BOG-FRS - Public Release, April 2023

[Restricted FR]
 

REPORT OF
 

HOLDING COMPANY
 

INSPECTION
 

HC Name: SVB Financial Group 

Location: Santa Clara, California 

RSSD Number: 1031449 

Inspection Commenced: April 5, 2021 

Inspection Concluded: April 16, 2021 

Financial Data as of: December 31, 2020 

THIS DOCUMENT IS STRICTLY CONFIDENTIAL 

This document has been prepared by an examiner selected or approved by the Board of Governors of the 

Federal Reserve System. The document is the property of the Board of Governors and is furnished to directors 

and management for their confidential use. The document is strictly privileged and confidential under applicable 

law, and the Board of Governors has forbidden its disclosure in any manner without its permission, except in 

limited circumstances specified in the law (12 U.S.C 1817(a) and 1831(m)) and in the regulations of the Board of 

Governors (12 C.F.R. 261.20). Under no circumstances should the directors, officers, employees, trustees or 

independent auditors disclose or make public this document or any portion thereof except in accordance with 

applicable law and the regulations of the Board of Governors. Any unauthorized disclosure of the document 

may subject the person or persons disclosing or receiving such information to the penalties of Section 641 of the 

U.S. Criminal Code (18 U.S.C. 641). Each director or trustee, in keeping with his or her responsibilities, should 

become fully informed regarding the contents of this document. In making this review, it should be noted that 

this document is not an audit, and should not be considered as such. 

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July 9, 2021 

Board of Directors 

SVB Financial Group 

3003 Tasman Drive 

Santa Clara, California 95054 

Dear Members of the Board: 

The Federal Reserve Bank of San Francisco (FRBSF) conducted a full-scope inspection of SVB Financial 

Group (SVBFG) beginning on April 5, 2021, based on December 31, 2020 financial statements. Our 

inspection concluded on April 16 and overall results were reviewed with management on June 2. This 

Report of Inspection (ROI) concludes the 2020 supervisory cycle. 

SUMMARY CONCLUSIONS 

SVBFG’s financial condition and risk management practices are satisfactory; nonbanking activities have 

become increasingly significant, but do not negatively impact Silicon Valley Bank (SVB). SVB’s Bank 

Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance 

program is now adequate, and the 2017 enforcement action was terminated. While overall risk 

management is acceptable, weaknesses evidenced by significant operational and technology risk 

governance shortcomings, insufficient lending and credit risk monitoring controls, and a stagnant 

independent credit review function support a downgrade to Internal Controls. As Internal Controls and 

Risk Monitoring are regarded as Fair, the board is expected to provide necessary resources and 

oversight to ensure management expeditiously remediates noted weaknesses. 

SCOPE 

SVBFG was inspected under the authority of section 5(c) of the Bank Holding Company Act of 1956, as 

amended. The inspection’s primary objectives were to assess the organization’s overall risk 

management and consolidated financial condition. We assessed the parent company's ability to act as a 

source of strength to SVB, reviewed intercompany transactions to determine compliance with laws and 

regulations, and assessed management’s progress in remediating outstanding supervisory issues. 

Additionally, the March 22 nonbanking activities target, and the cycle’s continuous monitoring activities 

inform our conclusions. 

RATINGS 

SVBFG remains in satisfactory condition and is rated a composite “2” according to the Federal Reserve 

System’s Uniform Bank Holding Company rating system. Ratings are assigned on a scale from 1 to 5 in 

ascending order of supervisory concern. 

Rating 2 (Satisfactory). Holding companies in this group are fundamentally sound but 

may have modest weaknesses in risk management practices or financial condition. The 

weaknesses could develop into conditions of greater concern but are believed 

correctable in the normal course of business. As such, the supervisory response is 

limited. Cash flow is adequate to service obligations, and the nondepository entities are 

unlikely to have a significant negative impact on the subsidiary depository institution. 

