Restricted FR 

REPORT OF JOINT EXAMINATION 

CALIFORNIA DEPARTMENT 

OF BUSINESS OVERSIGHT 

FEDERAL RESERVE BANK 

OF SAN FRANCISCO 

Silicon Valley Bank 

Santa Clara, CA 

EXAMINER-IN-CHARGE Redacted DBO Redacted FRB 

THIS REPORT OF EXAMINATION IS STRICTLY CONFIDENTIAL 

This report has been prepared by examiners appointed or approved by the Board of Governors of 

the Federal Reserve System and the California Department of Business Oversight. The report is the 

property of the Board of Governors and the California Department of Business Oversight, and is 

furnished to directors and management for their confidential use. The report is strictly privileged and 

confidential under applicable law, and the Board of Governors and the California Department of 

Business Oversight have forbidden its disclosure in any manner without their 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. 261.11). Management is required by law to send a copy of this report to 

independent auditors engaged to conduct audits of the insured institution. Under no circumstances 

should the directors, officers, employees, trustees or independent auditors disclose or make public this 

report or any portion thereof except in accordance with applicable law and the regulations of the Board 

of Governors. Any unauthorized disclosure of the report 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). 

The information contained in this report is based upon the books and records of the bank, upon 

statements made to the examiner by directors, officers, and employees, and upon Information obtained 

from other sources believed to be reliable and presumed by the examiner to be correct. 

It is recommended that each director, in keeping with his or her responsibilities both to depositors 

and to shareholders, thoroughly review the report In making this review, it should be noted that an 

examination is not the same as an audit, and this report should not be considered an audit report. 

Bank Number 1462 

RSSD Number 802866 

Examination Date October 3, 2016 

Financial Statement Date September 30. 2016 

BOG-FRS - Public Release, April 2023
CALIFORNIA DEPARTMENT OF FINANCIAL INSTITUTIONS 

SACRAMENTO OFFICE 

1810 - 13TH STREET 

SACRAMENTO, CALIFORNIA 95814 

(916) 322-5966 

FEDERAL RESERVE BANK OF SAN FRANCISCO 

101 MARKET STREET 

SAN FRANCISCO, CALIFORNIA 94105 

(415) 974-2000 

March 7, 2017 

Board of Directors 

Silicon Valley Bank 

3005 Tasman Drive 

Santa Clara, CA 95054 

Subject: Transmittal of Joint Safety and Soundness Report of Examination 

Members of the Board: 

Enclosed is a copy of the October 3, 2016 joint Federal Reserve Bank (FRB)/California 

Department of Business Oversight (DBO) Report of Examination (Report). 

Summary of Examination Findings 

The findings of this joint examination indicate that the Bank's overall condition is satisfactory. Liquidity remains strong, while capital, asset quality, management, earnings, and sensitivity to 

market risk continue to be satisfactory. Credit quality remains satisfactory and the level of 

adverse classifications is manageable. Management has made significant progress remediating the Matters Requiring Attention (MRA) cited during the asset quality target in May 2016 to 

improve loan documentation and ensure there is sufficient detail and support to assess risk in the 

credit portfolio. Management's progress in remediating this MRA will be evaluated during the 

asset quality target in May 2017. 

Management remains satisfactory, primarily reflecting the Bank's overall financial condition. However, weaknesses were noted in the BSA/AML and compliance functions. Internal control 

deficiencies combined with insufficient program oversight resulted in the issuance of two 

Matters Requiring Immediate Attention following the BSA Target in August 2016. Further, management was also unable to fully remediate the three outstanding BSA MRAs requiring improvement in the risk assessment and methodology, risk management over system 

implementation, and the Office of Foreign Assets Control program. Given the significant 

weaknesses in the BSA/AML compliance program, a Memorandum of Understanding was issued 

on January 26, 2017 requiring immediate corrective action to strengthen risk management 

practices and address program deficiencies. 

In addition, the compliance function does not consistently meet the supervisory expectations of 

SR 16-11, which requires management to ensure that appropriate policies, controls, and risk 

monitoring systems are in place to comply with laws, regulations, and supervisory requirements. Processes do not consistently ensure that key assumptions and procedures used in measuring and 

monitoring risks are sufficiently documented to allow for effective challenge and validation. A 

BOG-FRS - Public Release, April 2023
new MRA will be issued requiring management to develop a more comprehensive process to 

ensure that all business units have consistent documentation standards and comply with internal 

policies, regulations, and regulatory guidance. Refer to the Matters Requiring Board Attention 

section of the Report for details on required corrective action. 

Although many of the BSA/AML and compliance issues were self-identified by internal audit, remediation efforts to correct deficiencies are still in the assessment and planning phase. The successful and timely execution of plans to address regulatory concerns will be required for 

management to remain effective. 

The Bank remains in compliance with the Information Technology (IT) Board Resolution (BR) 

and has implemented broad, positive changes to the program. Management of IT activities is 

much improved; however, management will require additional time to improve processes and 

remediate weaknesses in application and maintenance processes. The BR will remain in place 

until all weaknesses have been remediated and until examiners can validate corrective actions 

during the IT target in the first quarter of 2017. 

Action Requested 

The Report includes a new MRA related to improving the Bank's compliance program. Within 

30 days of receipt of this Report, please respond detailing your efforts to address the MRA as 

well as other advisory items presented through the Report. Please send your response to both the 

Sacramento DBO office and the FRB in San Francisco. 

Each member should thoroughly review the Report and acknowledge their review by signing the 

Signatures of Directors page included as the last page of the Report. Please retain the page with 

the Report and record the Board's review of the Report in Board minutes. 

Confidentiality Notice 

This Report is the property the California Department of Business Oversight and the Board of 

Governors of the Federal Reserve System and is furnished to the Bank for its confidential use. Under no circumstances shall the Bank or any of its directors, officers, or employees disclose or 

make public in any manner the Report or any portion thereof. The law provides penalties for 

unauthorized disclosure of any information of this Report. If any subpoena or legal process 

calling for reproduction of this Report is received, both agencies must be notified immediately. 

DBO Post Examination Survey 

A DBO Post Examination Survey will be emailed separately to your CEO for you to provide 

feedback to our department about the examination process. We appreciate your time and 

attention in completing the survey and look forward to receiving your comments. 

BOG-FRS - Public Release, April 2023
If you have questions, you may contact DBO Redacted 

or FRB Central Point of Contact Redacted 

Sincerely, Redacted 

Redacted 

Redacted

Department of Business Oversight

Central Point of Contact 

Federal Reserve Bank of San Francisco 

Redacted 

Redacted 

Enclosure(s) 

cc: Federal Deposit Insurance Corporation, San Francisco 

BOG-FRS - Public Release, April 2023
Table of Contents 

Matters Requiring Board Attention 1 

Examination Conclusions and Comments 4 

Compliance with Enforcement Actions 11 

Violations of Laws and Regulations 13 

Examination Data and Ratios 14 

Comparative Statements of Financial Condition 15 

Items Subject to Adverse Classification 16 

Concentrations 18 

Analysis of Earnings 19 

Composite Ratings Definitions 20 

Signatures of Directors 21 

All dollar amounts are reported in thousands, unless otherwise indicated. 

