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within ninety (90) days, the Board shall develop, implement, and thereafter ensure Bank adherence to systems, which provide for effective monitoring of: (a) compliance with the Bank’s lending policy and construction underwriting standards, laws, rules, and regulations pertaining to the Bank’s lending function; (b) a system to track and analyze policy exceptions; (c) adequacy of credit and collateral documentation, and (d) concentrations of credit. (4) On a quarterly basis management will provide the Board with a written report including the identification of loans not in conformance with the Bank’s lending policies, and exceptions to the Bank’s lending policy and underwriting standards. (5) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy and underwriting standards developed pursuant to this Article. (6) Upon completion, the Board shall submit a copy of the program to the Assistant Deputy Comptroller for review.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) standards for obtaining current and satisfactory collateral valuations; (d) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (de) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ef) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (ni) measures to correct a requirement that all credits that deviate from the deficiencies in Bank’s normal course of business, including all credits that deviate from the AssociationBank’s lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight written strategic plan or are outside of the loan approval processbank’s defined trade area in (g) above, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require receive the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rj) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the Board shall establish requirements for all new and renewed loans that have loan officer certification of compliance with the loan policy, or if exceptions exist, that they are reported in the credit presentation, and approved by the appropriate lending committee authority. (3) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the “Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers guidelines for unknown or inappropriate purposes unsecured lending, including but not limited to use as a source of permanent working capitalmaximum loan amortization periods, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high maximum loan to value ratios, financing was extended to pay for developer’s soft costsmaturities, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.minimal credit standards; (b) a provision that current safe and satisfactory credit information will be obtained sound limits on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loanmachinery and equipment loans; (ec) collection procedures, to include follow-up efforts, efforts that are systematically and progressively stronger; (fd) a pricing policy that takes into consideration costs, general overhead, procedures to ensure lenders obtain and probable loan losses, while providing analyze documentation for a reasonable margin of profitall participations purchased in accordance with Banking Circular 181; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (oe) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish lower dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required;; and (ii) establish lower dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pf) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)prudent banking practices, setting forth the criteria under which extensions or renewals of extensions of credit may be approved. At a minimum the policy these guidelines shall: (i) ensure that extensions and renewals are not made for the sole purpose of reducing the volume of loan delinquencies; anddelinquencies or to improve a borrower’s debt service coverage ratios or to match competition, unless supported by prudent underwriting; (ii) provide guidelines and establish limitations on the maximum number of renewals allowed in any one year and over the life of a loan; (iii) require the collection of interest prior to renewals or extensions; and, (iv) prohibit capitalization of interestinterest unless such capitalization is deemed appropriate pursuant to the guidance in Examining Circular 229, Guidelines for Capitalization of Interests on Loans. (qg) charge-guidelines for charging off guidelines, by type of loan or other assetassets, including Other Real Estate Owned, addressing that address the circumstances under which a charge-off would be appropriate and ensuring the recognition of ensure that losses are recognized within the quarter of discovery; and (rh) guidelines for periodic review and reporting to the Board of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the revised policy shall be forwarded to the Assistant Deputy Comptroller for reviewreview and determination of no supervisory objection. (3) The Upon receipt of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Articlepolicy.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit, including unsecured loans; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October Banking Circular 255, dated July 30, 2009)1991, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. thereof (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (qo) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rp) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty one hundred and twenty (60120) days, the Board shall review and revise the AssociationBank’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period. (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (kb) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lc) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nd) measures to correct the deficiencies in the AssociationBank’s lending procedures noted in any ▇▇▇; (oe) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, in the amount of two hundred and fifty thousand dollars ($250,000.) or greater receive the prior approval of the Board, or a committee thereof. (pf) guidelines consistent with The Federal Financial Institutions Examination Council’s the Retail Classification Policy (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009OCC Bulletin 2000-20), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qg) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (rh) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy; (i) requirements for construction loans, draws and inspections; (j) an appraisal review process that is independent and effective; and (k) a process for periodic reviews and Board approval of the appraiser list. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and, (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and, (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and, (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (hg) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lh) guidelines and limitations on concentrations of credit; (mi) a limitation limitations on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nj) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pk) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (ql) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rm) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller ADC for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lj) guidelines and limitations on concentrations of credit; (mk) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (ol) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pm) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qn) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (ro) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) 60 days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board or its delegees shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (kg) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lh) guidelines and limitations on concentrations of credit; (mi) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nj) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇procedures; (ok) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) shall establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pl) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qm) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rn) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)utilize as guidance the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This revised policy shall incorporateinclude, but not necessarily be limited to, the following: (a) a description of acceptable types each type of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown loan the Bank may originate or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.purchase; (b) a provision prohibition against requesting or requiring borrowers or potential borrowers to sign notes in blank for later use; (c) a requirement that current and satisfactory credit information will be obtained on each borrower, including appropriate credit information on guarantors and partners of the borrower involved in the loan or collateral, and a search of public records for tax liens, judgments or other public information that impacts the creditworthiness of the borrower; (cd) a maturity scheduling related to schedule for each type of loan authorized, based on the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (de) maximum ratio ratios of loan value to the appraised value or acquisition costs of collateral securing the loan; (ef) collection procedures, to procedures that include follow-up efforts, that which are systematically and progressively strongerstronger and comply with Article IX of this Agreement; (fg) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (ji) distribution of loans by category; (kj) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lk) guidelines and limitations on concentrations of credit; (l) guidelines and limitations on the approval of overdrafts and the practice of debiting customers’ accounts when the debit creates or increases an existing overdrawn position; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on individual extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; (iii) establish reporting requirements and approval criteria for overdrafts; and (iiiiv) require that all credits which that deviate from the AssociationBank’s normal course of business, including all types of credits which deviate from not authorized under the Association’s written strategic planpolicy, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are accurately reflected as renewals and not as new notes and that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.interest and the renewal of loans without the payment of interest or a reduction in principal and the renewal of loans when new funds are the advanced; (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (r) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, implemented and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank adheres to the policy and has processes, personnel, and control systems adequate for the Bank to ensure implementation of implement and adherence adhere to the policy developed pursuant to this Articlepolicy.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following:the (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period. (b) a provision that current and satisfactory credit information will be obtained on each borrower; (cb) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (dc) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ed) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fe) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profitglobal cash flow analysis on each borrower supplemented by borrower- supplied information; (g) a definition of the Association’s trade area; (hf) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (kg) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lh) guidelines and limitations on concentrations of credit; (mi) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nj) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pk) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (ql) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rm) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision underwriting standards to ensure that the terms and conditions of construction loans are reasonable and that these relationships are closely monitored; (c) standards 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 will be obtained on each borrowerinformation; (cd) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (de) maximum ratio of loan value to appraised value or and acquisition costs of collateral securing the loan; (ef) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fg) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (gh) a definition of the Association’s Bank's trade area; (hi) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ij) a limitation on the aggregate outstanding volume of loans in relation to other balance sheet accountsbe serviced by the Bank’s lending staff, including not only the Bank’s loan portfolio, but also sold or participated loans that are serviced by the Bank’s lending staff; (jk) the distribution of loans by category; (kl) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (m) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (ln) guidelines and limitations on concentrations of credit; (mo) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (np) a provision that a detailed, written analysis of any loan or aggregated extensions of credit to any one borrower which exceeds one hundred thousand dollars ($100,000) shall be prepared and provided to the Board; (q) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇Report of Examination; (or) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written loan policy and strategic plan, receive the prior approval of the Board, or a committee thereof. (ps) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qt) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (u) guidelines for the Bank's problem loan resolution process; (v) guidelines and limitations for loan portfolio growth; and (rw) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the Loan policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the Loan policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policypolicy for the consumer and commercial portfolios. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇Report of Examination; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (s) guidelines for compliance with OCC Bulletin 2000-20; and (rt) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon Prior to adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for reviewreview and prior written determination of no supervisory objection. After the Assistant Deputy Comptroller has advised the Bank that he does not take supervisory objection to the policy, the Board shall immediately adopt, implement, and shall thereafter ensure adherence to, the terms of the lending policy. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the “Loan Portfolio Management” booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including any loan where the proceeds, or assets purchased with the proceeds, are transferred to an insider or an insider’s related interest, other than in a bona fide arm’s length transaction where the proceeds are used to acquired property, goods, or services; (i) at a minimum, guidelines for loans to insiders shall incorporate, but not necessarily be limited to: a statement that such loans will shall not be granted on terms more favorable than those offered to similar outside borrowersborrowers and procedures for documenting comparable transactions; an insider loan pricing policy; and, procedures for insider loans that require Board approval; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nf) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any the ▇▇▇▇ or any subsequent Report of Examination; (og) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the Association’s written strategic plan, business receive the prior approval of the Board, or a committee thereof. (ph) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)OCC Bulletin 2000-20, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum minimum, the policy shall: (i) shall ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and; (ii) provide guidelines and limitations on the capitalization of interest. (qi) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rj) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the . The Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any R▇▇▇;; and, (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof; (iv) require that all new, renewed, extended, restructured or altered credits in excess of fifty thousand dollars ($50,000) which deviate from the Bank’s lending policy receive the prior approval of the Board, or a committee thereof. A copy of the Board or committee approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (pv) require that all new, renewed, extended, restructured or altered credits in the amount of fifty thousand dollars ($50,000) or less which deviate from the Bank’s lending policy receive the prior written approval of the bank’s senior lending officer. A copy of the written approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (q) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller ADC for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇Report of Examination; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for reviewreview and prior written determination of no supervisory objection. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty one hundred twenty (60120) days, the Board shall review and revise the AssociationBank’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) guidelines for the appraisal ordering process that ensure independence; (f) guidelines for the scope and quality of appraisals that are in conformance with 12 C.F.R. Part 34 and Interagency Appraisal and Evaluation Guidelines dated October 27, 1994; (g) the circumstances in which a re-appraisal of properties is required; (h) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fi) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (hj) guidelines and limitations for loans originating outside of the AssociationBank’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jk) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of creditcredit consistent with Article VI of this Agreement; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the AssociationBank’s lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (r) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan lending policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.lending; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pf) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qg) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (h) unsecured lending guidelines for all departments; (i) 90-day note guidelines including maximum number of allowable renewals and amortization; (j) guidelines and underwriting criteria for the origination of consumer purpose loans that incorporate information contained in the Uniform Retail Classification and Account Management Policy Statement dated June 12, 2000; and (rk) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the lending policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policypolicy including conformance with the Uniform Retail Classification and Account Management Policy Statement, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the lending policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller's Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) establishing minimum requirements for uniform and comprehensive credit analysis, including full disclosure of all significant aspects of the proposed credit and an assessment of the risks involved, prior to credit approval; (d) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (de) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ef) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) limitations on participation loans by aggregate dollar per individual institution, and specific guidelines to properly administer participation loans; (l) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (m) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (ln) guidelines and limitations on concentrations of credit; (mo) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (np) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any Report of Examination (R▇▇▇;); and (oq) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s Bank's normal course of business, including all credits which deviate from the Association’s Bank's written strategic plan, receive the prior approval of the Board, or a committee thereof. (pr) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Banking Circular 255, Troubled Loan Workouts (October 30, 2009), and Loans to Borrowers in Troubled Industries setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qs) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rt) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (u) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) daysdays of the date of this Agreement, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the “Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) limitations regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit;, including methods (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇the Report of Examination; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) i. establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) . establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) . require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) i. ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) . provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (s) guidelines to ensure that the Allowance for Loan and Lease Losses methodology conforms to the Interagency Policy Statement on the ALLL dated December 13, 2006, as defined in the Report of Examination; and (rt) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any R▇▇▇;; and, (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof; (iv) require that all new, renewed, extended, restructured or altered credits in excess of fifty thousand dollars ($50,000) which deviate from the Bank’s lending policy receive the prior approval of the Board, or a committee thereof. A copy of the Board or committee approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (pv) require that all new, renewed, extended, restructured or altered credits in the amount of fifty thousand dollars ($50,000) or less which deviate from the Bank’s lending policy receive the prior written approval of the bank’s senior lending officer. A copy of the written approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (q) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.: (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller ADC for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty forty-five (6045) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (hg) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ih) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (ji) distribution of loans by category; (kj) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lk) guidelines and limitations on concentrations of credit; (ml) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nm) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (on) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (po) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qp) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rq) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, A copy of the Board's policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded submitted to the Assistant Deputy Comptroller for reviewreview and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the policy. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the “Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy; and (t) guidelines to ensure the responsible disclosure and administration of overdraft protection services in accordance with the Joint Guidance on Overdraft Protection Programs, dated February 18, 2005, as well as compliance with all other applicable laws relating to overdrafts, including the Regulation E opt-in requirements for ATM and one-time debit card transactions and the disclosures required pursuant to Regulation DD. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jh) distribution of loans by category; (ki) guidelines a prohibition regarding the use of brokered deposits, except locally generated deposits for loans the Certificate of Deposit Account Registry Services, to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowersfund loan growth or support criticized loans; (lj) guidelines and limitations on concentrations of credit; (mk) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nl) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (om) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pn) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qo) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (rp) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (q) Guidelines consistent with Banking Circular 181, setting forth the criteria for underwriting purchased participations; and (r) Guidelines consistent with OCC Bulletin 2000-20, setting forth the criteria consistent with regulatory guidance on classification of retail credits. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇;; and, (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof; (iv) require that all new, renewed, extended, restructured or altered credits in excess of fifty thousand dollars ($50,000) which deviate from the Bank’s lending policy receive the prior approval of the Board, or a committee thereof. A copy of the Board or committee approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (pv) require that all new, renewed, extended, restructured or altered credits in the amount of fifty thousand dollars ($50,000) or less which deviate from the Bank’s lending policy receive the prior written approval of the bank’s senior lending officer. A copy of the written approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (q) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.: (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller ADC for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policypolicy and construction underwriting standards. In revising this policythe loan policy and underwriting standards, the Board shall refer to 12 C.F.R. §§ 160.93 the Loan Portfolio Management and 160.170 Commercial Real Estate and Construction Lending booklets of the Comptroller’s Handbook. The loan policy (Lending Limitations letters a – o below) and Records for Lending Transactions). This policy construction underwriting standards (letters p – s below) shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (hg) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ih) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (ji) distribution of loans by category; (kj) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lk) guidelines and limitations on concentrations of credit; (ml) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nm) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (on) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the Association’s normal course of business, including all credits which deviate from the Association’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009), setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest. (qo) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (p) cash flow analyses are performed on construction loan borrowers; (q) copies of original invoices are received and retained in file, scrutinized and compared to the construction budget to identify and resolve cost overruns; (r) periodic inspections are performed on all construction projects; and (rs) guidelines all construction loans are either in conformity with the Bank's construction loan policies and procedures or in compliance with the Bank's written provisions for periodic review of the Association’s adherence exceptions to the revised lending policyloan policies and procedures. (2) Upon adoption, the loan policy and construction underwriting standards shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policypolicy and underwriting standards, and a copy of the policy and underwriting standards shall be forwarded to the Assistant Deputy Comptroller for review. (3) Within ninety (90) days, the Board shall develop, implement, and thereafter ensure Bank adherence to systems, which provide for effective monitoring of: (a) compliance with the Bank’s lending policy and construction underwriting standards, laws, rules, and regulations pertaining to the Bank’s lending function; (b) a system to track and analyze policy exceptions; (c) adequacy of credit and collateral documentation, and (d) concentrations of credit. (4) On a quarterly basis management will provide the Board with a written report including the identification of loans not in conformance with the Bank’s lending policies, and exceptions to the Bank’s lending policy and underwriting standards. (5) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy and underwriting standards developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) daysdays of the date of this Agreement, the Board shall review and revise the AssociationBank’s written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the “Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the AssociationBank’s trade area; (h) guidelines and limitations for loans originating outside of the AssociationBank’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) limitations regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit, including methods to monitor and stress test accepted concentrations; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the AssociationBank’s lending procedures noted in any ▇▇▇the Report of Examination; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) i. establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) . establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) . require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) i. ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) . provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; (s) guidelines to ensure that the Allowance for Loan and Lease Losses methodology conforms to the Interagency Policy Statement on the ALLL dated December 13, 2006, as defined in the Report of Examination; and (rt) guidelines for periodic review of the AssociationBank’s adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty one hundred twenty (60120) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines considering the skills and expertise of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developerthe Bank’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.staff; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) a requirement that all loan advances or renewals equal to or exceeding fifty thousand dollars ($50,000) be supported by written analysis of the credit’s: (i) purpose and terms, (ii) primary and secondary sources of repayment, (iii) current and historic cash flow and/or debt service coverage, (iv) current and historic solvency, (v) current and historic liquidity, (vi) collateral adequacy, (vii) assigned risk rating with support for the rating, (viii) pricing, and (ix) compliance with applicable law and Bank policy; (d) guidelines and limitations on desired current ratio, debt-to-equity ratio, and debt service coverage ratio for various types of credit; (e) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (df) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (eg) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fh) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, and interest rate risk, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lj) guidelines and limitations on concentrations regarding volume of creditclassified assets as a percentage of Tier I Capital plus the Allowance for Loan and Lease Losses; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s lending procedures noted in any ▇▇▇; (ok) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the Association’s written strategic plan, business receive the prior approval of the Board, or a committee thereof. (pl) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qm) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rn) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (hd) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ie) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jf) distribution of loans by category; (kg) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (h) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (li) guidelines and limitations on concentrations of credit; (mj) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nk) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (ol) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pm) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qn) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (ro) guidelines for periodic review of the Association’s adherence to the revised lending policy. Guidelines are consistent with those set forth in Banking Circular 181 (Revised) dated August 2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy1984, and a copy the requirements of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.12 C.F.R. Part

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A- LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) provide specific guidance for construction and development loans; (m) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) a prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇;; and, (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof; (iv) require that all new, renewed, extended, restructured or altered credits in excess of fifty thousand dollars ($50,000) which deviate from the Bank’s lending policy receive the prior approval of the Board, or a committee thereof. A copy of the Board or committee approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (pv) require that all new, renewed, extended, restructured or altered credits in the amount of fifty thousand dollars ($50,000) or less which deviate from the Bank’s lending policy receive the prior written approval of the bank’s senior lending officer. A copy of the written approval shall be maintained in the credit file of the affected borrower(s), and shall state the reason for deviating from the lending policy to include an assessment of why the deviation is in the best interest of the bank. (q) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller ADC for review. (3) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty one hundred twenty (60120) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)“Loan Portfolio Management” booklet of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) guidelines for the appraisal ordering process that ensure independence; (f) guidelines for the scope and quality of appraisals that are in conformance with 12 C.F.R. Part 34 and Interagency Appraisal and Evaluation Guidelines dated October 27, 1994; (g) the circumstances in which a re-appraisal of properties is required; (h) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (fi) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (hj) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jk) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of creditcredit consistent with Article VI of this Agreement; (m) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (n) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (o) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (p) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (q) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (r) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty ninety (6090) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, A-LPM, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s trade area; (h) guidelines and limitations for loans originating outside of the Association’s trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (l) guidelines and limitations on concentrations of credit; (mf) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (ng) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇Report of Examination; (oh) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pi) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qj) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rk) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) daysBy July 31, 2002, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Loan Portfolio Management booklet, of the Comptroller’s Handbook. This policy shall incorporate, but not necessarily be limited to, the following: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) a distribution of loans by category; (k) when policy exceptions are acceptable and how they should be identified, mitigated, documented, tracked, and reported to the Board; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and; (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy.; (2t) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller specific underwriting guidelines for review.consumer lending; and (3u) The Board shall ensure that the Association has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.guidelines detailed in OCC Bulletin 2000-20 -

LENDING POLICY. (1) Within sixty (60) days, the Board shall review and revise the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 the Loan Portfolio Management, A-LPM, and 160.170 (Lending Limitations Commercial Real Estate and Records for Lending Transactions). This policy shall incorporateConstruction Lending, but not necessarily be limited toA-CRE, booklets of the following:Comptroller’s (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision that current and satisfactory credit information will be obtained on each borrower; (c) prudent underwriting standards that are clear and measurable, including but not limited to: (i) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (dii) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (ed) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (ge) a definition of the Association’s Bank's trade area; (hf) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (ig) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (jh) distribution of loans by category; (ki) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lj) guidelines and limitations on concentrations of credit; (mk) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (nl) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇; (om) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pn) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qo) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rp) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.

