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CALIFORNIA DEPARTMENT OF 

FINANCIAL PROTECTION AND INNOVATION 

FEDERAL RESERVE BANK OF 

SAN FRANCISCO 

2101 ARENA BOULEVARD 

SACRAMENTO, CALIFORNIA 95834 

(916) 576-4941 

101 MARKET STREET 

SAN FRANCISCO, CALIFORNIA 94108 

(415) 974-2000 

August 17, 2022 

Board of Directors 

Silicon Valley Bank/Silicon Valley Bank Financial Group 

3003 Tasman Drive 

Santa Clara, California 95054 

Dear Board Members: 

This letter conveys current supervisory ratings, the status of supervisory issues for SVB 

Financial Group (SVBFG or the "Firm”) and its subsidiary bank, Silicon Valley Bank (SVB or the 

“Bank”) based on supervisory work performed over the course of 2021 and first half of 2022. 

This assessment reflects the conclusions from firm-specific examination work, continuous 

monitoring, engagement or coordination with other regulators and meetings with 

management and directors. 

We delayed issuing the ratings for the 2021 supervisory cycle to account for the full onset of 

large bank supervisory expectations and to better assess the thematic root causes 

associated with the previously cited supervisory findings. This letter formally communicates 

the ratings we presented to the Firm’s board on July 21, 2022. While the Federal Reserve Bank 

of San Francisco (FRBSF) issues the LFI rating1

, CAMELS ratings covering SVB are issued jointly 

with the California Department of Financial Protection and Innovation (CDFPI). Most of the 

assessment used to support the ratings was based off examination work conducted jointly by 

the FRBSF and CDFPI. 

Executive Summary 

This is the first LFI rating to be issued to the Firm. The Governance & Control (G&C) rating is 

rated Deficient-1, while the Liquidity (L) and Capital (C) are rated Conditionally Meets 

Expectations and Broadly Meets Expectations, respectively. Many of the governance and risk 

management related matters, which drove the Deficient-1 rating, are detailed in the 

Governance Examination supervisory letter issued on May 31, 2022. In the time leading up to 

SVB crossing the $100 billion consolidated assets threshold, the firm experienced significant 

growth but did not maintain a risk management function commensurate with the growing size 

1 12 CFR 225.2 and SR Letter 19-3/CA 19-2, Large Financial Institution (LFI) Rating System. 

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and complexity of the firm. It is imperative that the board of directors and management work 

diligently to remediate these important deficiencies. 

The Deficient-1 (D-1) rating assigned for SVBFG’s Governance and Controls and the “Fair” 

ratings assigned for SVB’s Management and Risk Management indicate operational 

deficiencies in practices or capabilities that put the Firm’s prospects for remaining safe and 

sound through a range of conditions at significant risk. In addition to the findings centered in 

first line business units, such as information technology, information security, corporate 

compliance, and treasury, the recent Governance Examination also identified thematic, root 

cause deficiencies related to ineffective board oversight, the lack of effective challenge by 

the second line independent risk function, insufficient third line internal audit coverage of the 

independent risk management function, and ineffective risk reporting. While the board and 

executive management have started many projects to address these issues, the deficiencies 

are not correctable in the normal course of business. We will evaluate the corrective actions 

the Firm will be implementing in response to the Board Effectiveness and Risk Management 

Program MRIAs cited in the previously referenced Governance Examination supervisory letter. 

The Conditionally Meets Expectations (CME) rating assigned for SVBFG’s Liquidity Risk 

Management and Positions indicates that certain, material financial weaknesses in practices 

or capabilities may place the Firm’s prospects for remaining safe and sound through a range 

of conditions at risk if not resolved in a timely manner. Key liquidity risk management 

deficiencies, identified in the Liquidity Target Examination supervisory letter issued on 

November 2, 2021, include internal liquidity stress testing design weaknesses, such as the lack 

of deposit segmentation, the lack of differentiation between market and idiosyncratic risk 

scenarios, and the lack of testing of the firm’s contingency funding plan. The examination also 

identified a lack of effective challenge by the second line independent risk function over the 

first line treasury business unit. SVBFG’s CME rating and SVB’s liquidity rating downgrade from 

“Strong” to “Satisfactory” are directly tied to the liquidity-related MRIA and MRAs highlighted 

in Exhibit B. Actions to correct liquidity issues are scheduled for completion within the 2022 

supervisory cycle. Failure to adequately address these findings will likely result in a more 

adverse rating. 

