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The firm selected for testing a control that consisted of an annual review of certain loans including an evaluation of loan grades. The loan grade was an important input in determining whether a loan would be individually evaluated for impairment or considered as part of the general reserve component of the ALL. The firm did not evaluate the specific review procedures that the control owner performed to evaluate the appropriateness of the loan grade. (AS 2201.42 and .44)

The issuer used a model to estimate the general reserve component of the ALL which consisted of quantitative qualitative and unallocated components. The unallocated component represented a significant portion of the general reserve. The following deficiencies were identified: · The firm selected for testing a control that consisted of the evaluation of the reasonableness of the ALL including the general reserve. The firm did not evaluate the specific review procedures the control owner performed to assess the reasonableness of certain assumptions used to estimate the general reserve. (AS 2201.42 and .44)

The issuer used loan charge-offs as inputs to determine the general reserve component of the ALL. The firm selected for testing a control that included the review of loan charge-offs and the evaluation of charge-offs excluded from the calculation. The firm did not evaluate the specific review procedures the control owner performed to evaluate the charge-offs excluded from the calculation. (AS 2201.42 and .44)

The firm selected for testing a control over the review of qualitative factors which are inputs used in determining the general reserve component of the ALL. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of the assigned loan risk ratings. The loan risk rating was an important input in estimating the ALL and determining whether a loan would be individually or collectively evaluated for impairment. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of certain assumptions used to estimate the quantitative component of the ACL for loans collectively evaluated for impairment. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of these assumptions that were outside of the range of assumptions the issuer established under its ACL methodology. (AS 2201.42 and .44)

The issuer assigned certain loans a loan risk rating which was an important input in estimating the quantitative component of the ACL. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's review of the loan risk ratings assigned to certain loans. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of the loan risk ratings. (AS 2201.42 and .44)

The issuer's ALLL included a reserve for loans collectively evaluated for impairment. This reserve included a component that was determined by using certain qualitative factors. The following deficiencies were identified: - The firm selected for testing controls that consisted of the issuer's review of the qualitative component of the ALLL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the basis point adjustments for the qualitative factors. (AS 2201.42 and .44)

The issuer's general reserve component of the ALL included a qualitative reserve. For each of the qualitative factors evaluated in determining the reserve the issuer assigned a risk level and then assigned basis point adjustments based on the risk level. The firm selected for testing several controls over the review of the ALL. The firm did not evaluate the specific review procedures the control owners performed to evaluate the reasonableness of the risk levels and related basis point adjustments. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ALL using various qualitative factors. The following deficiency was identified: · The firm selected for testing controls that included the issuer's reviews of the qualitative factors for reasonableness. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these qualitative factors. (AS 2201.42 and .44)

The issuer used a service organization to host maintain and manage the information technology (IT) system that the issuer used to initiate process and record transactions related to the ALL. The firm selected for testing controls that consisted of the issuer's review of access to this information system. The firm did not evaluate the specific review procedures that the control owners performed to determine whether to initially grant access to users and whether the granted role access continued to be appropriate. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of certain loans for potential impairment. The firm did not evaluate the specific review procedures that the control owners performed to review these loans for potential impairment. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ALL that included a qualitative base adjustment based on basis points established for certain qualitative factors and a qualitative overlay adjustment based on assumptions provided by the company's specialist. The firm selected for testing certain controls that consisted of the issuer's review of the ALL including an assessment of the qualitative reserve component. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the qualitative reserve component of the ALL. (AS 2201.42 and .44)

The firm selected for testing a control over the review of the adequacy of the ALL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of certain assumptions used to determine the ALL. (AS 2201.42 and .44)

The firm selected for testing a control over the review of assigned loan grades. The loan grades were an important input in estimating the ALL. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the assigned loan grades. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the review of the qualitative component of the general reserve. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer assigned loan grades to certain of its loans. The loan grades were an important input in determining whether a loan would be individually evaluated for impairment or considered as part of the general reserve. The following deficiencies were identified: · The firm selected for testing a control that consisted of the external loan review ('ELR') of assigned loan grades for certain loans. The firm did not evaluate the specific review procedures that the external loan reviewers performed to assess the reasonableness of the assigned loan grades. (AS 2201.42 and .44)

