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The Bank’s revenues are derived primarily from interest on loans and, to a lesser extent, interest on investment securities and mortgage-backed securities.
−Removed: The Bank also generates revenues from other income including deposit fees, service charges and investment advisory fees.
+Added: The Bank also generates revenues from other income including deposit fees and service charges.
The Bank previously offered investment advisory and financial planning services under the name of Harbor West Wealth Management Group, a division of the Bank, through a networking arrangement with a registered broker-dealer and investment advisor.
36 unchanged sentences
We also originate a limited number of loans in New Jersey.
−Removed: Although we no longer originate loans in Connecticut, we also have a limited number of loans in this state.
−Removed: At December 31, 2024, $1.6 billion, or 89.2%, of our portfolio was secured by loans in the New York State/New York Metropolitan Area, $163.1 million, or 9.0%, of our portfolio was secured by loans in the Massachusetts/Boston Metropolitan Area and $32.7 million, or 1.8%, of our portfolio was secured by loans in Connecticut and New Jersey.
+Added: Although we no longer originate loans in Connecticut, we have one loan totaling $118,000 in this state.
+Added: At December 31, 2025, $1.6 billion, or 87.4%, of our portfolio was secured by loans in the New York State/New York Metropolitan Area, $182.7 million, or 9.8%, of our portfolio was secured by loans in the Massachusetts/Boston Metropolitan Area, and $51.9 million, or 2.8%, of our portfolio was secured by loans in New Jersey.
Construction Loans.
−Removed: We have been originating construction loans secured by the construction of multi-family and single family properties in Massachusetts and by the construction primarily of multi-family, residential condominium properties, and occasionally non-residential properties located in New York State, primarily in Bronx, Orange, Rockland and Sullivan Counties, for more than a decade.
+Added: We have been originating construction loans secured by the construction of multi-family, residential condominium properties, and occasionally non-residential properties located in New York State, primarily in Bronx, Orange, Rockland and Sullivan Counties, for more than a decade.
Since the latter part of 2013, we have primarily made construction loans to borrowers and developers who we know or who are referred to us by existing customers for construction in high absorption, homogeneous communities in our New York State market area.
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This lack of balance between supply and demand leads to available units being under contracts of sale or leases signed very soon after certificates of occupancy are received by the building owners.
−Removed: Generally, in homogeneous communities, units that are under construction have purchase agreements before they are complete.
+Added: Generally, in homogeneous communities, units that are under construction have purchase agreements before they are completed.
We will make construction loans on condominium buildings, containing between two to more than 250 units or for single family homes and single family housing developments of as many as 400 homes, in each case in high absorption and/or homogeneous areas.
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We also lend on projects, completed in stages, of up to $45 million.
−Removed: For projects above $33 million, we generally partner with a participating bank from outside our market area.
+Added: For projects above $40 million, we may partner with a participating bank from outside our market area.
We typically grant separate land and construction loans and occasionally site development loans secured by the project.
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At December 31, 2025, the construction loan portfolio was comprised primarily of 439 New York construction loans with $1.8 billion in committed amount, comprising of outstanding disbursed balances of $1.3 billion and undisbursed loans in process of $402.7 million.
−Removed: The remaining two construction loans are located in New Jersey, with $10.6 million in committed amount, $10.5 million in disbursed amount, and undisbursed loans in process of $110,000.
+Added: The remaining four construction loans are located in New Jersey, with $24.9 million in committed amount, $24.9 million in disbursed amount, and no undisbursed loans in process.
At December 31, 2025, if we were to combine land, construction and development loans as one loan on a project, our construction loan portfolio consisted of 247 loans totaling $1.8 billion in committed amount, comprised of outstanding disbursed balance of $1.3 billion and undisbursed loans in process of $402.7 million.
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If we were to combine land, construction and development loans as one loan on a project, the average loan size in our construction loan portfolio was $7.3 million in committed amount, comprised of outstanding disbursed balances of $5.4 million and undisbursed loans in process of $1.6 million at December 31, 2025.
−Removed: Our largest outstanding construction loan at December 31, 2024 had a committed amount of $27.2 million, an outstanding balance of $26.9 million, and an undisbursed available balance of $373,000.
+Added: Our largest outstanding construction loan at December 31, 2025 had a committed amount of $34.8 million, an outstanding balance of $34.8 million, and no undisbursed available balance.
This loan was performing in accordance with its terms at December 31, 2025 and is secured by the development of a 131 apartment unit multi-family building located in the Bronx, New York.