BOG-FRS - Public Release, April 2023
Matters Requiring Board Attention 

Matters Requiring Attention (MRA) 

Compliance Program 

The compliance department does not consistently meet supervisory expectations of SR 16-11 which requires 

management to ensure that appropriate policies, controls, and risk monitoring systems are in place to comply with 

laws, regulations, and supervisory requirements. Systems do not consistently ensure that key assumptions and 

procedures used in measuring and monitoring risks are sufficiently documented to allow for effective challenge 

and validation. The compliance function currently relies on business units to self-regulate and assess their own 

compliance to policy and regulatory requirements. The system is prone to errors and omissions, evidenced by four apparent violations of Regulation O, inconsistent documentation, several outdated policies, and instances 

where the business unit was not fully compliant with internal policies and regulatory guidance. 

Required Action: Management is required to evaluate and improve processes to comply with all internal 

policies, regulations, and regulatory guidance. These processes must include: 

• Ensuring full compliance with internal policies. For example, management should: 

Require the review and approval of the capital planning framework by the Asset Liability Committee (ALCO) per the Capital Planning and Management Policy. Comply with Treasury policies requiring the annual review of model assumptions and 

quarterly back-testing of the interest rate risk (IRR) model. • Implementing effective internal controls and monitoring processes, including: 

Documenting key assumptions and limitations of the capital buffer methodology to allow for 

effective challenge and testing. Ensuring that procedures prevent overdraft payments in conformance with Regulation O. 

• Updating internal policies and procedures to comply with supervisory guidance, including: 

Memorializing informal processes into written procedures to ensure ongoing monitoring of 

municipal bonds per SR 98-12. Requiring the reporting of net counterparty credit risk exposure to ALCO at a frequency commensurate with the materiality and complexity of exposures per SR 11-10. Incorporating SR 10-1 guidance into internal policies to ensure management sufficiently 

measures and understands IRR as well as underlying assumptions. 

Management Response: Management agreed with these recommendations and has taken initial steps to review, 

assess, and improve the compliance department and its processes. Management committed to develop an 

updated compliance framework and address weaknesses noted during this examination by 9/30/17, 

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Summary of New Findings 

Matters Requiring Attention 

Issue Main Category Sub Category 

Expected 

Completion 

Date 

Compliance Program Management-Risk 

Management 

Board & 

Management 

Oversight 

9/30/17 

SUMMARY OF OUTSTANDING FINDINGS 

Matters Requiring Immediate Attention 

Issue Main Category Status 

Timeframe for 

Completion 

Date 

Internal Controls: CDD, EDD, and Suspicious Activity Monitoring BSA Officer and 

Administration 

BSA/AML Issues Risk 

Management Open 3/31/17 

BSA/AML Issues Risk 

Management Open 3/31/17 

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SUMMARY OF OUTSTANDING FINDINGS 

Matters Requiring Attention 

Issue Main Category Status 

Timeframe 

for 

Completion 

Date 

Program Oversight- Risk 

Assessment 

BSA/AML Issues Risk 

Management Carry Forward 3/31/17 

Risk Management of System 

Implementation 

BSA/AML Issues Risk 

Management Carry Forward 3/31/17 

BSA/OFAC Program BSA/AML Issues Risk 

Management Carry Forward 3/31/17 

Credit File Documentation and 

Support Credit Risk Management Pending Verification 9/30/17 

IT - Board and Management 

Oversight IT Related Issues (per 98-9) Pending Verification 3/31/17 

Application Implementation and 

Maintenance IT Related Issues (per 98-9) Pending Verification 8/31/16 

BOG-FRS - Public Release, April 2023
Examination Conclusions and Comments 

Current Exam 

10/03/2016 

Prior Exam 

10/13/2015 

Prior Exam 

Ratings by Examination Function 10/06/2014 

Risk Management Composite 2 2 2 

Risk Management Component: 

Capital 2 2 2 

Asset Quality 2 2 2 

Management 2 2 2 

Earnings 2 2 2 

Liquidity 1 1 1 

Sensitivity to Market Risk 2 2 2 

Information Technology1 3 3 2 

1

 Information Technology examination was conducted as of 3/14/16. 

SCOPE 

A joint safety and soundness examination of Silicon Valley Bank (SVB or Bank) was conducted by the California 

Department of Business Oversight (CDBO) and the Federal Reserve Bank of San Francisco (FRBSF/Reserve 

Bank), beginning 10/3/16. The examination included an assessment of the CAMELS components, review of the 

internal audit function, and overall adequacy of risk management practices. In addition to information obtained 

through continuous monitoring, ratings in this report incorporated results from examinations throughout the year 

which included: Information Technology (IT) Target, Asset Quality (AQ) Target, Consumer Compliance and 

Community Reinvestment Act Examination, and the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Target. 

The financial date utilized for this examination was 6/30/16 while loan data was as of 7/31/16; however, the 

financial data was updated to 9/30/16 as available. All figures and ratios referred to in this Report of Examination 

(Report) are derived from the Uniform Bank Performance Report dated 9/30/16 unless otherwise noted. 

OVERALL CONDITION 

The Bank's overall condition is satisfactory. Earnings remain satisfactory, as net income has benefited from a 

shift in earning assets from lower yielding investments to loans. Liquidity remains strong with substantial and 

reliable sources of on-balance sheet liquidity to meet present and anticipated funding needs. Sensitivity to market 

risk continues to be adequately managed. Capital levels remain satisfactory and commensurate with the Bank's 

risk profile. Management has remediated the MRA to develop a comprehensive and effective capital contingency plan. Asset quality remains satisfactory. The level of adverse classifications is manageable despite a fluctuation 

in classified loans during the past year due to market uncertainty and lower than normal investor sentiment. Credit risk management practices are acceptable. Bank management successfully resolved the MRA requiring accurate identification of impaired and troubled restructured debt and the MRA requiring new standards to ensure 

independent enterprise valuations for leveraged loans. However, a new MRA was cited in the Supervisory Letter 

dated 8/15/16 to improve loan documentation and ensure that there is sufficient detail and support to assess the 

BOG-FRS - Public Release, April 2023
risk in the credit portfolio. Management has made significant progress to remediate this MRA and processes are 

expected to be validated by internal audit by 9/30/17. 

Management remains satisfactory, reflecting the overall satisfactory condition of the bank. Risk management is 

also satisfactory; however, management is required to improve processes to ensure full compliance with all 

internal policies, regulations, and regulatory guidance, as well as ensure clear and consistent documentation to 

support key management decisions and policies. Management committed to address this MRA by 9/30/17. 