The Broadly Meets Expectations (BME) rating assigned for Capital Planning and Positions 

indicates that the Firm implemented practices to maintain sufficient capital levels based on 

the applicable supervisory guidance2

 at the time of our September 2021 Capital Target 

2

 The examination used the following supervisory letter guidance to support this assessment: SR 11-7, Guidance of Model Risk 

Management; SR 12-7, Guidance on Stress Testing for Banking Organizations with Total Consolidated Assets of More than $10 

Billion; SR 12-17, Consolidated Supervision Framework for Large Financial Institutions. 

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Examination, as well as assessing gaps to Regulatory Capital Rules3

 for Category IV firms as 

defined by the Federal Reserve Tailoring Rule.4 

Enforcement Action 

Shortly after issuance of this supervisory letter, the FRBSF and the CDFPI will initiate an 

informal, non-public, enforcement action, in the form of a Memorandum of Understanding 

(MOU). The MOU provisions reflect the Matters Requiring Immediate Attention cited in the 

previously referenced Governance Examination and Liquidity Target Examination supervisory 

letters. The enforcement action provisions are designed to hold SVBFG/SVB’s board and 

executive management accountable for addressing the root cause deficiencies contributing 

to ineffective governance and risk management. 

3

 12 CFR Parts 208, 217, and 225, Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, 

Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-weighted Assets, Market Discipline and 

Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule. 

4

 12 CFR Parts 217, 225, 238 and 252, Capital Planning and Stress Testing Requirements for Large Bank Holding Companies, 

Intermediate Holding Companies and Savings and Loan Holding Companies. 

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Under the LFI rating system, SVBFG is assigned the following ratings: 

Rating Component Current Rating 

Governance and Controls (G&C) Deficient -1 

Liquidity (L) Conditionally Meets Expectations 

Capital (C) Broadly Meets Expectations 

LFI Ratings Components 

Governance and Controls (G&C) - Deficient 1 

The G&C rating reflects our assessment of the firm's effectiveness in: (1) aligning strategic 

business objectives with risk appetite and risk management capabilities; (2) maintaining 

effective and independent risk management and control functions, including internal audit; 

(3) promoting compliance with laws and regulations, including for consumer protection; and 

(4) planning for ongoing operational resiliency of the firm. 

Board Effectiveness 

The board's oversight does not meet supervisory expectations. As noted in the Governance 

Exam supervisory letter, the board did not provide effective oversight of management's 

implementation of the LFI transition plan, or the execution of corrective actions needed to 

address the root causes for various issues cited from the prior and current supervisory cycles. 

The board committees did not sufficiently challenge management on the design and content 

of the risk information presented to directors. Risk management deficiencies, such as those 

identified through regulatory examinations or reviews performed by independent risk 

functions, have not been meaningfully considered in the Firm's incentive compensation 

program or executive officer performance evaluations. Lastly, the Firm's board lack members 

with relevant large financial institution risk management experience, and this attribute hinders 

the board's ability to provide effective oversight. 

Risk Management Program 

The Firm's risk management program is not effective. The current risk management 

framework is not comprehensive, does not incorporate coverage for all risk categories, and 

does not address foundational enterprise level risk management matters, such as risk 

acceptance, issues management and escalation protocols. While the Firm has recently hired 

several new senior officers with LFI risk management experience, these new members of 

senior management are in various stages of completing baseline gap assessments. 

Remediation plans to address the identified gaps will require time beyond the normal course 

of business. Executive management across all three lines of defense will need to demonstrate 

project management discipline to achieve an effective, holistic risk management program. 
       

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Lastly, the Firm’s risk reporting does not present information for effective decision-making 

within the context of why management should/should not accept the risks for the topic being 

presented. 

