Western Alliance Bank

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

Brokered deposits $20,833M against total deposits $66,760M. 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.

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 $1,058M plus loans 90 days or more past due and still accruing $583M, measured against total loans and leases $56,279M.

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.

FASB ASC Topic 326, Financial Instruments - Credit Losses; 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 $374M is measured against nonaccrual loans $1,058M while nonaccrual loans are measured against total loans and leases $56,279M.

Provide the current CECL methodology, qualitative factor support, loss-rate support, individually evaluated loan analysis, charge-off timing review, and board approval materials showing why the allowance remains appropriate despite low nonaccrual coverage.