+Added: The loan subsequently paid-off in January 2026.
Our largest committed construction loan project at December 31, 2025 was comprised of five loans with a total commitment of $49.2 million of which 50.0% of the commitment of four of the five loans has been sold to another financial institution thereby reducing our committed portion to $27.4 million.
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These loans are secured by the development of a 160,000 square foot class A office building located in Monsey, New York.
−Removed: At December 31, 2024, our largest outstanding credit relationship with one borrower totaled $51.6 million, comprising of four construction loans with $33.1 million in committed amount, three commercial and industrial lines of credit with $15.0 million in committed amount, and six stand-by letters of credit with $3.5 million in committed amount.
+Added: At December 31, 2025, our largest outstanding credit relationship with one borrower totaled $57.1 million, comprising of four construction loans with $33.1 million in committed amount, five commercial and industrial lines of credit with $20.0 million in committed amount, and eight stand-by letters of credit with $4.0 million in committed amount.
Of the $57.1 million in committed amount, $11.2 million of the commitment in construction loans has been sold to two other financial institutions thereby reducing our committed portion to $45.9 million.
Our portion of these construction loans had an outstanding balance of $16.0 million and undisbursed loans in process of $255,000 at December 31, 2025.
−Removed: The three commercial and industrial lines of credit had an outstanding balance of $6.2 million and undisbursed available balance of $8.8 million at December 31, 2024.
−Removed: The six stand-by letters of credit have not been drawn upon.
+Added: The five commercial and industrial lines of credit had an outstanding balance of $14.2 million and undisbursed available balance of $5.8 million at December 31, 2025.
+Added: The eight stand-by letters of credit have not been drawn upon.
All of these loans were performing in accordance with their terms at December 31, 2025.
−Removed: At December 31, 2024, our largest outstanding committed construction loan relationship with one borrower totaled $45.9 million, of which $8.0 million of the commitment in construction loans has been sold to two other financial institutions thereby reducing our committed portion to $37.9 million.
−Removed: Our portion of these construction loans had an outstanding balance of $31.6 million and undisbursed loans in process of $6.2 million at December 31, 2024.
+Added: At December 31, 2025, our largest outstanding committed construction loan relationship with one borrower totaled $56.5 million, with an outstanding balance of $22.1 million and undisbursed available balance of $34.4 million.
+Added: Of these loans, two loans with a total committed amount of $26.5 million, an aggregate outstanding balance of $7.7 million, and an aggregate undisbursed available balance of $18.8 million were granted for the purpose of facilitating the sale of a foreclosed property located in the Bronx, New York.
All of these loans were performing in accordance with their terms at December 31, 2025.
+Added: At December 31, 2025, our next largest outstanding committed construction loan relationship with one borrower totaled $53.1 million, of which $8.1 million of the commitment in construction loans has been sold to another financial institution thereby reducing our committed portion to $45.1 million.
+Added: Our portion of these construction loans had an aggregate outstanding balance of $32.2 million and total undisbursed available balance of $12.7 million.
+Added: All of these loans were performing in accordance with their terms at December 31, 2025.
Commercial and Industrial Loans.
We provide credit to commercial and industrial businesses that are located within our market area.
−Removed: We also provide commercial and industrial loans to real estate developers in the New York
−Removed: Metropolitan Area.
+Added: We also provide commercial and industrial loans to real estate developers in the New York Metropolitan Area.
Pursuant to our lending policy, we generally limit the aggregate of all loans and lines of credit (including unused commitments) to any one borrower to no more than 10% of our Tier 1 Capital.
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At December 31, 2025, the largest outstanding commercial and industrial loan was comprised of an unsecured line of credit with an outstanding balance of $10.0 million and no remaining available line of credit.
−Removed: The borrower also has two other commercial and industrial loans with total lines of credit of $2.1 million, outstanding balances of $1.3 million, and remaining available line of credit of $750,000 at December 31, 2024.
−Removed: In addition, this borrower has three construction loans with a total commitment of $16.0 million, an outstanding disbursed balance of $13.4 million, and undisbursed loans in process balance of $2.5 million at December 31, 2024.
−Removed: At December 31, 2024, our largest outstanding commercial and industrial loan relationship with one borrower was comprised of five lines of credit totaling $9.7 million, outstanding balances of $5.4 million, and remaining available lines of credit totaling $4.3 million.
−Removed: The borrower also has two commercial and industrial term loans with outstanding balances of $2.5 million at December 31, 2024.