Internal Audit (IA) 

IA's coverage of risk management is less than effective. While IA has effectively covered 

certain functional areas, such as capital planning and Bank Secrecy Act compliance, IA 

missed several key areas relevant to the Firm’s LFI transition and foundational risk 

management. Despite indicators of deficiencies in second line independent risk management, 

IA did not provide sufficient coverage of this area in their 2020 or 2021 audit plans. 

Additionally, IA exhibited a slow and reactive approach to testing the effectiveness of the 

Firm’s LFI transition plan, risk management programs and functions, and integration of 

acquired entities, such as Leerink Partners. IA’s reporting to the Audit Committee does not 

align with guidance set forth under Federal Reserve Supervision and Regulation Letter 13-1 

Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing. Lastly, the 

Audit Committee did not effectively challenge IA senior management on matters related to 

sufficient IA Plan coverage or the substance of the reporting needed for the Audit Committee 

to fulfill its oversight responsibilities. 

Liquidity – Conditionally Meets Expectations 

The liquidity rating reflects our assessment of: (1) the governance and risk management 

processes used by the firm to determine the amount of liquidity necessary to cover risks and 

exposures and support activities through a range of conditions; and (2) the sufficiency of 

liquidity positions to comply with regulatory requirements and support the firm’s ongoing 

obligations through a range of conditions. 

While actual and post-stress liquidity positions reflect a sufficient buffer, the Firm lacks 

several foundational liquidity risk management elements. These missing elements may 

negatively affect the sufficiency of the Firm’s post-stress liquidity buffer. Notable elements 

that management must address include more granular deposit segmentation to produce 

effective modeling of deposit outflows during stress; more comprehensive testing of its 

contingent funding plan to assess the feasibility of funding options under stress; and more 

effective challenge provided by the second line independent risk function to ensure that the 

first line Treasury business unit has appropriately executed its liquidity risk management 

responsibilities. 

This rating is time-bound and dependent on effective remediation of the open supervisory 

issues. The specific conditions that the Firm must address are described in detail as part of the 

two MRIAs and four MRAs cited in the Liquidity Target Examination supervisory letter issued on 

November 2, 2022. 

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Capital - Broadly Meets Expectations 

The capital rating reflects our assessment of: (1) the governance and planning processes used 

by the firm to determine amount of capital necessary to cover risks and exposures, and 

support activities through a range of conditions; and (2) the sufficiency of capital positions to 

comply with regulatory requirements and support the firm's ability to continue to serve as a 

financial intermediary through a range of conditions. 

The Firm's actual and internal post-stress capital positions reflect a sufficient buffer to comply 

with applicable regulatory requirements and to serve as a financial intermediary through a 

range of conditions. Management has demonstrated effective governance and planning 

processes to determine the amount of capital necessary to cover the Firm's risks and 

exposures. This assessment is primarily based off the Capital Target Examination completed 

on October 1, 2021. We also considered the RCM reviews completed in the fourth quarter 2021 

and the first quarter 2022. During these RCM reviews, we noted the effective challenge that 

all three lines of defense applied to the Firm's dry-run capital plan submissions in advance of 

the first formal Capital Plan submitted to the Federal Reserve subject to the 2022 Horizontal 

Capital Review (HCR). The scope of this supervisory assessment does not include the 2022 

HCR - those results will be communicated through a separate letter on August 19, 2022. 

Depository Institution Ratings - CAMELS 

Under the Uniform Financial Institution Rating System, SVB is assigned the following ratings: 

Uniform Financial Institution Rating System Previous Rating 

April 5, 2021 

Current Rating 

June 30, 2022 

Composite Rating Satisfactory "2" Fair "3" 

Capital Satisfactory "2" Satisfactory "2" 

Asset Quality Satisfactory "2" Satisfactory "2" 

Management Satisfactory "2" Fair "3" 

Earnings Satisfactory "2" Satisfactory "2" 

Liquidity Strong "1" Satisfactory "2" 

Sensitivity to Market Risk Satisfactory "2" Satisfactory "2" 
       

 

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Capital – Satisfactory “2” 

SVB’s capital levels are satisfactory relative to its risk profile. Management has proactively 

monitored capital adequacy relative to internal goals and limits. Notable points supporting 

this assessment include: 

	 As the bank experienced rapid growth, the parent company issued over $7.5 billion in 

common and preferred equity during 2021. Proceeds from these issuances were used 

to maintain the bank’s capital ratios, most notably the Tier 1 leverage ratio, in line with 

internal goals. 

