What changed in this filing

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Item 1. Business

2026-02-27 compared with 2025-02-28 · 62 added, 78 removed, 390 unchanged (26% of the section changed)

5 unchanged sentences

Information on our website should not be considered a part of this Annual Report on Form 10-K.

The Company provides a broad range of banking products and services to small and medium-sized businesses, professionals, and individuals primarily in Northern California through eight branch offices.

The Bank opened a full service branch in Downtown San Francisco in September 2024.

The Company provides a broad range of banking products and services to small and medium-sized businesses, professionals, and individuals primarily in Northern California through nine branch offices.

The Bank opened a full-service branch in Walnut Creek in September 2025.

The Bank’s deposits are insured in whole or in part by the FDIC.

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We believe that our market growth confirms the quality of the purpose-driven and integrity-centered banking that we strive to deliver to our customers.

During 2024, we continued our expansion into the San Francisco Bay Area, including the opening of a full service branch in Downtown San Francisco in September 2024.

We hired eight business development officers, four relationship managers, three loan officers, one relationship specialist, one treasury solutions specialist, and one branch manager during 2024 as part of our expansion.

During 2025, we continued our expansion into the San Francisco Bay Area, including the opening of a full service branch in Walnut Creek in September 2025.

We hired three business development officers, three loan officers, and four additional staff to support these operations during 2025 as part of our expansion.

Our Products and Services

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We offer a variety of loans to small and medium-sized businesses, professionals, and individuals, including commercial real estate, commercial, commercial land and construction, and farmland loans.

Although a substantial portion of our loan portfolio consists of commercial real estate loans within our market, our portfolio is diverse and includes a significant amount of SBA loans to customers nationwide.

Although a substantial portion of our loan portfolio consists of commercial real estate loans within our market, our portfolio is diverse and includes SBA loans to customers nationwide.

To a lesser extent, we also offer residential real estate and construction loans and consumer loans.

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The guarantee is conditional and covers a portion of the risk of payment default by the borrower, but not the risk of improper closing and servicing by the lender.

As such, prudent underwriting and closing processes are

essential to effective utilization of the 7(a) program.

We typically sell in the secondary market the SBA-guaranteed portion of the SBA loans we originate.

As such, prudent underwriting and closing processes are essential to

effective utilization of the 7(a) program.

We typically sell the SBA-guaranteed portion of the SBA loans we originate in the secondary market.

Consumer and other loans :

As of December 31, 2025, we had $275.5 million in consumer and other loans, representing 6.77% of total loans before deferred fees.

We make a variety of loans in relatively small amounts to individuals for personal purposes, primarily for home repairs and improvements.

These loans consist primarily of loans purchased in a loan purchase program with a non-bank lender, generally made to professionals for the purpose of large personal or household purchases.

The loans are unsecured, fixed rate loans.

These loans also include loans purchased or originated through financing partnerships which are no longer active.

Under those financing programs, we made a variety of loans in relatively small amounts to individuals for personal purposes, primarily for home repairs and improvements.

Consumer loans are underwritten based on the individual borrower’s income, current debt level, past credit history, and the value of any available collateral.

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In keeping with our mission of purpose-driven and integrity-centered banking, we seek credit arrangements that serve our local community and provide attractive risk-adjusted returns to us.

We pursue our objectives and are mindful of liquidity, flexibility, and risk considerations by exercising controls on non-interest expenses and close management of our assets and liabilities.

We periodically set guidelines aimed to maintain stability of our loan-to-deposit ratio, minimize past-due and non-accrual loans, and achieve an optimal loan mix and concentration.

We pursue our objectives while remaining mindful of liquidity, flexibility, and risk considerations by exercising controls on non-interest expenses and close management of our assets and liabilities.

We periodically set guidelines designed to maintain stability of our loan-to-deposit ratio, minimize past-due and non-accrual loans, and achieve an optimal loan mix and concentration.

We seek well-margined and collateralized loan opportunities to borrowers with extensive professional asset operating experience.

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Representing 97.49% of our total liabilities as of December 31, 2025, deposits are our primary source of funding for our business operations.

As of December 31, 2024, we held total deposits of $3.6 billion, including $922.6 million in non-interest-bearing deposits.

We offer a complete array of deposit products for small and medium-sized businesses, professionals, and individuals, including a variety of checking and savings accounts, time deposits, and money market accounts.