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The table below lists SVBFG's composite, component, and subcomponent RFI/C (D) ratings assigned at 

this inspection and those assigned during the prior two cycles. 

Current 

Inspection 

12/31/20 

Prior 

Inspection 

12/30/19 

Prior 

Inspection 

12/31/18 

SVB Financial Group 

R - Risk Management 2 2 2 

Components: 

Board and Senior Management Oversight 2 2 2 

Policies, Procedures, and Limits 2 2 2 

Risk Monitoring and MIS 3 3 3 

Internal Controls 3 2 2 

F - Financial Condition 2 2 2 

Components: 

Capital 2 2 2 

Asset Quality 2 2 2 

Earnings 2 2 2 

Liquidity 1 1 1 

I - Impact of Parent and Non-Depository 

Subsidiaries on Depository Institution 

2 2 2 

C - Composite Rating 2 2 2 

(D) - Depository Institution 2 2 2 

MATTERS REQUIRING ATTENTION (MRA)1 

Examiners did not identify any new matters requiring attention. Outstanding matters and disposition are 

summarized as follows: 

SUMMARY OF OUTSTANDING FINDINGS 

Matters Requiring Attention 

Timeframe for

Completion Date2 Issue Target Area Status Comments 

Cited at 7/29/19 Corporate Governance 

Target; management action plan received

on 12/6/19, and supervisory feedback 

provided 10/28/20. Remediation efforts 

projected completion is 6/30/22. 

ERM Controls 

Monitoring 

Management — 

Risk Management 

Carry 

Forward 3/31/21

Cited at 7/29/19 Corporate Governance 

Target; management action plan received

on 12/6/19, business line remediation

competed 6/30/20, internal validation

report issued 9/23/20, and supervisory 

review completed in this event. 

Model Overlay/ 

Assumption 

Governance 

Management — 

Risk Management Closed 9/30/20

1

 MRA are matters that are important and that the Federal Reserve expects a banking organization to address over time. 2

 Management's original target date for remediation of the supervisory issue (includes audit validation as applicable). 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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RISK MANAGEMENT – 2 

Overall, risk management is satisfactory. Board and senior management oversight, and policies, 

procedures and limits remain satisfactory; however, risk monitoring and management information 

systems (MIS) remains fair and internal controls is downgraded to fair. Undeveloped controls in the first 

line of defense (FLoD) and an ineffective second line of defense (SLoD) inherently limit risk monitoring’s 

efficacy. Management remains receptive to supervisory feedback and increased board engagement is 

noted as SVBFG has begun taking steps to add separation and strength to FLoD and SLoD controls 

governance. With an expectation of continued rapid growth regarding size, complexity, and global 

presence, a near term focus on acquisition integration must be a priority as other strategic projects are 

considered. Accordingly, the board is encouraged to remain diligent in ensuring appropriate resourcing, 

adequate control environment, and prudent governance processes are developed and maintained. 

Board and Senior Management Oversight – 2 

Board and senior management oversight is satisfactory. The board provides adequate oversight of 

corporate strategies, significant policies, and risk management practices and SVBFG has demonstrated 

resiliency despite the pandemic’s financial disruptions. Additionally, the bank’s BSA/AML and OFAC 

compliance programs are adequate, and the 2017 enforcement action was terminated late in 2020. 

Although financial performance remains stable, a three lines of defense model adopted in 2018 

continues to lack needed traction; FLoD controls programs are insufficient and inconsistent, and the 

Enterprise Risk Management (ERM) program remains ineffective. In 2020, the bank’s URSIT rating was 

downgraded to less-than-satisfactory reflecting significant supervisory concerns cited in Information 

Technology (IT) and operational risk management programs and issues in credit risk management have 

also surfaced. 

Recent board additions and increased engagement have enhanced the group’s ability to provide 

appropriate oversight to management of an increasingly complex technology and operating 

environment. Clear support for upscaling talent has resulted in more capable functional leadership, and 

meaningful actions are being taken to address regulatory concerns. New operating roadmaps and 

project plans are receiving appropriate governance, and early indications of initial progress to remediate 

IT/operational risk governance weaknesses and improve ERM are visible. 

