Common use of PROBLEM LOAN MANAGEMENT Clause in Contracts

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed in the Bank’s criticized loan list. (4) Within thirty (30) days of establishing the plan required by Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) contain, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacy; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for criticized relationships of $250,000 or above, the PLM shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty forty-five (3045) days of this Agreementdays, the Board shall adoptreview, implementin concert with Article III, the demonstrated experience and thereafter ensure adherence to a written plan to reduce skills of those individuals that have responsibility for managing problem commercial loans and the volume of problem assets by ensuring that management promptly addresses Board will determine whether outside expertise is necessary for more complex commercial and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255commercial real estate borrowers and transactions. (2) The Board’s compliance with Paragraph Within ninety (190) of this Article days, the Board shall include the development create and implementation of policy guidance setting forth actions implement a problem loan management policies and procedures that management will take to strengthen or reduce problem loans, including, at sets a minimum, guidelines on the followinghierarchy for criticized loans that establishes: (a) extensions or renewals of construction and development loansearly intervention guidelines; (b) the use of interest reserves after initial loan termminimum workout plan requirements; (c) the curtailment or re-margining frequency and content of outstanding loan balances upon renewal or extensionreports to the Board; and (d) the freezing of loan commitments on problem guidelines for advancing funds and approving renewed or restructured loans. (3) Effective as of the date of this AgreementWithin ninety (90) days, the Board shall take immediate ensure that workout plans are created for all criticized commercial loans that equal or exceed two hundred and continuing action fifty thousand dollars (250,000). The workout plans will include, at a minimum: (a) a summary of the loan exposure and guarantors and any related debt; (b) summary of collateral, condition, and date of valuation; (c) the risk rating and support for the rating; (d) determination of accrual and impairment status; (e) a synopsis of the financial condition of the borrower and guarantor, if applicable; (f) comments to protect its interest address the appropriateness of any charge-off amounts or specific allocations consistent with accounting standard A.S.C. 310-10, Receivables – Allowance for Credit Losses; (g) a detailed plan to address the primary concerns, including borrower contact and collateral valuations; (h) determination of whether or not the loan qualifies as a Troubled Debt Restructuring based on recent actions; (i) due dates and timeframes for follow-up; and (j) triggers that would result in those assets listed a downgrade or upgrade of classification or a change in the Bank’s criticized loan listaccrual status. (4) Within thirty (30) days of establishing the plan required by Paragraph (1) of this Articledays, the Board shall prepare develop, implement, and submit thereafter ensure Bank adherence to systems which provide for effective monitoring of: (a) early problem loan identification to assure the timely identification and rating of loans and leases based on lending officer submissions; (b) statistical records that will serve as a basis for identifying sources of problem loans and leases by industry, size, collateral, division, group, indirect dealer, and individual lending officer; (c) previously charged-off assets and their recovery potential; (d) compliance with the Bank's lending policies and laws, rules, and regulations pertaining to the Assistant Deputy Comptroller for Bank's lending function; (e) adequacy of credit and collateral documentation; (f) independent ongoing credit review and appropriate communication to management and the Board of Directors; and (g) concentrations of credit. (5) Within ninety (90) days, on a prior monthly basis management will provide the Board with written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) containreports including, at a minimum, analysis and documentation of the followingfollowing information: (a) an identification the identification, type, rating, and amount of the expected sources of repayment problem loans and an analysis of their adequacyleases; (b) the appraised value identification and amount of supporting collateral delinquent loans and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuationleases; (c) an analysis of current credit and satisfactory credit information, including cash flow analysis where loans are to be repaid from operationscollateral documentation exceptions; (d) the proposed action to eliminate the basis identification and status of criticism and the time frame for its accomplishmentcredit related violations of law, rule or regulation; (e) trigger dates for positive borrower actions or for the identity of the loan officers to reassess the strategy, enact collection plans, officer who originated each loan reported in accordance with subparagraphs (a) through (d) of this Article and make appropriate downgrades or place on nonaccrual;Paragraph; and (f) a determination an analysis of whether the loan is impaired and the amount concentrations of the impairmentcredit, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for criticized relationships of $250,000 or above, the PLM shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewalssignificant economic factors, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve general conditions and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves their impact on the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests quality of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of creditloan and lease portfolios.

PROBLEM LOAN MANAGEMENT. (1) Within thirty ninety (3090) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed in the Bank’s criticized loan list. (4) Within thirty (30) days of establishing the plan required by Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller ADC for a review and prior written determination of no supervisory objection, a written program designed to reduce identify and manage the Bank’s criticized problem assets to maintain safe and sound levels (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure for developing action plans for each problem credit that Problem Loan Memoranda (“PLM”) contain, at a minimum, analysis and documentation of would contain the followingfollowing information: (a) an identification and explanation of the problems and causes that led to the asset’s criticized status; (b) a decision of whether to rehabilitate or to exit the credit relationship; (c) an identification of the expected sources of repayment and an analysis of their adequacy; (bd) the appraised current value of supporting collateral collateral, as determined by an appraisal or an evaluation, and the position of the Bank’s lien on such collateral where applicable applicable, as well as other necessary documentation to support the collateral valuation; (ce) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (df) the accrual designation and justification for the