Columbia Bank

Interagency Policy Statement on Funding and Liquidity Risk Management (March 2010); FFIEC Liquidity and Funds Management Handbook

Gross loans and leases $37,752M against total deposits $41,793M. A loans/deposits ratio above 100% indicates the institution funds loan growth with non-deposit (wholesale, brokered, or borrowed) funding sources, increasing liquidity and funding-cost sensitivity.

Provide an updated Contingency Funding Plan with specific playbook triggers (deposit-runoff thresholds, asset-sale order). Quantify uninsured-deposit runoff under stress scenarios. Document back-up borrowing capacity at FHLB, the discount window, and any standing facilities; pre-position collateral.

FFIEC Liquidity and Funds Management Handbook; OCC Comptroller's Handbook, Liquidity booklet

Cash and balances at depositories $1,382M against total assets $51,566M. This is a narrow liquidity proxy (cash + interbank balances only) and excludes the institution's unencumbered securities portfolio, which is its primary liquidity buffer at normal sizing. Levels below 4% combined with weak alternative funding sources merit explicit Contingency Funding Plan review.

Provide a full liquidity position report including unencumbered securities (Treasuries, agency MBS), available FHLB / discount window collateral, and 30-day net cash outflow projections. Demonstrate the Contingency Funding Plan addresses scenarios where cash positions decline and securities cannot be sold without loss.