7 unchanged sentences
Foreign exchange rates, commodity prices (other than energy) and equity prices are not expected to pose significant market risk to us.
−Removed: The responsibility for managing market risk rests with the Asset and Liability Management Committee (“ALCO”), which operates under policy guidelines established by our board of directors.
−Removed: The acceptable negative variation in net interest revenue due to a 100 basis point increase or decrease in interest rates is generally limited by these guidelines to plus or minus 10-12%.
+Added: The responsibility for managing market risk rests with the Asset and Liability Management Committee (“ALCO”), which operates under policy guidelines and risk appetite established by the Company’s board of directors.
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.
3 unchanged sentences
Our interest rate sensitivity is illustrated in the following table.
−Removed: The table reflects rate-sensitive positions as of June 30, 2022 and is not necessarily indicative of positions on other dates.
+Added: The table reflects rate-sensitive positions as of September 30, 2022 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: June 30, 2022
+Added: September 30, 2022
(in thousands) 0-3 month
30 unchanged sentences
The Federal Reserve’s federal funds target affects short-term borrowing;
−Removed: the prime lending rate, Bloomberg Short Term Yield Index (“BSBY”), LIBOR and other alternative indexes are the basis for most of our variable-rate loan pricing.
+Added: the prime lending rate, Secured Overnight Financing Rate, Bloomberg Short Term Yield Index, LIBOR and other alternative indexes are the basis for most of our variable-rate loan pricing.
The 10-year treasury rate is also monitored because of its effect on prepayment speeds for mortgage-backed securities.
2 unchanged sentences
See Note 10 - Derivative Financial Instruments for more information on interest rate derivative contracts.
−Removed: For modeling purposes, the “shock test” scenarios as of June 30, 2022 assume immediate, sustained 100 and 200 basis point increases in interest rates, as well as a 100 basis point decrease in interest rates.
−Removed: As of June 30, 2021, the scenarios assumed a sustained 100 and 200 basis point increase in interest rates.
+Added: For modeling purposes, the “shock test” scenarios as of September 30, 2022 assume immediate, sustained 100 and 200 basis point increases in interest rates as well as a 100 basis point decrease in interest rates.
+Added: As of September 30, 2021, the scenarios assumed a sustained 100 and 200 basis point increase in interest rates.
As short-term rates remained low through 2021, we did not believe that analysis of an assumed decrease in interest rates would provide meaningful results.
8 unchanged sentences
Twelve Months as Compared to Most Likely Scenario
−Removed: June 30, 2022 June 30, 2021
+Added: September 30, 2022 September 30, 2021
(in thousands) 100 bps Increase 200 bps Increase 100 bps Decrease 100 bps Increase 200 bps Increase
12 unchanged sentences
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.
−Removed: Based on our transition progress to date, we ceased originating LIBOR-based products and began originating BSBY based loans in December 2021.
−Removed: We are also prepared with other alternative benchmarks to support the transition from LIBOR.
+Added: Based on our transition progress to date, we ceased originating LIBOR-based products and began originating alternative indexed products in December 2021.
Over the next 9 months, we will continue to transition all remaining LIBOR-based products to an alternative benchmark.
1 unchanged sentence
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.