+Added: The borrower also has two other commercial and industrial loans with the Bank with total lines of credit of $2.1 million, aggregate outstanding balances of $1.3 million, and a remaining available line of credit of $750,000 at December 31, 2025.
+Added: In addition, this borrower has three construction loans with a total commitment of $16.0 million and an aggregate outstanding disbursed balance of $16.0 million at December 31, 2025.
+Added: At December 31, 2025, our largest outstanding commercial and industrial loan relationship with one borrower was comprised of three lines of credit totaling $5.4 million, with aggregate outstanding balances of $3.5 million, and aggregate remaining available lines of credit totaling $1.9 million.
+Added: The borrower also has five commercial and industrial term loans with aggregate outstanding balances of $8.1 million at December 31, 2025.
In addition, the borrower has a mortgage loan secured by a non-residential property with an outstanding balance of $358,000 at December 31, 2025.
−Removed: All the aforementioned commercial and industrial loans and mortgage loan were performing according to their terms at December 31, 2024.
+Added: All the aforementioned commercial and industrial loans, construction loans, and mortgage loan were performing according to their terms at December 31, 2025.
Multifamily and Mixed-Use Real Estate Loans.
−Removed: We offer adjustable-rate mortgage loans secured by multifamily and mixed-use real estate.
−Removed: These loans are comprised primarily of loans on moderate income apartment buildings located in our lending territory and include;
−Removed: loans on cooperative apartment buildings (in the New York area);
−Removed: and loans for Section 8 multifamily housing.
−Removed: In New York, most of the apartment buildings that we lend on are rent-stabilized or free market buildings.
−Removed: Mixed-use real estate loans are secured by properties that are intended for both residential and business use.
+Added: At this time, we offer adjustable-rate mortgage loans secured by cooperative apartment buildings in the New York City area.
+Added: We are not originating multifamily loans that would be subject to potential rent freezes.
We originate multifamily and mixed-use real estate loans in Massachusetts and, on a limited basis, in New Jersey.
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We have been originating multifamily and mixed-use real estate loans in the New York State/New York Metropolitan Area for 92 years.
−Removed: In the New York State/New York Metropolitan Area, our ability to continue to grow our portfolio is dependent on the continuation of our relationships with mortgage brokers, as the multifamily and mixed-use real estate loan market is primarily broker driven.
−Removed: We have longstanding relationships with mortgage brokers in the New York market area, who are familiar with our lending practices and our underwriting standards.
+Added: In the New York State/New York Metropolitan Area, our ability to continue to grow our portfolio is dependent on the continuation of our relationships with existing borrowers and to a lesser extent mortgage brokers.
+Added: We have longstanding relationships with a select number of mortgage brokers in the New York market area, who are familiar with our lending practices and our underwriting standards.
We also deal directly with building owners throughout our lending area.
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At December 31, 2025, multifamily and mixed-use real estate loans to borrowers in the Massachusetts/Boston Metropolitan Area totaled $177.5 million.
−Removed: We originate a variety of adjustable-rate and balloon multifamily and mixed-use real estate loans.
+Added: We have originated a variety of adjustable-rate and balloon multifamily and mixed-use real estate loans.
The adjustable-rate loans have fixed rates for a period of one, two, three and five years and then adjust every one, two, three or five years thereafter, based on the terms of the loan.
Maturities on these loans can be up to 15 years, and typically they amortize over a 20 to 30- year period.
−Removed: Interest rates on our adjustable-rate loans are adjusted to a rate that equals the applicable one-, two-, three- or five-year Federal Home Loan Bank (“FHLB”) of New York or FHLB of Boston advance
−Removed: rate plus a margin.
−Removed: The balloon loans have a maximum maturity of five years.
+Added: Interest rates on our adjustable-rate loans are adjusted to a rate that equals the applicable one-, two-, three- or five-year Federal Home Loan Bank (“FHLB”) of New York advance rate plus a margin.
+Added: The balloon loans have a maturity of five years to fifteen years with rate adjustments every five years.
The lifetime interest rate cap is five percentage points over the initial interest rate of the loan (four percentage points for loans with one-, two- and three-year terms).
The typical multifamily or mixed-use real estate loan refinances within the first five-year period and, in doing so, generates prepayment penalties ranging from one to five points of the outstanding loan balance.
−Removed: Under our loan-refinancing program, borrowers who are current under the terms and conditions of their contractual obligations can apply to refinance their existing loans to the rates and terms then offered on new loans after the payment of their contractual prepayment penalties.
