What changed in this filing

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Item 1. Business

2021-03-11 compared with 2020-03-09 · 92 added, 52 removed, 632 unchanged (19% of the section changed)

3 unchanged sentences

Chicago, Illinois;

Atlanta, Georgia;

Bellevue, Washington;

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Reference to the Company’s website address is not intended to incorporate any of the information contained on the Company’s website into this document.

COVID-19 Pandemic

The ongoing COVID-19 pandemic, and governmental and societal responses thereto, have had a severe impact on recent global economic and market conditions, including significant disruption of, and volatility in, financial markets;

global supply chain disruptions;

and the institution of social distancing and shelter-in-place requirements that have resulted in temporary closures of many businesses, lost revenues, and increased unemployment throughout the U.S., but also specifically in California, where most of the Company’s operations and a large majority of its customers are located.

On March 27, 2020, the CARES Act was enacted to address the economic impact resulted from the COVID-19 pandemic.

The CARES Act included various initiatives, such as extended unemployment benefits, mortgage forbearance, the Small Business Administration (“SBA”) Paycheck Protection Program (“PPP”) and the temporary relief from troubled debt restructuring (“TDRs”).

The Economic Aid Act was signed into law on December 27, 2020, and provided additional stimulus relief, reauthorized PPP, and extended the temporary relief from TDR treatment for certain loans modified in connection with COVID-19.

Since the beginning of the crisis, the Company has taken a number of steps to protect the safety of its employees and to support its customers.

The Company has enabled its staff to work remotely and established safety measures within its bank premises and branches for both employees and customers.

In order to support its customers, the Company has been in close contact with its customers, assessing the level of impact on their businesses, and putting a process in place to evaluate each client’s specific situation and provide relief programs where appropriate.

SBA PPP Loans

As a part of the Company’s efforts to assist its customers during the COVID-19 pandemic, the Company maintained 1,585 SBA PPP loans of $135.7 million as of December 31, 2020.

The SBA guarantees 100% of the PPP loans made to eligible borrowers, and the loans are eligible to be forgiven if certain conditions are met, at which point the SBA will make payments to the Bank for the forgiven amounts.

These loans are included in the Company’s commercial and industrial (“C&I”) portfolio and have an interest rate of 1%.

The substantial majority of the PPP loans in our portfolio have a maturity of two years.

For additional information on loans, see “Loans Held-For-Investment and Allowance for Loan Losses” included in Item 7 and Note 4 to the Consolidated Financial Statements included in Item 8 of this Annual Report on Form 10-K.

Loan Modifications Related to the COVID-19 Pandemic

As a part of the CARES Act, the temporary relief from TDRs provided an option for financial institutions to suspend the U.S.

generally accepted accounting principles (“GAAP”) requirements and regulatory determinations for loan modifications related to the COVID-19 pandemic that would otherwise be categorized as a TDR from March 1, 2020, through the earlier of 60 days after the date of the COVID-19 National Emergency comes to an end or December 31, 2020.

On April 7, 2020, the federal banking regulators also issued the “Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customer Affected by the Coronavirus (Revised)” (the “Interagency Statement”) to encourage banks to work prudently with borrowers and describe the banking regulators’ interpretation of how accounting rules for TDR apply to certain modifications related to the COVID-19 pandemic.

On December 27, 2020, the Economic Aid Act was signed into law, which extended the applicable period of the temporary relief from TDRs under the CARES Act to the earlier of 60 days after the date of the COVID-19 National Emergency comes to an end or January 1, 2022.

As of December 31, 2020, the Company’s loans under modified terms related to the COVID-19 pandemic, including payment deferments and interest only payments, totaled $36.1 million.

All of these loans under modified terms related to the COVID-19 pandemic were accounted for under section 4013 of the CARES Act and not considered TDRs.

All types of modifications have initial modification terms of 6-months or less.

Liquidity and Capital

In addition, the Company has been monitoring its liquidity and capital closely.

As of December 31, 2020, the Company maintained $194.1 million, or 10.1% of total assets, of cash and cash equivalents and $526.1 million, or 27.4% of total assets, of available borrowing capacity.

All regulatory capital ratios were also well above the regulatory well capitalized requirements as of December 31, 2020, while establishing additional provision for loan losses of $13.2 million for the year ended December 31, 2020.