The issuer assigned loan grades to certain of its loans. The loan grades were an important input in determining whether a loan would be individually evaluated for impairment or considered as part of the general reserve. The following deficiencies were identified: · The firm selected for testing a control that consisted of the review of assigned loan grades for loans not subject to the ELR control discussed above. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ALL using certain qualitative factors. The following deficiencies were identified: • The firm selected for testing a control that consisted of the issuer's review of the qualitative reserve component of the ALL including an assessment of the qualitative factors for reasonableness. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of the qualitative factors. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined one of the qualitative reserve components of the ALL using certain qualitative factors. The following deficiencies were identified: • The firm selected for testing a control that included the issuer's review of this qualitative reserve component of the ALL including an assessment of the qualitative factors for reasonableness. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of these qualitative factors. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ALL using certain qualitative factors. The following deficiencies were identified: • The firm selected for testing a control that consisted of the issuer's reviews of the qualitative factors. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain adjustments that the issuer made to the calculation of these qualitative factors. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of assumptions used to determine the qualitative adjustments used to estimate the ALL for loans collectively evaluated for impairment. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain of these assumptions. (AS 2201.42 and .44)

The issuer determined the qualitative reserve component of the ACL using various qualitative factors. The following deficiencies were identified: · The firm selected for testing a control that included the issuer's reviews of these qualitative factors. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain factors. (AS 2201.42 and .44)

The issuer engaged a specialist to assist it in determining the quantitative reserve component of the ACL using a model that was developed by the company's specialist. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's review of the ACL. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the forecasting assumption developed by the company's specialist and used in the model. (AS 2201.42 and .44)

The issuer assigned each loan a loan risk rating which was an important input in estimating the quantitative component of the ACL. The firm selected for testing a control that included the issuer's review of the risk ratings for certain loans. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these risk ratings. (AS 2201.42 and .44)

The issuer determined the qualitative reserve component of the ACL using various qualitative factors. The firm selected for testing controls that included the issuer's reviews of these factors. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these factors. (AS 2201.42 and .44)

The firm selected for testing controls that consisted of the issuer's validation of the models that the issuer used to estimate the quantitative component of the ACL for loans collectively evaluated for impairment. As part of the review to validate these models the control owners performed various tests of (1) the models such as sensitivity analyses and benchmark comparisons to other models and (2) the data used to develop the models and any underlying assumptions. The firm did not evaluate the specific review procedures that the control owners performed to (1) conduct and evaluate the results of these tests and (2) verify the accuracy and completeness of the data the control owners used in these tests. (AS 2201.42 and .44)

The issuer's general reserve component of the ALL included a qualitative reserve component that was determined by certain qualitative factors. The firm selected for testing a control that included the review of the qualitative component of the general reserve. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer's general reserve component of the ALL included a qualitative reserve component that was determined by certain qualitative factors. The firm selected for testing a control that included the review of the qualitative component of the general reserve. The firm did not evaluate the review procedures that the control owner performed with respect to certain qualitative factors including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer's general reserve component of the ALL included a qualitative reserve component that was determined by certain qualitative factors. The firm selected for testing a control that included the review of the qualitative component of the general reserve. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

Loan risk ratings were an important input in estimating the issuer's ALL. The firm selected for testing a control designed to validate loan risk ratings assigned by the issuer to certain categories of its loans. The issuer used internal loan reviewers (ILRs) and an external loan reviewer (ELR) in the operation of this control. The following deficiencies were identified: · The firm did not evaluate the review procedures that the ILRs performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer used certain qualitative factors to determine the qualitative component of the ALL. The firm selected for testing a review control over certain data used in the calculation of the qualitative reserve. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

Loan risk grades were an important input in estimating the issuer's ALL. The firm selected for testing a control designed to validate loan risk grades assigned by the issuer to certain categories of loans. The control included the review of loan risk grades by the issuer's external loan reviewer (ELR). The following deficiencies were identified: · The firm did not evaluate the review procedures that the control owners performed to evaluate the appropriateness of the issuer's loan grades. (AS 2201.42 and .44)

On a periodic basis the issuer evaluates potential problem loans. The firm selected for testing a control that included the review of potential problem loans. The following deficiencies were identified: · The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer developed the ACL for loans collectively evaluated for impairment using various models that were maintained by a service organization. The firm obtained a service auditor's report for this service organization. The following deficiency was identified: • The firm selected for testing a control that included the issuer's review of certain ACL assumptions that the service organization used in its models. The firm did not perform procedures to evaluate the specific review procedures that the control owners performed to assess the reasonableness of these assumptions. (AS 2201.42 and .44)