+Added: Under our loan-refinancing program, borrowers who are current under the terms and conditions of their contractual obligations and would not be subject to rent freezes can apply to refinance their existing loans to the rates and terms then offered on new loans after the payment of their contractual prepayment penalties.
In making multifamily and mixed-use real estate loans, we primarily consider the net operating income generated by the real estate to support the debt service, the borrower’s financial resources, the income level and managerial expertise of the borrower, the marketability of the property and our lending experience with the borrower.
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Our current policy is to require a minimum debt service coverage ratio (the ratio of earnings after subtracting all operating expenses to debt service payments) of between 1.25x and 1.40x depending on the rating of the underlying property.
−Removed: The average multifamily loan debt-service coverage is 2.58x and the average loan-to-value ratio of our multifamily real estate loans is 37.5%.
−Removed: The average mixed-use real estate loan debt-service coverage is 2.98x and the average loan-to-value ratio of our mixed-use real estate loans is 37.5%.
+Added: We believe we have adequately managed our multifamily and mixed-use loan portfolio risk.
+Added: At December 31, 2025, the average multifamily loan debt-service coverage was 2.58x and the average loan-to-value ratio of our multifamily real estate loans was 43.4%.
+Added: The average mixed-use real estate loan debt-service coverage was 3.01x and the average loan-to-value ratio of our mixed-use real estate loans was 26.8%.
+Added: The average cooperative loan debt-service coverage was 2.86x and the average loan-to-value ratio of our cooperative real estate loans was 9.6%.
On multifamily and mixed-use real estate loans, our current policy is to finance up to 75% of the lesser of the appraised value or purchase price of the property securing the loan on purchases and refinances of Class A and B properties and up to 65% of the lesser of the appraised value or purchase price for properties that are rated Class C.
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In reaching a decision on whether to make a multifamily residential or mixed-use real estate loan, we consider the net operating income of the property, the borrower’s expertise, credit history and profitability, and the value of the underlying property.
−Removed: As of December 31, 2024, the largest outstanding multifamily real estate loan had a balance of $12.8 million and was performing according to its terms.
−Removed: This loan is secured by a 62-unit two building apartment complex located in Boston, Massachusetts.
+Added: As of December 31, 2025, our largest outstanding multifamily real estate loan had a balance of $19.8 million and was performing according to its terms.
+Added: This loan is secured by a 70-unit building apartment complex with a ground floor commercial unit located in the Bronx, New York.
Our largest mixed-use real estate loan had a balance of $4.0 million and was performing according to its terms at December 31, 2025.
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Our non-residential real estate loans are generally secured by office buildings, medical facilities, and retail shopping centers that are primarily located within our lending area.
−Removed: At December 31, 2024, our non-residential real estate loan portfolio was comprised of $25.3 million of loans secured by properties in the New York State/New York Metropolitan Area, $3.1 million of loans secured by properties in the Massachusetts/Boston Metropolitan Area, and $993,000 of loans secured by properties in New Jersey.
+Added: At December 31, 2025, our non-residential real estate loan portfolio was comprised of $34.9 million of loans secured by properties located within high demand/high absorption areas in the New York State/New York Metropolitan Area, $2.6 million of loans secured by properties in the Massachusetts/Boston Metropolitan Area, and $942,000 of loans secured by properties in New Jersey.
Our non-residential real estate loans are structured in a manner similar to our multifamily and mixed-use real estate loans, typically at a fixed rate of interest for three to five years and then a rate that adjusts every three to five years over the term of the loan, which is typically 15 years.
−Removed: Interest rates and payments on these loans generally are based on the one-, two-, three- or five-year FHLB of New York or FHLB of Boston advance rate plus a margin.
−Removed: interest rate cap is five percentage points over the initial interest rate of the loan (four percentage points for loans with one-, two- and three-year terms).
+Added: Interest rates and payments on these loans generally are based on the one-, two-, three- or five-year FHLB of New York advance rate plus a margin.
+Added: The lifetime interest rate cap is five percentage points over the initial interest rate of the loan (four percentage points for loans with one-, two- and three-year terms).
Loans are secured by first mortgages that generally do not exceed 75% of the property’s appraised value.
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We also consider any checking accounts with overdrawn balances as a consumer loan even though the customer typically deposits sufficient funds the next business day to cover the overdrawn balance.
−Removed: At December 31, 2024, our portfolio of consumer loans was $1.6 million, or 0.09% of total loans, comprised primarily of checking accounts with overdrawn balances of $1.6 million and one line for overdraft protection with a balance of $1,000.