designation; (g) the proposed action action, by the Bank or the borrower, to eliminate the basis of criticism and the time frame for its accomplishment;; and (eh) trigger dates for positive borrower actions upgrading or for loan officers downgrading the credit relationship. (2) The Problem Assets Program shall also include policies and procedures to reassess address criticized asset levels including: (a) a threshold level of classified assets based on capital level under which to implement the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrualplan; (fb) a determination specific plans for the reduction of whether the loan is impaired and the amount of the impairment, consistent problem assets by asset type with FASB Statement of Financial Accounting Standards No. 114, Accounting target reductions by Creditors for Impairment of a Loanmonth; and (gc) for criticized relationships of $250,000 a documented quarterly review by the Board, or abovedesignated committee thereof, the PLM shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs efforts to execute the budgeted amount; (iv) a comparison of sales activity specific plans to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating to the projectreduce problem asset levels. (53) Upon receiving a written determination of no supervisory objection from the Assistant Deputy ComptrollerADC, the Board shall immediately implement and thereafter ensure adherence to the program Problem Assets Program required by this Article. (64) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, The Bank shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including including, but not limited to, renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized by the OCC in the ▇▇▇, in any subsequent a Report of ExaminationExamination or otherwise, or in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to credit, are one hundred thousand dollars ($100,000) or exceeding $250,000more, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves certifies in writing within the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; andpresentation that: (ba) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by compromised; and (b) the extension or renewal is necessary to promote the best interests of creditthe Bank, with documentation for the reasons thereof and that include consideration of subparagraphs (a) through (h) under Paragraph (1) of this Article.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan listreview or in any list provided to management by the National Bank Examiners during any subsequent examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies procedures for the quarterly submission and procedures to ensure that review of Problem Loan Memoranda Asset Reports (“PLMPARs” or “PAR”) of all criticized credit relationships or Other Real Estate (“ORE”) totaling two hundred fifty thousand dollars ($250,000) or more. PARs shall contain, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacy; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation, as directed by Article VI of this Agreement; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) an assessment of the borrower’s global cash flow; (e) an assessment of any guarantor’s global cash flow; (f) the current grade and proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (eg) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place the loan on nonaccrual; (fh) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and; (gi) for criticized relationships of two hundred fifty thousand dollars ($250,000 250,000) or aboveabove that were made for the purpose of constructing or developing commercial real estate, the PLM PARs shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viiivi) any other significant information relating to the project; and (j) an evaluation of the progress made in the last quarter. (53) Upon receiving a written determination Within thirty (30) days of no supervisory objection from the Assistant Deputy Comptrollerend of each calendar quarter, the Board Bank shall immediately implement assess the overall progress made pursuant to this Article and thereafter ensure adherence determine appropriateness of the actions taken pursuant to the program required by this Article. (64) A copy of each PLM PAR prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREOORE, and the assessment made pursuant to Paragraph (3) of this Article, shall be submitted to available upon request for the Assistant Deputy Comptroller within fifteen (15) days inspection of each calendar quarter endthe National Bank Examiners. (75) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan review, review or in any subsequent list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed two hundred fifty thousand dollars ($250,000), unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, writing the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those classified and special mention assets listed in identified by OCC examiners, external loan review, or the Bank’s criticized loan listBank (hereafter, the “problem assets”). (42) Within thirty ninety (3090) days of establishing the plan required by Paragraph (1) date of this ArticleAgreement, the Board shall prepare develop written procedures with assigned responsibility for the quarterly submission and submit to the Assistant Deputy Comptroller for a prior written determination review of no supervisory objection, a written program designed to reduce the Bank’s criticized reports of all problem assets totaling one hundred thousand dollars (the $100,000) or above (“Problem Assets ProgramPAR”). The Problem Assets Program Each PAR shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) containrequire, at a minimum, analysis and documentation of the following: (a) an identification of the current expected sources of repayment and an analysis of their adequacyrepayment; (b) detailed collateral information, including, as applicable, the appraised current value of supporting collateral collateral, the condition of the collateral, and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuationposition; (c) an analysis concessions made to the terms of the credit, if any, and how doing so will improve the problem credit; (d) trigger dates for borrower actions or for loan officer reassessment of strategy and enactment of collection plans; (e) the root causes of the credit weakness; (f) current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (fg) a determination of whether the loan is impaired and the amount of the impairmentimpairment amount, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors generally accepted accounting principles (“GAAP”); (h) analysis and reasoning to support the current risk rating along with specific action plans and trigger dates for Impairment of a Loanrisk rating changes; and (gi) for criticized relationships of $250,000 a review, at least quarterly, by the Board or above, the PLM shall also includea designated committee thereof to: (i) measure progress and reevaluate the initial scheduled maturity date suitability of the loan, number of extensions and/or renewals, and current maturity date;action plans; and (ii) project development status; (iii) a comparison of development costs to document the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment effectiveness of the borrowerresponsible officer’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating efforts to eliminate the projectweakness in each problem asset relationship. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (63) A copy of each PLM PAR prepared during the month pursuant to Paragraph (2) of each quarter end (e.g., March, June, September, and December)this Article, along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREOproblem asset, shall be submitted to the Assistant Deputy Comptroller within fifteen forty-five (1545) days of each calendar quarter end. (74) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including overdrafts, renewals, extensions of the payment or principal due date, or capitalization of accrued interest, but excluding advances on previously approved lines of credit, to a borrower whose loans or other extensions of credit are criticized in considered problem assets by the ▇▇▇OCC examiners, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination Bank, and whose aggregate loans or other extensions of credit equal to or exceeding credit, exceed two hundred fifty thousand dollars ($250,000, ) unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the full Board or a designated committee thereof approves the credit extension and documents extension; (b) the Board explains in writing, writing how the reasons that such credit extension is necessary to promote the best interests of the Bank; and; (bc) the Board explains in writing how the credit extension will not compromise the Board’s formal plan to collect or strengthen the criticized asset will not be compromised problem asset; and (d) the Board’s written determinations required by this Article are maintained in the extension of creditborrower’s credit file.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, by internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, Article shall require the Board shall prepare quarterly submission and submit to the Assistant Deputy Comptroller for a prior written determination review of no supervisory objection, a written program designed to reduce the Bank’s reports of all criticized assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda credit relationships or Other Real Estate (“PLMORE”) totaling two hundred fifty thousand dollars ($250,000) or more, and require the preparation of Problem Asset Reports (“PARs” or “PAR”) that contain, at a minimum, analysis and documentation of the following:documentation (a) an identification of the expected sources of repayment and an analysis of their adequacy; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the current loan grade and proposed action to eliminate the basis of criticism and the time frame for its accomplishmentsuch elimination; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual;; and (f) a determination of whether the a loan is impaired and measuring the amount of the impairment, consistent with the guidance set forth in the Federal Financial Institutions Examination Council’s “Interagency Policy Statement on the Allowance for Loan and Lease Losses” dated December 13, 2006 (OCC Bulletin 2006-47), and July 20, 2001 (OCC Bulletin 2001-37), and Accounting Standards Codification 310-10 (formerly known as FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for criticized relationships of $250,000 or above, the PLM shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating to the project). (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (63) A copy of each PLM PAR prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREOORE, shall be submitted to the Assistant Deputy Comptroller within fifteen thirty (1530) days of each calendar quarter end. (74) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed two hundred fifty thousand dollars ($250,000), unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit. (5) Within ninety (90) days of this Agreement, the Board shall ensure that the President, Senior Loan Officer, and all lending officers receive appropriate training on the development of prudent workout plans and strategies for problem borrowers.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ROE, in any subsequent Report of Examination, by internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies procedures for the monthly submission and procedures to ensure review of problem asset reports for all criticized credit relationships totaling $100,000 or above, that Problem Loan Memoranda (“PLM”) containrequire, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacyrepayment; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, strategy and enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (gf) for criticized relationships of $250,000 100,000 or aboveabove that were made for the purpose of constructing or developing CRE, the PLM reports shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) current market conditions and activity; (vi) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vivii) an assessment of the borrower’s global cash flow; (viiviii) an assessment of any the guarantor’s global cash flowability to support the project; and (viiiix) any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (73) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed $250,000100,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of creditcompromised.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to establish a written plan to that will reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions Extensions or renewals of construction and development loans; (b) the The use of interest reserves after initial loan term; (c) the The curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the The freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed in on the Bank’s criticized loan list. (4) Within thirty days (30) days of establishing the plan required by Paragraph paragraph (1) of this ArticleArticle , the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized classified assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) contain, at a minimum, analysis and documentation of the following: (a) an An identification of the expected sources of repayment and an analysis of their adequacy; (b) the The appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an An analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the The proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger Trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a A determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for For criticized relationships of $250,000 or above, the PLM shall also include: (i) the The initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project Project development status; (iii) a A comparison of development costs to the budgeted amount; (iv) a A comparison of sales activity to the original sales projections; (v) amount Amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an An assessment of the borrower’s global cash flow; (vii) an An assessment of any guarantor’s global cash flow; and (viii) any Any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are on the Bank’s criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the The Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the The Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those classified or special mention assets listed in identified by OCC examiners, external loan review, or the Bank’s criticized loan listBank (hereafter, the “problem assets”). (42) Within thirty (By June 30) days of establishing the plan required by Paragraph (1) of this Article, 2024, the Board shall prepare develop written