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Regulatory Fines

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Outsourced IRR Modeling

Client will be provided with quarterly Interest Rate Risk (IRR) reports addressing all Regulatory required reporting scenarios. Plansmith will develop and document all key Interest Rate Risk model assumptions (decay rates, loan prepayments, deposit repricing, and driver rate selection). The service also includes complete examination and audit support.

IRR Assumption Development & Documentation

Plansmith will develop Interest Rate Risk (IRR) model assumptions (decay rates, loan prepayments, deposit re-pricing, and driver rate selection) to ensure consistency between current Regulatory guidance and Client’s pricing and funding strategies. Plansmith will develop a Client specific “Assumption Documentation Report” summarizing and supporting all of Client’s key model assumptions as required by the 2010 FFIEC Advisory on Interest Rate Risk Management. Plansmith will also assist during Client’s next Regulatory examination regarding any issues arising from Interest Rate Risk model assumptions, mechanics, and output.

IRR Sensitivity & Stress Testing

Plansmith will conduct three separate sensitivity tests on the Regulatory identified key model assumptions of asset prepayments, non-maturity deposit repricing, and non-maturity deposit decay rates. Plansmith will separately stress test the assumptions in each area, rerun the model under the revised assumptions, and provide a narrative report comparing the original output to the sensitivity tested results.

Outsourced Cash Flow Modeling

Plansmith will assist in the development of three cash flow model stress scenarios, including Client-specific and systemic events as required by the FFIEC’s 2010 Interagency Policy Statement on Funding and Liquidity Risk. Plansmith will provide a written narrative detailing the stress scenarios and suggestions for parameters for each of them. Each quarter for one year, Plansmith will conduct cash flow modeling for Client and provide reports detailing the results of the stress-tests, as well as the base/expected case.

IRR Backtesting

Plansmith will conduct IRR backtesting for the Client and provide a written report summarizing the procedures and results. The backtesting will include the earnings-at-risk model results and selected key model assumptions.

Decay Rate Studies

Plansmith will develop and provide documentation of Client-specific non-maturity deposit decay rates for Demand Deposits, NOW, Money Market, and Savings accounts. The analysis will also incorporate a full surge deposit analysis using historical institution-specific data.

Loan Prepayment Studies

Plansmith will develop Client-specific dynamic loan prepayment assumptions. The prepayment assumptions will be based on Client-specific data and include prepayment rates for stable, rising, and falling rate shock scenarios.

Cash Flow Model Stress Scenario Development

Plansmith will assist in the development of cash flow model stress scenarios, including Client-specific and systemic events as required by the FFIEC’s 2010 Interagency Policy Statement on Funding and Liquidity Risk. Plansmith will also provide a written narrative detailing the stress scenarios, and suggestions for policy parameters for each scenario.

Board Training

Plansmith will deliver Board training focusing on the Client’s Interest Rate Risk management report. Training will cover the primary measurement and risk methodologies, key model assumptions, Regulatory expectations for Interest Rate Risk (IRR) and liquidity management, and the Client’s risk profile.

ALCO Participation

Each quarter, a Plansmith consultant will meet with management (via teleconference) to: – Comprehensively review all model results – Provide input to management on the magnitude of current Interest Rate Risk (IRR) and liquidity risk positions – Monitor compliance with Client’s policy limits – Provide input on current Regulatory areas of concern – Discuss factors unique to Client that impact policy specifics

IRR Policy Review & Development

Plansmith will develop comprehensive Interest Rate Risk (IRR) policy guidance to ensure compliance with Regulatory expectations. Plansmith will also assist Client in developing appropriate limits for Interest Rate Risk measurements. The policy guidance will address the following: – The Interest Rate Risk Management System – Board & Senior Management Oversight – Risk Measurement and Modeling – Risk Limits – Risk Monitoring and Reporting – Review and Validation

Liquidity Policy Review & Development

Plansmith will develop comprehensive liquidity policy guidance to ensure compliance with Regulatory directives and will assist Client in developing appropriate limits for liquidity measurements. The guidance will address the following areas: – Liquidity and Funding Oversight – Liquidity and Funding Issues – Overall Funding Strategy – Measurement of Liquidity and Funding Risk – Reporting Procedures and Corrective Action – Contingency Funding – Independent Review

Contingency Funding Plan Review & Development

Plansmith will develop a comprehensive CFP detailing three cash flow model stress scenarios, including Client-specific and systemic events as required by the FFIEC’s 2010 Interagency Policy Statement on Funding and Liquidity Risk. The CFP will address the following areas: – Stress Events – Monitoring Framework for Contingent Events – Levels of Severity and Timing – Funding Sources and Needs Projections – Potential Funding Sources – Liquidity Event Management Process – Testing of Standby Liquidity – Review of Plan

Capital Stress Testing

Plansmith will develop three separate stress test scenarios, conduct the noted stress tests, and perform reverse stress testing. Client will be provided with a Capital Stress Test summary narrative report documenting the stress test, including methodology, assumptions, and assessment of results.

Capital Planning

Plansmith will develop a Capital Maintenance Plan and Policy for Client which will include a management development session and comprehensive risk profile assessment. The Plan will address the following areas: – Client’s Risk Profile – Capital Requirements – Capital Alternatives – Dividends – Reporting Requirements and Policy Exceptions – Policy Review

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