	 Management developed idiosyncratic stress scenarios to complement their use of 

stressed macroeconomic variables over a nine-quarter forecasted period. Outcomes 

from the internal stress tests were appropriately used to assess the sufficiency of SVB’s 

capital buffer through a range of conditions. 

	 SVB’s balance sheet structure mitigates some of the risks associated with its recent 

rapid growth. 64 percent of the bank’s total assets are in cash and fixed income 

securities, and 93 percent of the bank’s fixed income securities are in U.S. Treasuries 

and government agencies. 

Asset Quality – Satisfactory “2” 

SVB’s asset quality and credit administration practices are satisfactory. Notable points 

supporting this assessment include: 

	 Total and weighted adversely classified assets, measured in relation to tier 1 capital 

and reserves, were 10.62 percent and 2.20 percent, respectively, as of March 31, 2022, 

and have trended lower over the past several supervisory cycles. 

	 Loan growth has been centered in two lower risk products with historically low loss 

rates: (i) capital call lines of credit to private equity and venture capital funds and 

(ii) single family residential mortgages to higher net worth private banking clients. 

	 SVB’s Internal Loan Review function has effectively tested the accuracy of the first line 

business unit and second line independent risk's loan grading decisions. No adverse 

grading differences have been identified in the current and prior supervisory cycles 

Management and Risk Management – Fair “3” 

SVB’s management and board performance needs improvement and is less than satisfactory. 

Notable points supporting this assessment include: 

	 SVB’s board did not provide effective oversight of implementation of the Risk 

Management framework and execution of the LFI transition plan. This lack of oversight 

has resulted in management having to re-develop a Risk Transformation Project two 

years after their original LFI gap assessment and transition plan. 

	 SVB’s board did not hold management accountable for the thematic root causes 

contributing to the supervisory findings related to information technology, information 

security, liquidity risk management, and second line independent risk. 

	 SVB’s risk reporting used for management and board oversight does not sufficiently 

address all areas of risk to the bank nor does it provide an effective basis for decisions 

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on what risks should or should not be accepted. 

	 SVB’s third line Internal Audit did not provide sufficient coverage of the second line 

independent risk function in both its 2020 and 2021 audit plans. Additionally, the Audit 

Committee did not effectively challenge IA management on their decisions related to 

coverage of the LFI transition plan implementation and second line independent risk 

function’s execution of the Risk Management Framework. 

Earnings – Satisfactory “2” 

SVB’s earnings are satisfactory to support operations and maintain adequate capital and 

allowance for credit losses. Notable points supporting this assessment include: 

 The bank’s earnings are accretive to capital despite significant expenditures to build 

the necessary risk management infrastructure. 

	 Management has implemented strategies to decrease reliance on warrant gains and 

diversify revenue sources through gradual changes in the investment portfolio 

structure, increased foreign exchange service fees resulting from the bank’s increasing 

global footprint of its client base, and increased fee income from the planned growth 

in the private banking and investment banking business lines. 

Sensitivity to Market Risk – Satisfactory “2” 

SVB’s Sensitivity to Market Risk is adequately controlled with moderate potential that 

earnings performance or capital positions will be adversely affected. Notable points 

supporting this assessment include: 

	 Management has established a moderately asset sensitive balance sheet structure, 

and the bank has benefitted from the recent interest rate increases. Management has 

appropriately considered strategies to limit the impact of potential declining rate 

scenarios. 

	 Interest rate hedges implemented in 2021 have effectively mitigated the bank’s 

exposure to rising interest rates. Down rate mitigation strategies, such as loan pricing 

floors and receive fixed/pay floating interest rate swaps, are being presented through 

the existing governance committees and subject to effective challenge by the second 

line independent risk function. 

Composite Rating – Fair “3” 

SVB’s Composite rating reflects the supervisory concerns related to Management and Risk 

Management. The deficiencies referenced in the assessment of Management and Risk 

Management reflect weaknesses ranging from moderate to severe. Management may lack 

the ability or willingness to effectively address weaknesses within appropriate time frames. 