+Added: At December 31, 2025, our portfolio of consumer loans was $58,000, or 0.003% of total loans, comprised primarily of five checking accounts with overdrawn balances.
Consumer loans may entail greater risk than do residential mortgage loans, particularly in the case of consumer loans that are unsecured or secured by assets that depreciate rapidly.
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Loan originations come from a number of sources.
−Removed: The primary source of loan originations are our in-house loan officers and referrals from customers and, to a much lesser extent, mortgage loan brokers and local realtors.
+Added: The primary source of loan originations are our in-house loan officers and referrals from customers and, to a
+Added: much lesser extent, mortgage loan brokers and local realtors.
Historically, we have primarily originated our own loans and retained them in our portfolio.
While in the past we purchased a limited number of participations from one financial institution that also serves high absorption areas in Brooklyn, New York, we currently do not have any purchased participation loans in our portfolio.
−Removed: We also purchased whole residential and non-residential mortgage loans from a Massachusetts financial
−Removed: institution during 2021.
+Added: We also purchased whole residential and non-residential mortgage loans from a Massachusetts financial institution during 2021.
At December 31, 2025, these whole purchased loans totaled $2.0 million and were performing according to their terms.
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Our lending activities follow written, non-discriminatory underwriting standards and loan origination procedures established by our board of directors and management.
−Removed: All construction, multifamily, mixed use and nonresidential real estate loans and commercial and industrial loans must be approved by a unanimous vote of the members of the Loan Committee, which is composed of the Chairman and Chief Executive Officer, President and Chief Operating Officer, Chief Financial Officer, and a Senior Vice President.
+Added: All construction, multifamily, mixed use and nonresidential real estate loans, and commercial and industrial loans must be approved by a unanimous vote of the members of the Loan Committee, which is composed of the Chairman and Chief Executive Officer, President and Chief Operating Officer, Chief Financial Officer, and an Executive Vice President.
At each monthly meeting of the board of directors, the board reviews all commitments issued, regardless of size.
1 unchanged sentence
Pursuant to New York law and federal banking regulations, the aggregate amount of loans that the Bank is permitted to make to any one borrower or a group of related borrowers is generally limited to 15% of its capital, surplus fund and undivided profits (25% if the amount in excess of 15% is secured by “readily marketable collateral”).
−Removed: At December 31, 2024, based on the 15% limitation, the Bank’s loans-to-one-borrower limit was approximately $43.6 million.
−Removed: On the same date, the Bank had no borrowers with outstanding balances in excess of this amount.
+Added: At December 31, 2025, based on the 15% limitation, the Bank’s loans-to-one-borrower limit was approximately $51.0 million, upon which we self-imposed an internal loans-to-one borrower limit of $45.0 million to manage risk.
+Added: As previously noted, we have one borrower with total outstanding committed loans of $56.5 million, an aggregate outstanding balance of $22.1 million, and a total undisbursed available balance of $34.4 million.
+Added: Of these loans, two loans with committed amount of $26.5 million, a total outstanding balance of $7.7 million, and a total undisbursed available balance of $18.8 million were granted for the purpose of facilitating the sale of a foreclosed property located in the Bronx, New York.
+Added: We do not believe these two loans were subject to the loans-to-one-borrower limit, pursuant to our salvage power regarding foreclosed properties.
+Added: All of these loans were performing in accordance with their terms at December 31, 2025.
+Added: At December 31, 2026, the Bank had no other borrowers with outstanding balances in excess of loans-to-one-borrower limit of $51.0 million.
Loan Commitments .
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If payment is not received by the 30th day of delinquency, additional letters are sent and phone calls are made to the customer.
−Removed: When the loan becomes 60 days past due and if the borrower is unresponsive, we generally commence foreclosure proceedings against any real property that secures the loan or attempt to repossess any personal property that secures a commercial and industrial or consumer loan.
+Added: When the loan becomes 60 days past due and if the borrower is unresponsive, we generally commence foreclosure proceedings against any real property that secures the loan or attempt to repossess any personal property that secures a commercial
+Added: and industrial or consumer loan.
If a foreclosure action is instituted and the loan is not brought current, paid in full, or refinanced before the foreclosure sale, the property securing the loan generally is sold at foreclosure.
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We have legal authority to invest in various types of liquid assets, including U.S.
−Removed: Treasury obligations, securities of various federal agencies and of state and municipal governments, municipal securities, deposits at the Federal Home Loan Bank of New York and certificates of deposit of federally insured institutions.
+Added: Treasury obligations, securities of various federal agencies and of state and municipal governments, municipal securities, deposits at the Federal Home Loan Bank of New York and the Federal Reserve Bank of New York, and certificates of deposit of federally insured institutions.
