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 necessary, on a quarterly basis.
Additionally, the Credit Policy Committee (“CPC”) specifically manages risk relative to commodity price market risks.
13 unchanged sentences
December 31, 2021
−Removed: (in thousands) 0-3 mo
−Removed: Balance 4-12 mo
−Removed: Balance 1-3 yr
−Removed: Balance 3+ yr
+Added: (in thousands) 0-3 months
+Added: Balance 4-12 months
+Added: Balance 1-3 years
+Added: Balance 3+ years
Balance Total
−Removed: Interest-bearing deposits in other banks, federal funds sold and securities purchased under resale agreements $ 9,032,807 $ — $ — $ — $ 9,032,807
+Added: Interest-bearing deposits in other banks $ 7,765,996 $ — $ — $ — $ 7,765,996
Investment securities(1) 58,162 1,568 20,474 3,503,604 3,583,808
8 unchanged sentences
Repurchase agreements, federal funds purchased, FHLB borrowings 2,202,832 — — — 2,202,832
−Removed: Subordinated notes — — — 282,490 282,490
−Removed: Trust preferred subordinated debentures — — — 113,406 113,406
+Added: Long-term debt 270,486 — — 658,252 928,738
Total borrowings 2,473,318 — — 658,252 3,131,570
14 unchanged sentences
The Federal Reserve’s federal funds target affects short-term borrowing;
−Removed: the prime lending rate and LIBOR are the basis for most of our variable-rate loan pricing.
−Removed: The 10-year treasury rate is also monitored because of its effect on prepayment speeds for mortgage-backed securities and MSRs.
+Added: the prime lending rate, LIBOR and other alternative indexes are the basis for most of our variable-rate loan pricing.
+Added: The 10-year treasury rate is also monitored because of its effect on prepayment speeds for mortgage-backed securities.
These are our primary interest rate exposures.
−Removed: 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 December 31, 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 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 December 31, 2020 assume immediate, sustained 100 and 200 basis point increases only.
−Removed: 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.
+Added: We are currently not using derivatives to manage our interest rate exposure, although we may do so in the future if that appears advisable.
+Added: For modeling purposes, the “shock test” scenarios as of December 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 remained low throughout 2021, we do not believe that analysis of an assumed decrease in interest rates would provide meaningful results.
+Added: We will continue to evaluate these scenarios as interest rates change.
Our interest rate risk exposure model incorporates assumptions regarding the level of interest rate on indeterminable maturity deposits (demand deposits, interest-bearing transaction accounts and savings accounts) for a given level of market rate change.
7 unchanged sentences
December 31, 2021 December 31, 2020
−Removed: (in thousands) 100 bps Increase 200 bps Increase 100 bps Increase 200 bps Increase 100 bps Decrease
+Added: (in thousands) 100 bps Increase 200 bps Increase 100 bps Increase 200 bps Increase
Change in net interest income $ 48,802 $ 124,986 $ 35,286 $ 87,613
2 unchanged sentences
Actual results will differ from simulated results due to timing, magnitude and frequency of interest rate changes as well as changes in market conditions, customer behavior and management strategies, among other factors.
−Removed: Our business relies upon a large volume of loans, derivative contracts and other financial instruments with attributes that are either directly or indirectly dependent on LIBOR to establish their interest rate and/or value.
In 2017, the U.K.
−Removed: Financial Conduct Authority announced that it would no longer compel banks to submit rates for the calculation of LIBOR after 2021.
+Added: Financial Conduct Authority announced that it would no longer compel banks to submit rates for the calculation of the London Interbank Offered Rate (“LIBOR”) after 2021.
The administrator of LIBOR has proposed to extend publication of the most commonly used U.S.
2 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.
−Removed: The full impact of alternatives to LIBOR on the valuations, pricing and operation of our financial instruments is not yet known;
−Removed: 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 company, 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 determinations and internal and external stakeholders are apprised of the transition.
+Added: We have significant exposure to financial instruments with attributes that are either directly or indirectly dependent on LIBOR to establish their interest rate and/or value, some of which mature after December 31, 2021.
+Added: We have established a working group, consisting of key stakeholders from throughout the Company, to monitor developments relating to LIBOR changes and to guide the Bank’s response.
+Added: This team is continuing to work 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.
+Added: Based on our transition progress to date, we have ceased originating LIBOR-based products and began originating Bloomberg Short Term Yield Index based loans in December 2021.
+Added: We are prepared with other alternative benchmarks, as necessary, to support the transition from LIBOR.
+Added: Over the next 18 months, we will continue to transition all remaining LIBOR-based products to an alternative benchmark.
+Added: We will also continue to evaluate the transition process and align our trajectory with regulatory guidelines regarding the cessation of LIBOR as well as monitor new developments for transitioning to alternative reference rates.
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.