At this time, the Company cannot estimate the long-term impact of the COVID-19 pandemic, but these conditions impacted and are expected to impact its business, results of operations, and financial condition negatively.

Corporate Name Change

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Lending Activities

The Company’s core lending strategy is, through the Bank, to build and maintain a diversified loan portfolio based on the type of customers (e.g., businesses versus individuals), loan products (e.g., real estate loans, commercial and industrial loans, other consumer loans), geographical locations, and different industries in which its business customers are engaged (e.g., manufacturing, wholesale and retail trade, hospitality, etc.).

The Company’s core lending strategy is, through the Bank, to build and maintain a diversified loan portfolio based on the type of customers (e.g., businesses versus individuals), loan products (e.g., real estate loans, C&I loans, other consumer loans), geographical locations, and different industries in which its business customers are engaged (e.g., manufacturing, wholesale and retail trade, hospitality, etc.).

The Company focuses its lending activities on loans that are originated from within its primary lending areas and seeks to be the premier provider of lending products and services in those market areas.

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◦ Commercial property - loans secured by commercial real estate (“CRE”) other than loans guaranteed by the U.S.

Small Business Administration (“SBA”);

◦ Residential property - loans secured by single family residential (“SFR”) real estate;

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◦ Construction.

Commercial and industrial (“C&I”) loans consist of:

• Commercial and industrial loans consist of:

◦ Commercial term;

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◦ SBA commercial term;

◦ SBA PPP loans.

• Other consumer loans consist of automobile secured loans and personal loans.

The following table presents the composition of the Company’s loans held-for-investment (presented net of deferred fees and costs) as of the dates indicated:

($ in thousands)

Percentage to Total

($ in thousands) Amount Percentage to Total Amount Percentage to Total

Real estate loans:

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Residential property 198,431 12.5 % 235,046 16.3 %

SBA property 126,570 8.0 % 129,837 8.9 %

Construction 15,199 1.0 % 19,164 1.3 %

Commercial and industrial loans:

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SBA commercial term 21,878 1.4 % 25,332 1.7 %

SBA PPP 135,654 8.6 % — — %

Other consumer loans

21,773 1.4 % 23,290 1.6 %

Loans held-for-investment

$ 1,583,578 100.0 % $ 1,450,831 100.0 %

The following table presents the composition of the Company’s loans held-for-sale as of the dates indicated:

($ in thousands)

Percentage to Total

($ in thousands) Amount Percentage to Total Amount Percentage to Total

Real estate loans:

Residential property $ 300 15.2 % $ 760 38.5 %

SBA property 1,411 71.3 % 150 7.6 %

Commercial and industrial loans:

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Real Estate Loans.

Real estate loans consist of commercial property loans, which are secured by CRE (e.g., retail shopping centers, industrial/manufacturing properties, multifamily apartment properties, office buildings etc.), SFR real estate, SBA property loans, and construction loans.

A majority of real estate lending activities originate from businesses and individuals within the Company’s primary lending areas.

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Loan fees on these products, interest rates and other provisions of residential property loans are determined by the Company on the basis of its own pricing criteria and competitive market conditions.

Interest rates and payments on ARM loans generally are adjusted annually based on the one-year London Interbank Offered Rate (“LIBOR”) or one-year Constant Maturity Treasury (“CMT”).

Interest rates and payments on ARM loans generally are adjusted annually based on the one-year Constant Maturity Treasury (“CMT”).

The spreads are fixed and thus the interest rate on these loans change in parallel with any changes in the applicable selected rates.

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In addition, all residential property loans contain due-on-sale clauses providing that the Bank may declare the unpaid amount due and payable upon the sale of the property securing the loan.

As of December 31, 2019 and 2018 , approximately 56.6% and 65.6% , respectively, of total loans were adjustable rate loans.

As of December 31, 2020 and 2019, approximately 88.4% and 93.6%, respectively, of residential property loans were ARM loans.

Construction loans are comprised of residential construction and commercial construction.

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The policy maximum LTV for construction loans is 70% and for land development loans is 50%.

Commercial and Industrial Loans.

The C&I loan category includes commercial term loans, commercial lines of credit, and SBA commercial term loans.

Commercial and Industrial Loans (Excluding SBA PPP loans).