As of December 31, 2025, we held total deposits of $4.2 billion, including $1.1 billion in non-interest-bearing deposits.

We offer a comprehensive array of deposit products for small and medium-sized businesses, professionals, and individuals, including a variety of checking and savings accounts, time deposits, and money market accounts.

We also provide a wide range of deposit services, including debit cards, remote deposit capture, online banking, mobile banking, and direct deposit services.

We obtain most of our deposits from individuals, small and medium-sized businesses, and municipalities in our market.

We solicit deposits through our relationship-driven team of dedicated and accessible bankers and through community-focused marketing.

We solicit deposits through our relationship-driven team of dedicated and accessible bankers, as well as through community-focused marketing.

We emphasize obtaining deposit relationships at loan origination.

We provide a high level of customer service to our depositors.

We have invested in personnel, business and compliance processes, and technology that enable us

to acquire, and efficiently and effectively serve, a wide array of business deposit accounts, while continuing to provide the level of customer service for which we are known.

We have invested in personnel, business and compliance processes, and technology that enable us to acquire, as well as efficiently and effectively serve a wide array of business deposit accounts, while continuing to provide the level of customer service for which we are known.

As of December 31, 2025, our 53 largest deposit relationships, each accounting for more than $10.0 million, totaled $2.0 billion, or 47.82% of our total deposits.

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Our profitability depends in large part upon our continued ability to successfully compete with these institutions for lending opportunities, deposit funds, financial products, bankers, and potential acquisition targets.

We conduct business through eight branches in our key market of Northern California.

We opened a full service branch in Downtown San Francisco in September 2024.

We conduct business through nine branches in our key market of Northern California.

We opened a full service branch in Walnut Creek in September 2025.

Many other commercial and community banks, savings institutions, credit unions, and other financial institutions maintain a physical presence in our primary market area, and some maintain only a virtual presence.

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We depend on our reputation of having greater personal service than our competitors, as well as consistency, flexibility, our ability to make credit and other business decisions quickly, and our deep knowledge of competitor strengths and weaknesses.

Based on the FDIC Summary of Deposits as of June 30, 2024, Five Star ranks sixth in the Sacramento-Roseville-Folsom metropolitan statistical area (“MSA”) by deposit market share with deposits of $2.8 billion and four branches.

As of June 30, 2024, total market deposits in the Sacramento-Roseville-Folsom MSA were $92.2 billion, of which $75.4 billion, or approximately 81.77%, is held by five money center banks across 181 branches.

We are the 43rd largest insured depository institution in California by deposits as of June 30, 2024.

Based on the FDIC Summary of Deposits as of June 30, 2025, the Bank ranks sixth in the Sacramento-Roseville-Folsom metropolitan statistical area (“MSA”) by deposit market share with deposits of $3.1 billion and four branches.

As of June 30, 2025, total market deposits in the Sacramento-Roseville-Folsom MSA were $94.7 billion, of which $77.3 billion, or approximately 81.55%, was held by five money center banks across 174 branches.

We are the 39th largest insured depository institution in California by deposits as of June 30, 2025.

Information Technology Systems

We have made, and continue to make, significant investments in our information technology systems and staff for our banking and lending operations and treasury management activities.

We believe this investment will support our continued growth and enable us to enhance our capabilities to offer new products, improve overall customer experience, improve profitability through efficiencies, and provide scalability for future growth.

We believe this investment will support our continued growth and enable us to enhance our capabilities to offer new products, improve overall customer experience, improve

profitability through efficiencies, and provide scalability for future growth.

We utilize nationally recognized software vendors and their cloud/hosted models, which allow us to outsource the processing of our data.

Our internal network and e-mail systems are administered by a managed service provider specializing in financial institutions, and we maintain our

production infrastructure in a data center facility near Reno, Nevada.

Our internal network and e-mail systems are administered by a managed service provider specializing in financial institutions, and we maintain our production infrastructure in a data center facility near Reno, Nevada.

This site provides for power and connectivity redundancy, and we maintain a disaster recovery program, including a cloud-based recovery environment.

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We have elected not to opt out of such extended transition period, which means that when a standard is issued or revised and it has different application dates for public or private companies, we, as an emerging growth company, can adopt the new or revised standard at the time private companies adopt the new or revised standard.