Financial institutions in this rating category require more than normal supervision as indicated 

by the nature of the corrective actions required for the various findings cited in the current 

and prior supervisory cycles. The MRIAs cited in the previously referenced Governance Exam 

and Liquidity Examination supervisory letters will be the basis for the informal enforcement 

action provisions that the FRBSF and CDFPI will issue. 

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Closing 

We request that this supervisory letter be reviewed by the board of directors. Additionally, 

the directors are to sign the Signature of Directors page (Attachment D) acknowledging that 

they have read and understood the findings contained in this letter. Please retain this 

acknowledgement in your files for future review by examiners from the Federal Reserve. At 

this time, no additional written remediation plans are required other than those to address the 

MRIAs cited in the previously referenced in the Governance Examination supervisory letter. 

Please send all supervisory correspondence from your institution in electronic format only, 

copying our centralized mailbox as a recipient at @sf.frb.org and 

CDFPI at @dfpi.ca.gov. 

Redacted Redacted Redacted

We appreciate the assistance received from your management team and staff throughout 

the year. As a reminder, this letter is the property of the Board of Governors and is furnished to 

directors and management for their confidential use under applicable law5

 as well as CA 

Financial Code 452. We welcome the opportunity to further discuss any aspect of this letter or 

our supervisory process with members of the board or management.6

 Should you have any 

comments or questions regarding this letter, please directly contact 

CDFPI nd FRBSF 

Redacted Redacted Redacted Redacted

5 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. 

6

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

appeals process as described in the Appeals Process and Board Ombudsman (Ombuds) Policy Statement (See also 85 Fed. 

Reg. 15,175 (March 17, 2020)). The Ombuds can provide assistance regarding questions related to the appeals process and claims 

of retaliation as well as assist in facilitating the informal resolution of a supervised institution’s concerns prior to the filing of a 

formal appeal. For more information about the Ombuds, please visit the Federal Reserve Board’s public website. 

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Sincerely, 


Redacted

Redacted

Department of Financial Protection and Innovation LFBO Dedicated Supervisory Team Lead 

Federal Reserve Bank of San Francisco 

By: 

Redacted

Enclosures 

cc: Greg Becker, Chief Executive Officer 

Redacted

FDIC 

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Attachment A - Other Applicable Ratings 

Depository Institution Ratings - Other Ratings 

Rating System Previous Rating 

(Date) 

Previous Rating 

(Date) 

Current Rating 

(Date) 

URSIT 2-3-2-2/2 

(6-5-19) 

2-3-2-2/3 

(2-11-21) 

2-3-2-3/3 

(2-18-22) 

Consumer 

Compliance 

2 

(10-21-16) 

2 

(1-2-19) 

2 

(6-21-21) 

Community 

Reinvestment Act 

Satisfactory 

(10-21-16) 

Satisfactory 

(1-2-19) 

Outstanding 

(11-29-21) 

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Attachment B – Open Supervisory Issues 

Outstanding Federal Reserve and CDFPI MRAs and MRIAs as of 6-30-22 

Issue 

Type 

Date 

Issued Issue Summary Source Event Comments 

MRA 6-24-22 

Governance of 

Corporate Compliance 

Monitoring and Testing 

2022 BSA/AML and 

OFAC Exam 

MRA 6-24-22 OFAC Sanctions Risk 

Management 

2022 BSA/AML and 

OFAC Exam 

MRIA 5-31-22 Board Effectiveness 2022 Governance 

Exam 

MRIA 5-31-22 Independent Risk 

Management 

2022 Governance 

Exam 

MRIA 5-31-22 

Internal Audit 

Effectiveness 

2022 Governance 

Exam 

MRA 11-19-21 

Consumer Compliance 

Change Management 

and Issues Escalation 

2021 Consumer 

Compliance Exam 

MRA 11-19-21 Consumer Compliance 

Risk Management 

2021 Consumer 

Compliance Exam 

MRA 11-19-21 Consumer Compliance 

Dispute Process 

2021 Consumer 

Compliance Exam 

MRA 11-19-21 

Fair Lending Program 

Compliance Risk 

Management 

2021 Consumer 

Compliance Exam 

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MRA 11-2-21 

Internal Liquidity Stress 

Testing 

Design 

2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRA 11-2-21 Deposit Segmentation 2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRA 11-2-21 Liquidity Limits 

