10 unchanged sentences
These guidelines establish maximum levels for short-term borrowings, short-term assets and public and brokered deposits and minimum levels for liquidity, among other things.
−Removed: Oversight of our compliance with these guidelines is the ongoing responsibility of the ALCO, with exceptions reported to the Risk Management Committee, and to our board of directors if deemed necessary, on a quarterly basis.
+Added: Oversight of our compliance with these guidelines is the ongoing responsibility of the ALCO, with exceptions reported to the Executive Risk Committee, and to our board of directors if deemed necessary, on a quarterly basis.
Additionally, the Credit Policy Committee ("CPC") specifically manages risk relative to commodity price market risks.
2 unchanged sentences
Our interest rate sensitivity is illustrated in the following table.
−Removed: The table reflects rate-sensitive positions as of September 30, 2020 , and is not necessarily indicative of positions on other dates.
+Added: The table reflects rate-sensitive positions as of March 31, 2021, and is not necessarily indicative of positions on other dates.
The balances of interest rate sensitive assets and liabilities are presented in the periods in which they next reprice to market rates or mature and are aggregated to show the interest rate sensitivity gap.
7 unchanged sentences
Interest Rate Sensitivity Gap Analysis
−Removed: September 30, 2020
−Removed: (in thousands)
+Added: March 31, 2021
+Added: (in thousands) 0-3 mo
+Added: Balance 4-12 mo
+Added: Balance 1-3 yr
+Added: Balance 3+ yr
+Added: Balance Total
Interest-bearing deposits in other banks, federal funds sold and securities purchased under resale agreements
+Added: $ 11,428,111 $ — $ — $ — $ 11,428,111
Investment securities(1) 46,621 1,898 23,642 3,370,897 3,443,058
4 unchanged sentences
Interest-bearing customer deposits $ 16,254,399 $ — $ — $ — $ 16,254,399
+Added: CDs & IRAs 156,801 381,762 63,423 4,505 606,491
Traditional brokered deposits 200,000 610,251 546,187 — 1,356,438
1 unchanged sentence
Repurchase agreements, federal funds purchased, FHLB borrowings
−Removed: Subordinated notes
−Removed: Trust preferred subordinated debentures
+Added: 2,515,587 — — — 2,515,587
+Added: Long-term debt 268,982 — — 395,986 664,968
Total borrowings 2,784,569 — — 395,986 3,180,555
Total interest sensitive liabilities $ 19,395,769 $ 992,013 $ 609,610 $ 400,491 $ 21,397,883
+Added: GAP $ 13,245,805 $ 450,755 $ 223,537 $ 4,210,176 $ —
Cumulative GAP $ 13,245,805 $ 13,696,560 $ 13,920,097 $ 18,130,273 $ 18,130,273
1 unchanged sentence
Stockholders’ equity 3,159,482
+Added: Total $ 18,334,124
(1) Investment securities based on fair market value.
10 unchanged sentences
These are our primary interest rate exposures.
−Removed: We are currently not using derivatives to manage our interest rate exposure although we may do so in the future if that appears advisable.
−Removed: For modeling purposes, the “shock test” scenarios as of September 30, 2019 assume immediate, sustained 100 and 200 basis point increases in interest rates and a 100 basis point decrease in interest rates.
−Removed: As short-term rates have declined during the first nine months of 2020, we do not believe that analysis of an assumed decrease in interest rates would provide meaningful results.
−Removed: As such, the scenarios as of September 30, 2020 assume immediate, sustained 100 and 200 basis point increases only.
+Added: We are currently not using derivatives to manage our interest rate exposure, except for MSRs, although we may do so in the future if that appears advisable.
+Added: For modeling purposes, the “shock test” scenarios as of March 31, 2021 and 2020 assume immediate, sustained 100 and 200 basis point increases in interest rates.
+Added: As short-term rates declined during 2020 and remain low through the first three months of 2021, we do not believe that analysis of an assumed decrease in interest rates would provide meaningful results.
We will continue to evaluate these scenarios as interest rates change, until short-term rates rise above 3.0%, at which point we will resume evaluations of shock scenarios in which interest rates decrease.
7 unchanged sentences
Twelve Months as Compared to Most Likely Scenario
−Removed: September 30, 2020
−Removed: September 30, 2019
−Removed: (in thousands)
−Removed: 100 bps Increase
−Removed: 200 bps Increase
−Removed: 100 bps Increase
−Removed: 200 bps Increase
−Removed: 100 bps Decrease
+Added: March 31, 2021 March 31, 2020
+Added: (in thousands) 100 bps Increase 200 bps Increase 100 bps Increase 200 bps Increase
Change in net interest income $ 38,809 $ 93,622 $ 77,720 $ 161,553
5 unchanged sentences
Financial Conduct Authority announced that it would no longer compel banks to submit rates for the calculation of LIBOR after 2021.
+Added: The administrator of LIBOR has proposed to extend publication of the most commonly used U.S.
+Added: Dollar LIBOR settings to June 30, 2023 and to cease publishing other LIBOR settings on December 31, 2021.
+Added: federal banking agencies issued guidance strongly encouraging banking organizations to cease using U.S.
+Added: dollar LIBOR as a reference rate in new contracts as soon as practicable and in any event by December 31, 2021.
+Added: It is not possible to know whether LIBOR will continue to be viewed as an acceptable market benchmark, what rate or rates may become accepted alternatives to LIBOR or what the effect of any such changes in views or alternatives may have on the financial markets for LIBOR-linked financial instruments.
The full impact of alternatives to LIBOR on the valuations, pricing and operation of our financial instruments is not yet known;
however, the primary instruments that may be impacted include loans, securities, borrowings and derivatives indexed to LIBOR that mature after December 31, 2021.
−Removed: We have established a working group, consisting of key stakeholders from throughout the Bank, to monitor developments relating to LIBOR uncertainty and changes and to guide the Bank's response.
−Removed: This team is currently working to ensure that our technology systems are prepared for the transition, our loan documents that reference LIBOR-based rates have been appropriately amended to reference other methods of interest rate determination and internal and external stakeholders are apprised of the transition.
+Added: We have established a working group, consisting of key stakeholders from throughout the company, to monitor developments relating to LIBOR uncertainty and changes and to guide the Bank's response.
+Added: This team is currently working to ensure that our technology systems are prepared for the transition, our loan documents that reference LIBOR-based rates have been appropriately amended to reference other methods of interest rate determinations and internal and external stakeholders are apprised of the transition.
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.