procedures with assigned responsibility for the quarterly submission and submit to the Assistant Deputy Comptroller for a prior written determination review of no supervisory objection, a written program designed to reduce the Bank’s criticized reports of all problem assets (the “Problem Assets ProgramPAR”). The Problem Assets Program Each PAR shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) containrequire, at a minimum, analysis and documentation of the following: (a) an identification of the current expected sources of repayment and an analysis of their adequacyrepayment; (b) the appraised value of supporting collateral historical payment history and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuationcurrent payment status; (c) an analysis detailed collateral information, including, as applicable, the current value of supporting collateral, the condition of the collateral, and the Bank’s lien position; (d) status of property tax payments and business registrations; (e) up to date information regarding communication between the borrower and the SBA and/or USDA, if applicable; (f) workout strategies or concessions made to the terms of the credit, if any, and how doing so will improve the problem credit; (g) trigger dates for borrower actions or for loan officer reassessment of strategy and enactment of collection plans; (h) the root causes of the credit weakness; (i) current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (fj) a determination of whether the loan is impaired and the amount of the impairmentimpairment amount, consistent with FASB Statement generally accepted accounting principles (“GAAP”); (k) a breakdown of Financial Accounting Standards No. 114, Accounting by Creditors any credit exposures subject to split classifications; (l) analysis and reasoning to support the current risk rating along with specific action plans and trigger dates for Impairment of a Loanrisk rating changes; and (gm) for criticized relationships of $250,000 a review, at least quarterly, by the Board or above, the PLM shall also includea designated committee thereof to: (i) measure progress and reevaluate the initial scheduled maturity date suitability of the loan, number of extensions and/or renewals, and current maturity date;action plans; and (ii) project development status; (iii) a comparison of development costs to document the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment effectiveness of the borrowerresponsible officer’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating efforts to eliminate the projectweakness in each problem asset relationship. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (63) A copy of each PLM PAR prepared during the month pursuant to Paragraph (2) of each quarter end (e.g., March, June, September, and December)this Article, along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREOproblem asset, shall be submitted to the Assistant Deputy Comptroller within fifteen forty-five (1545) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, by internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies and procedures enhancements to ensure that Problem Loan Memoranda the Bank’s Criticized Asset Reports (“PLM”) CARs), to be submitted monthly to the Board, for all criticized credit relationships totaling $200,000 or above. The revised CARs shall contain, at a minimum, analysis and documentation of the following: (a) a complete credit history, to include, at a minimum: (i) loan origination date; (ii) loan purpose; (iii) grade history, including the reason for any grade change; (iv) any material changes since the previous CAR was filed; (b) an identification of the expected sources of repayment and an analysis of their adequacyrepayment; (bc) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (cd) an analysis of current and satisfactory credit information, including to include, at a minimum, the timely analysis of tax returns, financial statements, news reports, global cash flow analysis where loans are to be repaid from operationsflow, contingent liabilities, and other indicators of possible problems; (de) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (ef) trigger dates for positive borrower actions or for loan officers to reassess the strategy, strategy and enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for criticized relationships of $250,000 200,000 or aboveabove that were made for the purpose of constructing or developing CRE, the PLM reports shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) current market conditions and activity; (vi) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vivii) an assessment of the borrower’s global cash flow; (viiviii) an assessment of any the guarantor’s global cash flowability to support the project; and (viiiix) any other significant information relating to the project. (53) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program The CARs required by Paragraph (2) of this Articlearticle shall cover the entire credit relationship, rather than the current process of generating separate reports for individual loans. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (74) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed $250,000200,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by compromised. (5) The Board shall conduct a review, on at least a monthly basis, to determine the extension status of creditall criticized assets and Bank management’s adherence to the requirements of this Article.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized Report of Examination dated as of March 31, 2009, in any subsequent Report of Examination, by the loan listreview conducted as of June 30, 2009 or any subsequent internal or external loan review, or in any list provided to management by the National Bank Examiners during any subsequent examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies procedures for the quarterly submission and procedures to ensure that review of Problem Loan Memoranda Asset Reports (“PLMPARs” or “PAR”) of all criticized credit relationships or Other Real Estate (“ORE”) totaling five hundred thousand dollars ($500,000) or more. PARs shall contain, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacy; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation, as directed by Article VI of this Agreement; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) an assessment of the borrower’s global cash flow; (e) an assessment of any guarantor’s global cash flow; (f) the current grade and proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (eg) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (fh) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and; (gi) for criticized relationships of five hundred thousand dollars ($250,000 500,000) or aboveabove that were made for the purpose of constructing or developing CRE, the PLM PARs shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viiivi) any other significant information relating to the project; and (j) an evaluation of the progress made in the last quarter. (53) Upon receiving a written determination Within thirty (30) days of no supervisory objection from the Assistant Deputy Comptrollerend of each calendar quarter, the Board Bank shall immediately implement assess the overall progress made pursuant to this Article, and thereafter ensure adherence determine appropriateness of the plans, policies and procedures adopted pursuant to the program required by