Inspection Commenced: December 4, 2017 

Inspection Concluded: March 22, 2018 

Financial Data as of: September 30, 2017 

 

 

 

 

 

 

 

 

 

 

 

 

RESTRICTED FR
 

REPORT OF
 

BANK HOLDING COMPANY
 

INSPECTION
 

BHC Name: SVB Financial Group 

Location: Santa Clara, California 

RSSD Number: 1031449 

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 1831m) 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. 

BOG-FRS - Public Release, April 2023
June 13, 2018 

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 (FRB) conducted a roll-up inspection of SVB Financial Group 

(SVBFG), using information as of September 30, 2017. The on-site portion of the inspection commenced 

on February 26, 2018, and concluded on March 22, 2018. A meeting was held with management1

 on 

April 4, 2018, to discuss the findings and recommendations. This letter constitutes the final report of 

inspection (ROI) for the 2017 supervisory cycle. 

SCOPE 

The company was inspected under the authority of Section 5(c) of the Bank Holding Company Act of 

1956, as amended. The primary objectives of the inspection were to assess and assign RFI (D) 

composite, component, and subcomponent ratings, which focus on risk management, the financial 

condition of the consolidated organization, and the potential negative impact of parent and nonbank 

operations on the sole depository institution, Silicon Valley Bank (SVB). Examiners also assessed the 

holding company's ability to act as a source of managerial and financial strength to SVB. In addition, the 

inspection scope included a review of the company's enterprise risk management (ERM) and corporate 

compliance programs. 

This inspection leveraged the work of the recent roll-up examination of the subsidiary bank conducted 

jointly by the FRB and the California Department of Business Oversight (CDBO) as of September 30, 2017. 

The inspection also leveraged other examination work and continuous monitoring activity conducted 

during the 2017 supervisory cycle, including the results of target examinations that focused on the 

following areas: 

Supervisory Event 2017 Rating Event Date 

Dodd Frank Act Stress Testing - SVBFG In Compliance, with findings 10/02/17 

Bank Secrecy Act (BSA) - SVB Less than Satisfactory, with findings 10/16/17 

Asset Quality - SVB Satisfactory, with findings 05/08/17 

Information Technology (IT) - SVB Satisfactory 02/27/17 

Throughout the ROI, the performance of SVBFG is compared to peer group averages of other bank 

holding companies (BHCs) of similar size and structure. The company's peer group included all bank 

holding companies having consolidated assets equal to or greater than $10.0 billion. 

1

 Meeting attendees: SVBFG Attendees: Laura Izurieta, Chief Risk Officer, John Peters, Head of Internal Audit, Redacted , Redacted 

Kamran Husain, Chief Accounting Officer, Redacted , Redacted , Redacted Redacted , Redacted, Redacted 

Suanne Mingrone, Head of Regulatory Relations, Redacted , Redacted , Redacted , Redacted, 

Redacted, Redacted ; CDBO Redacted Redacted ; FRB Redacted, Central Point of Contact, Redacted , 

Redacted 

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SUMMARY OF INSPECTION CONCLUSIONS 

The overall condition of SVBFG remains satisfactory, which primarily reflects the satisfactory condition 

of the depository institution. Risk management is satisfactory and supported by satisfactory ratings in 

board and senior management oversight, policies and procedures, and internal controls. However, risk 

monitoring and Management Information Systems (MIS) remains fair due to weaknesses in 

management’s ability to effectively identify and monitor key risks and vulnerabilities. The financial 

condition of the company remains satisfactory. All subcomponents are rated satisfactory with the 

exception of liquidity, which remains strong. The BHC and its nonbank subsidiaries pose a limited 

likelihood of significant negative impact to SVB. 