The C&I loan category includes commercial term loans, commercial lines of credit, SBA commercial term loans, and SBA PPP loans.

Commercial term loans are typically extended to finance business acquisitions, permanent working capital needs, and/or equipment purchases.

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Small Business Administration Loans (reported as either Real Estate Loans or Commercial and Industrial Loans) .

The Bank offers SBA loans for qualifying businesses for amounts up to $5.0 million.

In addition to PPP loans, the Bank offers SBA loans for qualifying businesses for amounts up to $5.0 million.

The Bank primarily extends SBA loans known as SBA 7(a) loans and SBA 504 loans.

SBA 7(a) loans are typically extended for working capital needs, purchase of inventory, purchases of machinery and equipment, debt refinance, business acquisitions, start-up financing or the purchase or construction of owner-occupied commercial property.

Excluding PPP loans, SBA 7(a) loans are typically extended for working capital needs, purchase of inventory, purchases of machinery and equipment, debt refinance, business acquisitions, start-up financing or the purchase or construction of owner-occupied commercial property.

SBA 7(a) loans are typically term loans with maturities up to 10 years for loans not secured by real estate and up to 25 years for real estate secured loans.

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Depending on the loan amount, each loan is typically guaranteed 75% to 85% by the SBA, with a maximum gross loan amount to any one small business borrower of $5.0 million and a maximum SBA guaranteed amount of $3.75 million.

On December 27, 2020, and through September 30, 2021, the guaranty percentage provided by the SBA was temporarily increased to 90% under the Economic Aid Act.

The Bank is generally able to sell the guaranteed portion of the SBA 7(a) loans in the secondary market at a premium.

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Chicago, Illinois;

Atlanta, Georgia;

Bellevue, Washington;

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While the Company believes it is well positioned within this highly competitive industry, the industry could become even more competitive as a result of legislative, regulatory, economic, and technological changes, as well as continued consolidation within the industry.

Human Capital

At December 31, 2020, the Company had a total of 241 full-time employees and 7 part-time employees.

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Management considers its employee relations to be satisfactory.

It is through our employees, and their ties to the local community, that we are able to dutifully support the communities we serve.

Working within, and giving back to, the local community is the hallmark of a true community bank.

The Company has long been committed to comprehensive and competitive compensation and benefits programs as the Company recognizes that it operates in intensely competitive environments for talent.

Retention of skilled and highly trained employees is critical to the Company’s strategy of being a trusted resource to its communities and strengthening relationships with its clients through employees.

Community banking is often considered a relationship banking model rather than a purely transactional banking model.

The Company’s employees are critical to the Company’s ability to develop and grow relationships with its clients.

Furthering the Company’s philosophy to attract and retain a pool of talented and motivated employees who will continue to advance the purpose and contribute to the Company’s overall success, compensation and benefits programs include:

equity-based compensation plan, health/dental/vision insurances, life insurance, 401(K) plan, benefits under the Family Medical Leave Act, workers’ compensation, paid vacation and sick days, holiday pay, training/education, leave for bereavement, wedding and jury duty.

The Company invests in its employees’ future by sponsoring and prioritizing continued education throughout its employee ranks.

The Company encourages its employees to participate in educational activities, which improve or maintain their skills in their current position, as well as to enhance future opportunities at the Company.

The Company's employees are notified periodically of available internal course offerings.

Employees may also choose to take external extension courses for a maximum of two courses per quarter or semester.

All employees are able to participate in regular educational seminars run by outside parties, including but not limited to the American Bankers Association and Bankers Compliance Group.

In order to develop a workforce that aligns with the Company’s corporate values, it regularly sponsors local community events so that its employees can better integrate themselves in communities.

The Company believes that employees’ well-being and personal and professional development is fostered by outreach to the communities it serves.

The Company’s employees’ desire for active community involvement enables the Company to sponsor a number of local community events and initiatives, including donating personal protective equipment such as masks and hand wipes to non-profit organizations during the COVID-19 pandemic, hosting annual PCB scholarship that provides financial assistance to local low-to-moderate income community, conducting financial literacy training to seniors in affordable housing facilities, and participating in the Volunteer Income Tax Assistance annually to assist the community in free tax preparation.

The Company strives to place the health and well-being of employees above all else.

Never has this been more necessary than during the COVID-19 pandemic.

