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The issuer assigned a loan grade to each loan. The loan grade was an important input in determining whether the loan would be individually evaluated for impairment or considered as part of the general reserve. The firm's sample to test the reasonableness of loan grades was too small because in determining its sample size the firm did not appropriately consider the characteristics of the population. (AS 2315.23 and .23A)

The firm's sample to test the reasonableness of loan grades was too small because in determining its sample size the firm did not appropriately consider the characteristics of the population. (AS 2315.23 and .23A)

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's substantive procedures to test the reasonableness of the assigned loan risk rating for these loans included selecting a sample of loans for testing. The sample size that the firm used was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37)

The sample size the firm used in its substantive procedures to test the reasonableness of the assigned loan grades was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2315.19 .23 and .23A)

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 sample size the firm used in its substantive procedures to test the reasonableness of the assigned loan grades was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2315.19 .23 and .23A)

The issuer assigned certain loans a loan risk rating which was an important input in estimating the quantitative component of the ACL. The firm's substantive procedures to test the reasonableness of the assigned loan risk rating for these loans included selecting a sample of loans for testing. The firm's sample size was too small to provide sufficient appropriate audit evidence because in determining the sample size the firm did not take into account tolerable misstatement the allowable risk of incorrect acceptance and the characteristics of the population. (AS 2315.16 .23 and .23A)

The issuer assigned certain loans a loan risk rating which was an important input in estimating the quantitative component of the allowance for credit losses (ACL). The firm's substantive procedures to test the reasonableness of the assigned loan risk rating for these loans included selecting a sample of loans for testing. The firm's sample was too small to provide sufficient appropriate audit evidence because in determining its sample the firm did not consider the characteristics of the population. (AS 2315.16 .23 and .23A)

The issuer assigned certain loans a loan risk rating which was an important input in estimating the quantitative component of the allowance for credit losses (ACL). The firm's substantive procedures to test the reasonableness of the assigned loan risk rating for these loans included selecting a sample of loans for testing. The firm's sample was too small to provide sufficient appropriate audit evidence because in determining its sample the firm did not consider the relationship of the sample to the relevant audit objective and the allowable risk of incorrect acceptance. (AS 2315.16 .23 and .23A)

The firm selected for testing controls that consisted of the issuer's review of (1) risk ratings assigned to certain commercial loans (2) loans that were identified as having higher risk characteristics and (3) the reasonableness of the ALL general reserve. With respect to the review of risk ratings control the firm did not consider the complexity of the control and the significance of the judgments made by the control owners in determining the sample size used to test this control. (AS 2201.46)

The sample size the firm used in certain of its substantive procedures to test the ALL was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The sample size the firm used in certain of its substantive procedures to test the accuracy of the loan data input into the model was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The sample sizes the firm used in certain of its substantive procedures to test the ACL were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiency in the firm's loan-grading control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The firm selected for testing a control that consisted of the issuer's review of risk grades assigned to commercial graded loans. The loan grades were an important factor in estimating the ALL. The sample size used by the firm to test the control was too small to provide sufficient appropriate audit evidence to support its conclusion that the control was operating effectively. (AS 2201.46)

The sample size the firm used in its substantive procedures to test the reasonableness of assigned loan grades was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The firm selected for testing a control that consisted of the external review of loan grades. The sample size used by the firm to test the control was too small to provide sufficient appropriate audit evidence to support its conclusion that the control was operating effectively. As a result the sample size the firm used in its substantive procedures to test the reasonableness of assigned loan grades was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 and .23 and .23A)

As part of the issuer's overall credit risk assessment for commercial loans collectively evaluated for impairment the issuer determined loan grades for each loan. These loan grades were an important factor in estimating the ALL for commercial loans. The following deficiencies were identified: · The sample size the firm used in certain of its substantive procedures to test the appropriateness of the assigned loan grades for commercial loans was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The firm concluded that a control over the loan officers' annual credit review (“ACR”) of the reasonableness of assigned loan grades was deficient because certain of the ACRs were not completed as of the end of the year for commercial loan relationships. The firm concluded that it represented a significant deficiency after determining the percentage of noncompliance of ACRs and identifying and testing two compensating controls that consisted of a credit monitoring (“CM”) control and an independent loan review over certain commercial loan relationships. The firm did not sufficiently evaluate the severity of the control deficiency due to the following: · The sample size the firm used to test the second compensating control was designed assuming a certain level of evidence the firm planned to obtain from testing the ACR control over assigned loan grades. Due to the identified control deficiency in the ACR control the ACR control tested did not provide the planned level of evidence. As a result the sample size the firm used to test the second compensating control was too small to provide the necessary evidence about its operating effectiveness. (AS 2201.68)

The sample sizes the firm used in certain of its substantive procedures to test the ALL were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The sample sizes the firm used in certain of its substantive procedures to test the reasonableness of assigned loan grades were too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The sample size the firm used in certain of its substantive procedures to test the reasonableness of assigned loan risk ratings was too small to provide sufficient appropriate audit evidence because these procedures were based on a level of control reliance that was not supported due to the deficiency in the firm's control testing described above. Further the sample size the firm used in certain of its substantive procedures to test the reasonableness of assigned loan risk ratings was too small to provide sufficient appropriate audit evidence because the firm did not take into account the relevant factors in determining its sample size including tolerable misstatement for the population the allowable risk of incorrect acceptance and the characteristics of the population. (AS 2301.16 .18 and .37; AS 2315.16 .19 .23 and .23A)

Loan risk ratings were an important input in estimating the issuer's ALL. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the reasonableness of loan risk ratings was too small to provide sufficient appropriate audit evidence because the procedure was designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer's ALL included reserves for impaired loans. The following deficiency was identified: · The sample size the firm used in its substantive procedure to test the valuation of impaired loans was too small to provide sufficient appropriate audit evidence because the procedure was designed based on a level of control reliance that was not supported due to the deficiency in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)

The issuer's general reserve component of the ALL included a qualitative reserve component. In determining the qualitative reserve component the issuer used loan risk grades and basis point adjustments for qualitative factors. The following deficiencies were identified: - The sample size the firm used in its substantive procedures to test the reasonableness of loan risk grades was too small to provide sufficient appropriate audit evidence because these procedures were designed based on a level of control reliance that was not supported due to the deficiencies in the firm's control testing discussed above. (AS 2301.16 .18 and .37; AS 2315.19 .23 and .23A)