Item 4. Controls and Procedures
Item 4. Controls
and Procedures
We have carried out
an evaluation, under the supervision and with the participation of our management, including our President and Chief Executive Officer
(our CEO) and our Executive Vice President and Chief Financial Officer (our CFO), of the effectiveness of our disclosure controls and
procedures (as defined in Rule 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the Exchange Act)) as of
the end of the period covered by this report. Based upon that evaluation, our CEO and CFO concluded that our disclosure controls and
procedures were operating effectively in providing reasonable assurance that (a) the information required to be disclosed by us in the
reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported within the time periods specified
in the Securities and Exchange Commission’s rules and forms, and (b) such information is accumulated and communicated to our management,
including our CEO and CFO, as appropriate to allow timely decisions regarding required disclosure.
Changes in Internal
Control Over Financial Reporting
The Company adopted
Financial Accounting Standards Board Accounting Standards Update 2016-13, “Financial Instruments – Credit Losses (Topic 326):
Measurement of Credit Losses on Financial Instruments,” and related updates, as described further in Note 2 Summary of Significant
Accounting Policies in Item 1 of this Form 10-Q, effective January 1, 2023. Related to the adoption of these new accounting standards,
the Company modified certain internal controls and designed and implemented certain new internal controls over the measurement of the
allowance for credit losses on loans and the reserve for unfunded commitments and related disclosures. New internal controls related
primarily to the modeling of expected credit losses on loans, including controls over critical data and other inputs and model results.
There were no other changes in the Company’s internal control over financial reporting during the three months ended March 31,
2023 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial
reporting.
Part II Other Information
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.