The Northern Trust Company

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 $124,949M and insured deposits $12,688M 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.

FFIEC UBPR User's Guide §IV — Earnings Analysis; OCC Comptroller's Handbook, "Interest Rate Risk"

Year-to-date net interest margin is 1.56%. Compressed margin can reduce core earnings capacity and may indicate asset-yield pressure, funding-cost pressure, interest-rate-risk exposure, or adverse balance-sheet mix.

Provide management's margin analysis, including earning-asset yields, funding costs, repricing gaps, deposit betas, and modeled sensitivity to parallel and nonparallel rate shocks. Document board-approved actions to restore sustainable margin without assuming excessive credit, liquidity, or interest-rate risk.

Interagency Policy Statement on Allowances for Credit Losses (June 2020; revised April 2023) - https://www.federalreserve.gov/frrs/guidance/interagency-policy-statement-on-allowances-for-credit-losses.htm

Allowance for credit losses $168M is measured against total loans and leases $43,391M. A very low allowance-to-loans ratio requires support that expected credit losses are appropriately estimated under CECL.

Provide the CECL model documentation, historical loss support, qualitative-factor framework, segmentation analysis, back-testing results, and board materials supporting the allowance level relative to the size, composition, and risk profile of the loan portfolio.

OCC Comptroller's Handbook, "Earnings"

Year-to-date net interest margin is 1.56% while the efficiency ratio is 74.19%. The combination of sub-3% margin and above-70% efficiency ratio indicates weakened recurring earnings capacity from both revenue pressure and operating-cost burden.

Provide an integrated earnings analysis showing whether margin pressure, deposit repricing, asset mix, noninterest expense, or fee-income weakness is the primary driver. Submit a board-approved profitability plan with coordinated pricing, funding, balance-sheet, and expense actions and quarterly monitoring metrics.