Santander Bank, N.A.

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 $928M plus loans 90 days or more past due and still accruing $9M, measured against total loans and leases $51,335M.

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.

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

Year-to-date net interest margin is 2.46%. 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.

FFIEC UBPR User's Guide §IV — Earnings Analysis

Efficiency ratio is 79.32%. An elevated efficiency ratio indicates noninterest expense is consuming a high share of operating revenue and may weaken the institution’s ability to absorb credit costs, funding-cost pressure, or revenue disruption.

Provide expense and revenue decomposition by major line item, including compensation, occupancy, technology, professional services, and noninterest income trends. Submit a board-reviewed operating plan with measurable expense controls, revenue initiatives, and quarterly efficiency targets.

OCC Comptroller's Handbook, "Earnings"

Year-to-date net interest margin is 2.46% while the efficiency ratio is 79.32%. 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.