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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's approach for substantively testing the ALL was to test the issuer's process. The firm did not evaluate whether the issuer had a reasonable basis for the basis points used for the qualitative base adjustment and for its selection of basis points from a range of potential basis points. (AS 2501.16)

The firm's approach for substantively testing the ALL was to test the issuer's process. The firm did not evaluate the reasonableness of the assumptions developed by the company's specialist that were used in the qualitative overlay adjustment. (AS 1105.A8b)

The engagement team did not perform any substantive procedures to test or as discussed above sufficiently test controls over the accuracy and completeness of reports from the issuer's systems that the firm used as audit evidence in its substantive procedures. (AS 1105.10)

For loans that were collectively evaluated for impairment the issuer determined the qualitative reserve component of the ALL using qualitative factors. The firm's approach for substantively testing this reserve was to review and test management's process. The firm did not perform procedures to evaluate the reasonableness of the basis points for each qualitative factor that were applied to determine the qualitative component beyond comparing these basis points to the basis points that were applied in prior years and assessing whether certain changes or lack thereof to the basis points from the prior year were directionally consistent with internal or external data. (AS 2501.09 .10 and .11) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020]

The issuer used a service organization to process and record transactions related to loans and for information it used to determine the ALL. In addition the issuer used data and reports from this service organization in the operation of certain controls the firm selected for testing. The firm did not evaluate whether the service auditor's report provided sufficient evidence because the firm did not assess the scope of the examination and applications covered the controls tested the way in which the tested controls related to the issuer's controls and the results for those tests of controls. (AS 2201.B21)

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 the adequacy of the ALL. The firm did not identify and test any controls over the appropriateness of the loan grades that were an important factor in estimating the ALL. (AS 2201.39)

The firm's approach for substantively testing the ALL was to test the issuer's process. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate the reasonableness of certain significant assumptions because the firm did not evaluate whether the issuer had a reasonable basis for these assumptions. Further the firm used certain external data to develop an expectation for the range of these significant assumptions but did not perform procedures to evaluate the relevance of this data. (AS 1105.04 and .06; AS 2501.16)

The firm's approach for substantively testing the ALL was to test the issuer's process. The following deficiencies were identified: · The firm did not perform any procedures to evaluate the reasonableness of certain other significant assumptions. (AS 2501.16)

The firm's approach for substantively testing the ALL was to test the issuer's process. The following deficiencies were identified: · The firm did not perform any procedures to test or in the alternative sufficiently test controls over the accuracy of certain data produced by the service organization and used by the issuer in estimating the ALL. (AS 2301.08 and .11)

The firm's approach for substantively testing the ALL was to test the issuer's process. The firm did not perform sufficient procedures to evaluate the reasonableness of certain significant assumptions because the firm did not evaluate whether the issuer had a reasonable basis for these assumptions. Further the firm used certain external data to develop an expectation for the range of these significant assumptions but did not perform procedures to evaluate the relevance of this data. (AS 1105.04 and .06; AS 2501.16)

The firm's approach for substantively testing the ALL was to test the issuer's process. The issuer used certain data produced by its service organization to develop the ALL. The firm did not perform procedures to test the accuracy of this data. (AS 2301.08 and .11)

The issuer calculated the qualitative component of the allowance for loan losses by applying basis points to each qualitative factor. The firm's approach for substantively testing the qualitative component was to test the issuer's process. The firm did not evaluate the reasonableness of significant assumptions used by the issuer to develop this component. (AS 2501.16)

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 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 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)

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 test the aspect of this control that addressed the accuracy and completeness of the reports used in the operation of this control. (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 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)

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 the qualitative reserve component of the ALL using certain qualitative factors. The following deficiencies were identified: • The firm's approach for substantively testing the ALL was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of the qualitative reserve component of the ALL because the firm's procedures to test the qualitative factors the issuer used to determine the reserve were limited to (1) reading the issuer's ALL memorandum and (2) comparing the qualitative factors the issuer used at year end to those used in prior periods. (AS 2501.09 .10 and .11)

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 one of the qualitative reserve components of the ALL using certain qualitative factors. The following deficiencies were identified: • The firm's approach for substantively testing the ALL was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of the qualitative reserve component of the ALL because the firm's procedures to test the qualitative factors the issuer used to determine the reserve were limited to (1) reading the issuer's ALL memorandum and related analysis of the factors and (2) comparing the qualitative factors the issuer used at year end to those used in prior periods. (AS 2501.09 .10 and .11)

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)

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's approach for substantively testing the ALL was to review and test management's process. The firm did not sufficiently evaluate the reasonableness of the qualitative reserve component of the ALL because the firm did not perform procedures to evaluate certain adjustments that the issuer made to the calculation of these qualitative factors the issuer used to determine the reserve. (AS 2501.09 .10 and .11)