While management is credited with its responsiveness to regulatory findings, the board and 

management are encouraged to be proactive in maintaining an adequate risk management program to 

reduce reliance on internal audit or outside resources to identify risk management weaknesses. In 

reviewing its governance framework for management committees, SVBFG is considering the use of 

formal advisory committees to support executive decision-making processes and developing a SLoD 

Pause process to facilitate ERM’s effective challenge role. In discussions with SVBFG’s General Counsel, 

examiners encouraged management to ensure appropriate documentation is maintained to evidence 

fully informed decisions by executives and effective challenge by an independent SLoD. Additionally, as 

management projects continued rapid growth for SVBFG, board oversight and executive management 

diligence must ensure resources of an appropriate level and skill are available to carryout remediation 

plans without disruption and process improvements are sustainable. 

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Policies, Procedures, and Limits – 2 

Policies, procedures, and limits is satisfactory. Policies and procedures cover major business areas and 

provide a clear delineation of accountability and lines of authority. Limits are tracked for compliance in 

various reports and committee packages provided to the board and senior management. The risk 

appetite statement is appropriate for SVBFG’s inherent risk and complexity. Policies are centrally 

tracked to ensure timely board review and approval. 

Risk Monitoring and MIS – 3 

Risk monitoring and MIS remain fair. While MIS is acceptable in many financial areas, SVBFG is unable to 

monitor and report aggregate exposures as non-financial risks and controls are not sufficiently and 

consistently documented. Board MIS is adequate, but holistic and accurate risk reporting hinges on 

successful remediation of supervisory concerns related to the ERM program, Independent Credit 

Review, Loan/Credit Administration, and IT. As identified within IT in 2018, and cited at the enterpriselevel in 2019, SVBFG’s ERM program has not provided credible challenge to FLoD Controls Inventory, 

Testing, and Monitoring (Controls ITM) program. 

Early in 2021, management outlined a multi-phase plan for FLoD to complete Controls ITM for all 

identified risks and for SLoD to implement a Controls Oversight, Validation, and Monitoring (Controls 

OVM) program of FLoD alignment to enterprise standards. Business units, products, and processes have 

been prioritized and management expects fully functioning ERM processes for all risks and controls by 

mid-year 2022. Additionally, as disparate systems and manual spreadsheets are used to capture and 

generate source MIS for various risk reports, SVBFG is in the process of implementing a centralized 

Global Risk Management (GRC) tool to achieve a consistent approach, standards and methodology for 

non-financial controls, and to capture and report risks on a real time basis. The tool could enable timely 

aggregation of risk monitoring information across business lines and enterprise wide. 

The Model Overlay/Assumption Governance MRA was addressed and is closed. Although the MRA and 

corresponding remediation activities were limited to capital stress testing, SVBFG’s Head of Operational 

Risk Management indicated model governance standards are being incorporated into a firm-wide 

program. 

Internal Controls – 3 

Internal controls is downgraded to fair. Supervisory concerns cited across the organization share a 

thematic weakness in FLoD governance/nonfinancial controls and insufficient SLoD oversight which 

hinder holistic and transparent risk reporting. The volume and significance of IT/operational risk internal 

control deficiencies increased through the 2020 supervisory cycle and new issues surfaced in loan 

administration and internal credit review. At this point, the system of internal controls does not provide 

adequate coverage of SVBFG’s key risks and business activities. 

A mid-year 2020 supervisory evaluation of management’s progress remediating the 2019 ERM Controls 

Monitoring MRA resulted in critical feedback to SVBFG that the FLoD was inconsistently performing the 

firm’s Controls ITM program and the SLoD was ineffective in board and executive reporting. 

Management acknowledged that additional effort was needed and engaged consultants to develop a 

standardized Controls ITM program for consistent implementation across the FLoD. Early in 2021, SVBFG 

created and filled a Chief Controls Officer position to oversee the enterprise Controls ITM program. 

