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We believe our integrated business model distinguishes us from other banks and non-bank financial services companies in the markets in which we operate.
−Removed: As of December 31, 2024, we provided fiduciary and advisory services on $7.32 billion of trust and investment management assets ("AUM"), and we had total assets of $2.92 billion, total loans excluding mortgage loans held for sale and loans held for sale of $2.43 billion, total deposits of $2.51 billion, and total shareholders’ equity of $252.3 million.
+Added: As of December 31, 2025, we provided fiduciary and advisory services on $7.28 billion of trust and investment management assets (AUM), and we had total assets of $3.15 billion, total loans excluding mortgage loans held for sale of $2.65 billion, total deposits of $2.75 billion, and total shareholders’ equity of $265.6 million.
Our mission is to be the best private bank for the Western wealth management client.
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Our target clients include successful entrepreneurs, professionals and other high net worth individuals or families, along with their businesses and philanthropic organizations.
−Removed: We offer our services through a branded network of boutique private trust bank offices, loan production offices, and trust offices, which we believe are strategically located in affluent and high-growth markets in twenty locations across Colorado, Arizona, Wyoming, Montana, and California.
+Added: We offer our services through a branded network of boutique private trust bank offices, loan production offices, and trust offices, which we believe are strategically located in affluent and high-growth markets in nineteen locations across Colorado, Arizona, Wyoming, Montana, and California.
We generate a significant portion of our revenues from non-interest income, which we produce from our trust, investment management, and other advisory services as well as through the origination and sale of mortgage loans.
The balance of our revenue is generated from net interest income, which we derive from our traditional banking products and services.
−Removed: For the year ended December 31, 2024, non-interest income was $27.7 million or 30.7% of total income before non-interest expense and net interest income, before the provision for credit losses, was $64.3 million, or 71.4% of total income before non-interest expense.
+Added: For the year ended December 31, 2025, Total non-interest income was $26.6 million or 27.4% of Total income before non-interest expense and Net interest income, before Provision for credit losses, was $75.4 million, or 77.8% of Total income before Non-interest expense.
We believe that we have developed a unique approach to private banking to best serve our Western wealth management clients primarily as a result of the combination of the following factors:
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• Deepening Existing Client Relationships.
−Removed: We deliver our services though our twenty local boutique private trust bank offices, loan production offices, and trust offices.
+Added: We deliver our services though our nineteen local boutique private trust bank offices, loan production offices, and trust offices.
This allows us to use multi-discipline sales and client service teams, in-market, to ensure we are meeting each client’s comprehensive set of needs.
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In a ddition, some borrowers secure a commercial purpose loan with 1-4 family residential properties.
−Removed: As of December 31, 2024, 1-4 family residential loans were $962.9 million, or 39.8% of our total loan portfolio, consisting of $133.6 million and $829.3 million of fixed-rate and adjustable-rate loans, respectively.
+Added: As of December 31, 2025, 1-4 family residential loans were $1.03 billion , or 39.1% of our total loan portfolio, consisting of $123.6 million and $910.1 million of fixed-rate and adjustable-rate loans, respectively.
While we typically originate loans with adjustable rates and maturities up to 30 years, as of December 31, 2025, the average term on our 1-4 family portfolio was 23.6 years with an average remaining term of 20.3 years.
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Our processes emphasize early stage review of loans, regular credit evaluations and management reviews of loans, which supplement the ongoing and proactive credit monitoring and loan servicing provided by our bankers.
−Removed: Our Chief Risk Officer, together with our central underwriting, credit administration and loan operations teams, provides credit oversight.
−Removed: We periodically review all credit risk portfolios to ensure that the risk identification processes are functioning properly and that our credit standards are followed.
+Added: Our Executive Director, Banking and Mortgages, together with our central underwriting, credit administration and loan operations teams, provides credit oversight.
+Added: We periodically review all credit risk portfolios to ensure that the risk identi fication processes are functioning properly and that our credit standards are followed.
In addition, a third-party loan review is performed to assist in the identification of problem assets and to confirm our internal risk rating of loans.
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We have experienced banking and business development teams who we believe provide superior client service, creative cash management solutions and competitive pricing to market our depository products and services.