The Information Technology (IT) target examination report transmitted to the bank on 6/14/16 noted that IT 

remains less than satisfactory, but is improving. The Bank remains in compliance with the Board Resolution and 

has implemented broad, positive changes to the IT program. Although management of IT activities is much 

improved, management will require additional time to execute on their plans to improve IT processes and 

remediate weaknesses in application and maintenance processes. Management has substantially addressed the 

two remaining IT MRAs related to stabilizing IT management and improving processes for application 

implementation and maintenance. Both of the MRAs are expected to be resolved by 3/31/17. The Board 

Resolution will remain in place until all weaknesses have been remediated and corrective actions are validated. 

The BSA/AML compliance program was considered less than satisfactory during the August target examination. Internal control deficiencies combined with insufficient program oversight have weakened the ability to 

effectively identify, investigate and report suspicious activities in a timely manner. As a result, the Supervisory Letter dated 12/12/16 included an internal controls pillar violation and two Matters Requiring Immediate 

Attention (MRIA) to improve internal controls and oversight of the BSA/AML program. In addition, management was unable to fully remediate the three outstanding MRAs requiring improvement in the risk 

assessment and methodology, risk management over system implementation, and the Office of Foreign Assets 

Control (OFAC) program. Given the significant weaknesses in the BSA/AML compliance program, a 

Memorandum of Understanding was issued on 1/26/17 requiring immediate corrective action to strengthen risk 

management practices and address program deficiencies. Management committed to remediate the three MRAs 

and two MRIAs by 3/31/17. 

The FRBSF Consumer Compliance and Consumer Financial Protection Bureau (CFPB) examinations resulted in 

satisfactory ratings. However, in the examination report transmitted to the bank on 10/21/16, the Reserve Bank 

noted weaknesses in bank procedures and staff knowledge that led to isolated violations of the flood hazard 

insurance provisions of Regulation H and Regulation CC (Expedited Funds Availability Act). Management has 

already taken steps to correct and prevent these issues from occurring in the future. The 10/26/16 CFPB report 

also noted violations in loan originator compensation and Home Mortgage Disclosure Act reporting. The CFPB 

report cited MRAs to ensure that corrective action is performed to address violations and incorrect data related to 

mortgage originations and the Home Mortgage Disclosure Act. 

MANAGEMENT/RISK MANAGEMENT - 2 

Management is satisfactory. The rating reflects the overall satisfactory condition of the bank and management's 

ability to maintain stable earnings, capital, asset quality, and strong liquidity. Risk management practices over 

credit, liquidity, market and legal functions continue to be adequate, and IT management practices have improved 

during the past year. However, weaknesses were noted in the Bank's compliance and BSA/AML functions, and 

remediation efforts are still in the assessment and planning phase. Although many of these issues were self- identified by internal audit, these deficiencies resulted in the issuance of a Memorandum of Understanding and 

two MRIAs following the BSA Target, and a compliance related MRA during this examination. While risk is 

BOG-FRS - Public Release, April 2023
mitigated by the Bank's stable financial condition, the successful and timely execution of plans to address 

regulatory concerns is required for management to remain effective. 

The compliance function does not consistently meet the supervisory expectations of SR 16-11, which requires 

management to ensure that appropriate policies, controls, and risk monitoring systems are in place to comply with 

laws, regulations, and supervisory requirements. In addition, processes do not consistently ensure that key assumptions and procedures used in measuring and monitoring risks are sufficiently documented to allow for 

effective challenge and validation. The function, instead, heavily relies on business units to self-regulate and 

assess their own compliance to policy and regulatory requirements. This system is prone to errors and omissions, evidenced by four apparent violations of Regulation O, inconsistent documentation, several outdated policies, and 

instances where the business was not fully compliant with internal policies and regulatory guidance. A new MRA 

will be issued requiring management to develop a more comprehensive process to ensure that all business units 

have consistent documentation standards and comply with internal policies, regulations, and regulatory guidance. Refer to the Matters Requiring Board Attention section for details on required corrective action. 

Management has the willingness, experience, resources, and appropriate strategy to address the issues within the 

compliance and BSA/AML functions. The plan to improve the BSA/AML and compliance departments closely models the approach taken by the board to improve IT, which focused on strengthening leadership and filling key 

management positions. The recent hires of the Chief Risk Officer (CRO) and BSA Officer are expected to 

provide the requisite leadership to remediate deficiencies and improve the effectiveness of the BSA/AML and 

compliance programs. In addition, the CRO recruited a highly experienced BSA consultant to assist the new 

BSA Officer in improving internal controls and bolstering the oversight function. Management also initiated 

efforts to review, assess, and improve the compliance department and its processes. The enhanced program will 

supplement risk management processes within the business units and ensure full compliance with internal 

policies, regulations, and regulatory guidance. 

Management has demonstrated the ability to remediate MRAs and comply with regulatory enforcement actions. Three MRAs were closed during this examination cycle, including two credit MRAs and one capital MRA. The 

Bank is compliant with the IT Board Resolution. Although the Board Resolution will remain in place until the 

overall performance of IT is returned to a satisfactory condition, examiners have noted broad improvements 

within the IT department. Management has begun remediating the MRA to improve credit documentation and is 

expected to have auditable results in the third quarter of 2017. 

Internal Audit 

Risk is mitigated by an effective internal audit program, which notably self-identified and escalated weaknesses 

within the BSA/AML and compliance departments. The function continues to provide an independent and 

objective assessment of the bank's internal control, governance, and risk management processes. Audit staff 

resources and expertise, inclusive of co-sourced auditors, are sufficient to complete the audit plan. The 2016 

Audit Plan is on track for timely completion. Auditable entities are reviewed in a frequency commensurate with 

their risk, and exceptions are reported to the Audit Committee with appropriate rationale. Audits are 

comprehensive and workpapers adequately support the findings and conclusions of the audits. Effective issue 

tracking processes are in place to monitor the status of open audit findings and validate management's corrective 

actions. 

BOG-FRS - Public Release, April 2023
CAPITAL - 2 

Capital levels remain satisfactory and commensurate with the bank's risk profile. The Tier One and Total Risk 

Based Capital ratios of 12.77% and 13.83% remain relatively unchanged from prior examination levels. During the year, the Tier 1 Leverage Ratio increased from 7.13% to 7.74% as a result of earnings augmentation and 

tapered asset growth. Although the leverage ratio remains significantly lower than peer, risk is mitigated by satisfactory capital management and the low risk of the large investment portfolio which accounts for more than 

half of total assets. 

Capital management is satisfactory and contingency planning has improved. Policies and procedures are 

adequate and encompass a more refined contingency planning process, which continues to incorporate results 

from DFAST (Dodd Frank Act Stress Testing). Issues noted during the prior examination have been addressed, and the Capital Contingency Planning MRA has been closed. However, there is insufficient documentation of the 

capital buffer methodology and governance over the capital planning process. Per internal policy, the Bank is 

required to document the capital buffer methodology, key assumptions, limitations, support, and effective 

challenge. The MRA regarding enhancement of the compliance program will require management to ensure that 

documentation practices comply with internal policies. Refer to the Matters Requiring Board Attention section 

for details on required corrective action. 