this Article. (64) A copy of each PLM PAR prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREOORE, and the assessment made pursuant to Paragraph (3) of this Article, shall be submitted to the Assistant Deputy Comptroller within fifteen thirty (1530) days after the end of each calendar quarter endquarter. (75) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇Report of Examination dated as of March 31, 2009, in any subsequent Report of Examination, in the loan review conducted as of June 30, 2009 or any subsequent internal or external loan review, or in any subsequent list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed five hundred thousand dollars ($250,000500,000), unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, by internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any examination. (42) Within thirty (30) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies procedures for the monthly submission and procedures to ensure review of problem asset reports for all criticized credit relationships totaling $100,000 or above, that Problem Loan Memoranda (“PLM”) containrequire, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacyrepayment; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, strategy and enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (gf) for criticized relationships of $250,000 100,000 or aboveabove that were made for the purpose of constructing or developing CRE, the PLM reports shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) current market conditions and activity; (vi) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vivii) an assessment of the borrower’s global cash flow; (viiviii) an assessment of any the guarantor’s global cash flowability to support the project; and (viiiix) any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (73) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed $250,000100,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of creditcompromised.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to establish a written plan designed to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions Extensions or renewals of construction and development loans; (b) the The use of interest reserves after initial loan term; (c) the The curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the The freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed in on the Bank’s criticized loan list. (4) Within thirty days (30) days of establishing the plan required by Paragraph paragraph (1) of this ArticleArticle , the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized classified assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures designed to ensure that Problem Loan Memoranda (“PLM”) contain, at a minimum, analysis and documentation of the following: (a) an An identification of the expected sources of repayment and an analysis of their adequacy; (b) the The appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an An analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the The proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger Trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a A determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for For criticized relationships of $250,000 or above, the PLM shall also include: (i) the The initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project Project development status; (iii) a A comparison of development costs to the budgeted amount; (iv) a A comparison of sales activity to the original sales projections; (v) amount Amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an An assessment of the borrower’s global cash flow; (vii) an An assessment of any guarantor’s global cash flow; and (viii) any Any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are on the Bank’s criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the The Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the The Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. ‌ (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its the Bank’s interest in those assets listed in classified and special mention loans identified by OCC examiners, external loan review, or the Bank’s criticized loan listBank (hereafter, problem loans). (42) Within thirty (30) days of establishing the plan required by Paragraph (1) of this ArticleBy October 31, 2022, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, adopt a written program designed to reduce identify, measure, monitor, and control the Bank’s criticized assets problem loans (the “Problem Assets Loan Program”). The Problem Assets Loan Program shall include or address, at a minimum, the development following matters: (a) policies that address problem loan management that include, at a minimum, responsibilities and accountability for identifying, measuring, monitoring, and controlling problem loans, risk rating definitions, nonaccrual definition, problem asset report (PAR) requirements and reporting, and collateral valuation requirements; (b) aggregate reporting of policies classified assets and special mention asset levels by risk rating as a percentage of Tier 1 capital plus the ALLL with trend analyses to the Board or a designated committee thereof every quarter; and (c) training for credit approval committee members, loan officers, and credit staff on problem loan management and the Bank’s Problem Asset Program, policy, and processes. (3) By October 31, 2022, the Board shall develop written procedures to ensure that Problem Loan Memoranda with assigned responsibility for the quarterly submission and review of reports of all problem assets totaling one hundred thousand dollars (“PLM”$100,000) containor above (PAR). Each PAR shall require, at a minimum, analysis and documentation of the following: (a) an identification of the current expected sources of repayment and an analysis of their adequacyrepayment; (b) detailed collateral information, including, as applicable, the appraised current value of supporting collateral collateral, the condition of the collateral, and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuationposition; (c) an analysis concessions made to the terms of the credit, if any, and how doing so will improve the problem credit; (d) trigger dates for borrower actions or for loan officer reassessment of strategy and enactment of collection plans; (e) the root causes of the credit weakness; (f) current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (fg) a determination of whether the loan is impaired and the amount of the impairmentimpairment amount, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors generally accepted accounting principles (GAAP); (h) analysis and reasoning to support the current risk rating along with specific action plans and triggers for Impairment of a Loanrisk rating changes; and (gi) for criticized relationships of $250,000 a review, at least quarterly, by the Board or above, the PLM shall also includea designated committee thereof to: (i) measure progress and reevaluate the initial scheduled maturity date suitability of the loan, number of extensions and/or renewals, and current maturity date;action plans; and (ii) project development status; (iii) a comparison of development costs to document the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment effectiveness of the borrowerresponsible officer’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating efforts to eliminate the projectweakness in each problem