At December 31, 2025, our investment portfolio consisted primarily of mutual funds, residential mortgage-backed securities issued by Fannie Mae, Freddie Mac, and Ginnie Mae with stated final maturities of 10 years or more, and municipal securities with maturities of one years or more.
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This strategy allows us to match the maturity of these deposits very effectively to the term of our construction loans, which make up a majority of the loans in our loan portfolio.
−Removed: We may utilize advances from the Federal Home Loan Bank of New York to supplement our supply of lendable funds and to meet deposit withdrawal requirements.
+Added: From time to time, we have historically utilized advances from the Federal Home Loan Bank of New York to supplement our supply of lendable funds and to meet deposit withdrawal requirements.
The Federal Home Loan Bank functions as a central reserve bank providing credit for member financial institutions.
−Removed: As a member, we are required to own capital stock in the Federal Home Loan Bank of New York and are authorized to apply for advances on the security of such stock and certain of our mortgage loans and other assets (principally securities that are obligations of, or guaranteed by, the United States), provided certain standards related to credit-worthiness have been met.
+Added: Member financial institutions are required to own capital stock in the Federal Home Loan Bank of New York and are authorized to apply for advances on the security of such stock and certain of our mortgage loans and other assets (principally securities that are obligations of, or guaranteed by, the United States), provided certain standards related to credit-worthiness have been
Advances are made under several different programs, each having its own interest rate and range of maturities.
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The Federal Reserve Bank of New York (“FRBNY”) approved on August 30, 2023 the Bank’s eligibility to pledge loans under the Borrower-in-Custody program of the FRBNY thereby allowing the Bank to borrow from the Discount Window at the FRBNY.
−Removed: As of December 31, 2024, we had no FRBNY borrowings and an available borrowing limit of $834.7 million.
+Added: As of December 31, 2025, we had outstanding FRBNY borrowings of $70.0 million and an available borrowing limit of $768.8 million.
In addition, we are party to a loan agreement with Atlantic Community Bankers Bank under which we can borrow up to $8.0 million in short-term borrowings.
There were no outstanding borrowings with Atlantic Community Bankers Bank at December 31, 2025.
+Added: We have elected to withdraw the loans we have pledged to secure Federal Home Loan Bank of New York advances and some of our correspondent banking services to become effective in or around March 2026, but we will remain a member of the Federal Home Loan Bank of New York after such withdrawals become effective.
+Added: We intend to utilize the FRBNY for some of our future correspondent banking services.
Regulation and Supervision
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New York State banking law gives the Superintendent authority to issue an order to a New York State-chartered banking institution to appear and explain an apparent violation of law, to discontinue unauthorized or unsafe practices, and to keep prescribed books and accounts.
−Removed: Upon a finding by the New York State Department of Financial Services that any director, trustee, or officer of any banking organization has violated any law, or has continued unauthorized or unsafe practices in conducting the business of the banking organization after having been notified by the Superintendent
−Removed: to discontinue such practices, such director, trustee, or officer may be removed from office after notice and an opportunity to be heard.
+Added: Upon a finding by the New York State Department of Financial Services that any director, trustee, or officer of any banking organization has violated any law, or has continued unauthorized or unsafe practices in conducting the business of the banking organization after having been notified by the Superintendent to discontinue such practices, such director, trustee, or officer may be removed from office after notice and an opportunity to be heard.
The Superintendent also has authority to appoint a conservator or a receiver for a savings or commercial bank under certain circumstances.
24 unchanged sentences
As of December 31, 2025, the Bank had not elected the community bank leverage ratio alternative reporting framework.
−Removed: The Federal Deposit Insurance Corporation Improvement Act required each federal banking agency to revise its risk-based capital standards for insured institutions to ensure that those standards take adequate account of interest-rate
−Removed: risk, concentration of credit risk, and the risk of nontraditional activities, as well as to reflect the actual performance and expected risk of loss on multifamily residential loans.
+Added: The Federal Deposit Insurance Corporation Improvement Act required each federal banking agency to revise its risk-based capital standards for insured institutions to ensure that those standards take adequate account of interest-rate risk, concentration of credit risk, and the risk of nontraditional activities, as well as to reflect the actual performance and expected risk of loss on multifamily residential loans.
The FDIC, along with the other federal banking agencies, adopted a regulation providing that the agencies will take into account the exposure of a bank’s capital and economic value to changes in interest rate risk in assessing a bank’s capital adequacy.