Risk management remains satisfactory. Management continues to refine risk management practices to 

address the growing complexity of the organization and meet heightened regulatory standards, and the 

Matters Requiring Attention (MRA) related to the development and initial implementation of 

compliance and ERM frameworks have been remediated. However, further improvement is necessary 

to ensure adequate risk identification and monitoring. The October 2017 bank examination cited 

weaknesses within the compliance and ERM functions with respect to risk oversight and effective 

challenge. As a result, risk monitoring processes may not provide management with sufficient 

information to identify and monitor key risks and vulnerabilities. Management is in the process of 

remediating the bank level MRA to improve the risk management framework, and ensure that the level 

of risk monitoring is appropriate for the size and complexity of the organization. The October 2017 Bank 

Secrecy Act (BSA) target also noted that while management has made significant progress to build out 

key functions to address weaknesses in monitoring processes, additional time is needed to fully 

implement effective program oversight and internal controls. As such, the Memorandum of 

Understanding (MOU) will remain in place until BSA deficiencies are fully remediated. 

The financial condition of the company is satisfactory. Consolidated asset quality is satisfactory and the 

level of adverse classifications remains manageable. Consolidated earnings continue to fully support 

operations, sufficiently fund the loan loss reserve, and augment capital. Consolidated liquidity remains 

strong as the firm maintains substantial and reliable sources of liquidity to meet present and anticipated 

funding needs. Consolidated capital remains satisfactory and sufficient to support the risk profile of the 

company. Management has made progress towards remediating the MRAs noted during the October 2017 

Dodd Frank Act Stress Testing (DFAST) review, which required better support and analysis of model 

methodologies as well as improvement in oversight and documentation of model risk processes. 

The potential of significant impact of parent and non-depository subsidiaries on the depository institution is 

limited. Management has enhanced risk monitoring processes for the tracking of investments held by the 

parent company to ensure compliance with applicable regulatory limitations. However, data storage and 

reporting tools rely on significant manual processes for both compilation and data verification. A new MRA 

is cited requiring management to implement a new investment tracking software system, and complete a 

third party validation to ensure the accuracy of investment data. Management committed to address this 

MRA by March 31, 2019. On a standalone basis, the parent company is in satisfactory condition with 

sufficient cash flow to fund operating expenses. Risk management of parent and nonbank activities is 

sufficient to mitigate impact to the bank, and the parent continues to provide financial and managerial 

resources to support SVB as needed. The company and bank remain in compliance with Regulation W. 

No Consumer Compliance or Community Reinvestment Act examinations were conducted during 2017. 

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BOG-FRS - Public Release, April 2023
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). BHCs 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 non-depository entities are 

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

The table below lists the composite, component, and subcomponent RFI/C(D) ratings assigned to the 

company at this inspection, as well as the ratings assigned at the two prior inspections. 

SVB Financial Group Current Prior Prior 

Inspection Inspection Inspection 

12/04/1 7 12/27/1 6 11/09/1 5 

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 2 

Internal Controls 2 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 2 2 2 

Subsidiaries on Depository Institution 

C - Composite Rating 2 2 2 

(D) - Depository Institution 2 2 2 

BOG-FRS - Public Release, April 2023
MATTERS REQUIRING ATTENTION2 

MRA - Investment Tracking Framework 

Issue: Management has developed a process to reliably and accurately gather investment information 

in a manner consistent with SR 16-113 guidance for risk monitoring and management information 

reporting. However, the data storage and reporting tools rely on significant manual intervention for 

both data compilation and verification. To address these concerns, management plans to implement a 

new investment tracking software system, and complete a third party validation of the entire 

monitoring framework. 

Required Action: Management is required to ensure the accuracy of investment data by completing the 

final steps of its project plan to fully implement and independently validate the investment tracking 

software system. 

Management Response: Chief Accounting Officer Kamran Husain, and Executive Vice President and 

Head of Internal Audit John Peters agreed to address the issue by March 31, 2019. 