ASSET QUALITY - 2 

Asset quality remains satisfactory. The level of adverse classifications is manageable; however, classified loans 

have fluctuated due to a period of market uncertainty and lower than normal investor sentiment, which negatively impacted the performance of the early stage loan portfolio and increased the level of problem assets and credit 

losses. There was also deterioration in several larger loans within the sponsor-led buyout portfolio. Total 

classifications as of September 30, 2016 were 28.5% of capital and reserves, compared to 26.5% during the prior 

examination and 31.4% during the May 2016 Asset Quality target (AQ Target). The level of nonperforming loans has declined since the prior examination; however, net losses remain elevated at 0,47% of total loans. 

Credit risk management remains satisfactory, based on acceptable credit underwriting standards and an effective 

credit risk rating system. Practices and underwriting are relatively unchanged and in compliance with long standing internal policies. The credit risk rating system is accurate and effective, as evidenced by the lack of 

examiner initiated downgrades and a robust process in assigning and validating risk ratings. Client relationships 

are closely managed which allows for early detection of problem loans. A credit risk rating matrix is utilized to 

assign risk ratings tailored to the bank's various loan types. This matrix is comprehensive; however, it could be 

further enhanced to more directly consider the borrower's ability to reduce leverage for sponsor-led buyout loans. 

Credit File Documentation and Support 

Management has made significant progress to remediate the MRA for improving credit documentation. Additional information was noted within recent credit files, including key milestones, triggers, and timelines to 

track loan performance for pre-profit loans. Management is also in the process of developing enhanced enterprise 

valuation reports with additional narrative and support for key assumptions. Examiners noted that file support 

could also be enhanced with documentation of management's review and acceptance of the enterprise values 

upon credit origination. Tangentially, when credits have significant financial deterioration, documentation could 

be strengthened with analysis as to whether the valuations remain accurate and reliable. The remediation plan to 

BOG-FRS - Public Release, April 2023
fully address all portions of the MRA is reasonable and new processes are expected to be presented to internal 

audit for validation during the third quarter of 2017. 

Internal Credit Review 

The internal credit review function is effective and provides an independent review of the loan portfolio. Advisory comments from the prior examination regarding independence of the lending function have been 

addressed, and other enhancements to strengthen credit review processes are in process. 

Investment Portfolio 

The quality of the investment portfolio remains satisfactory. Overall credit risk in the portfolio is minimal as the 

$20.4 billion investment portfolio predominantly consists of U.S. Treasury and mortgage-backed securities. Further, management focuses on controlling market risk by maintaining low portfolio duration. 

Mortgage Lending 

The mortgage lending program is satisfactory. Policies, procedures, underwriting criteria, and ongoing monitoring processes are acceptable. Loans are provided to private bank customers who generally have high net 

worth and strong cash flow. Notably, there have been no material credit losses in this portfolio. 

Concentrations of Credit 

Concentrations of credit have moderated downwards and management oversight of concentration risk remains 

acceptable. Since the prior examination, the level of higher-risk pre-profit loans has declined from 223% of 

capital and reserves to 157%. Concentrations levels were furthered diluted due to increasing capital. In addition, there were significant increases in lower-risk private equity and venture capital loans which have historically reported low credit losses. 

Concentration guidelines remain acceptable. Internal reports used to monitor concentration activities are 

adequate and loan concentration levels remain well within board approved guidelines. Concentration reports 

include detailed schedules that present credit exposures by niche groups, product types, and service segments. Reports also compare current concentration levels against risk appetite thresholds. 

Allowance of Loans and Lease Losses (ALLL) 

The ALLL methodology and level are appropriate. The reserve methodology remains unchanged and is 

comprised of three segments which include the general reserve, the qualitative reserve, and specific reserve. Data 

and support for the three calculations are reasonable. Total reserves were relatively unchanged at 1.26% as 

compared to 1.29% of total loans during the prior examination. This level represents adequate coverage of 2.8 

times trailing four quarter gross losses and 3.0 times net losses. The MRA requiring appropriate identification of 

impaired and troubled debt restructuring has been remediated and was closed during the AQ Target. 

Insider Loans and Regulation O 

The supervision of insider loans remains acceptable with regards to requirements for maintaining insider loan 

terms on par with non-insider credits. However, there were apparent violations of Regulation O as a result of four 

BOG-FRS - Public Release, April 2023
overdrafts being paid on an insider checking account. The occurrences were limited to one account. Refer to the 

Violations of Law page for further information. 

EARNINGS - 2 

Earnings remain satisfactory and sufficient to support operations, adequately fund the loan loss reserve, and 

augment capital. The bank reported a return on average assets of 0.85% on net income of $274.4 million, which 

is higher than 0.76% on $223.8 million in the prior year. Income has benefited from a shift in earning assets from 

lower yielding investments to loans, which has boosted the net interest margin from 2.65% to 2.78%. The cost of 

funds remains low at 0.02% and all other expenses, including provision expenses, remain stable. 

Budgeting practices are satisfactory. The Bank's financial performance is tracking closely to the budget and the 

outlook for remainder of the year is stable. Continued growth and increasing fee income support favorable 

projections in 2017. 

LIQUIDITY - 1 

Liquidity levels remain strong and funds management practices are adequate. The Bank has substantial and 

reliable sources of on-balance sheet liquidity to meet present and anticipated funding needs. On-balance sheet 

liquidity is comprised of $19.8 billion which accounts for 46.4% of total assets. High levels of liquidity is made 

possible by a diversified deposit base, comprised largely of non-maturity core deposits, with the top 25 depositors 

making up only 10.3% of total deposits. 

The main sources of liquidity include an average of $754 million in cash flow per quarter from the investment 

portfolio, and $1.3 billion in deposits at the Federal Reserve. Secondary sources of liquidity are sufficient to 

support ancillary needs and support the level of off-balance sheet commitments. Total available off balance sheet 

liquidity include $17.3 billion in unencumbered security repo value, $1.7 billion in Federal Home Loan Bank 

borrowing lines, and $813 million at the Federal Reserve discount window. Additionally, the Bank has $1.5 

billion in unsecured federal funds borrowing lines with correspondent banks and $2.3 billion in repo lines. All 

lines are currently unused. 

Policy risk limits, liquidity stress test, and the contingency funding plan are appropriate. Policies ensure 

sufficient funding for both anticipated and unanticipated events, and also establish a liquidity buffer for 

unexpected liquidity stress events. Management has enhanced the contingency funding plan and stress testing practices to align with interagency guidance. 

SENSITIVITY TO MARKET RISK - 2 

Sensitivity to market risk is satisfactory. The balance sheet continues to be asset sensitive, which is attributable to 

a loan portfolio comprised predominantly of variable rate products and an investment portfolio with a low 

duration of 2.3 years. The Bank's internal model indicates net interest income (NII) would increase between 

15.5% and 46.7% for rate shocks between 100 basis points and 300 basis points. Economic Value of Equity (EVE) would also increase in all positive rate shock environments. To illustrate, a positive rate shock of 200 basis 

points would increase NII by $367.4 million and EVE by $1.8 billion. 

