CIBC Bank USA

OCC Comptroller's Handbook, Rating Credit Risk (April 2001) - https://occ.treas.gov/publications-and-resources/publications/comptrollers-handbook/files/rating-credit-risk/index-rating-credit-risk.html; FFIEC UBPR User's Guide, Section III, Analysis of Past-Due, Nonaccrual & Restructured Loans and Leases - https://www.ffiec.gov/data/ubpr/report-user-guide

Nonperforming loans consist of nonaccrual loans $577M plus loans 90 days or more past due and still accruing $0M, measured against total loans and leases $36,237M.

Provide board and management analysis of the nonperforming loan drivers, updated risk-rating support, workout and collection status for material credits, charge-off review support, and portfolio-level action plans for segments contributing to elevated nonperformance.

Federal Reserve, Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank (April 28, 2023); Joint Agency Statement on Liquidity Risk Management (July 28, 2023); FDIC FIL-84-2008, Liquidity Risk Management

Total deposits $49,368M and insured deposits $17,713M indicate material uninsured-deposit exposure. Uninsured deposits are calculated as total deposits less insured deposits and can be more prone to rapid runoff under stress. Threshold calibration: post-SVB community-bank median uninsured share is 40-55%; this rule fires above 55% because that level requires explicit liquidity contingency planning.

Provide deposit segmentation by customer type, size, relationship tenure, and operational dependency. Update liquidity stress assumptions for uninsured runoff, identify high-confidence contingent funding sources (FHLB, discount window, BTFP collateral pre-positioning), and document board-approved concentration limits and trigger-based escalation.