SUMMARY OF NEW FINDINGS 

Matters Requiring Attention 

Expected 

Issue Main Category Sub Category Completion 

Date 

Investment Tracking Framework Management-Risk Monitoring and 3/31/19 Management MIS Issues 

2

 Supervisory follow-up may consist of MRIAs and MRAs. MRIAs arising from an examination, inspection, or any other supervisory activity are 

matters of significant importance and urgency that the Reserve Bank requires banking organizations to address immediately and include: (1) 

matters that have the potential to pose significant risk to the safety and soundness of the banking organization; (2) matters that represent 

significant noncompliance with applicable laws or regulations; and (3) repeat criticisms that have escalated in importance due to insufficient 

attention or inaction by the banking organization, (4) in the case of consumer compliance examinations, matters that have the potential to 

cause significant consumer harm. MRAs constitute matters that are important and must be addressed to ensure safe, sound and compliant 

operation, but the threat is less immediate and, therefore, may be addressed over a reasonable and specified period of time. Thus, the key 

distinction between MRIAs and MRAs is the nature and severity of matters requiring corrective action, as well as the immediacy with which 

the banking organization must begin and complete corrective actions. MRIAs and MRAs will remain open until resolution and examiners 

confirm the banking organization's corrective actions. 

3

 SR 16-11, Supervisory Guidance for Assessing Risk Management at Supervised Institutions with Total Consolidated Assets Less than $50 Billion 

< https://www.federalreserve.gov/supervisionreg/srletters/sr1611.htm>. 

BOG-FRS - Public Release, April 2023
SUMMARY OF OUTSTANDING FINDINGS 

Matters Requiring Attention 

Timeframe for Issue Main Category Status Comments Completion Date 

Risk Management Management-Risk Closed Required actions Closed during 

Management have been current inspection. 

completed. 

Compliance Program Management-Risk Closed A new MRA will be Closed during 

Management cited for investment current inspection. 

Tracking framework. 

Bank Secrecy BSA/AML Closed Required actions Closed during 

Act/Anti Money Issues Risk have been current inspection. 

Laundering (AML) Management completed. 

Model Risk Management - Risk Open MRM continues to Outstanding 

Management Management address outstanding 

MRA issues. 

Rationale & Support Capital - Capital Stress Open MRA was cited as 12/31/18 

of DFAST Framework Testing (DFAST) during the 2017 

DFAST target. 

RISK MANAGEMEN T - 2 

Risk management remains satisfactory. The board provides appropriate oversight over the company's 

business strategies and risk management practices, and the management team has demonstrated the 

ability and willingness to address weaknesses and correct deficiencies. Policies, procedures, and limits 

provide adequate coverage of risks inherent in the firm's significant activities. Internal controls are 

satisfactory with notable improvement within the IT function, and internal audit continues to provide a 

reliable and effective assessment of internal control processes. However, risk monitoring and MIS 

remains fair due to weaknesses in management's ability to effectively monitor key risks and 

vulnerabilities. While management has made progress in implementing effective compliance and ERM 

frameworks, risk management practices require further improvement to ensure sufficient risk 

identification and monitoring. Management has committed to remediate the MRA cited during the 

October 2017 bank examination to align risk management practices with SR 16-11 and ensure 

compliance with regulations, supervisory guidance, and internal guidance, as well as provide sufficient 

independent oversight to address the full range of risks for the institution. 

Corporate Compliance 

The compliance function has developed a framework to ensure that business units comply with internal 

policies, regulations, and regulatory guidance. Improvements since the prior inspection include a new 

organizational structure, supported by updated policies and procedures that more clearly define roles, 

responsibilities, and accountabilities. However, while management has addressed requirements of the 

compliance framework MRA, additional work is needed to implement the project plan for the build out 

and staffing of the function. Remaining tasks to be completed with respect to the corporate compliance 

project plan will be assessed through the risk management MRA that was cited during the October 2017 

bank examination. 

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The organization has also made significant progress on developing a reliable process to ensure that its 

many equity and warrant investments remain compliant with regulations. The compliance framework 

for monitoring investments has been strengthened; however, the data storage and reporting tools rely 

on significant manual intervention for both compilation and data verification. The bank’s project plan 

includes implementing new software to automate tracking and validating the process by a third party. A 

new MRA is cited requiring management to ensure the accuracy of investment data by completing the 

final steps of its project plan. Refer to the Matters Requiring Attention section of the report for details 

and required corrective action. 