BOG-FRS - Public Release, April 2023
Other exposures from foreign exchange and warrant activities are well managed and present limited risk to the 

bank. Foreign exchange transactions are provided as a client service and risk is mitigated by immediate 

settlement on the spot market. Warrants obtained are sold to the holding company for fair market value, which 

effectively minimizes Bank risk. 

Policies and procedures arc adequate with the exception of certain areas that should be enhanced to ensure that 

policies and practices fully conform to regulatory guidance. Derivative counterparty credit risk exposures are not 

included in reports to the Asset Liability Committee or the Finance Committee as required by SR letter 11-10, Interagency Counterparty Credit Risk Management Guidance. Although ongoing monitoring of municipal 

securities is adequate, there are no formalized policies and procedures documenting the process as required by SR 

98-12. There were also several areas where interest rate risk (IRR) management did not fully align with the 

requirements of SR 10-1, Interagency Guidance on IRR Management. These items do not pose a significant risk 

to the institution, but should be addressed by management in order to fully align with all aspects of regulatory guidance. The MRA regarding enhancement of the compliance program will require management to fully align 

policies with all aspects of regulatory guidance. Refer to the Matters Requiring Board Attention section for 

details on required corrective action. 

The plan to implement a new IRR model in the first quarter of 2017 is expected to address many of the issues 

cited by examiners and fully align practices to regulatory guidance. Efforts have been on schedule; however, examiners noted that formal project management during the implementation of the IRR model would improve the 

likelihood that the new model is successfully deployed. 

EXIT MEETING WITH MANAGEMENT AND THE BOARD 

An exit meeting was held via teleconference on 12/14/16. Attendees on behalf of Bank management were Greg Becker, Chief Executive Officer, Michael Dreyer, Chief Operating Officer, Michael Descheneaux, Chief 

Financial Officer, Michael Kruse, Treasurer, Laura Izurieta, Chief Risk Officer, Redacted 

Marc Cadieux, Chief Credit 

Officer, Redacted 

. Representing the California Department of Business 

Oversight was Redacted , Examiner-in-Charge, Redacted, Asset Manager, and Redacted 

Redacted . Representing the Federal Reserve Bank of San Francisco were Redacted , Central Point 

of Contact, Redacted Credit Risk Specialist, and Redacted 

DIRECTORATE RESPONSIBILITY 

Each member of the Board of Directors is responsible for thoroughly reviewing this Report. Each Director must 

sign the Signature of Directors page, which affirms that he or she has reviewed the Report in its entirety. 

DBO Examiner-In-Charge (Signature) 

Redacted 

FRB Examiner-in-Charge Redacted 

DBO Redacted

Redacted 

FRB Redacted 

BOG-FRS - Public Release, April 2023
Compliance with Enforcement Actions 

Action Date 

Board Resolution 07/23/15 

SVB's Board adopted a Resolution to address the less than satisfactory condition of the information technology function. The bank is in compliance with all provisions; however, as noted previously, the Resolution should 

remain in place until the overall performance of IT is returned to a satisfactory condition. Provisions 6 and 7, not 

listed, refer to details regarding the Resolution. 

Board and Senior Management Oversight 

1) Resolved: The Board and senior management shall provide sufficient oversight, as appropriate, in all aspects 

of IT management. The Board shall direct senior management to submit, within ninety (90) days following the adoption of the Resolution, to the Reserve Bank and the Department a plan, with specific tasks, timelines, and responsible parties to address Board and management oversight weaknesses noted in the Report, including: 

a) Timely and effective execution of the ITSS Program; b) Stability of IT management, including the allocation of adequate resources and employment of 

qualified staff, and definition of roles, responsibilities, and expectations; c) Definition of roles, responsibilities, tasks, and timeframes as they apply to the IT Strategic Plan, and 

the establishment of reports and metrics to track progress; and 

d) Revision of policies, procedures, and standards, consistent with the corporate-wide policy framework managed by the Office of the Chief Risk Officer. 

Compliance - The Bank submitted an acceptable plan on August 27, 2015, and management is on track to 

accomplish the tasks outlined in the plan as scheduled. Key management positions have been filled. An IT 

Strategy Management Framework, which defines activities, deliverables, roles and responsibilities related to 

the IT Strategic Plan, was developed by management. The first quarterly IT Strategic Plan review was 

presented to the IT Steering Committee in the fourth quarter of 2015 and to the Audit Committee on January 20, 2016. All IT policies, procedures, standards, and guidelines have been updated or developed, and a 

process has been established to ensure policies and procedures are reviewed and updated periodically. However, while management has substantially completed all tasks necessary to comply with this provision, IT 

management is not yet considered stable until the Bank successfully executes the plans and demonstrates 

sustained performance. 

Compliance with Rules, Laws, and Regulations 

2) Resolved: The Board shall direct senior management to submit, within ninety (90) days following the 

adoption of the Resolution, to the Reserve Bank and the Department a plan, with specific tasks, timelines, and 

responsible parties to address all compliance deficiencies noted in the Report, including: 

a) Noncompliance with SR 11-9 - Interagency Supplement to Authentication in an Internet Banking Environment relating to the Bank's authentication tool; b) Noncompliance with Regulation II (Debit Card Interchange Fees and Routing); and 

BOG-FRS - Public Release, April 2023
c) Noncompliance with required vendor management processes pursuant to the FFIEC Supervision of 

Technology Service Providers Handbook, relating to the performance of a risk analysis and follow-up with respect to one of the Bank's key vendors, Redacted . 

Compliance - The Bank submitted an acceptable plan on August 27, 2015. Management has completed all the 

tasks set forth in the above plan. SVB is now in compliance with the applicable rules, laws, and regulations. 

Risk Management 

3) Resolved: The Board shall direct senior management to submit, within ninety (90) days following the 

adoption of the Resolution, to the Reserve Bank and the Department a plan, with specific tasks and timelines, to address all risk management weaknesses noted in the Report, including: 

a) Multi-factor authentication — the establishment and implementation of effective controls, identification of the root cause of all control breakdowns or failures, and identification of other tools 

currently in use and ensuring that they are properly set up and configured; and, b) Business continuity planning — the resolution of the issue identified by Internal Audit relating to the 

design of disaster recovery testing exercises; and reporting to the Board on the overall assessment and 

conclusion on the success of business continuity planning recovery exercises. 

Compliance - The Bank submitted an acceptable plan on August 27, 2015. The plan included completing the 

root cause analysis of control breakdowns, identifying current tools to ensure proper implementation and 

configuration, and completing disaster recovery testing by year-end 2016 when the migration to the new 

colocation facility in Dallas is completed. Management has successfully remediated the issues noted in this 

provision. 

Compliance with the Resolution 

4) Resolved: The Board shall oversee the remediation of the weaknesses as set forth in the Resolution in 

accordance with the plans as submitted by management, and hereby directs management to report on the 

progress of such remediation to the Audit Committee or the Board on at least a quarterly basis. Reports shall 

be documented in the Audit Committee or Board minutes and retained for future supervisory review. 