In response to the COVID-19 pandemic, the Company has taken significant steps to protect the health and well-being of its employees and customers, including implementing a work-from-home policy for over 60% of employees, limiting lobby hours throughout branch offices, and prioritizing drive-thru and appointment banking.

Supervision and Regulation

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federal and state law.

As a result, the growth and earnings performance of the Company and its subsidiaries may be affected not only by management decisions and general economic conditions, but also by the requirements of federal and state statutes and by the regulations and policies of various bank regulatory agencies, including the California Department of Business Oversight (“CDBO”), the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Bureau of Consumer Financial Protection (“CFPB”).

As a result, the growth and earnings performance of the Company and its subsidiaries may be affected not only by management decisions and general economic conditions, but also by the requirements of federal and state statutes and by the regulations and policies of various bank regulatory agencies, including the California Department of Financial Protection and Innovation (“CDFPI”), the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Bureau of Consumer Financial Protection (“CFPB”).

Furthermore, tax laws administered by the Internal Revenue Service (“IRS”) and state taxing authorities, accounting rules developed by the Financial Accounting Standards Board (“FASB”), securities laws administered by the SEC and state securities authorities, Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) laws enforced by the U.S.

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• in the so-called “Volcker Rule,” subject to numerous exceptions, prohibiting depository institutions and affiliates from certain investments in, and sponsorship of, hedge funds and private equity funds and from engaging in proprietary trading.

On February 3, 2017, President Trump signed an executive order calling for his administration to review existing U.S.

financial laws and regulations, including the Dodd-Frank Act, in order to determine their consistency with a set of “core principles” of financial policy.

The core financial principles identified in the executive order include the following:

empowering Americans to make independent financial decisions and informed choices in the marketplace, save for retirement, and build individual wealth;

preventing taxpayer-funded bailouts;

fostering economic growth and vibrant financial markets through more rigorous regulatory impact analysis that addresses systemic risk and market failures, such as moral hazard and information asymmetry;

enabling American companies to be competitive with foreign firms in domestic and foreign markets;

advancing American interests in international financial regulatory negotiations and meetings;

and restoring public accountability within federal financial regulatory agencies and “rationalizing” the federal financial regulatory framework.

Many aspects of the Dodd-Frank Act are subject to rulemaking and will take effect over several years, making it difficult to anticipate the overall financial impact on the Company.

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however, in many respects, the ultimate impact of the Dodd-Frank Act will not be fully known for years, and no current assurance may be given that the Dodd-Frank Act, or any other new legislative changes, will not have a negative impact on the results of operations and financial condition of the Company and the Bank.

On August 24, 2018, President Trump signed the Economic Growth, Regulatory Relief and Consumer Protection Act (the “Economic Growth Act”), which repeals or modifies certain provisions of the Dodd-Frank Act and eases regulations on all but the largest banks.

The Economic Growth Act’s highlights include improving consumer access to mortgage credit that, among other things, (i) exempt banks with less than $10 billion in assets from the ability-to-repay requirements for certain qualified residential mortgage loans;

On August 24, 2018, President Trump signed the Economic Growth Act, which repealed or modified certain provisions of the Dodd-Frank Act and eased regulations on all but the largest banks.

The Economic Growth Act’s highlights included improving consumer access to mortgage credit that, among other things, (i) exempt banks with less than $10 billion in assets from the ability-to-repay requirements for certain qualified residential mortgage loans;

(ii) not require appraisals for certain transactions valued at less than $400,000 in rural areas;

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(v) require the CFPB to clarify how TILA-RESPA Integrated Disclosure (“TRID”) applies to mortgage assumption transactions and construction-to-permanent home loans as well as outline certain liabilities related to model disclosure use, and (vi) provide that federal banking regulators may not impose higher capital standards on High Volatility Commercial Real Estate exposures unless they are for acquisition, development or construction (“ADC”), and clarifies ADC status.

