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 Executive Risk 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 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 March 31, 2021, and is not necessarily indicative of positions on other dates.
+Added: The table reflects rate-sensitive positions as of June 30, 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: March 31, 2021
+Added: June 30, 2021
(in thousands) 0-3 mo
37 unchanged sentences
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.
−Removed: 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.
−Removed: 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.
+Added: For modeling purposes, the “shock test” scenarios as of June 30, 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 six 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: March 31, 2021 March 31, 2020
+Added: June 30, 2021 June 30, 2020
(in thousands) 100 bps Increase 200 bps Increase 100 bps Increase 200 bps Increase
10 unchanged sentences
dollar LIBOR as a reference rate in new contracts as soon as practicable and in any event by December 31, 2021.
−Removed: 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.
+Added: At this time, it is not possible to predict 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;
3 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.