Enterprise Risk Management 

The initial phase of the implementation plan for the new ERM framework has been completed. The roll 

out of the new risk and control self-assessment (RCSA) framework introduced enhanced procedures 

using standard taxonomies for operational risk, process, product, and control. The framework expanded 

the ERM universe from business units to include sub-divisions with unique risk characteristics, allowing 

management to analyze and assess process risk in greater detail. In addition, management developed a 

risk register to aggregate risk both horizontally by risk category groups and vertically by assessment 

units. Finally, the ERM function introduced a quarterly report which produces a synopsis of key cross‐

functional risk and risk themes identified as a result of RCSAs, audit findings, regulatory findings, and 

other risk assessment activities. The MRA related to the implementation of the risk management 

framework has been sufficiently addressed and is closed. However, as noted previously, further 

strengthening of oversight from ERM is necessary to ensure the effectiveness of risk identification, 

monitoring, and control. 

Board and Senior Management Oversight – 2 

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

management practices over the credit, liquidity, market, and legal functions. The board and 

management team have demonstrated the ability and willingness to address problem areas by providing 

sufficient resources and oversight to remediate deficiencies, as evidenced by the closure of seven bank 

and holding company MRAs during the 2017 supervisory cycle, and the return of the IT function to a 

satisfactory condition. However, examiners continue to identify weaknesses where risk management 

processes have not kept pace with growth, due to a lack of clearly defined roles and responsibilities for 

risk oversight and effective challenge. The risk management MRA cited during the October 2017 bank 

examination requires further strengthening of oversight from the Corporate Compliance and ERM 

functions to ensure that risk identification, monitoring and control processes remain effective. 

Corrective action will be verified during the roll-up bank examination in the fourth quarter of 2018. 

Policies, Procedures, and Limits – 2 

Policies, procedures, and limits are satisfactory. Management has established adequate policies and 

procedures to cover risks inherent in the firm’s significant activities, and limits are appropriately aligned 

with the risk appetite framework. The ERM Policy Office is in the process of improving governance, 

testing and monitoring processes for policies and procedures, and has established a roadmap to house 

all policies and procedures in a centralized repository to ensure consistency throughout the company. 

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Risk Monitoring and Management Information Systems – 3 

Risk monitoring and MIS remain fair. While management has successfully completed the initial phase of 

the implementation plan for the new ERM framework, risk management practices require further 

improvement to ensure effective risk identification and monitoring. The October 2017 bank 

examination identified weaknesses within the compliance and ERM functions with respect to risk 

oversight and effective challenge. As a result, risk monitoring processes may not provide management 

with adequate information to identify and monitor key risks and vulnerabilities. In addition, the current 

system of controls and risk monitoring does not sufficiently ensure compliance with policies, supervisory 

guidance, and regulations. Management is in the process of remediating the MRA cited during the bank 

examination to improve the risk management framework. 

Internal Controls – 2 

Internal controls remain satisfactory. The system of internal controls provides adequate coverage of the 

firm’s major risks and business areas. Internal control processes within the IT function have improved as 

weaknesses in the areas of E-Banking and Mobile Security have been remediated. Management also 

made significant progress to improve the BSA/AML internal control framework; however, additional 

time is required to ensure that updated processes are operating effectively. The internal audit function 

continues to provide a reliable and effective assessment of internal control, governance, and risk 

management processes. 

FINANCIAL CONDITION – 2 

Capital – 2 

Consolidated capital remains satisfactory and sufficient to support the overall risk profile of the 

company. The tier 1 leverage ratio, tier 1 risk-based capital (RBC) ratio, total RBC ratio, and common 

equity tier 1 capital were 8.34 percent, 13.32 percent, 14.29 percent, and 12.96 percent, respectively, as 

of September 30, 2017. Capital ratios have remained relatively stable since the prior inspection. The 

tier 1 leverage ratio continues to remain below peer levels due to the size of the investment portfolio 

relative to total assets. In December 2017, management redeemed $51.5 million in trust preferred 

securities. 

