29 unchanged sentences
however, these additional limitations do not apply to our outstanding trust preferred securities.
−Removed: Our Tier 2 capital as of December 31, 2024 includes $40.0 million of subordinated notes that were issued during 2020 and mature May, 2030.
−Removed: Generally, for subordinated debt with a minimum maturity of five years, there is no limit on the amount of subordinated debt that can be included in Tier 2 capital.
Historically, most of our revenues have been received in the form of dividends paid by our bank.
26 unchanged sentences
The Federal Reserve has established the following minimum capital standards for state-chartered, FDIC-insured member banks, such as our bank:
−Removed: (1) a minimum ratio of common equity Tier 1 capital to risk-weighted
−Removed: BUSINESS (continued)
−Removed: assets of 4.5%, (2) a minimum ratio of Tier 1 capital to risk-weighted assets of 6%, (3) a minimum ratio of total capital to total risk-weighted assets of 8%, and (4) a minimum leverage ratio of 4%.
+Added: (1) a minimum ratio of common equity Tier 1 capital to risk-weighted assets of 4.5%, (2) a minimum ratio of Tier 1 capital to risk-weighted assets of 6%, (3) a minimum ratio of total capital to total risk-weighted assets of 8%, and (4) a minimum leverage ratio of 4%.
A 2.5% common equity Tier 1 capital conservation buffer is also required.
−Removed: It is important to note that these regulatory capital rules provide minimum requirements, and higher capital levels may be required if warranted by the particular circumstances or risk profiles of individual banking organizations.
+Added: It is important to note that these regulatory capital rules provide minimum requirements, and higher capital levels may be required if warranted by the particular circumstances or risk profiles of
+Added: BUSINESS (continued)
+Added: individual banking organizations.
In addition, the federal bank regulatory agencies are required biennially to review risk-based capital standards to ensure that they adequately address interest rate risk, concentration of credit risk and risks from non-traditional activities.
32 unchanged sentences
Insider Transactions .
−Removed: Our bank is subject to certain restrictions imposed by the Federal Reserve Act on "covered transactions" with us or our subsidiaries, which include investments in our stock or other securities issued by us or our
−Removed: BUSINESS (continued)
−Removed: subsidiaries, the acceptance of our stock or other securities issued by us or our subsidiaries as collateral for loans, and extensions of credit to us or our subsidiaries.
+Added: Our bank is subject to certain restrictions imposed by the Federal Reserve Act on "covered transactions" with us or our subsidiaries, which include investments in our stock or other securities issued by us or our subsidiaries, the acceptance of our stock or other securities issued by us or our subsidiaries as collateral for loans, and extensions of credit to us or our subsidiaries.
Certain limitations and reporting requirements are also placed on the deposit rates paid, and the amounts and terms of extensions of credit, by our bank to the directors and officers of the holding company, the bank, and the subsidiaries of the bank;
to the principal shareholders of the holding company;
−Removed: and to "related interests" of such directors, officers, and principal shareholders.
+Added: and to "related
+Added: BUSINESS (continued)
+Added: interests" of such directors, officers, and principal shareholders.
In addition, federal law and regulations may affect the terms upon which any person becoming one of our directors or officers or a principal shareholder may obtain credit from banks with which our bank maintains a correspondent relationship.
16 unchanged sentences
We have experienced, and expect to continue to experience, increased costs and expenses related to compliance with these consumer protection regulations as well as new regulations that may be implemented in the future.
+Added: Community Reinvestment Act .
+Added: The Community Reinvestment Act (CRA) requires federal banking regulators to assess the record of financial institutions in meeting the credit needs of the communities they serve, including low- and moderate-income neighborhoods, consistent with safe and sound operations.
+Added: In October 2023, federal banking regulators issued a final rule to modernize and strengthen CRA regulations.
+Added: The final rule includes revised assessment area standards, new retail lending and community development tests, and updated data collection and reporting requirements.
+Added: The federal banking regulators have proposed rescinding the new rules and are currently applying the prior regulatory framework under the CRA.
+Added: Our bank has a longstanding commitment to community development and reinvestment in the areas it serves and continually monitors developments related to CRA requirements.
Anti-Money Laundering and the USA PATRIOT Act .
2 unchanged sentences
These regulations include FinCEN's Customer Due Diligence Requirements for Financial Institutions, which is designed to identify and verify the identity of natural persons (known as beneficial owners) of legal entity customers who own, control and profit from companies when those companies open accounts.
+Added: BUSINESS (continued)
2018 Regulatory Reform .
1 unchanged sentence
While the 2018 Act maintained most of the regulatory structure established by the Dodd-Frank Act, it amended certain aspects of the regulatory framework for small depository institutions with assets of less than $10 billion and for large banks with assets of more than $50 billion.
−Removed: BUSINESS (continued)
The 2018 Act also included regulatory relief for community banks regarding regulatory examination cycles, call reports, the Volcker Rule (proprietary trading prohibitions), mortgage disclosures, and risk weights for certain high-risk commercial real estate loans.
16 unchanged sentences
We do not expect that this new excise tax will have a material impact on our operations or results.
+Added: One Big Beautiful Bill .
+Added: In 2025, Congress enacted H.R.
+Added: 1, the Reconciliation Act of 2025 (commonly referred to as the "One Big Beautiful Bill"), which contains numerous provisions affecting financial institutions, their customers, and the broader economy.
+Added: The legislation makes permanent many of the individual and business tax provisions originally enacted in the Tax Cuts and Jobs Act of 2017, including the reduced individual income tax rates, the increased standard deduction, the 20% qualified business income deduction for pass-through entities under section 199A, the increased estate and gift tax exemption, and 100% bonus depreciation for qualified property.
+Added: The legislation also modifies the business interest deduction limitation under Section 163(j) to restore the add-back of depreciation, amortization, and depletion when calculating adjusted taxable income, and increases the Section 179 expensing limit to $2.5 million.
+Added: The legislation includes several provisions that may directly benefit our bank and its customers.
+Added: The state and local tax ("SALT") deduction cap is increased from $10,000 to $40,000 for tax years 2025 and 2026, which may positively affect our customers in Michigan and support residential real estate demand in our service area.
+Added: Additionally, the legislation provides that 25% of interest received by qualified lenders, including FDIC-insured depository institutions, on loans secured by agricultural or rural real estate is excluded from gross income.
+Added: The legislation also creates new deductions for qualified tips, qualified overtime compensation, and interest on loans for U.S.-assembled passenger vehicles, which may affect consumer financial capacity and demand for certain loan products.
+Added: With respect to financial institution regulation, the legislation reduces the CFPB’s funding cap from 12% to 6.5% of the Federal Reserve System's combined earnings, which may result in reduced CFPB enforcement activity and rulemaking.
+Added: BUSINESS (continued)
+Added: The legislation also imposes a 1% excise tax on certain outbound cash remittance transfers, which may impose compliance and collection obligations on financial institutions that serve as remittance transfer providers.
+Added: The ultimate impact of this legislation on our operations, financial condition, and results of operations will depend on the implementation of these provisions by the applicable regulatory and taxing authorities and cannot yet be fully determined.
Future Legislation
6 unchanged sentences
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.