Framework 

2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRA 11-2-21 Contingent Funding Plan 2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRIA 11-2-21 

Liquidity Risk 

Management Project 

Plan 

2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRIA 11-2-21 

Effective Challenge – 

Second Line Financial 

Risk Management 

2021 Liquidity Target 

Exam 

Factor 

considered 

in CME 

Liquidity 

Rating 

MRA 8-17-21 Loan Risk Rating System 

Granularity 

2021 Asset Quality 

Target Exam 

MRA 8-17-21 Governance of Lending 

Procedures 

2021 Asset Quality 

Target Exam 

MRA 5-3-21 

Internal Loan Review 

Risk Assessment Process 

2021 Asset Quality 

Target Exam 

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MRA 5-3-21 

First Line Credit Risk 

Management 

Roles and 

Responsibilities 

2021 Asset Quality 

Target Exam 

MRIA 2-11-21 Information Technology 

Asset Management 

2021 Information 

Technology Target 

Exam 

MRIA 2-11-21 

Vendor Risk 

Management 

2021 Information 

Technology Target 

Exam 

MRA 2-11-21 Data Governance 

2021 Information 

Technology Target 

Exam 

MRA 2-11-21 Data Protection 

2021 Information 

Technology Target 

Exam 

MRA 2-11-21 Technology Risk 

Management 

2021 Information 

Technology Target 

Exam 

MRIA 6-3-20 

Information Security 

Vulnerability 

Risk Management 

2020 Information 

Technology Target 

Exam 

MRA 6-3-20 Identity Access Risk 

Management 

2020 Information 

Technology Target 

Exam 

MRA 11-19-19 

Enterprise Risk 

Management Controls 

Monitoring 

2019 Information 

Technology Target 

Exam 

MRA 6-5-19 

Effective Challenge – 

Second Line Information 

Technology Risk 

Management 

2019 Information 

Technology Target 

Exam 

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Attachment C – Closed Supervisory Issues 

Closed Federal Reserve and CDFPI Issues During 2021 Supervisory Cycle 

Issue 

Type 

Date 

Issued Issue Summary Source Event Comments 

MRA 6-3-20 Audit Committee MIS 

2020 Information 

Technology Target 

Exam 

Issue 

Closed on 

2-11-22 

MRA 6-3-20 Governance of Disaster 

Recovery Planning 

2020 Information 

Technology Target 

Exam 

Issue 

Closed on 

2-17-21 

MRA 6-3-20 Information Technology 

Risk Taxonomy 

2020 Information 

Technology Target 

Exam 

Issue 

Closed on 

2-17-21 

MRA 6-5-19 Firewall Management 

2019 Information 

Technology Target 

Exam 

Issue 

Closed on 

2-17-21 

MRA 3-6-19 Model Risk 

Management 

2019 Full Scope Safety 

and Soundness Exam 

Issue 

Closed on 

5-3-21 

MRA 11-19-19 

Governance of Model 

Assumptions and 

Overlays 

2019 BHC Inspection 

Issue 

Closed on 

7-9-21 

MRA 6-3-20 Governance – Disaster 

Recovery Plan Testing 

2020 Information 

Technology Target 

Exam 

Issue 

Closed on 

8-6-21 

MRA 6-5-19 Information Security Risk 

Reporting 

2019 Information 

Technology Target 

Exam 

Issue 

Closed on 

8-6-21 

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Attachment D - Signature of Directors 


We, the undersigned members of the Board of Directors of SVBFG and Silicon Valley Bank, 

have personally reviewed the contents of the summary report dated August 17, 2022. 

Signature of Board Members Date 

Kay Matthews 

Greg Becker 

Eric A. Benhamou 

Elizabeth Burr 

Alison Davis 

Richard Daniels 

Joel P. Friedman 

Jeffery N. Maggioncalda 

Mary J. Miller 

Kate D. Mitchell 

Garen K. Staglin 

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