In addition, the Economic Growth Act’s highlights also include regulatory relief for certain institutions, whereby among other things, it simplifies capital calculations by requiring regulators to adopt a threshold for a community bank leverage ratio of between 8% to 10%, institutions under $10 billion in assets that meet such community bank leverage ratio will automatically be deemed to be well-capitalized, although regulators retain the flexibility to determine that a depository institution may not qualify for the community bank leverage ratio test based on the institution’s risk profile, and exempts community banks from Section 13 of the BHCA if they have less than $10 billion in total consolidated assets;

In addition, the Economic Growth Act’s highlights also included regulatory relief for certain institutions, whereby among other things, it simplified capital calculations by requiring regulators to adopt a threshold for a community bank leverage ratio of between 8% to 10%, institutions under $10 billion in assets that meet such community bank leverage ratio will automatically be deemed to be well-capitalized, although regulators retain the flexibility to determine that a depository institution may not qualify for the community bank leverage ratio test based on the institution’s risk profile, and exempts community banks from Section 13 of the BHCA if they have less than $10 billion in total consolidated assets;

and exempts banks with less than $10 billion in assets, and total trading assets and liabilities not exceeding more than 5% of their total assets, from the Volcker Rule restrictions on trading with their own capital.

The Economic Growth Act also adds certain protections for consumers, including veterans and active duty military personnel, expanded credit freezes and creation of an identity theft protection database.

The Economic Growth Act also makes changes for bank holding companies, as it raises the threshold for automatic designation as a systemically important financial institution from $50 billion to $250 billion in assets, subjects banks with $100 billion to $250 billion in total assets to periodic stress tests, exempts from stress test requirements entirely banks with under $100 billion in assets, and requires the federal banking regulators to, within 180 days of passage, raise the asset threshold under the Small Bank Holding Company Policy Statement from $1 billion to $3 billion.

The Economic Growth Act also adds certain protections for student borrowers.

The Economic Growth Act also added certain protections for consumers, including veterans and active duty military personnel, expanded credit freezes and creation of an identity theft protection database.

The Economic Growth Act also made changes for bank holding companies, as it raised the threshold for automatic designation as a systemically important financial institution from $50 billion to $250 billion in assets, subjects banks with $100 billion to $250 billion in total assets to periodic stress tests, exempts from stress test requirements entirely banks with under $100 billion in assets, and required the federal banking regulators to, within 180 days of passage, raised the asset threshold under the Small Bank Holding Company Policy Statement from $1 billion to $3 billion.

The Economic Growth Act also added certain protections for student borrowers.

On June 17, 2019, the federal bank regulatory agencies jointly issued a final rule to streamline regulatory reporting requirements and committed to further review of reporting burdens for smaller institutions.

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Under the revised PCA provisions of the FDIA, an insured depository institution generally will be classified in the following categories based on the capital measures indicated:

Total Risk-Based Capital Ratio

Tier 1 Risk-Based Capital Ratio

CET 1 Risk-Based Capital Ratio

Tier 1 Leverage Ratio

PCA category Total Risk-Based Capital Ratio Tier 1 Risk-Based Capital Ratio CET 1 Risk-Based Capital Ratio Tier 1 Leverage Ratio

Well capitalized

10.0% 8.0% 6.5% 5.0%

Adequately capitalized

8.0% 6.0% 4.5% 4.0%

Undercapitalized

< 8.0% < 6.0% < 4.5% < 4.0%

Significantly undercapitalized

< 6.0% < 4.0% < 3.0% < 3.0%

Critically undercapitalized

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The rule proscribes what is included in tangible equity capital and average total consolidated assets.

The CBLR framework will be available for banks to use in their March 31, 2020, call report.

A CBLR bank that ceases to meet any of the qualifying criteria in a future period but maintains a leverage ratio greater than 8% will be allowed a grace period of two reporting periods to satisfy the CBLR qualifying criteria or to otherwise comply with the generally applicable capital requirements.

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The Company is also a bank holding company within the meaning of Section 1280 of the California Financial Code.

Consequently, the Company is subject to examination by, and may be required to file reports with, the CDBO.

Consequently, the Company is subject to examination by, and may be required to file reports with, the CDFPI.

Acquisitions, Activities and Change in Control

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“Control” is conclusively presumed to exist upon the acquisition of 25% or more of the outstanding voting securities of a bank or bank holding company, but may arise under certain circumstances between 5% and 24.99% ownership.

Under the California Financial Code, any proposed acquisition of “control” of the Bank by any person (including a company) must be approved by the Commissioner of the CDBO.

Under the California Financial Code, any proposed acquisition of “control” of the Bank by any person (including a company) must be approved by the Commissioner of the CDFPI.

