Goldman Sachs Bank USA

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

Year-to-date net interest margin is 1.86%. 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.

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 $2,892M plus loans 90 days or more past due and still accruing $487M, measured against total loans and leases $189,637M.

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.

12 CFR § 337.6 — Brokered deposits; FDIC Brokered Deposit Rule

Brokered deposits $70,241M against total deposits $389,733M. Elevated brokered-deposit reliance can increase liquidity sensitivity, funding-cost volatility, and supervisory restrictions if capital condition weakens.

Provide a brokered-deposit funding plan with board-approved concentration limits, maturity distribution, rate-sensitivity analysis, and contingency actions if brokered channels become unavailable or restricted. Demonstrate compliance monitoring for 12 CFR § 337.6.