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respect to a financial institution’s concentrations in CRE lending activities.
−Removed: The CRE Concentration Guidance identifies certain concentration levels that, if exceeded, will expose the institution to additional supervisory analysis with regard
−Removed: to the institution’s CRE concentration risk.
+Added: The CRE Concentration Guidance identifies certain concentration levels that, if exceeded, will expose the institution to additional supervisory analysis with regard to
+Added: the institution’s CRE concentration risk.
The CRE Concentration Guidance is designed to promote appropriate levels of capital and sound loan and risk management practices for institutions with a concentration of CRE loans.
−Removed: In general, the
−Removed: CRE Concentration Guidance establishes the following supervisory criteria as preliminary indications of possible CRE concentration risk:
−Removed: (1) the institution’s total construction, land development and other land loans represent 100% or more of
−Removed: total capital;
+Added: In general, the CRE
+Added: Concentration Guidance establishes the following supervisory criteria as preliminary indications of possible CRE concentration risk:
+Added: (1) the institution’s total construction, land development and other land loans represent 100% or more of total
or (2) total CRE loans as defined in this guidance, or Regulatory CRE, represent 300% or more of total capital, and the institution’s Regulatory CRE has increased by 50% or more during the prior 36-month period.
−Removed: Pursuant to the
−Removed: CRE Concentration Guidance, loans secured by owner occupied CRE are not included for purposes of the CRE concentration calculation.
−Removed: As of March 31, 2023, our Regulatory CRE represented 290.49% of our total Bank capital and our construction, land development and other land loans represented 86.38% of our total Bank capital, as compared to
+Added: Pursuant to the CRE
+Added: Concentration Guidance, loans secured by owner occupied CRE are not included for purposes of the CRE concentration calculation.
+Added: As of June 30, 2023, our Regulatory CRE represented 276.55% of our total Bank capital and our construction, land development and other land loans represented 69.91% of our total Bank capital, as compared to 304.72%
and 101.20% as of December 31, 2022, respectively.
During the prior 36-month period, our Regulatory CRE has decreased 75.67%.
−Removed: We are actively working to manage our Regulatory CRE concentration, and we believe that our underwriting
−Removed: policies, management information systems, independent credit administration process, and monitoring of real estate loan concentrations are currently sufficient to address the CRE Concentration Guidance.
−Removed: We utilize enhanced CRE monitoring
−Removed: techniques as expected by banking regulators as our concentrations have approached or exceeded the regulatory guidance.
−Removed: Nevertheless, the Federal Reserve could become concerned about our CRE loan concentrations, and it could limit our ability
−Removed: to grow by restricting its approvals for the establishment or acquisition of branches, or approvals of mergers or other acquisition opportunities, or by requiring us to raise additional capital, reduce our loan concentrations or undertake other
−Removed: remedial actions.
+Added: We are actively working to manage our Regulatory CRE concentration, and we believe that our underwriting policies,
+Added: management information systems, independent credit administration process, and monitoring of real estate loan concentrations are currently sufficient to address the CRE Concentration Guidance.
+Added: We utilize enhanced CRE monitoring techniques as
+Added: expected by banking regulators as our concentrations have approached or exceeded the regulatory guidance.
+Added: Nevertheless, the Federal Reserve could become concerned about our CRE loan concentrations, and it could limit our ability to grow by
+Added: restricting its approvals for the establishment or acquisition of branches, or approvals of mergers or other acquisition opportunities, or by requiring us to raise additional capital, reduce our loan concentrations or undertake other remedial
Adverse developments affecting the banking industry, such as recent bank failures or concerns involving liquidity, may have material adverse effects on our operations.
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Additionally, these events have caused significant disruption, volatility and reduced valuations of equity and other securities of banks in the capital markets.
−Removed: These events occurred during a
−Removed: period of rapidly rising interest rates, which, among other things, has resulted in unrealized losses in our available for sale debt securities portfolio and increased competition for bank deposits.
−Removed: These events could lead to increases in our
−Removed: interest expense, as it has raised and may continue to raise interest rates paid to depositors in order to compete with other banks, and in an effort to replace deposits, seek borrowings which carry higher interest rates.
+Added: These events occurred during a period
+Added: of rapidly rising interest rates, which, among other things, has resulted in unrealized losses in our available for sale debt securities portfolio and increased competition for bank deposits.
+Added: These events could lead to increases in our interest
+Added: expense, as it has raised and may continue to raise interest rates paid to depositors in order to compete with other banks, and in an effort to replace deposits, seek borrowings which carry higher interest rates.
Recent bank failures have caused concern and uncertainty regarding the liquidity adequacy of the banking sector as a whole and resulted in some regional and community bank customers choosing to maintain deposits
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increase in demand from other banks or due to insufficient levels of pledgeable assets, our ability to borrow funds may be materially adversely impacted.
+Added: Any changes to regulations, regulatory policies, laws, or supervisory or enforcement activities arising from the recent events in the banking industry could increase our
+Added: expenses and adversely impact our operations.
+Added: In addition to operational impacts to the Company, the recent high-profile negative events in the banking industry may also result in changes to the laws and regulations governing banks and bank holding companies.
+Added: As part of the financial services industry, we are subject to extensive federal and state regulation and supervision.
+Added: Changes to regulations, regulatory policies, laws, or supervisory or enforcement activities could affect us in substantial and
+Added: adverse ways, including limiting the services and products we may offer, restrict our ability to pay dividends, result in us incurring higher costs, or subject us to higher capital requirements.
+Added: Inability to access short-term funding, loss of
+Added: client deposits or changes in our credit ratings could increase the cost of funding, limit access to capital markets or negatively impact our overall liquidity or capitalization.
+Added: We may be impacted by concerns regarding the soundness or
+Added: creditworthiness of other financial institutions, which can cause disruption within the financial markets and increased expenses.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.