−Removed: As of December 31, 2024 , total deposits we re $2.51 billion, a n decrease of $14.8 million, or 0.6%, compared to $2.53 billion as of December 31, 2023.
+Added: As of December 31, 2025 , total deposits we re $2.75 billion, an increase of $232 million , or 9.2% , compared to $2.51 billion as of December 31, 2024.
As of December 31, 2025 , our deposit portfolio contained a diverse mix of deposits, as shown below:
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These local teams have personal and professional networks and relationships with centers of influence to market our wealth advisory products and services.
−Removed: As of December 31, 2024 , total AUM was $7.32 billion, an increase of $568.0 million, or 8.4%, compared to $6.75 billion as of December 31, 2023.
+Added: As of December 31, 2025 , total AUM was $7.28 billion, a decrease of $43.0 million, or 0.6%, compared to $7.32 billion as of December 31, 2024.
As of December 31, 2025 , we provided fiduciary and advisory services on $7.28 billion of trust and investment management assets, as shown below:
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Sales and marketing support is provided centrally but delivered locally.
−Removed: • Our investment platform is controlled by our central investment research group, which has a strong research focus and includes many associates who have Chartered Financial Analyst designations, with oversight by our Chief Investment Officer and our Investment Policy Committee.
+Added: • Our investment platform is controlled by our central investment research group, which has a strong research focu s and includes many associates who have Chartered Financial Analyst designations, with oversight by our Executive Director, Wealth and Fiduciary and our Inv estment Policy Committee.
• Operational support for these profit center and product group teams is provided by our central trust and investment management support center team.
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Our Enterprise Risk Management (ERM) Committee oversees our ERM program.
−Removed: This group contains key members of management including the Chief Executive Officer, the Chief Operating Officer, the Chief Financial Officer, and the Chief Risk Officer.
+Added: This group contains key members of ma nagement including the Chief Operating Officer, Chief Financial Officer, Executive Director Legal and Governance, and the Executive Director Risk, Human Capital, and Operations.
In order to carry out the ERM program, we have developed the following objectives to:
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We provide meaningful work for our associates by connecting their role to the Company’s mission and vision as well as simplifying and streamlining repetitive tasks to make work more interesting and value added.
−Removed: We are building career paths, development opportunities and accountabilities into each role so that throughout the associates lifecycle there is opportunity to master skills and pursue professional and personal growth.
+Added: We are building role-based development opportunities and accountabilities into each role so that throughout the associates lifecycle there is opportunity to master skills and pursue professional and personal growth.
People First is also about building connection and community with the Company.
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Compensation and Benefits
−Removed: We offer a total rewards program to attract and retain team-oriented, respectful, problem solvers.
−Removed: Our compensation program includes competitive salary/hourly pay and incentive pay in the form of an annual bonus and stock awards to officers and certain members of the management team.
+Added: We offer a total rewards program to attract and retain team-oriented, respectful, problem solvers who have a growth mindset.
+Added: Our compensation program includes competitive salary/hourly pay and incentive pay in the form of quarterly bonuses and annual stock awards to officers and certain members of the management team.
We have significant insider ownership and the Board of Directors has approved stock ownership guidelines applicable to our executive officers and other key position holders to further align management and shareholder interests.
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We are always looking for ways to improve processes, products, and services.
−Removed: Client focused – First Western’s highly ethical DNA guides us to act in the client’s interest while protecting the Bank.
−Removed: Our clients know that as their trusted partner, FW has the strength and sophistication to help them for generations.
+Added: Growth mindset – First Westerns have a growth mindset and entrepreneurial spirit.
+Added: We are always looking for ways to grow profitably.
+Added: When our world changes, we adapt and take advantage of new opportunities through continual improvement.
Available Information
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bank regulatory regime is the protection of depositors, the Deposit Insurance Fund (DIF) , and the banking system as a whole, not the protection of the Company’s shareholders.
−Removed: As a bank holding company, we are subject to inspection, examination, supervision, and regulation by the Board of Governors of the Federal Reserve System (the "Federal Reserve").