LENDING POLICY. (1) Within sixty (60) days, the Board shall review review, revise, and revise thereafter ensure Bank adherence to the Association’s Bank's written loan policy. In revising this policy, the Board shall refer to 12 C.F.R. §§ 160.93 and 160.170 (Lending Limitations and Records for Lending Transactions)the Comptroller's Handbook booklets governing Asset Quality. This policy shall incorporate, but not necessarily be limited to, the followingfollowing items: (a) a description of acceptable types of loans that will ensure that: (i) commercial lines of credit are not extended to borrowers for unknown or inappropriate purposes including but not limited to use as a source of permanent working capital, to make speculative investments, or for unknown purposes; and (ii) lending management employs prudent lending practices in its area of land development loans and ceases prior practices in which loans were originated with high loan to value ratios, financing was extended to pay for developer’s soft costs, and lending management renewed loans without requiring the necessary principal reductions or terming out loans over a reasonable repayment period.loans; (b) a provision requirement that current and satisfactory credit information will be obtained on each borrower; (c) maturity scheduling related to the anticipated source of repayment, the purpose of the loan, and the useful life of the collateral; (d) maximum ratio of loan value to appraised value or acquisition costs of collateral securing the loan; (e) collection procedures, to include follow-up efforts, that are systematically and progressively stronger; (f) a pricing policy that takes into consideration costs, general overhead, and probable loan losses, while providing for a reasonable margin of profit; (g) a definition of the Association’s Bank's trade area; (h) guidelines and limitations for loans originating outside of the Association’s Bank's trade area; (i) a limitation on aggregate outstanding loans in relation to other balance sheet accounts; (j) distribution of loans by category; (k) prohibition regarding the use of brokered deposits to fund loan growth or support criticized loans; (l) guidelines for loans to insiders, including a statement that such loans will not be granted on terms more favorable than those offered to similar outside borrowers; (lm) guidelines and limitations on concentrations of credit; (mn) a limitation on the type and size of loans that may be made by loan officers without prior approval by the Board or a committee established by the Board for this purpose; (no) measures to correct the deficiencies in the Association’s Bank's lending procedures noted in any ▇▇▇Report of Examination; (op) guidelines designed to improve Board oversight of the loan approval process, specifically with regard to credits exhibiting significant risk. At a minimum, the policy shall: (i) establish dollar limits on extensions of credit to any one borrower, above which the prior approval of the Board, or a committee thereof, would be required; (ii) establish dollar limits on aggregate extensions of credit to any one borrower, above which any new extensions of credit to that borrower, regardless of amount, would require the prior approval of the Board, or a committee thereof; and (iii) require that all credits which deviate from the AssociationBank’s normal course of business, including all credits which deviate from the AssociationBank’s written strategic plan, receive the prior approval of the Board, or a committee thereof. (pq) guidelines consistent with The Federal Financial Institutions Examination Council’s (FFIEC) Policy Statement on Prudent Commercial Real Estate Loan Workouts (October 30, 2009)Banking Circular 255, setting forth the criteria under which renewals of extensions of credit may be approved. At a minimum the policy shall: (i) ensure that renewals are not made for the sole purpose of reducing the volume of loan delinquencies; and (ii) provide guidelines and limitations on the capitalization of interest.; (qr) charge-off guidelines, by type of loan or other asset, including Other Real Estate Owned, addressing the circumstances under which a charge-off would be appropriate and ensuring the recognition of losses within the quarter of discovery; and (rs) guidelines for periodic review of the Association’s Bank's adherence to the revised lending policy. (2) Upon adoption, the policy shall be implemented, the Board shall thereafter ensure Association direct Bank adherence to the policy, and a copy of the policy shall be forwarded to the Assistant Deputy Comptroller for review. (3) The Board shall ensure that the Association Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policy developed pursuant to this Article.