Compliance - The Board and senior management have provided the necessary resources to address IT 

weaknesses and continue to closely monitor actions taken to resolve the MRAs. Quarterly progress reports are 

provided to the Audit Committee and Risk Committee for their review. 

Other Provisions 

5) Resolved: Within forty-five (45) days after the end of each calendar quarter (March 31, June 30, September 

30 and December 31) following the adoption of the Resolution, the Bank shall submit to the Reserve Bank 

and the Department a written progress report detailing the status of compliance with each provision of the 

Resolution. In addition, each progress report shall include a description of any updates to the IT Strategic 

Plan and the progress of the ITSS Program. Such progress reports shall be continued until the Reserve Bank 

and the Department have released the Bank in writing. 

Compliance - The most recent progress report was dated November 14, 2016. 

BOG-FRS - Public Release, April 2023
Violations of Laws and Regulations 

California Financial Code Section 1362 

California Financial Code Section 1362 requires state licensees to comply with Federal Reserve Bank's 

Regulation O Section 215.4(e), which states: 

"(1) No member bank may pay an overdraft of an executive officer or director of the bank or executive officer or 

director of its affiliates on an account at the bank, unless the payment of funds is made in accordance with: 

(i) A written, preauthorized, interest-bearing extension of credit plan that specifies a method of repayment; or 

(ii) A written, preauthorized transfer of funds from another account of the account holder at the bank. 

(2) The prohibition in paragraph (e)(1) of this section does not apply to payment of inadvertent overdrafts on an 

account in an aggregate amount of $1,000 or less, provided: 

(i) The account is not overdrawn for more than 5 business days; and 

(ii) The member bank charges the executive officer or director the same fee charged any other customer of the 

bank in similar circumstances." 

Redacted has two accounts held jointly with Redacted Between December 2015 and 

March 2016, one of the accounts was overdrawn on four instances. Appropriate approval to extend credit to 

cover the insufficient funds was not in place during the time of the transactions. Funds were replenished by branch deposits, and not by a written, pre-authorized plan or funds transfer. Additionally, all instances were over 

$1M. As a result, the four overdrafts are apparent violations of law. 

Management Response: Management acknowledged the apparent violations and committed to reviewing 

processes in order to prevent future occurrence. The account was also closed. 

BOG-FRS - Public Release, April 2023
Examination Data and Ratios 

ASSET QUALITY ADVERSELY CLASSIFIED 

Substandard Doubtful Loss Total 

Loans and Leases 760,941 107,560 868,501 

Securities 

Other Real Estate Owned 

Other Assets 

Other Transfer Risk 

Subtotal 760,941 107,560 868,501 

Contingent Liabilities 150,952 1,443 152,395 

Totals at Exam Date 09/30/2016 911,893 109,003 1,020,896 

Totals at Prior Exam 09/30/2015 737,800 105,800 843,600 

Totals at Prior Exam 09/30/2014 747,295 8,993 756,288 

Exam Date Prior Exam Prior Exam 

09/30/2016/J 09/30/2015 09/30/2014 

Total Special Mention 364,508 246,100 248,811 

Adversely Classified Items Coverage Ratio 28.48 26.48 30.47 

Total Adversely Classified Assets/Total Assets 2.04 2.05 1.89 

Past Due and Nonaccrual Loans and Leases/Gross Loans and Leases 0.57 0.85 0.24 

Adversely Classified Loans and Leases/Total Loans 4.54 5.51 5.41 

ALLL/Total Loans and Leases 1.26 1.29 1.07 

CAPITAL Exam Date Prior Exam Prior Exam 

09/30/2016/J 09/30/2015 09/30/2014 

Tier 1 Leverage Capital/Average Total Assets 7.74 7.13 7.05 

Tier 1 Risk-Based Capital/Risk-Weighted Assets 12.77 12.79 12.11 

Total Risk-Based Capital/Risk-Weighted Assets 13.83 13.85 13.06 

Capital Category The capital category relates only to the Prompt Corrective Action W W W 

provisions of Part 325 of the FDIC Rules and Regulations. PCA Categories: 

W - Well-capitalized, A — Adequately capitalized, U - Undercapitalized, S - Significantly undercapitalized, C - Critically undercapitalized 

Period Ended Peer Period Ended Period Ended 

09/30/2016 09/30/2016 12/31/2015 12/31/2014 

Retained Earnings/Average Total Equity 11.20 4.98 10.71 12.00 

Asset Growth Rate 3.84 11.55 17.11 51.24 

Cash Dividends/Net Income 38.01 

EARNINGS Period Ended Peer Period Ended Period Ended 

09/30/2016 09/30/2016 12/31/2015 12/31/2014 

Net Income (After Tax)/Average Assets 0.85 1.01 0.76 0.80 

Net Interest Income (TE)/Average Earning Assets 2.78 3.37 2.65 2.88 

Total Noninterest Expense/Average Assets 1.81 2.50 1.77 2.04 

LIQUIDITY Period Ended Peer Period Ended Period Ended 

09/30/2016 09/30/2016 12/31/2015 12/31/2014 

Net Non-Core Funding Dependence New $100M (4.62) 14.90 1.15 4.29 

Net Non-Core Funding Dependence New $250M* (4.64) 12.50 1.13 4.26 

Net Loans and Leases/Assets 44.23 67.30 37.49 37.82 

*Ratio reflects time deposits exceeding the $250M deposit insurance limit as non-core funding; this data was not collected prior to 

March 31, 2010. 

BOG-FRS - Public Release, April 2023
Comparative Statements of Financial Condition 

ASSETS 09/30/2016 12/31/2015 

Total Loans and Leases 19,111,415 16,734,570 

Less: Allowance for Loan & Lease Losses 240,556 217,542 

Loans and Leases (net) 18,870,859 16,517,028 

Interest-Bearing Balances 2,023,540 890,315 

Federal Funds Sold and Securities Purchased Under Agreements to Resell 157,365 119,202 

Trading Account Assets 160,669 98,936 

Securities: Held-to-Maturity (at Amortized Cost) 7,791,949 8,790,963 

Available-for-Sale (at Fair Value) 12,647,836 16,360,270 

Total Earning Assets 41,652,218 42,776,714 

Cash and Noninterest-Bearing Balances 302,621 466,353 

Premises and Fixed Assets 44,515 36,454 

Other Real Estate Owned 

Direct and indirect investments in real estate ventures 

Intangible Assets 

Other Assets 665,120 775,718 

TOTAL ASSETS 42,664,474 44,055,239 

LIABILITIES 

Deposits 38,685,543 39,539,262 

Federal Funds Purchased and Securities Sold Under Agreements to Repurchase 135,000 

Other Borrowed Money 178,550 781,255 

Other Liabilities 348,260 492,327 

Subordinated Notes and Debentures 47,094 48,350 

Total Liabilities 39,259,447 40,996,194 

EQUITY CAPITAL 

Perpetual Preferred Stock 

Common Equity Capita! 3,405,027 3,059,045 

Includes net unrealized holding gains (losses) on available-for-sale securities. 