As such, our consolidated financial statements may not be comparable with those of a public company that is not an emerging growth company, or those of a public company that is an emerging growth company that has opted out of using the extended transition period, because of the potential differences in accounting standards used.

However, we may early adopt certain accounting standards, as the JOBS Act does not preclude an emerging growth company from adopting a new or revised accounting standard early than the time that such standard applies to private companies to the extent early adoption is permitted.

As such, our consolidated

financial statements may not be comparable with those of a public company that is not an emerging growth company, or those of a public company that is an emerging growth company that has opted out of using the extended transition period, because of the potential differences in accounting standards used.

Risk Management

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We provide a competitive compensation and benefits program to help meet the needs of our employees.

In addition to salaries, this program includes annual bonus opportunities, a 401(k) plan with an employer matching contribution, healthcare and insurance benefits, flexible spending accounts, paid time off and family leave, and an employee assistance program.

In addition to salaries, this program includes annual bonus opportunities, a 401(k) plan with an employer matching contribution, healthcare and insurance benefits, health reimbursement accounts, paid time off and family leave, and an employee assistance program.

Learning and Development

We invest in the growth and development of our employees by providing a multi-dimensional approach to learning that empowers, intellectually grows, and professionally develops our colleagues under the leadership of a Director of Employee

We facilitate the educational and professional development of our employees through support to attend conferences and obtain degrees, licenses, and certifications while employed by us.

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We believe it is our shared responsibility to build a strong foundation of community by fostering a culture of belonging and inclusion.

We also remain focused on the investment in, economic development of, and sustainability of the geographical service areas in which we serve.

We also remain focused on investing and economically developing the geographical service areas in which we serve, as well as on their sustainability.

The Governance and Nominating Committee is committed to diversity on our board of directors and compliance with applicable rules, regulations, and guidance regarding the composition of our leadership.

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We are committed to ethical business practices and accounting transparency, as evidenced through our involvement in the community and results of examinations by regulators.

Dedication to Diversity, Equity, and Inclusion

Diversity, Equity, and Inclusion (“DE&I”) is essential in our workplace.

We have a fully engaged Executive Vice President, Chief Operating Officer who leads our DE&I efforts.

Our Human Resources department is focused on our commitment to DE&I through hiring practices and employee training.

Dedication to Community Impact and Inclusion

Community Impact and Inclusion is essential in our workplace.

We have an Executive Vice President, Chief Operating Officer and a Vice President, Director of Community Impact and Inclusion who lead our efforts in this area.

Our Human Resources department is focused on our commitment to inclusion through hiring practices and employee training.

We are committed to ensuring that all employees feel a sense of belonging in the workplace and that processes and programs are impartial, fair, and provide equal opportunity for every individual.

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Federal and state banking laws impose a comprehensive system of supervision, examination, regulation, and enforcement on the operations of insured banks and their holding companies.

Supervision and regulation of banks, their holding companies, and affiliates is intended primarily for the protection of depositors and customers, the Deposit Insurance Fund

(the “DIF”) of the FDIC, and the U.S.

Supervision and regulation of banks, their holding companies, and affiliates is intended primarily for the protection of depositors and customers, the Deposit Insurance Fund (the “DIF”) of the FDIC, and the U.S.

banking and financial system, rather than holders of our capital stock.

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Any change in the statutes, regulations or regulatory policies applicable to us, including changes in their interpretation, expectations or implementation, could have a material effect on our business and operations.

To this end, due to the recent issuance of certain executive orders by the President of the United States, it may not be clear for a period of time as to what the priorities of the three prudential banking agencies, the OCC, Federal Reserve, and FDIC, may be with respect to their respective supervisory and enforcement matters for banks and bank holding companies during the current administration.

For example, one executive order requires independent agencies, including the Federal Reserve and FDIC, to submit to the White House Office of Management and Budget (“OMB”) major orders proposed by these agencies for OMB’s review.

OMB would also write “performance standards and management objectives” to the heads of independent agencies, and review and adjust their budgets, including the Federal Reserve (excluding with respect to its monetary policy function) and the FDIC.

As a result, it may take longer for the prudential banking agencies to establish their supervisory and enforcement priorities and develop and adopt new rules and regulations, or make changes to existing rules and regulations.

Another executive order requires agency heads to determine whether ongoing enforcement of any regulations identified in their regulatory review is compliant with law and policy of the current administration.