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Federal law permits well capitalized and well managed bank and savings and loan holding companies to acquire banks in any state, subject to Federal Reserve Board approval, certain concentration limits and other specified conditions.
−Removed: Interstate mergers of banks are also authorized, subject to regulatory approval and other specified conditions.
+Added: Interstate mergers of banks are also authorized, subject to regulatory
+Added: approval and other specified conditions.
In addition, amendments made by the Dodd-Frank Act permit banks to establish de novo branches on an interstate basis to the extent that branching is authorized by the law of the host state for the banks chartered by that state.
23 unchanged sentences
Generally, Section 23A of the Federal Reserve Act and the Federal Reserve Board’s Regulation W limit the extent to which the bank or its subsidiaries may engage in “covered transactions” with any one affiliate to an amount equal to 10.0% of such institution’s capital stock and surplus, and with all such transactions with all affiliates to an amount equal to 20.0% of such institution’s capital stock and surplus.
−Removed: Section 23B applies to “covered transactions” as well as to certain other transactions and requires that all such transactions be on terms substantially the same, or at least as favorable, to the institution or subsidiary as those provided to a non-affiliate.
+Added: Section 23B applies to “covered transactions” as well as to
+Added: certain other transactions and requires that all such transactions be on terms substantially the same, or at least as favorable, to the institution or subsidiary as those provided to a non-affiliate.
The term “covered transaction” includes the making of loans to, purchase of assets from, and issuance of a guarantee to an affiliate, and other similar transactions.
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The Bank’s latest FDIC CRA rating was “Outstanding.”
−Removed: On October 24, 2023, the FDIC, the OCC and the Federal Reserve issued a final rule amending the agencies’ CRA regulations.
−Removed: The final rule (i) encourages banks to expand access to credit, investment and banking services in low- and moderate-income communities, (ii) adapts to changes in the banking industry, including mobile and online banking, (iii) provides greater clarity and consistency in the application of CRA regulations and (iv) tailors CRA evaluations and data collection to bank size and type.
−Removed: Under the final rule, the agencies will evaluate bank performance
−Removed: across the varied activities they conduct and communities in which they operate so that the CRA continues to be an effective tool to address inequities in access to credit and financial services.
−Removed: The final rule also updates existing CRA regulations to evaluate lending outside traditional assessment areas generated by the growth of non-branch delivery systems, such as online and mobile banking, branchless banking, and hybrid models.
−Removed: In addition, the final rule implements a new metrics-based approach to evaluating bank retail lending and community development financing, using benchmarks based on peer and demographic data.
−Removed: Most of the final rule’s requirements will become effective beginning on January 1, 2026 and the remaining requirements, including the final rule’s data reporting requirements, will become effective on January 1, 2027.
The Bank is also subject to provisions of the New York State banking law which imposes continuing and affirmative obligations upon banking institutions organized in New York State to serve the credit needs of its local community (the “NYCRA”) which are substantially similar to those imposed by the federal CRA.
17 unchanged sentences
through sharing of information about security threats between the U.S.
−Removed: government and private sector organizations, including financial institutions such as the Company.
+Added: government and private sector
+Added: organizations, including financial institutions such as the Company.
The Cybersecurity Information Sharing Act also authorizes companies to monitor their own systems, notwithstanding any other provision of law, and allows companies to carry out defensive measures on their own systems from potential cyber-attacks.
1 unchanged sentence
Specifically, the new rules require a banking organization to notify its primary federal regulator as soon as possible, and no later than 36 hours after, the banking organization determines that a "computer-security incident" rising to the level of a "notification incident" has occurred.
−Removed: Notification is required for incidents that have materially affected or are reasonably likely to materially affect
−Removed: the viability of a banking organization's operations, its ability to deliver banking products and services, or the stability of the financial sector.
+Added: Notification is required for incidents that have materially affected or are reasonably likely to materially affect the viability of a banking organization's operations, its ability to deliver banking products and services, or the stability of the financial sector.
Service providers are required under the rule to notify affected banking organization customers as soon as possible when the provider determines that it has experienced a computer-security incident that has materially affected or is reasonably likely to materially affect the banking organization's customers for four or more hours.
23 unchanged sentences
The Bank complied with the foregoing requirements during 2019.
−Removed: March 15, 2020, the Federal Reserve Board reduced reserve requirement to 0% effective as of March 26, 2020, which eliminated reserve requirements for all depository institutions.
+Added: On March 15, 2020, the Federal Reserve Board reduced reserve requirement to 0% effective as of March 26, 2020, which eliminated reserve requirements for all depository institutions.