asset relationship. (54) Upon receiving a written determination adoption of no supervisory objection from the Assistant Deputy ComptrollerProblem Loan Program, the Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, Problem Loan Program and December), along with any amendments thereto. The Board comments regarding shall review the effectiveness of the effort to eliminate Problem Loan Program at least annually, and more frequently if necessary or if required by the weaknesses OCC in each credit writing, and amend the Problem Loan Program as needed or to dispose of directed by the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter endOCC. (75) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including overdrafts, renewals, extensions of the payment or principal due date, or capitalization of accrued interest, but excluding advances on previously approved lines of credit, to a borrower whose loans or other extensions of credit are criticized in considered problem assets by the ▇▇▇OCC examiners, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination Bank, and whose aggregate loans or other extensions of credit equal to or exceeding credit, exceed one hundred thousand dollars ($250,000, 100,000) unless each of the following conditions is are met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the full Board or a designated committee thereof approves the credit extension and documents extension; (b) the Board explains in writing, writing how the reasons that such credit extension is necessary to promote the best interests of the Bank; and; (bc) the Board explains in writing how the credit extension will not compromise the Board’s formal plan to collect or strengthen the criticized asset will not be compromised problem asset; and (d) the Board’s written determinations required by this Article are maintained in the extension of creditborrower’s credit file.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed subject to adverse classification in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, by internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any examination. (2) Within ninety (90) days of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to specific procedures designed to ensure that risk rating and nonaccrual designation definitions in the loan policy are adhered to. (3) Within ninety (90) days of this Agreement, the Board and management must develop and implement a plan that provides for external training on loan risk ratings, nonaccrual, impairment, and loss recognition for all lenders and loan committee members, the implementation of which must be completed within one hundred twenty (120) days of this Agreement. (4) Within thirty The Board must ensure an annual or more frequent independent and qualified loan review that assesses credit risk in the loan portfolio, compliance with bank policy, and validates internal risk ratings. The Board must ensure that the engaged loan reviewer adheres to the terms of engagement. (305) days of establishing the plan required by The Board’s compliance with Paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program Article shall include the development of policies and procedures for the quarterly submission and review of reports of all credit relationships subject to ensure that Problem Loan Memoranda criticism or adverse classification or Other Real Estate Owned (“PLMOREO”) totaling fifty thousand dollars ($50,000) or more, and that require the preparation of loan status reports (“LSR”) that contain, at a minimum, analysis and documentation of the following: (a) the basis for criticism and proper risk rating and accrual designation; (b) an identification of the expected sources of repayment and an analysis of their adequacy; (bc) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (cd) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (de) the current grade and proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (ef) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual;; and (fg) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for criticized relationships of $250,000 or above, the PLM shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viii) any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this ArticleASC 310-10. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December)LSR, along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen ten (1510) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the first Board meeting following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension receipt of creditsuch report.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of the date of this Agreement, the Board Bank shall adopttake action to protect its interest in those assets criticized in the ▇▇▇, implementin any subsequent ▇▇▇, and thereafter ensure adherence by internal or external loan review, or in any list provided to a written plan to reduce management by the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255National Bank Examiners during any examination. (2) The Board’s compliance with Paragraph Within ninety (190) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as days of the date of this Agreement, the Board shall take immediate establish a Problem Loan Management Program for the purpose of restoring and continuing action to protect its interest in those assets listed in reclaiming classified assets, including commercial loans, consistent with Appendix F of the Real Estate and Construction Lending Booklet of the Comptroller’s Handbook (formerly OCC Banking Circular 255), and reducing the level of criticized loans of the Bank’s criticized loan list. (43) Within thirty one hundred and twenty (30120) days of establishing the plan required by Paragraph (1) date of this ArticleAgreement, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Loan Management Program shall include the development and implementation of policies a written action plan for each criticized lending relationship with an aggregate exposure to the Bank exceeding one hundred fifty thousand dollars ($150,000), each such plan to be updated at least quarterly and procedures with action plans and updated action plans reported to ensure that Problem Loan Memoranda the Compliance Committee; (“PLM”4) containWritten action plans required by this Article shall include, at a minimum, analysis and documentation of the following: (a) a summary of loan exposure, guarantors and any related debt; (b) an identification of the expected sources source of repayment and an analysis of their adequacyrepayment; (bc) the appraised value summary of supporting collateral collateral, condition and date of valuation; (d) the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuationapplicable; (ce) an analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (df) the risk rating and support for the rating;, (g) a list of the proposed action actions to be taken to eliminate the basis of criticism and the time frame for its accomplishmentaccomplishment of each action on the list; (h) an analysis of whether the relationship constitutes a troubled debt restructuring under Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) 310-40 (pre-codification reference: Statement of Financial Accounting Standards (“FAS”) Statement No. 114); and (i) contact information for each borrower and guarantor. (5) Within ninety (90) days of the date of this Agreement, the Board shall develop and implement policies and procedures