This executive order also provides that to preserve resources and ensure lawful enforcement, agency heads, in consultation with the Director of the OMB, shall, on a case-by-case basis and as appropriate and consistent with applicable law, then direct the termination of all such enforcement proceedings that do not comply with the Constitution, laws, or the policy of the current administration.

It is unclear what impact these orders will have on the supervisory and enforcement activities of the OCC, Federal Reserve, and FDIC.

The following is a summary of material elements of the regulatory and supervisory framework applicable to us and the Bank.

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We are a bank holding company registered under the Bank Holding Company Act of 1956, as amended (the “BHC Act”).

As a result, we are primarily subject to the supervision, examination, and reporting requirements of the BHC Act, Federal Deposit Insurance Act (the “FDI Act”), the regulations of the Federal Reserve and FDIC, and certain of the requirements imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”).

As a result, we are primarily subject to the supervision, examination, and reporting requirements of the BHC Act, Federal Deposit Insurance Act (the “FDI Act”), and the regulations of the Federal Reserve and FDIC.

Federal law subjects bank holding companies, such as the Company, to restrictions on the types of activities in which they may engage and to a range of supervisory requirements and activities, including regulatory enforcement actions for violations of laws and regulations.

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Provisions of the FDI Act known as the Bank Merger Act impose similar approval standards for an insured depository institution to merge with another insured depository institution or a non-insured institution.

On September 17, 2024, the FDIC finalized changes to its Statement of Policy on Bank Merger Transactions (the “Policy Statement”), which outlines factors that the FDIC will consider when evaluating a proposed bank merger transaction.

Also on September 17, 2024, the United States Department of Justice (the “DOJ”) withdrew its 1995 Bank Merger Guidelines and announced that it will instead evaluate the competitive impact of bank mergers using its 2023 Merger Guidelines that the DOJ applies to mergers in all industries.

On September 17, 2024, the United States Department of Justice (the “DOJ”) withdrew its 1995 Bank Merger Guidelines and announced that it will instead evaluate the competitive impact of bank mergers using its 2023 Merger Guidelines that the DOJ applies to mergers in all industries.

Compared to the 1995 Bank Merger Guidelines, the 2023 Merger Guidelines set forth more stringent concentration limits and add several largely qualitative bases on which the DOJ may challenge a merger.

While the effect of these changes for particular transactions remains unclear, both the Policy Statement and the change in the DOJ’s bank merger antitrust policy may make it more difficult and/or costly for us to obtain regulatory approval for an acquisition or otherwise result in more onerous conditions to obtain approval for an acquisition.

The BHC Act, as amended by the interstate banking provisions of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 (the “Riegle-Neal Act”), permits us to acquire a bank located in any other state, regardless of state law to the contrary, subject to certain deposit percentage, aging requirements, and other restrictions.

While the effect of changes in the DOJ’s bank merger antitrust policy for particular transactions remains unclear, the changes may make it more difficult and/or costly for us to obtain regulatory approval for an acquisition or otherwise result in more onerous conditions to obtain approval for an acquisition.

The BHC Act, as amended by the interstate banking provisions of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 (the “Riegle-Neal Act”), permits us to acquire a bank located in any other state, regardless of state law to the contrary, subject to certain deposit concentration limits, aging requirements, and other restrictions.

The Riegle-Neal Act also generally permits national- and state-chartered banks to branch interstate through acquisitions of banks in other states.

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Capital adequacy regulations and prompt corrective action regulations involve quantitative measures of assets, liabilities, and certain off-balance sheet items calculated under regulatory accounting practices, as well as qualitative judgments by the regulators about components of capital, risk-weightings, and other factors.

United States capital regulations were substantially revised in 2013 as a result of changes in the Dodd-Frank Act and Basel III capital rules.

The Federal Reserve and the FDIC, the primary federal regulators of the Company and Bank, respectively, have substantially similar generally applicable risk-based capital ratio and leverage ratio requirements.

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For purposes of calculating the denominator of the risk-based capital ratios, a banking institution’s assets and some of its specified off-balance sheet commitments and obligations are assigned to various risk categories.

For purposes of calculating the numerator of the capital ratios, capital, at both the holding company and bank levels, is classified in one of three tiers depending on the “quality” and loss-absorbing features of the capital instrument.

For purposes of calculating the numerator of the capital ratios, capital, at both the holding company and bank levels, is classified in one of

three tiers depending on the “quality” and loss-absorbing features of the capital instrument.