The California Financial Code defines “control” as the power, directly or indirectly, to direct the Bank’s management or policies or to vote 25% or more of any class of the Bank’s outstanding voting securities.

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The deposit accounts of the Bank are insured by the FDIC’s DIF to the maximum extent provided under federal law and FDIC regulations.

As a California-chartered non-member bank, the Bank is subject to examination, supervision, and regulation by the CDBO, the chartering authority for California banks, and by the FDIC.

As a California-chartered non-member bank, the Bank is subject to examination, supervision, and regulation by the CDFPI, the chartering authority for California banks, and by the FDIC.

Depositor Preference

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Supervisory Assessments

California-chartered banks are required to pay supervisory assessments to the CDBO to fund its operations.

The amount of the assessment paid by a California bank to the CDBO is calculated on the basis of the institution’s total assets, including consolidated subsidiaries, as reported to the CDBO.

During the year ended December 31, 2019 , the Bank paid supervisory assessments to the CDBO totaling $136 thousand .

California-chartered banks are required to pay supervisory assessments to the CDFPI to fund its operations.

The amount of the assessment paid by a California bank to the CDFPI is calculated on the basis of the institution’s total assets in California, including consolidated subsidiaries, as reported to the CDFPI.

During the year ended December 31, 2020, the Bank paid supervisory assessments to the CDFPI totaling $139 thousand.

Capital Requirements

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Under the California Financial Code, the Bank is permitted to pay a dividend in the following circumstances:

(i) without the consent of either the CDBO or the Bank’s shareholders, in an amount not exceeding the lesser of (a) the retained earnings of the Bank;

(i) without the consent of either the CDFPI or the Bank’s shareholders, in an amount not exceeding the lesser of (a) the retained earnings of the Bank;

or (b) the net income of the Bank for its last three fiscal years, less the amount of any distributions made during the prior period;

(ii) with the prior approval of the CDBO, in an amount not exceeding the greatest of:

(ii) with the prior approval of the CDFPI, in an amount not exceeding the greatest of:

(a) the retained earnings of the Bank;

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or (c) the net income for the Bank for its current fiscal year;

and (iii) with the prior approval of the CDBO and the Bank’s shareholders (i.e., the Company) in connection with a reduction of its contributed capital.

and (iii) with the prior approval of the CDFPI and the Bank’s shareholders (i.e., the Company) in connection with a reduction of its contributed capital.

The payment of dividends by any financial institution is affected by the requirement to maintain adequate capital pursuant to applicable capital adequacy guidelines and regulations, and a financial institution generally is prohibited from paying any dividends if, following payment thereof, the institution would be undercapitalized.

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Branching Authority

California banks, such as the Bank, may, under California law, establish a banking office so long as the bank’s board of directors approves the banking office and the CDBO is notified of the establishment of the banking office.

California banks, such as the Bank, may, under California law, establish a banking office so long as the bank’s board of directors approves the banking office and the CDFPI is notified of the establishment of the banking office.

Deposit-taking banking offices must be approved by the FDIC, which considers a number of factors, including financial history, capital adequacy, earnings prospects, character of management, needs of the community and consistency with corporate power.

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Banking regulators examine banks for compliance with the economic sanctions regulations administered by OFAC and failure of a financial institution to maintain and implement adequate OFAC programs, or to comply with all of the relevant laws or regulations, could have serious legal and reputational consequences for the institution.

The Bank stipulated to the issuance of a consent order in April 2019, which replaced an informal agreement in January 2018 with the FDIC and CDBO that requires the Bank to take certain steps and improve processes and training relating to BSA and AML laws and regulations, and to improve its monitoring of high rate deposits.

While we do not expect this enforcement action to change our business strategy, our failure to comply with the consent order could have a negative impact on our business, including our ability to establish new branches or LPOs.

Concentrations in Commercial Real Estate

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Failure to comply with applicable laws and regulations could subject the Bank and its officers and directors to administrative sanctions and potentially substantial civil money penalties.

The CDBO also has broad enforcement powers over the Bank, including the power to impose orders, remove officers and directors, impose fines and appoint supervisors and conservators.

The CDFPI also has broad enforcement powers over the Bank, including the power to impose orders, remove officers and directors, impose fines and appoint supervisors and conservators.

Financial Privacy

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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