The Bank of New York Mellon

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

Year-to-date net interest margin is 1.38%. 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.

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 $291,378M and insured deposits $16,650M 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.