Other Equity Capital 

Total Bank Equity Capital 3,405,027 3,059,045 

Noncontrolling (minority) Interests in Consolidated Subsidiaries 

Total Equity Capital 3,405,027 3,059,045 

TOTAL LIABILITIES AND EQUITY CAPITAL 

42,664,474 44,055,239 

OFF-BALANCE SHEET ITEMS 

Unused Commitments 14,926,779 14,637,610 

Letters of Credit 1,650,069 1,464,938 

Other Off-Balance Sheet Items 117,873 59,519 

Other Derivative Contracts 3,145,787 2,974,431 

Appreciation (Depreciation) in Held-to-Maturity Securities 93,384 (32,342) 

Footnotes: 

BOG-FRS - Public Release, April 2023
Items Subject to Adverse Classification 

Includes assets and off-balance sheet items which are detailed in the following categories; 

Substandard Assets - A Substandard asset is inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral 

pledged, if any. Assets so classified must have a well-defined weakness or weaknesses that jeopardize the liquidation of the debt. They are 

characterized by the distinct possibility that the institution will sustain some loss if the deficiencies are not corrected. Doubtful Assets - An asset classified Doubtful has all the weaknesses inherent in one classified Substandard with the added characteristic that the 

weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions, and values, highly questionable and improbable. Loss Assets - An asset classified Loss is considered uncollectible and of such little value that continuance as a bankable asset is not warranted. This 

classification does not mean that the asset has absolutely no recovery or salvage value, but rather it is not practical or desirable to defer writing off this 

basically worthless asset even though partial recovery may be effected in the future. CATEGORY 

AMOUNT, DESCRIPTION AND COMMENTS Substandard Doubtful Loss 

LOANS 

845,204

CORPORATE TECHNOLOGY 

121,171

This represents the aggregate balance of 37 individual credits within the Corporate Technology portfolio. The 

classified credits account for 8.6% this portfolio and 14.1% of all classifications. 

2,123,893

LARGE CORPORATION 

74,934 14,776 

This represents the aggregate balance of 25 individual credits within the Large Corporation portfolio. The 

classified credits account for 12.5% this portfolio and 12.5% of all classifications. 

3,334,716

PRE PROFIT 

451,025 12,115 

This represents the aggregate balance of 446 individual credits within the Pre-Profit Portfolio, which includes 

Angel, Emerging Tech (ET), Early Stage, Mid Stage, and Late Stage borrowers. The classified credits account 

for 9.1% this portfolio and 53.3% of all classifications. 

2,285,989

SPONSOR-LED BUYOUT 

96,108 80,669 

This represents the aggregate balance of 32 individual credits within the Sponsor-Led Buyout portfolio. The 

classified credits account for 6.9% this portfolio and 18.1% of all classifications. 

845,419 170

OTHER BORROWERS 

This represents the aggregate balance of 69 individual credits that were classified as "Null" by the bank's internal 

system. The classified credits account for a nominal portion of this portfolio and all classifications. 

1,281,656

PRIVATE BANK 

786

This represents one credit within the Private Bank portfolio. It accounts for a nominal portion of this portfolio and 

all classifications. 

7,303,964 2

BOG-FRS - Public Release, April 2023
CATEGORY 

AMOUNT, DESCRIPTION AND COMMENTS Substandard Doubtful Loss 

PRIVATE EQUITY AND VENTURE CAPITAL 

This represents one credit within the Private Equity and Venture Capital portfolio. It accounts for a nominal 

portion of this portfolio and all classifications. 

815,679 16,745 

WINERY 

This represents the aggregate balance of 21 individual credits within the Winery portfolio. The classified credits 

account for 2.1% this portfolio and represent a nominal portion of all classifications. 

TOTAL ADVERSELY CLASSIFIED LOANS 760,941 107,560 

CONTINGENT LIABILITIES 

828,799 23,066 

CORPORATE TECHNOLOGY 

2,519,603 37,398 

LARGE CORPORATION 

252,987 422 

OTHER BORROWERS 

2,612,192 80,935 

PRE PROFIT 

239,867 

PRIVATE BANK 

7,793,726 48 

PRIVATE EQUITY AND VENTURE CAPITAL 

388,837 6,814 1,443 

SPONSOR-LED BUYOUT 

189,091 332 

WINERY 

TOTAL ADVERSELY CLASSIFIED CONTINGENT 149,015 1,443 

LIABILITIES 

TOTAL ADVERSELY CLASSIFIED ITEMS 909,956 109,003 

BOG-FRS - Public Release, April 2023
Concentrations 

Listed below are material direct and indirect asset and funding concentrations, according to the following guidelines: 1) asset concentrations of 25% or 

more of Total Capital (loan related) or Tier 1 capital (non-loan related) by individual borrower, small interrelated group of individuals, single 

repayment source or individual project; 2) asset concentrations of 100% or more of Total Capital (loan related) or Tier 1 capital (non-loan related) by industry, product line, type of collateral, or short term obligations of one financial institution or affiliated group; 3) funding concentrations from a single 

source representing 10% or more of Total Assets; and 4) potentially volatile funding sources that when combined represent 25% or more of Total 

Assets (these sources may include brokered, large, high-rate, uninsured, Internet-listing-service deposits, Federal funds purchased or other potentially volatile deposits or borrowings.) Any other concentrations may be listed in the 25% category if desired. An appropriate percentage of total assets is 

used when a bank's capita! is so low as to make its use meaningless. U.S. Treasury securities, obligations of U.S. Government agencies and 

corporations, and any assets collateralized by same are not scheduled. 

Percentage of Capital as of (as 

Life Stage Commitment As Percent of Total Capital of 7/31/15) Other $779,155 22% 47% 

Non-Niche $319,251 9% 7% 

Winery $1,004,770 29% 30% 

Large Corp $4,643,495 132% 139% 

Corp Tech $1,674,002 48% 43% 

Private Client Services $1,521,523 43% 3% 

Venture Capital $4,140,531 118% 60% 

Private Equity Finns $10,957,159 312% 282% 

Sponsor -Led Buyout (SLBO) $2,674,825 76% 83% 

Late Stage $2,019,201 58% 61% 

Mid Stage $1,933,157 55% 82% 

ET (Emerging Tech) $74,327 2% 2% 

Early Stage $1,886,609 54% 76% 

Angel/Seed Finn $33,613 1% 2% 

Grand Total $33,661,619 960% 917.0% 

* Figures represented in thousands, data as of 7/31/16. 

Concentration risk management and risk exposures are acceptable. Internal limits and guidelines are derived 

from evaluating the probability of default and loss given default for various segments of the loan portfolio, known 

as niches. Riskier segments have lower limits and vice versa. Notably, the Early Stage portfolio, which accounts 

for 66% of all losses since 2006, is well within the internal limit of 100% of Tier 1 Capital and Reserves. 