Common equity Tier 1 capital is predominantly comprised of common stock instruments (including related surplus) and retained earnings, net of treasury stock, and after making necessary capital deductions and adjustments.

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These examinations may consider not only compliance with applicable laws and regulations, but also capital levels, asset quality and risk, management ability and performance, earnings, liquidity, sensitivity to market risk, and various other factors.

The regulatory agencies generally have broad authority to impose restrictions and limitations on the operations of a regulated entity when an agency determines, among other things, that such operations are unsafe or unsound, fail to comply with applicable law, or are otherwise inconsistent with laws and regulations or with the supervisory policies of these agencies.

unsound, fail to comply with applicable law, or are otherwise inconsistent with laws and regulations or with the supervisory policies of these agencies.

Anti-Money Laundering Initiatives and Sanctions Compliance

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Both regulatory agencies have the power to take enforcement action to prevent the development or continuance of unsafe or unsound banking practices or other violations of law.

The Bank is subject to supervision, examination, enforcement, and reporting requirements under the FDI Act, the California Financial Code, regulations of the FDIC and the DFPI, and certain of the requirements imposed by the Dodd-Frank Act.

The Company and the Bank are also subject to a wide range of consumer protection laws and regulations.

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These laws include, among others:

the Truth in Lending Act, the Truth in Savings Act, the Electronic Fund Transfer Act, the Expedited Funds Availability Act, the Equal Credit Opportunity Act, the Fair and Accurate Credit Transactions Act, the Fair Housing Act, the Fair Credit Reporting Act, the Fair Debt Collection Act, the GLB Act, the Home Mortgage Disclosure Act, the Right to Financial Privacy Act, the Real Estate Settlement Procedures Act, laws regarding unfair and deceptive acts and practices, and usury laws.

Additionally, the Dodd-Frank Act created the CFPB, which has authority to issue regulations prohibiting unfair, deceptive, or abusive acts or practices.

Because the Bank has assets of not more than $10 billion, its primary federal regulator, the FDIC, examines and enforces the Bank’s compliance with consumer financial protection laws.

However, the CFPB has rulemaking authority, including with respect to regulations prohibiting unfair, deceptive, or abusive acts or practices.

Additionally, the CFPB may participate in examinations of banks with not more than $10 billion in assets on a “sampling basis” and may refer potential enforcement actions against such banks to their primary federal regulators.

Many states and local jurisdictions have consumer protection laws analogous, and in addition, to those listed above.

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The privacy provisions of these laws may affect how consumer information is transmitted through diversified financial companies and conveyed to outside vendors.

On October 22, 2024, the CFPB released a final rule to implement Section 1033 of the Dodd-Frank Act.

Under the final rule, financial institutions are required, upon request, to make available to a consumer or third party authorized by the consumer certain information the Bank has concerning a consumer financial product or service covered by the rule, such as a credit card or a deposit account.

In issuing this rule, the CFPB said that the rule will move the U.S.

closer to an “open banking” system that will allow consumers to switch banks or other providers more easily.

The final rule also requires, among other things, covered data providers, such as the Bank, to establish a developer interface that satisfies certain performance and data security specifications through which the data provider can receive requests for, and provide, specific types of data covered by the rule in electronic, usable form to authorized third parties directly or through data aggregators.

Under the final rule, the Bank will be prohibited from charging fees for maintaining the developer interface or providing access to such data.

The Bank may also act as an authorized third party to request and access covered data under the final rule from other financial institutions that are covered data providers.

The final rule places data security, authorization, and other obligations on those authorized third parties, including limitations on secondary uses of the data received.

Industry organizations have challenged the final rule in court and the litigation is ongoing.

If the challenge is not successful, as a data provider, the Bank must comply with the rule beginning April 1, 2028.

We are monitoring the status of the litigation and evaluating the impact of this rule.

On October 22, 2024, the CFPB issued a final rule to implement Section 1033 of the Dodd-Frank Act.

Under the final rule, financial institutions such as the Bank that offer a consumer product or service covered by the rule would be required, upon request, to make available to a consumer or third party authorized by the consumer certain information the Bank has concerning such a product or service.

Industry organizations challenged the final rule in court.

On July 29, 2025, the district court granted a motion by the CFPB to stay the proceedings while the CFPB conducts a rulemaking to revise the final rule substantially.