+Added: As a bank holding company, we are subject to inspection, examination, supervision, and regulation by the Board of Governors of the Federal Reserve System (Federal Reserve).
The Bank, which is our subsidiary, is a Colorado-chartered commercial bank and is not a member of the Federal Reserve System (a "state nonmember bank").
−Removed: As such, the Bank is subject to regulation, supervision, and examination by both the Colorado Division of Banking (the "CDB") and the Federal Deposit Insurance Corporation ("FDIC").
+Added: As such, the Bank is subject to regulation, supervision, and examination by both the Colorado Division of Banking (CDB) and the Federal Deposit Insurance Corporation (FDIC).
In addition, we expect that any additional businesses that we may invest in or acquire will be regulated by various state and/or federal banking regulators.
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On September 9, 2022, the U.S.
−Removed: federal banking regulators announced their intent to revise regulatory capital requirements to align them with the regulatory capital standards that were finalized by the Basel Committee in December 2017, however a proposed rule has not yet been issued.
+Added: federal banking regulators announced their intent to revise regulatory capital requirements to align them with the regulatory capital standards that were finalized by the Basel Committee in December 2017.
+Added: On July 27, 2023, the OCC, Federal Reserve, and FDIC jointly released a Notice of Proposed Rulemaking that would implement the Basel III revisions for large banking organizations;
+Added: however, a final rule has not yet been issued.
In addition, the U.S.
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The impact of Basel IV on us will depend on the manner in which it is implemented by the federal bank regulators.
−Removed: In accordance with the Economic Growth, Regulatory Relief, and Consumer Protection Act (the "Regulatory Relief Act"), discussed below, the federal banking agencies published final rules implementing the community bank leverage ratio in November 2019.
+Added: In accordance with the Economic Growth, Regulatory Relief, and Consumer Protection Act (Regulatory Relief Act), discussed below, the federal banking agencies published final rules implementing the community bank leverage ratio in November 2019.
Under the final rules, which went into effect on January 1, 2020, depository institutions and depository institution holding companies that have less than $10 billion in total consolidated assets and meet other qualifying criteria, including a leverage capital ratio of greater than 9%, off-balance-sheet exposures of 25% or less of total consolidated assets and trading assets plus trading liabilities of 5% or less of total consolidated assets, are deemed "qualifying community banking organizations" and are eligible to opt into the community bank leverage ratio framework.
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If an insured depository institution fails, insured and uninsured depositors, along with the FDIC, will have priority in payment ahead of unsecured, non-deposit creditors, including the parent bank holding company, with respect to any extensions of credit they have made to such insured depository institution.
−Removed: In November 2023, the FDIC issued a final rule to implement a special assessment to recover losses to the DIF incurred as a result of 2023 bank failures and the FDIC's use of the systemic risk exception to cover certain deposits that were otherwise uninsured.
−Removed: The special assessment was based on estimated uninsured deposits as of December 31, 2022 (excluding the first $5.0 billion) and will be assessed at a quarterly rate of 3.36 basis points, over eight quarterly assessment periods, beginning in the first quarter of 2024.
−Removed: As a result of the exclusion for the first $5.0 billion in the final rule, we are not required to pay an assessment.
−Removed: Under the final rule, the estimated loss pursuant to the systemic risk determination will be periodically adjusted, and the FDIC has retained the ability to cease collection early, extend the special assessment collection period and impose a final shortfall special assessment on a one-time basis.
−Removed: The extent to which any such additional future assessments will impact our future deposit insurance expense is currently uncertain.
Consumer Financial Protection.
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Failure to comply with consumer protection requirements may also result in our failure to obtain any required bank regulatory approval for merger or acquisition transactions the Company may want to pursue or our prohibition from engaging in such transactions even if approval is not required.
−Removed: The Consumer Financial Protection Bureau ("CFPB") has broad rulemaking authority for a wide range of consumer financial laws that apply to all banks.
+Added: Notwithstanding ongoing legal, budgetary, and structural challenges affecting the Consumer Financial Protection Bureau (CFPB), the CFPB remains an active federal regulatory agency with continuing supervisory and enforcement authority and retains its broad rulemaking authority for a wide range of consumer financial laws that apply to all banks.