Exposure to higher risk borrowers continues to moderate. Early Stage loans have steadily declined as a 

percentage of Total Capital, and now represent 54% as compared to 76%. Mid Stage, Late Stage, and SLBO 

loans also represent a lesser portion of Total Capital at 55%, 58%, and 76%, respectively. While exposure to 

portfolios which have historically generated the majority of loss experience continue to decline, Venture Capital 

and Private Equity loans, which have had minimal losses, have been increasing and now nearly account for 45% 

of all commitments and 430% of total capital. 

BOG-FRS - Public Release, April 2023
Analysis of Earnings 

Comparative Statement of Income 

Period Ended 

09/30/2016 

Period Ended 

12/31/2015 

Period Ended 

12/31/2014 

Interest Income 887,027 1,050,551 892,380 

Interest Expense 5,697 6,124 12,648 

Net Interest Income 881,330 1,044,427 879,732 

Noninterest Income 241,528 279,906 222,993 

Total Noninterest Expense 582,035 711,783 635,451 

Provision for Loan and Lease Losses 88,687 97,677 60,272 

Securities Gains (Losses) 13,827 2 

Net Operating Income (Pre-Tax) 465,963 514,873 407,004 

Applicable Income Taxes 191,533 208,009 157,600 

Net Operating Income (After-Tax) 274,430 306,864 249,404 

Extraordinary Credits (Charges), Net 

Net Income (loss) attributable to bank 

and noncontrolling (minority) interests 274,430 306,864 249,404 

Less; Net income (loss) attributable to noncontrolling (minority) interests 

Net Income (loss) attributable to bank 274,430 306,864 249,404 

Other Increases/Decreases 

71,553 352,995 515,672 

Includes changes in the net unrealized holding gains (losses) on Available-ForSale Securities 

Cash Dividends 

Net Change in Equity Accounts 345,983 659,859 765,076 

Reconcilement of Allowance for Loan and Lease Losses 

Period Ended 

09/30/2016 

Period Ended 

12/31/2015 

Period Ended 

12/31/2014 

Beginning Balance 217,542 165,344 142,575 

Gross Loan and Lease Losses 71,466 51,022 42,885 

Recoveries 8,158 6,214 5,676 

Provision for Loan and Lease Losses 88,687 97,677 60,272 

Other Increases (Decreases) (2,365) (671) (294) Ending Balance 240,556 217,542 165,344 

Other Component Ratios and Trends 

Ratio Period Ended 

09/30/2016 

Period Ended 

12/31/2015 

Period Ended 

12/31/2014 

Net Interest Income (TE)/Average Earning Assets 2.78 2.65 2.88 

Total Noninterest Expense/Average Assets 1.81 1.77 2.04 

Net Income/Average Total Equity 11.20 10.71 12.00 

Net Losses/Average Total Loans and Leases 0.47 0.30 0.32 

Earnings Coverage of Net Losses (X) 8.54 13.67 12.56 

ALLL/Total Loans and Leases 1.26 1.30 1.15 

Noncurrent Loans and Leases/ALLL 

Footnotes: 

BOG-FRS - Public Release, April 2023
Composite Ratings Definition 

Safety and Soundness 

Composite - 2 

Financial institutions in this group are fundamentally sound. For a financial institution to receive this rating, generally no component rating should be more severe than 3. Only moderate weaknesses are present and are well 

within the board of directors' and management's capabilities and willingness to correct. These financial 

institutions are stable and are capable of withstanding business fluctuations. These financial institutions are in 

substantial compliance with laws and regulations. Overall risk management practices are satisfactory relative to 

the institution's size, complexity, and risk profile. There are no material supervisory concerns and, as a result, the 

supervisory response is informal and limited. 

Information Technology 

Composite - 3 

Financial institutions and service providers rated composite 3 exhibits some degree of supervisory concern due to 

a combination of weaknesses that may range from moderate to severe. If weaknesses persist, further deterioration 

in the condition and performance of the institution or service provider is likely. Risk management processes may 

not effectively identify risks and may not be appropriate for the size, complexity, or risk profile of the entity. Strategic plans are vaguely defined and may not provide adequate direction for IT initiatives. As a result, management often has difficulty responding to changes in business, market, and technological needs of the entity. Self-assessment practices are weak and are generally reactive to audit and regulatory exceptions. Repeat concerns 

may exist indicating that management may lack the ability or willingness to resolve concerns. The financial 

condition of the service provider may be weak and/or negative trends may be evident. While financial or 

operational failure is unlikely, increased supervision is necessary. Formal or informal supervisory action may be 

necessary to secure corrective action. 

BOG-FRS - Public Release, April 2023
Signatures of Directors 

We the undersigned directors of Silicon Valley Bank, Santa Clara, California, have personally reviewed the 

contents of the Report of Examination dated September 30, 2016. 

Signatures of Directors Date 

Gregory W. Becker 

Eric A. Benhamou 

David M. Clapper 

Roger F. Dunbar 

Joel P. Friedman 

Lata Krishnan 

Jeffrey N. Maggioncalda 

Mary J. Miller 

Kate Mitchell 

John F. Robinson 

Garen K. Staglin 

NOTE: This form should remain attached to the Report of Examination and be retained in the 

institution's file for review during subsequent examinations. The signatures 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. 

BOG-FRS - Public Release, April 2023
PRINCIPAL ABBREVIATIONS USED IN 

THIS REPORT 

Mtge Mortgage 

MV Market Value 

NP Notes Payable 

NPr Net Profit 

NR Notes Receivable 

NW Net Worth 

OA Other Assets 

OD Overdraft 

OL Other Liabilities 

ORE Other Real Estate 

P&L Profit and Loss 

Pfd Preferred 

P&I Principal and Interest 

PORE Potential Other Real Estate 

PV Par Value 

RE Real Estate 

REC Real Estate Contract 

SA Security Agreement 

SBA Small Business Administration 

SFR Single Family Residence 

SK Safekeeping 

S&B Stocks & Bonds 

TA Total Assets 

TCD Time Certificate(s) of Deposit 

TL Total Liablities 

TP Title Policy 

UCC Uniform Commercial Code 

VA Veterans' Administration 

Vs Versus 

WC Working Capital 

AP Accounts Payable 

AR Accounts Receivable 

AV Appraised Value 

CA Current Assets 

CG Continuing Guaranty 

CL Current Liabilities 

CM Comaker 

COM'L Commercial 

CPA Certified Public Accountant 

CSC Conditional Sales Contract 

CVLI Cash Value Life Insurance 

dba Doing Business As 

DPC Debts Previously Contracted 

DT Deed of Trust 

EG Endorsed and Guaranteed 

FA Fixed Assets 

FC Financial Code 

FDIC Federal Deposit Insurance 

Corporation 

F&F Furniture and Fixtures 

FHA Federal Housing Administration 

FRB Federal Reserve Bank 

FS Financial Statement 

IL Instalment Loan 

LC Letter(s) of Credit 

M Thousands 

MC Master Charge 

MM Millions 

Mdse Merchandise 

M&E Machinery and Equipment 

BOG-FRS - Public Release, April 2023