Capital risk management is adequate. Policies and procedures are adequate and include a capital 

contingency plan. SV&'’s stress testing framework and reporting continues to meet minimum DFAST 

guidance requirements. However, the October 2017 DFAST target cited a new MRA requiring better 

support and analysis of model methodologies and outcomes, including the overlay process. In addition, 

while management made efforts to remediate the prior model risk management MRA, oversight and 

documentation of model risk processes require further improvement. In addition, the October 2017 

bank examination cited an MRA to strengthen the capital planning methodology and detail how material 

risks are considered and documented in capital assessment and actions. Management committed to 

completing required actions by year-end 2018. 

Asset Quality – 2 

Consolidated asset quality is satisfactory and the level of adverse classifications remains manageable. 

Since the prior inspection, classifications have declined by $163.0 million to $913.0 million, or 

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20.5 percent of capital and reserves. The improvement in credit quality can be attributed to favorable 

venture capital investment conditions beginning in late 2016. Other credit quality metrics remain 

positive with net charge-offs declining from 0.5 percent of total loans since September 30, 2016, to 

0.3 percent. The level of past due and nonaccrual loans remains stable at 0.6 percent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Credit risk management remains satisfactory. Credit administration practices include acceptable 

policies, enhanced MIS reports, and an effective internal credit review function. Underwriting practices 

have not changed which provides stability in lending standards. Concentration risk remains 

considerable but has stabilized, as loan growth was primarily driven by inherently low risk categories 

such as capital call lending. The allowance for loan and lease losses (ALLL) methodology is appropriate 

and the level of the reserve remains appropriate. 

The quality of the investment portfolio remains acceptable. The investment portfolio, totaling 

$23.7 billion or 46.6 percent of consolidated assets, primarily consists of low risk U.S. Treasury and 

government agency securities. Risk monitoring of this portfolio is satisfactory, as evidenced by 

adequate pre-purchase assessments, sufficient monitoring, and appropriate committee oversight. 

Earnings – 2 

Consolidated earnings remain satisfactory. Earnings continue to fully support operations, sufficiently 

fund the loan loss reserve, and augment capital. Due to strong asset growth and a higher net interest 

margin, consolidated net income increased significantly from $283.2 million since the prior inspection to 

$373.3 million, for a return on average assets of 1.05 percent. The increase in the net interest margin 

was attributed to increasing interest rates resulting in higher loan and investment yields. 

Liquidity – 1 

Consolidated liquidity remains strong. The firm maintains substantial and reliable sources of liquidity to 

meet present and anticipated funding needs. Consolidated liquid assets, including $3.4 billion in cash 

and cash equivalents, provide ample coverage of projected cash outflows. Excess funding from deposit 

growth has been deployed to the bank’s investment portfolio which increased by 15.6 percent since the 

prior inspection to $23.7 billion. The investment portfolio, which includes $20.8 billion in unpledged 

securities, provides a significant source of contingent liquidity. Secondary sources of liquidity include 

unused, secure lines totaling $3.4 billion with the Federal Home Loan Bank, and $719.0 million at the 

FRB discount window. 

Consolidated liquidity risk management is adequate. The parent liquidity policy is adequate and 

includes appropriate limits. Stand-alone parent liquidity cash flow projections and stress testing results 

are regularly reviewed by Asset-Liability Committee and the board, and provide support for the current 

levels of cash held at the holding company. 

IMPACT – 2 

The bank holding company and its nonbank subsidiaries presents a limited likelihood of significant 

negative impact to SVB. On a standalone basis, the parent company remains in satisfactory condition. 

Risk management of parent and nonbank activities is sufficient to mitigate the impact to the bank, and 

the parent continues to provide financial and managerial resources to support SVB as needed. 

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Overall risk management practices of the parent and its nonbank subsidiaries are adequate. Board and 

management committee minutes reflect adequate oversight over nonbank activities, such as the 

strategic investing and funds management business. The parent company remains in compliance with 

all laws and applicable regulations, including Regulation W and DFAST requirements. In June 2017, the 

Board of Governors of the Federal Reserve System approved the company’s extension request to 

comply with the Volcker Rule. Management submitted a plan to achieve and maintain compliance with 

the Volcker Rule by July 2022, and will provide annual updates to the Board of Governors on their 

progress to divest $147.0 million in remaining ownership interests. 