The CFPB is authorized to issue rules for both bank and non-bank companies that offer consumer financial products and services, subject to consultation with the prudential banking regulators.
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Much of the CFPB’s rulemaking has focused on mortgage lending and servicing, including an important rule requiring lenders to ensure that prospective buyers have the ability to repay their mortgages.
−Removed: Other areas of current CFPB focus include consumer protections for prepaid cards, payday lending, debt collection, overdraft services and privacy notices.
+Added: Other areas of CFPB focus include consumer protections for prepaid cards, payday lending, debt collection, overdraft services and privacy notices.
The CFPB has been particularly active in issuing rules and guidelines concerning residential mortgage lending and servicing, issuing numerous rules and guidance related to residential mortgages.
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A violation of these restrictions may result in the assessment of substantial civil monetary penalties on the affected bank or any officer, director, employee, agent, or other person participating in the conduct of the affairs of that bank, the imposition of a cease and desist order, and other regulatory sanctions.
−Removed: In October 2023, the Federal Reserve, the FDIC and the Office of the Comptroller of the Currency (“OCC”), issued a joint final rule to modernize the CRA regulatory framework.
−Removed: The final rule is intended, among other things to adapt to changes in the banking industry, including internet and the expanded role of mobile and online banking, and to tailor performance standards to account for differences in bank size, and business models.
−Removed: The final rule introduces new tests under which the performance of banks with over $2 billion in assets will be assessed.
−Removed: The new rule also includes data collection and reporting requirements, some of which are applicable only to banks with over $10 billion in assets.
−Removed: Most provisions of the final rule will become effective on January 1, 2026, and the data reporting requirements will become effective on January 1, 2027.
Safety and Soundness Standards.
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Financial Privacy.
−Removed: In accordance with the Gramm-Leach-Bliley Act of 1999 (the "GLB Act"), federal banking regulators adopted rules that limit the ability of banks and other financial institutions to disclose nonpublic information about consumers to nonaffiliated third parties.
+Added: In accordance with the Gramm-Leach-Bliley Act of 1999 (GLB Act), federal banking regulators adopted rules that limit the ability of banks and other financial institutions to disclose nonpublic information about consumers to nonaffiliated third parties.
These rules require disclosure of privacy policies to consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information to a nonaffiliated third party.
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Anti-Money Laundering.
−Removed: Under federal law, including the Bank Secrecy Act and Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the "USA PATRIOT Act"), certain types of financial institutions, including insured depository institutions, must maintain anti-money laundering programs that include established internal policies, procedures and controls;
+Added: Under federal law, including the Bank Secrecy Act and Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act), certain types of financial institutions, including insured depository institutions, must maintain anti-money laundering programs that include established internal policies, procedures and controls;
a designated compliance officer;
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Interstate Banking and Branching
−Removed: Under the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1999 (the "Riegle-Neal Act"), a bank holding company may acquire banks in states other than its home state, subject to any state requirement that the bank has been organized and operating for a minimum period of time, not to exceed five years, and to certain deposit market-share limitations.
+Added: Under the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1999 (Riegle-Neal Act), a bank holding company may acquire banks in states other than its home state, subject to any state requirement that the bank has been organized and operating for a minimum period of time, not to exceed five years, and to certain deposit market-share limitations.
Bank holding companies must be well capitalized and well managed, not merely adequately capitalized and adequately managed, in order to acquire a bank located outside of the bank holding company’s home state.
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While we are compliant with BCM measures, the scope and severity of cyber and non-cyber, human, and non-human disaster events is unpredictable.
−Removed: The Federal Trade Commission's (FTC) Safeguard's Rule was updated effective January 2022.
The safeguard provision of the FTC's Gramm-Leach Bliley Act (GLBA) requires the Bank to take steps to protect their clients' information.
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While we are compliant with the FTC Safeguard's Rule, unforeseen risks and threats could challenge the strategy for protecting such information and the controls in place.
−Removed: Cloud Adoption
−Removed: Treasury Department Office of Cybersecurity and Critical Infrastructure Protection (OCCIP) released a report on the current landscape of cloud adoption in December 2022.