Federal Home Loan Bank System.
4 unchanged sentences
The Bank was in compliance with requirements for the Federal Home Loan Bank of New York with an investment of $340,000 at December 31, 2025.
+Added: We have elected to withdraw the loans we have pledged to secure Federal Home Loan Bank of New York advances and some of our correspondent banking services to become effective in or around March 2026, but we will remain a member of the Federal Home Loan Bank of New York after such withdrawals become effective.
+Added: We intend to utilize the FRBNY for some of our future correspondent banking services.
Holding Company Regulation
11 unchanged sentences
The Company is subject to the Federal Reserve Board’s capital adequacy guidelines for savings and loan holding companies (on a consolidated basis) which have historically been similar to, though less stringent than, those of the FDIC for the Bank.
−Removed: The Dodd-Frank Act, however, required the Federal Reserve Board to promulgate consolidated capital requirements for depository institution holding companies that are no less stringent, both quantitatively and in terms of components of capital, than those applicable to institutions themselves.
+Added: The Dodd-Frank Act, however, required the Federal Reserve Board to promulgate consolidated capital requirements for depository institution holding companies that are no less stringent, both
+Added: quantitatively and in terms of components of capital, than those applicable to institutions themselves.
Consolidated regulatory capital requirements identical to those applicable to the subsidiary banks apply to savings and loan holding companies;
24 unchanged sentences
The Federal Reserve Board considers several factors in evaluating a notice, including the financial and managerial resources of the acquirer and competitive effects.
−Removed: Control, as defined under the applicable regulations, means the power, directly or indirectly, to direct the management or policies of the company or to vote 25% or more of any class of voting securities of the company.
+Added: Control, as defined under the applicable regulations, means the power, directly or indirectly, to
+Added: direct the management or policies of the company or to vote 25% or more of any class of voting securities of the company.
Acquisition of more than 10% of any class of a savings and loan holding company’s voting securities constitutes a rebuttable presumption of control under certain circumstances, including where, as in the case of the Company, the issuer has registered securities under Section 12 of the Securities Exchange Act of 1934.
2 unchanged sentences
Emerging Growth Company Status
−Removed: The Company is an emerging growth company and, for so long as it continues to be an emerging growth company, the Company may choose to take advantage of exemptions from various reporting requirements applicable to
−Removed: other public companies but not to “emerging growth companies,” including, but not limited to, reduced disclosure obligations regarding executive compensation in our periodic reports and proxy statements, and exemptions from the requirements of holding a nonbinding advisory vote on executive compensation and stockholder approval of any golden parachute payments not previously approved.
+Added: The Company is an emerging growth company and, for so long as it continues to be an emerging growth company, the Company may choose to take advantage of exemptions from various reporting requirements applicable to other public companies but not to “emerging growth companies,” including, but not limited to, reduced disclosure obligations regarding executive compensation in our periodic reports and proxy statements, and exemptions from the requirements of holding a nonbinding advisory vote on executive compensation and stockholder approval of any golden parachute payments not previously approved.
As an emerging growth company, the Company is not subject to Section 404(b) of the Sarbanes-Oxley Act of 2002, which would require that our independent auditors review and attest as to the effectiveness of our internal control over financial reporting.
12 unchanged sentences
New England Commercial Properties LLC , a New York limited liability company and wholly owned subsidiary of the Bank, was formed in October 2007 to facilitate the purchase or lease of real property by the Bank.
−Removed: New England Commercial Properties, LLC currently owns one foreclosed property located in the Bronx, New York and one foreclosed property located in Pittsburgh, Pennsylvania.
+Added: New England Commercial Properties, LLC currently does not own any property.
NECB Financial Services Group, LLC , a New York limited liability company and wholly owned subsidiary of the Bank, was formed in the third quarter of 2012 as a complement to Harbor West Wealth Management Group to sell life insurance and fixed rate annuities.
4 unchanged sentences
3 Winterton Realty LLC , a New York limited liability company and wholly owned subsidiary of the Bank, was formed in October 2021 to facilitate the purchase of real property by the Bank and currently owns the Bank branch located in Bloomingburg, New York.
+Added: NECB Real Estate LLC , a New York limited liability company and wholly owned subsidiary of the Bank, was formed in October 2024 to facilitate the purchase or lease of real property by the Bank.
+Added: NECB Real Estate owned one foreclosed property located in the Bronx, New York prior to the property’s disposition in June 2025.
Executive Officers
11 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.