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More recently, a new Head of ERM was hired and additional SLoD resources are budgeted to ensure 

timely implementation of ERM playbooks, projects, and initiatives and to achieve a sustainable and 

scalable program. Additionally, resources in India will be used to supplement and assist in the Controls 

OVM program and perform periodic testing. Overall, the project plans appear reasonable with clearly 

defined ownership, enabling an end-to-end process owner to optimize handoffs and cross 

functional/entities interdependencies. The plan also provides a reasonable timeline on the alignment of 

FLoD’s controls to the ERM Program risk taxonomy focusing on non-financial risks, establishing 

repeatable testing routines, and maintaining a complete risks and controls catalog. At this inspection, 

examiners were unable to validate the Controls ITM and/or Controls OVM as Phase 1 was still underway. 

The long-term plan is focused on identifying, documenting, and building out an inventory of highest risks 

and accompanying controls by year end 2021, with the completion of all risks in mid-2022. 

Internal Audit (IA) remains effective. The Chief Audit Executive (CAE) provides the Audit Committee (AC) 

comprehensive quarterly updates with appropriate risk focus, and IA is independent and objective. 

Coverage of most key risks is adequate, and most auditable entities are reviewed on a frequency 

commensurate with risk; the frequency of ERM audit coverage was an exception as it had not been 

audited since 2018 and IA’s ERM risk assessment did not appear to fully consider growing regulatory 

concerns regarding the ERM program and the IT control environment. Although IA did not review the 

ERM program holistically, the SLoD was assessed during individual entity audits and weaknesses were 

noted as applicable. An ERM audit is planned for August 2021, and the CAE was encouraged to provide 

the AC with an annual opinion on the comprehensive adequacy of risk management processes. 

Although SVBFG’s FLoD and SLoD need improvement in relation to controls management, IA has been 

effective in identifying weaknesses in the areas of BSA/AML, IT, loan administration, and affiliate 

transactions. However, inconsistencies were noted with IA’s MRA validation test work. In two instances, 

the scope and test procedures were too narrowly focused, which inhibited IA’s ability to effectively 

assess the design/operating effectiveness and effectively challenge management’s remediation plans. 

The CAE was encouraged to consider expanding the breadth and depth of MRA validation work to 

ensure that sufficient testing is performed, and conclusions are well-supported. 

SVBFG’s Sarbanes-Oxley program is effectively managed. The firm’s external auditors concluded that 

financial risks and controls were adequately inventoried, monitored and tested. 

FINANCIAL CONDITION – 2 

SVBFG’s financial condition is satisfactory. The company demonstrated financial resilience despite 

significant unanticipated growth led by the influx of client funds and uncertainties caused by the 

pandemic. Capital, asset quality and earnings are rated satisfactory; and the liquidity position is strong.

3 

Capital – 2 

Consolidated capital is satisfactory relative to the firm’s risk profile and was prudently managed through 

the significant uncertainties of 2020. As the pandemic’s initial impact to SVBFG’s balance sheet became 

clear, management halted a share repurchase program and suspended bank-to-parent dividends while 

quarterly revisions were made to financial forecasts. A continuing unanticipated influx of client funds led 

to significant balance sheet growth and all capital ratios declining by approximately 150 basis points 

3 Unless otherwise noted, all financial information is as-of December 31, 2020 or for the 12 months ended December 31, 2020, as applicable. 

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during the 2020 supervisory cycle. The consolidated common tier one equity capital, tier one capital, 

total capital, and tier one leverage are 11.04 percent, 11.89 percent, 12.64 percent, and 7.45 percent, 

respectively. 

The influx of client funds generated unprecedented organic growth and SVBFG’s Tier One Leverage ratio 

briefly breached management’s initial threshold late in the cycle. Executives discussed capital 

management frequently with examiners and aggressive capital raising efforts that began in the fourth 

quarter have continued into early 2021 to improve all consolidated capital ratios. With cash and low-risk 

investment securities representing the majority of total assets, some concern related to leverage capital 

ratios is mitigated; however, management is encouraged to continue sharing capital management 

strategies with examiners and achieve the projected minimum 8.0 percent leverage ratio by year-end 

2021. 