−Removed: The report noted that financial institutions of all sizes are increasingly viewing cloud services as an important component of their technology program.
−Removed: The COVID-19 pandemic accelerated consumer demand for innovative offerings via digital channels, financial institution demand to accommodate remote work, and vendors favoring cloud-based offerings are all driving the trend in cloud adoption.
−Removed: Many larger financial institutions plan to adopt a hybrid model which includes both public and private cloud services and to have their own data centers.
−Removed: Significant benefits such as redundancy, scalability, and security are supporting cloud adoption.
−Removed: Six main challenges were noted by the OCCIP, for greater adoption of cloud by financial institutions:
−Removed: transparency in conducting due diligence on Cloud Service Providers (CSPs);
−Removed: gaps in expertise and tools as the growth of cloud service utilization outpaces the talent pool of technologists as well as the capability of financial institutions to validate rapid technological updates;
−Removed: exposure to potential operational incidents originating from CSPs;
−Removed: potential impact of market concentration in cloud service offerings on the financial services sector’s ability to be resilient against a large system failure or data breach which could impact multiple financial institutions and their customers;
−Removed: the dynamics of smaller institutions being at a disadvantage in securing preferred contract terms given the current market concentration;
−Removed: and the increasingly complex and diverse global landscape for cloud services providers and users to be compliant and to also be able to weather operational challenges with inconsistent regulatory frameworks.
−Removed: In 2023, the Treasury Department conveyed its commitment to work with financial regulators, industry, and cloud service providers to drive increased collaboration and transparency by building trust and cooperation to promote safe and effective migration for financial institutions choosing to adopt cloud services.
−Removed: Despite the challenges noted by the Treasury Department, it intends to be guided by its Strategic Vision for Supporting the Resilience of the Financial Sector’s Use of Cloud Services and will address issues that could impact operational resilience of the financial institution sector.
−Removed: The Company is in the process of adoption of a Zero Trust Network Architecture and related cloud security infrastructure to support its migration to the cloud.
−Removed: Despite extensive due diligence with our technology and security advisors and the known benefits of cloud adoption, unforeseen risks and threats in cyberspace continue to evolve to challenge our cybersecurity controls .
−Removed: In 2023, the SEC issued a final rule that requires disclosure of material cybersecurity incidents, as well as cybersecurity risk management, strategy and governance.
+Added: State regulators have also been increasingly active in implementing privacy and cybersecurity standards and regulations.
+Added: Recently, several states have adopted regulations requiring certain financial institutions to implement cybersecurity programs, and many states have also recently implemented or modified their data breach notification, information security and data privacy requirements.
+Added: The Company expects this trend of state-level activity in those areas to continue and are continually monitoring developments in the states in which its customers are located.
+Added: In addition, the SEC requires disclosure of material cybersecurity incidents, as well as cybersecurity risk management, strategy and governance.
Under this rule, banking organizations that are SEC registrants must generally disclose information about a material cybersecurity incident within four business days of determining it is material with periodic updates as to the status of the incident in subsequent filings as necessary.
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anti-money laundering (AML) regime.
−Removed: The NDAA includes the Anti-Money Laundering Act of 2020 (AML Act) and, within the AML Act, the Corporate Transparency Act (CTA).
+Added: The NDAA includes the Anti-Money Laundering Act of 2020 (AML Act).
The AML Act seeks to strengthen, modernize, and streamline the existing AML regime by promoting innovation, regulatory reform, and industry engagement through forums, such as the Bank Secrecy Act Advisory Group (BSAAG) and FinCEN Exchange.
The Act also calls for FinCEN to work closely with regulatory, national security, and law enforcement partners to identify risks and priorities and provide valuable feedback to the financial industry.
−Removed: The CTA establishes uniform beneficial ownership reporting requirements for corporations, limited liability companies, and other similar entities formed or registered to do business in the United States.
−Removed: Many provisions of the AML Act and the CTA require rulemaking or periodic reporting to Congress on implementation efforts, assessments, and findings.
Some of the key requirements of the AML Act requires FinCEN to:
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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.