The firm selected for testing certain controls over the review of changes to risk ratings credit quality monitoring collateral impairment analysis and loan write-offs. The firm did not perform procedures to evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's review of certain loans based on risk indicators including an identification of problem loans which operated during the first seven months of the year. The firm did not evaluate the review procedures that the control owner performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The issuer estimated the general reserve component of the ALL using the following significant assumptions: (1) loan segmentation (2) probability of default (“PD”) (3) loss given default (“LGD”) and (4) loan risk ratings (“LRR”). The issuer used a model to derive the PD and LGD assumptions using current and historical loan data (“loan data”) contained in two data warehouses. The following deficiencies were identified: · The firm selected for testing a control that included (1) the issuer's review of the LRRs assigned to loans meeting certain criteria and (2) procedures to monitor whether the LRRs for these loans were updated within the time frame established for the control. The firm did not evaluate the review procedures that the control owners performed including the criteria that the control owners used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

For loans that the issuer assessed collectively for impairment the issuer estimated the ALL using a model that consisted of quantitative and qualitative components. The issuer developed the qualitative component of the ALL by applying certain qualitative factors to each of its classes of loans. The firm selected for testing a control that consisted of a committee's review of the ALL including the qualitative factors. The firm did not evaluate the review procedures that the control owners performed to evaluate the qualitative factors including the criteria that the control owners used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

With respect to the ALL for loans that the issuer assessed collectively for impairment: The firm selected for testing controls that included a committee's review of certain assumptions used to estimate this ALL. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

With respect to the ALL for loans that the issuer assessed individually for impairment: The firm selected for testing a control that consisted of the issuer's review of loans that exceeded a loan grade threshold and the review of the impairment calculations for individually impaired loans. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of certain inputs and assumptions underlying the impairment calculations for individually impaired loans. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ACL using qualitative factors. With respect to one of these qualitative factors the following deficiency was identified: · The firm selected for testing controls that consisted of the issuer's reviews of the ACL including an assessment of this qualitative factor for reasonableness. The firm did not evaluate the specific review procedures that the control owner performed to assess the reasonableness of the significant assumptions the issuer used to develop this qualitative factor. (AS 2201.42 and .44)

The issuer's ALL included a general reserve which consisted of quantitative and qualitative components. The firm selected for testing a control that consisted of the issuer's review of the underlying data and primary calculations supporting an ALL analysis designed to assess the appropriateness of the quantitative and qualitative adjustments. The firm did not evaluate the specific review procedures that the control owner performed to (1) assess the appropriateness of the adjustments and (2) verify the accuracy and completeness of the data used in determining certain of the adjustments. (AS 2201.42 and .44)

The issuer's ALL included a qualitative reserve based on various qualitative factors. The following deficiency was identified: · The firm selected for testing two review controls over the issuer's determination of the qualitative reserve. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the assumptions used to develop the qualitative factors used in determining the qualitative reserve. (AS 2201.42 and .44)

The issuer reported an ACL that included both a quantitative and qualitative component. The issuer used certain qualitative factors including assigned loan risk grades to determine the qualitative component of the ACL. The following deficiency was identified: · The firm selected for testing a review control over the qualitative reserve. The firm did not evaluate the specific review procedures the control owners performed to evaluate the reasonableness of the basis points applied to the qualitative factors. (AS 2201.42 and .44)

The firm selected for testing a control that included the issuer's reviews of certain assumptions used to estimate the quantitative component of the ACL. In evaluating the design of this control the firm did not evaluate the specific review procedures that the control owner performed to evaluate the relevance of external information used in the operation of this control. (AS 2201.42 and .44)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ACL using certain qualitative factors. The firm's approach for substantively testing the qualitative component of the ACL was to test the issuer's process. The following deficiencies were identified: · The firm tested one of the issuer's controls over the determination of the ACL during an interim period. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of certain significant assumptions related to the qualitative factors. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's reviews of the ACL. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the reasonableness of the assumptions used to develop the ACL. (AS 2201.42 and .44)

For loans that the issuer assessed collectively for impairment the issuer estimated the ALL using a model that included loan charge-offs as inputs; these charge-offs were determined based in part on the fair value of the underlying assets. The following deficiencies were identified: · The firm selected for testing a control that consisted of the issuer's reviews of the fair values of the underlying assets. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a control that consisted of the issuer's reviews of the ACL. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of the ACL including the significant assumptions used. (AS 2201.42 and .44)