Asset Quality – 2 

Consolidated asset quality is satisfactory, with stable and manageable credit risk. Loans grew at 36.2 

percent in 2020 but growth was centered in lower risk segments. Classification levels remain moderate 

with a total classification ratio of 16.3 percent and a weighted classification ratio of 3.6 percent. The 

investment portfolio also experienced material growth, it now represents 41.0 percent of total assets, 

and is comprised primarily of low-risk higher credit quality assets. 

Earnings – 2 

Consolidated earnings remain satisfactory, above peer, and sufficient under normal conditions. Net 

income of $1.3 billion was aided significantly by warrant gains and investment banking revenue to 

produce a return on average assets of 1.42 percent, a decrease from 1.80 percent in 2019. Earnings 

were adversely impacted by multiple factors present during the pandemic including a low rate 

environment, an increase in expected losses/credit reserves, and deferred income. Although profitability 

remains favorable, nonbank revenue is strong, and nearly all earnings are retained, capital raising was 

needed to sufficiently augment capital. 

Liquidity – 1 

Consolidated liquidity is strong, as liquid assets comprise 51.7 percent of total assets. The funding 

structure remains almost wholly comprised of deposits with minimal noncore funding sources primarily 

being foreign deposits. During 2020, the firm benefited from extraordinary deposit growth with total 

deposits increasing from $62.0 billion to $102.0 billion. Despite the high amount of core funding, deposit 

concentrations remain, and flows can be volatile. This risk is partially mitigated by $10.7 billion in 

secured funding sources and comprehensive risk management practices meet current expectations. 

IMPACT – 2 

The parent and its nonbank subsidiaries present limited likelihood of significant negative impact to SVB. 

Nonbank activities provide complementary services to SVB’s clients and integration of nonbanking 

activities into the ERM program continues. The parent company remains financially flexible with low 

debt, adequate cash liquidity, and a demonstrated ability to access capital markets when needed to 

support SVB. 

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Parent Company Financial Analysis 

The parent company is financially satisfactory, and management monitoring is appropriate. With a 10.3 

percent debt-to-equity ratio, the company is modestly leveraged and maintains liquidity at a minimum 

of 18 months of cash needs. As the pandemic disrupted financial markets, management halted share 

repurchases and bank-to-parent dividends to preserve liquidity and provide support to SVB. These 

actions, combined with multiple debt and equity raises beginning in late 2020, demonstrate financial 

resiliency and helped address a declining SVB tier 1 leverage capital ratio brought on by material asset 

growth. Management continues to revise projections and has proposed capital actions for various 

scenarios, including continued rapid growth. 

Intercompany Transactions 

The bank, parent company, and non-bank subsidiaries remain in compliance with Regulation W, and 

practices align with interagency guidelines regarding income tax allocation in a holding company 

structure. Appropriate and timely reimbursement is provided to SVB for employee time providing 

services to nonbank affiliates and the parent company. A Regulation W audit report issued during the 

inspection assigned a “Needs Improvement” to the program’s FLoD and SLoD. The report cited a 

doubling of Regulation W affiliates related to expansionary nonbanking activities coupled with a lack of 

clear ownership of control activities and decentralized program governance to oversee end-to-end 

compliance across business units and control functions as root cause issues. IA’s observations related to 

the process for affiliate identification, perfection of collateral for credit transactions with affiliates, and 

affiliate transaction identification and monitoring. In the past, management has satisfactorily addressed 

audit findings and is expected to develop and execute appropriate remediation action plans. 

Nonbanking Activities 

Nonbank activities continue to expand and generate material revenue for the consolidated company. 