Parent liquidity remains sufficient to meet ongoing capital and funding needs. As of September 30, 2017, 

the parent company reported $664.1 million in cash and securities, more than sufficient to meet 

obligations over the next 24 months. In addition, cash inflows, which now include bank-to-parent 

dividends, are projected to outpace cash outflows through the forecast horizon. The degree of leverage is 

manageable with a debt-to-equity ratio of 17.3 percent, a decrease from 20.7 percent reported at the prior 

inspection. The company’s long-term debt decreased further in December 2017 when management 

completed the redemption of $51.5 million in trust preferred securities. The double leverage ratio remains 

low at 93.14 percent. 

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DEPOSITORY INSTITUTION – 2 

The subsidiary bank remains in satisfactory condition. This assessment is based on the roll-up 

examination conducted jointly by the CDBO and the FRB as of September 30, 2017. Overall 

management remains satisfactory, as evidenced by the bank’s overall sound financial condition and 

progress made to implement corrective actions, and address prior examination findings. Capital remains 

satisfactory with levels appropriate for the risk profile of the bank. Asset quality is satisfactory, 

reflecting adequate credit risk management and a stable level of problem loans. Earnings are 

satisfactory, as net income continues to increase from higher yields and asset growth. Liquidity is strong 

with considerable on-balance sheet liquidity to meet funding needs. Finally, sensitivity to market risk 

continues to be appropriately managed. 

OTHER MATTERS 

BSA/AML and Office of Foreign Assets Control (OFAC) Compliance Program 

The company’s S!/!ML and O&! compliance programs have improved but remain less than 

satisfactory. The BSA supervisory report transmitted to the bank on January 17, 2018, noted that 

management has made significant progress in addressing prior deficiencies, including remediating the 

MRAs related to the risk assessment process4 and system implementation. However, additional time is 

required to fully implement effective program oversight and internal controls, as well as complete the 

development of a comprehensive OFAC program. As a result, the oversight and internal controls MRIAs 

and the OFAC MRA remain open. The MOU will remain in place until these deficiencies are remediated. 

Information Technology 

The IT target examination report transmitted to the bank on June 15, 2017, noted that IT has improved 

and is now satisfactory. Management successfully remediated the MRAs related to stabilizing IT 

management and improving processes for application implementation and maintenance. Cybersecurity 

and information security programs remain effective, and the bank remains in compliance with the 

Gramm-Leach-Bliley Act. The Board Resolution is no longer in effect as all provisions have been 

sufficiently addressed. 

4

 MRAs related to the BSA risk assessment process were cited at the parent company and the subsidiary bank in 2015. Both MRAs will be 

closed as weaknesses in the overall BSA risk assessment process have been fully addressed. 

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BOG-FRS - Public Release, April 2023
CLOSING COMMENTS 

After you have reviewed this report5 and within 45 days of receipt, please advise us of the actions taken 

or planned to address the MRA. Upon completion of your review, each director should sign the 

enclosed Signature of Directors page to acknowledge their review. This letter and the signed Directors 

page should be retained with the permanent records of the bank holding company. 

We welcome your comments or questions regarding this inspection or our general supervisory process. 

If you have questions about this report of inspection, please do not hesitate to contact me at 

Redacted 

Sincerely, 

Redacted 

Redacted 

Central Point of Contract 

cc: Greg Becker, Chief Executive Officer 

Suanne Mingrone, Head of Regulatory Relations 

California Department of Business Oversight 

Federal Deposit Insurance Corporation 

Consumer Financial Protection Bureau 

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 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 1831m) 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. 

BOG-FRS - Public Release, April 2023
 

 

 

Signature of Directors Date 

Greg W. Becker 

Eric A. Benhamou 

David M. Clapper 

John Clendening 

Roger F. Dunbar 

Joel P. Friedman 

Kimberly A. Jabal 

Jeffrey N. Maggioncalda 

Mary J. Miller 

Kate D. Mitchell 

John F. Robinson 

Garin K. Staglin 

 

 

 

 

 

 

 

 

 

 

 

 

 

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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 as of September 30, 2017. 

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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