On August 22, 2025, the CFPB issued an advance notice of proposed rulemaking to solicit comments and data on several issues as part of a reconsideration of the final rule.

On October 29, 2025, the district court issued a preliminary injunction preventing the CFPB from enforcing the final rule until the CFPB has completed its reconsideration of the rule.

Under California law, the Bank may open branch offices throughout California with the prior approval of the DFPI.

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The DIF reserve ratio fell to below the statutory minimum of 1.35% during the COVID-19 pandemic.

The FDIC adopted a restoration plan in September 2020, which it amended in June 2022, to restore the DIF reserve ratio to at least 1.35% by September 30, 2028.

The FDIC adopted a restoration plan in September 2020, which it amended in June 2022, to restore the DIF

reserve ratio to at least 1.35% by September 30, 2028.

On October 18, 2022, the FDIC adopted a final rule to increase initial base deposit insurance assessment rates for insured depository institutions by two basis points, beginning with the first quarterly assessment period of 2023.

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In addition, the FDI Act provides that, in the event of the liquidation or other resolution of an insured depository institution, the claims of depositors of the institution, including the claims of the FDIC as subrogee of insured depositors, and certain claims for administrative expenses of the FDIC as a receiver, will have priority over other general unsecured claims against the institution, including those of its parent bank holding company.

On July 30, 2024, the FDIC issued a proposed rule that would revise the FDIC’s regulations governing the classification and treatment of brokered deposits.

The proposal would require many insured depository institutions to classify a greater amount of their deposits obtained with the involvement of third parties as brokered deposits.

An increase in the amount of brokered deposits on an insured depository institution’s balance sheet could, among other consequences, increase the institution’s deposit insurance assessment costs.

Community Reinvestment Act (“CRA”)

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A bank’s CRA performance is also considered in evaluating applications seeking approval for mergers, acquisitions, and new offices or facilities, and a CRA rating of less than “Satisfactory” may adversely affect the ability of a bank or its parent company to engage in such transactions.

The Bank received a rating of “Satisfactory” at its most recent CRA evaluation, dated as of July 22, 2024 and covering activities from 2021 through the evaluation date.

The FDIC’s evaluation of the Bank’s record of performance under the CRA is publicly available.

The FDIC’s CRA regulations provide that a bank may elect to have its CRA performance evaluated under a strategic plan.

This option enables a bank to structure its CRA goals and objectives to address the needs of its community consistent with its business strategy, operational focus, capacity, and constraints.

The Bank operated under a CRA Strategic Plan approved by the FDIC for the years 2019 to 2021 and received a rating of “Satisfactory” at its most recent CRA evaluation, dated as of July 22, 2024 and covering activities from 2021 through the evaluation date.

On October 24, 2023, the federal banking agencies issued a final rule amending the CRA regulations, to substantially revise how they evaluate an insured depository institution’s record of satisfying the credit needs of its entire communities, including low- and moderate-income individuals and neighborhoods.

Under the final rule, banks with assets of at least $2 billion, including the Bank, are considered large banks and their retail lending, retail services and products, community development financing, and community development services will be subject to periodic evaluation.

Depending on a large bank’s geographic distribution of lending, the evaluation of retail lending may include assessment areas in which the bank extends loans but does not operate any deposit-taking facilities, in addition to assessment areas in which the bank has deposit-taking facilities.

Additionally, while the final rule retains the option for a large bank to adopt a strategic plan, a strategic plan under the final rule will generally be required to cover the same tests and geographies as the revised framework applies to other large banks.

Most of the final rule’s new requirements were scheduled to become applicable beginning January 1, 2026.

The remaining new requirements, including data reporting requirements, were scheduled to become applicable on January 1, 2027.

However, industry organizations have challenged the final rule in court, and on March 29, 2024, the United States District Court for the Northern District of Texas granted an injunction and stay of the final rule.

The final outcome of such challenge is uncertain.

On October 24, 2023, the federal banking agencies issued a final rule revising their framework for evaluating banks’ records of community reinvestment under the CRA.

On July 16, 2025, these agencies issued a notice of proposed rulemaking to rescind the October 2023 final rule and restore the CRA framework that existed prior to the October 2023 final rule.

The Bank’s most recent performance evaluation was conducted using the CRA framework that existed prior to the October 2023 final rule.

FHLB Membership

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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.

What changed 10-K

Item 1. Business