These activities include venture capital investment and funds management offered through SVB Capital 

(a unit of the parent company), and investment bank and broker dealer activities operated by SVB 

Leerink (a subsidiary of the parent company). Integration into the ERM program activities remains a 

work in progress, particularly regarding SVB Leerink. Nonbanking assets account for only 1.9 percent of 

SVBFG’s consolidated assets but generated 31.6 percent of consolidated earnings with negligible 

financial risk. 

SVB Capital presents limited, adequately controlled financial and non-financial risk. Since 2000, SVB 

Capital has raised and invested in ten funds of funds, five direct investment funds, five opportunity 

funds, and one debt fund. Fundraising for three new investment funds are planned for 2021. Integration 

into SVBFG’s ERM practices are keeping pace with the expansion of managed fund products and the 

range of potential investors. SVB Capital has contributed significant positive operating results to the 

consolidated organization, with higher levels of assets under management and significant revenue 

generated by strong warrant income. 

SVB Leerink has focused on the healthcare and bio-pharmaceutical sector providing Equity Capital 

Markets, Merger and Acquisition Advisory, Equity Research and Institutional Sales and Trading. 

Management is planning to hire a team to implement operations for a strategic expansion into the 

technology sector, expanding services available to existing SVB customers. Financial Industry Regulatory 

Authority, SVB Leerink’s primary regulator, reports no current concerns with the operations of SVB 

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Leerink. However, only recently has SVBFG begun integration of SVB Leerink into the ERM program and 

the current risk assessment and internal controls identification process has not been completed. 

Management acknowledged the gaps and remediation efforts are underway. 

DEPOSITORY INSTITUTION – 2 

SVB remains in satisfactory condition as noted in the May 3 Report of Examination. Capital, Asset 

Quality, Management, Earnings, and Sensitivity remain satisfactory; Liquidity is regarded as strong. The 

SVB examination noted board and executive management provide appropriate oversight over most 

risks, though increased attention is needed to address IT/operational issues and other risks surfaced 

during the 2020 cycle. Two supervisory issues were cited (Formalization and Maturity of Internal Credit 

Review and Ownership of LoD Lending Controls), though they do not cause heightened concern. 

OTHER MATTERS 

BSA/AML and OFAC Compliance Program 

The bank’s BSA/AML and OFAC compliance program is adequate. After several years of rebuilding the 

program, risks are now adequately identified, monitored, and mitigated. The 2017 Memorandum of 

Understanding was terminated on December 1, 2020. 

Consumer Compliance 

The most recent FRBSF and Consumer Financial Protection Bureau (CFPB) compliance examinations have 

resulted in satisfactory ratings. The CFPB’s October 26, 2016 report identified violations related to loan 

originator compensation and Home Mortgage Disclosure Act reporting, and cited MRAs to ensure that 

corrective action was performed to address these violations and the FRBSF concurred with these 

findings. The October 22, 2018 FRBSF report noted that SVB continues to build out its consumer 

compliance risk management framework and did not identify any violations related to the nonenumerated consumer laws and regulations. SVB also operates under a Strategic Plan for compliance 

with the Community Reinvestment Act (CRA), and earlier this year the FRBSF approved the bank’s plan 

for the 2021-2023 timeframe. The bank’s CRA performance was most recently assessed as Satisfactory 

at the October 2018 review. Further, the FRBSF commenced a compliance and CRA examination of SVB 

on June 21. 

Information Technology 

SVB’s IT/operational risk management activities are less than satisfactory, with a high volume of 

MRIA/MRA outstanding. A report on the November 30, 2020 IT examination was issued on February 11 

and reported an URSIT composite downgrade to 3, and a downgrade to the Support & Delivery 

component to 3; IT Management was rated 3 at the February 19, 2019 examination. Several new and 

outstanding MRIA/MRA spanning cybersecurity, asset management, identity access management, data 

protection and governance, vendor management, and SLoD technology risk need to be addressed to 

improve the IT function and decrease operational risk to an acceptable level. SVB’s response to the most 

recent examination included action plans reasonably outlining the course of remediation activities for 

each issue and additional governance activities to ensure executive management and the board remain 

aware of progress. As internal validation of remediation efforts is projected to stretch into January 2023, 

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the board and executive management have been encouraged to seriously consider time-saving options 

such as staff augmentation, redirecting, or further prioritizing remediation efforts. 