governing the administration of problem loans, including but not limited to: (a) early intervention guidelines; (b) minimum workout plan requirements; (c) the frequency and content of reports to the Board; (d) guidelines for advancing funds and approving renewed or restructured loans; (e) trigger dates for positive borrower actions establishing when collateral securing a criticized loan must be reappraised or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrualreevaluated; (f) a determination ensuring the accuracy of whether the loan is impaired and the amount classifications resulting after consideration of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a LoanOCC Bulletin 2000-20; and, (g) establishing the method by which the effectiveness of loan workout efforts are reviewed and assessed by the loan review consultant engaged for criticized relationships periodic reviews under Article IV of $250,000 or abovethis Agreement. (6) Within thirty (30) days of the date of this Agreement, the PLM Board shall, subject to Paragraph (7) of this Article, employ a consultant or consultants qualified to assess the effectiveness of the Problem Loan Management Program on an ongoing quarterly review. The consultant shall also include:be utilized until such time as the Problem Loan Management Program is developed by the Board, implemented and demonstrated to be effective. (i7) Prior to the initial scheduled maturity date appointment or employment of any loan review consultant, loan workout specialist, or entering into any contract with a consultant or loan workout specialist, the Board shall submit the name and qualifications of the loan, number proposed consultant and the proposed terms of extensions and/or renewals, and current maturity date;employment to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection. (ii) project development status; (iii) a comparison of development costs to 8) Before terminating the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an consultant's assessment of the borrower’s global cash flow; (vii) an assessment effectiveness of any guarantor’s global cash flow; and (viii) any other significant information relating to the project. (5) Upon receiving a Problem Loan Management Program, the Board shall both certify the effectiveness of the Problem Loan Management Program, and receive prior written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (69) A copy The requirement to submit information and the provisions for prior written determination of each PLM prepared during no supervisory objection in this Article are based on the month authority of each quarter end (e.g., March, June, September, 12 U.S.C. § 1818(b) and December), along with any Board comments regarding do not require the effectiveness of the effort to eliminate the weaknesses in each credit Comptroller or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller to complete his/her review and act on any such information or authority within fifteen ninety (1590) days of each calendar quarter enddays. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to establish a written plan to that will reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions Extensions or renewals of construction and development loans; (b) the The use of interest reserves after initial loan term; (c) the The curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the The freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed in on the Bank’s criticized loan list. (4) Within thirty days (30) days of establishing the plan required by Paragraph paragraph (1) of this Article, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized classified assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda (“PLM”) contain, at a minimum, analysis and documentation of the following: (a) an An identification of the expected sources of repayment and an analysis of their adequacy; (b) the The appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable as well as other necessary documentation to support the collateral valuation; (c) an An analysis of current and satisfactory credit information, including cash flow analysis where loans are to be repaid from operations; (d) the The proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (e) trigger Trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (f) a A determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and (g) for For criticized relationships of $250,000 or above, the PLM shall also include: (i) the The initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project Project development status; (iii) a A comparison of development costs to the budgeted amount; (iv) a A comparison of sales activity to the original sales projections; (v) amount Amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an An assessment of the borrower’s global cash flow; (vii) an An assessment of any guarantor’s global cash flow; and (viii) any Any other significant information relating to the project. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (6) A copy of each PLM prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, shall be submitted to the Assistant Deputy Comptroller within fifteen (15) days of each calendar quarter end. (7) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are on the Bank’s criticized in the ▇▇▇, in any subsequent Report of Examination, in any internal or external loan review, or in any list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding $250,000, unless each of the following conditions is met: (a) the The Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the The Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan listreview, or in any list provided to management by the National Bank Examiners during any subsequent examination. (42) Within thirty sixty (3060) days of establishing the plan required by Paragraph (1) of this Articledays, the Board shall prepare develop written procedures for the quarterly submission and submit to the Assistant Deputy Comptroller for a prior written determination review of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies and procedures to ensure that Problem Loan Memoranda Asset Reports (“PLMPARs” or “PAR”) for all criticized and classified credit relationships totaling two hundred fifty thousand dollars ($250,000) or more. PARs shall contain, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacy; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral collateral, where applicable applicable, as well as other necessary documentation to support the collateral valuation; (c) an analysis of current and satisfactory credit information, including a cash flow analysis where loans are to be repaid from operations; (d) an assessment of the borrower’s global cash flow; (e) an assessment of any guarantor’s global cash flow; (f) the current accrual status and the appropriateness of the current accrual status, (g) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (eh) the identification of prior charge-offs or date of nonaccrual identification, if applicable; (i) the terms of any forbearance or restructure agreements, if applicable; (j) a summary of relevant communications with the borrower, including an assessment of these communications as they relate to collectability or the borrower’s willingness to cooperate with the Bank; (k) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place the loan on nonaccrual; (fl) a determination of whether the loan is impaired and the amount of the impairment, consistent with Accounting Standards Codification 310-10 (formerly known as FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and); (gm) for criticized relationships of two hundred fifty thousand dollars ($250,000 250,000) or aboveabove that were made for the purpose of constructing or developing commercial real estate, the PLM PARs shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iii) a comparison of development costs to the budgeted amount; (iv) a comparison of sales activity to the original sales projections; (v) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viiivi) any other significant information relating to the project; (n) an evaluation of the progress made in the last quarter. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (63) A copy of each PLM PAR prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose shall be available for the inspection of the OREO, shall be submitted to the Assistant Deputy Comptroller OCC’s National Bank Examiners within fifteen thirty (1530) days after the end of each calendar quarter endquarter. (74) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan review, review or in any subsequent list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed two hundred fifty thousand dollars ($250,000), unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.

PROBLEM LOAN MANAGEMENT. (1) Within thirty (30) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written plan to reduce the volume of problem assets by ensuring that management promptly addresses and intervenes, as appropriate, to resolve problem credit situations consistent with OCC Banking Circular 255. (2) The Board’s compliance with Paragraph (1) of this Article shall include the development and implementation of policy guidance setting forth actions that management will take to strengthen or reduce problem loans, including, at a minimum, guidelines on the following: (a) extensions or renewals of construction and development loans; (b) the use of interest reserves after initial loan term; (c) the curtailment or re-margining of outstanding loan balances upon renewal or extension; and (d) the freezing of loan commitments on problem loans. (3) Effective as of the date of this Agreement, the Board shall take immediate and continuing action to protect its interest in those assets listed criticized in the Bank’s criticized ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan listreview or in any list provided to management by the National Bank Examiners during any subsequent examination. (42) Within The Board’s compliance with Paragraph (1) of this Article shall include, within thirty (30) days of establishing the plan required by Paragraph (1) of this ArticleAgreement, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a written program designed to reduce the Bank’s criticized assets (the “Problem Assets Program”). The Problem Assets Program shall include the development of policies procedures for the quarterly submission and procedures to ensure that review of Problem Loan Memoranda Asset Reports (“PLMPARs” or “PAR”) of all criticized credit relationships or OREO totaling two hundred thousand dollars ($200,000) or more. PARs shall contain, at a minimum, analysis and documentation of the following: (a) an identification of the expected sources of repayment and an analysis of their adequacyrepayment; (b) the appraised value of supporting collateral and the position of the Bank’s lien on such collateral where applicable applicable, as well as other necessary documentation to support the collateral valuation, as directed by Article VIII of this Agreement; (c) an analysis of current and satisfactory credit information, including a cash flow analysis where loans are to be repaid from operations; (d) an assessment of the borrower’s global cash flow; (e) an assessment of any guarantor’s global cash flow; (f) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (g) the current accrual status, its appropriateness, and the date of nonaccrual identification, if applicable; (h) the amounts and dates of prior charge offs, if applicable; (i) the proposed action to eliminate the basis of criticism and the time frame for its accomplishment; (ej) the terms of the forbearance or restructure agreements, if applicable; (k) a summary of relevant communications with the borrower, including an assessment of these communications as they relate to collectability or the borrower’s willingness to cooperate with the Bank; (l) trigger dates for positive borrower actions or for loan officers to reassess the strategy, enact collection plans, and make appropriate downgrades or place on nonaccrual; (fm) a determination of whether the loan is impaired and the amount of the impairment, consistent with FASB Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan; and; (gn) for criticized relationships of two hundred thousand dollars ($250,000 200,000) or aboveabove that were made for the purpose of constructing or developing commercial real estate, the PLM PARs shall also include: (i) the initial scheduled maturity date of the loan, number of extensions and/or renewals, and current maturity date; (ii) project development status; (iiiii) a comparison of development costs to the budgeted amount; (iviii) a comparison of sales activity to the original sales projections; (viv) amount of initial interest reserve and the amount of any subsequent additions to the reserve; (vi) an assessment of the borrower’s global cash flow; (vii) an assessment of any guarantor’s global cash flow; and (viiiv) any other significant information relating to the project; (o) an evaluation of the progress made in the last quarter. (5) Upon receiving a written determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall immediately implement and thereafter ensure adherence to the program required by this Article. (63) A copy of each PLM PAR prepared during the month of each quarter end (e.g., March, June, September, and December), along with any Board comments regarding the effectiveness of the effort to eliminate the weaknesses in each credit or to dispose of the OREO, OREO shall be submitted to the Assistant Deputy Comptroller within fifteen thirty (1530) days after the end of each calendar quarter endquarter. (74) Effective as of the date of this Agreement, the Bank may not extend credit, directly or indirectly, including renewals, extensions or capitalization of accrued interest, to a borrower whose loans or other extensions of credit are criticized in the ▇▇▇, in any subsequent Report of Examination, in any subsequent internal or external loan review, review or in any subsequent list provided to management by the National Bank Examiners during any examination and whose aggregate loans or other extensions of credit equal to or exceeding exceed two hundred thousand dollars ($250,000200,000), unless each of the following conditions is met: (a) the Board or a designated committee thereof finds that the extension of additional credit is necessary to promote the best interests of the Bank and that prior to renewing, extending or capitalizing any additional interest on the credit, a majority of the Board or a designated committee thereof approves the credit extension and documents in writing, the reasons that such extension is necessary to promote the best interests of the Bank; and (b) the Board’s formal plan to collect or strengthen the criticized asset will not be compromised by the extension of credit.