The issuer used an information-technology (IT) system to initiate process and record loan-related transactions. The firm selected for testing certain controls over the issuer's review of user access to this IT system but did not evaluate the specific procedures that the control owners performed to determine whether to grant access to users or whether the granted access continued to be appropriate. (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 firm's approach for substantively testing the qualitative component of the ALL was to test the issuer's process. The firm did not evaluate whether the issuer had a reasonable basis for the basis points used for the qualitative factors and for its selection of basis points from a range of potential basis points. (AS 2501.16)

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 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. Due to the deficiencies in the firm's testing of the IT general controls (ITGCs) the firm did not sufficiently test controls over the accuracy and completeness of certain reports used in the operation of these controls. (AS 2201.46)

For loans collectively evaluated for impairment the firm's approach for substantively testing the ALL was to test the issuer's process. The following deficiencies were identified: · For one component of the issuer's qualitative reserve the firm did not evaluate whether the issuer had a reasonable basis for certain significant assumptions used and whether those assumptions were consistent with relevant industry regulatory and other external factors including economic conditions; existing market information; and/or other significant assumptions used by the issuer. (AS 2501.16)

For loans collectively evaluated for impairment the firm's approach for substantively testing the ALL was to test the issuer's process. The following deficiencies were identified: · For another component the firm did not evaluate whether the issuer had a reasonable basis for significant assumptions related to the basis points used for the qualitative base adjustment and for its selection of basis points from a range of potential basis points. (AS 2501.16)

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 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 identify and test any controls over the accuracy and completeness of certain loan information that the control owners used in the operation of this control. (AS 2201.39)

The issuer determined the qualitative reserve component of the ACL using various qualitative factors. The following deficiencies were identified: · The firm's approach for substantively testing the ACL was to test the issuer's process. The firm did not sufficiently evaluate the reasonableness of certain significant assumptions the issuer used to develop the qualitative reserve component of the ACL because its procedures were limited to a year-over-year comparison of these significant assumptions. (AS 2501.16)

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 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 reconciliation of certain loan data but did not identify and test any controls over the completeness of certain reports that the control owner used in the operation of this control. (AS 2201.39)

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 did not evaluate the reasonableness of the forecasting significant assumption that was developed by the company's specialist and used in the model. (AS 1105.A8b)

The issuer's general reserve component of the ALL included a qualitative reserve component ('qualitative component') that was determined by certain qualitative factors. The firm's approach for substantively testing the ALL was to review and test management's process. The firm did not perform procedures to evaluate the reasonableness of the basis points that were applied to determine the qualitative component beyond (1) reading the issuer's analysis and vouching the data to supporting documentation (2) comparing these basis points to the basis points that were applied in the prior year and (3) assessing whether certain changes or lack thereof to the basis points from the prior year were directionally consistent with internal or external data. (AS 2501.09 .10 and .11) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

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 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. For this control and two other controls the firm selected for testing over the ACL the firm did not identify and test any controls over the accuracy and completeness of certain loan information used in the operation of these controls. (AS 2201.39)

The issuer assigned each loan 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 for a sample of loans of the loan risk ratings assigned to the loans. The firm identified deviations in the operation of this control but did not evaluate the effect of these deviations on the operating effectiveness of the control. (AS 2201.48)

The issuer assigned each loan 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 for a sample of loans of the loan risk ratings assigned to the loans. In its testing of the operating effectiveness of this control the firm excluded certain loans from its testing population. (AS 2201.44)

The issuer assigned each loan 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 ratings for certain loans included making a selection of loans for testing. The firm identified differences in the assigned loan risk ratings but did not evaluate the effect of these differences on whether it had obtained sufficient appropriate audit evidence. Further the firm did not perform any substantive procedures to test the loan risk ratings for the loans that were excluded from the firm's control testing procedures discussed above. (AS 2301.08)

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 firm's approach for substantively testing the valuation of acquired loans as of the acquisition date and at year end was to test the issuer's process. The firm did not evaluate whether the methods the issuer used to value these loans were in conformity with GAAP including the requirements of FASB ASC Topic 310 Receivables related to (1) whether the acquired assets included loans with deterioration in credit quality since origination and (2) the measurement of purchased impaired loans. (AS 2501.10)

The issuer assigned a risk rating to each of its commercial loans. The loan risk rating was an important input in estimating the ACL for commercial loans collectively assessed for impairment. The firm selected for testing a control that consisted of the issuer's review for a sample of loans of the loan risk ratings assigned to certain commercial loans. The firm did not evaluate (1) the criteria the control owners used to select loans for review and (2) whether the sample of loans that were reviewed was sufficient to address the risks of material misstatement presented by the different risk characteristics inherent in the population of these loans. (AS 2201.42)

With respect to the allowance for loan losses (ALL) at one of the issuer's subsidiaries: The firm selected for testing a control that consisted of the issuer's review of the ALL. The firm did not identify and test any controls over the completeness of a manually prepared spreadsheet that was used in the operation of this control. (AS 2201.39)