CLOSING COMMENTS 

SVBFG has demonstrated financial resiliency and remains in satisfactory condition. The ERM program 

warrants continued attention to keep pace with the firm’s rapid growth, and a response to this ROI 

providing an update on remediation of the Controls Monitoring MRA is requested by August 23.

4 

Additionally, each director should sign the Signature of Directors page, and the board’s review of this 

ROI should be recorded in SVBFG’s corporate records. The contents of this letter are confidential and 

should not be made public.

5 

We appreciate the board and management’s attention and cooperation throughout the 2020 

supervisory cycle and look forward to meeting with the board to discuss the report’s contents and the 

firm’s transition to a large-bank supervisory program. Please direct any immediate questions or 

concerns related to this ROI’s conclusions, or any matter involving our supervision of SVBFG as a 

regional banking organization, to me at 

Redacted

or 

Redacted . 

Sincerely, 

Central Point of Contact 

Redacted Redacted

4 Any institution about which the Federal Reserve makes a written material supervisory determination is eligible to utilize the appeals process 

as described in Internal Appeals Process for Material Supervisory Determinations and Policy Statement Regarding the Ombudsman for the 

Federal Reserve System, 85 Fed. Reg. 15175 (March 17, 2020). An appeal under this process may be made of any written material supervisory 

determination, as defined in the policy statement. 

The Board’s Ombudsman (Ombudsman) can provide assistance regarding questions related to the System’s material supervisory determination 

appeals process and claims of retaliation. The Ombudsman can also provide assistance to facilitate the informal resolution of concerns prior to 

the filing of a formal appeal. An institution may contact the Ombudsman at any time by calling 1-800-337-0429, by sending a facsimile to 202-

530-6208, by writing to the Office of the Ombudsman, Board of Governors of the Federal Reserve System, Washington, D.C. 20551, or by 

sending an e-mail to ombudsman@frb.gov. 

5 This document has been prepared by an examiner selected or approved by the Board of Governors of the Federal Reserve System. The 

document is property of the Board of Governors and is furnished to the directors and management for their confidential use. The document is 

strictly privileged and confidential under applicable law, and the Board of Governors has forbidden its disclosure in any manner without its 

permission, except in limited circumstances specified in the law (12 U.S.C. 1817(a) and 1831m-1 and in the regulations of the Board of 

Governors (12C.F.R. 261.20). Under no circumstances should the directors, officers, employees, trustees, or independent auditors disclose or 

make public this document or any portions thereof except in accordance with applicable law and regulators of the Board of Governors. Any 

unauthorized disclosure of the document may subject the person or persons disclosing or receiving such information to the penalties of section 

641 of the U.S. Criminal Code (18, U.S. C. 641). Each director or trustee, in keeping with his or her responsibilities, should become fully informed 

regarding the contents of this document. In making this review, it should be noted that this document is not an audit and should not be 

considered as such. 

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SIGNATURE OF DIRECTORS 

We, the undersigned directors of SVB Financial Group, Santa Clara, California have personally reviewed 

the contents of the report of inspection dated December 31, 2020. 

Signature of Directors Date 

Greg W. Becker 

Eric A. Benhamou 

Richard Daniels 

Alison Davis 

Roger F. Dunbar 

Joel P. Friedman 

Jeffrey N. Maggioncalda 

Kay Matthews 

Mary J. Miller 

Kate D. Mitchell 

Garen K. Staglin 

NOTE: This form should remain attached to the report of inspection and be retained in the holding 

company’s file for review during subsequent inspections. The signature of committee members will 

suffice only if the committee includes outside directors and a resolution has been passed by the full 

board delegating the review to such committee. 

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