1

 FEDERAL DEPOSIT INSURANCE CORPORATION

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 MEETING OF THE ADVISORY COMMITTEE ON 

COMMUNITY BANKING

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 OPEN TO PUBLIC OBSERVATION

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 TUESDAY,

APRIL 13, 2021

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 The Board convened at 1:00 p.m. EST via

Video Teleconference, Jelena McWilliams,

Chairman, presiding. 

PRESENT:

 JELENA MCWILLIAMS, Chairman, Federal Deposit

Insurance Corporation

MARTIN J. GRUENBERG, Director, Federal

Deposit Insurance Corporation

ARLEAS UPTON KEA, Deputy to the Chairman for

External Affairs

 SHAZA ANDERSON, Member

MARK PITKIN, Member

PATTY MONGOLD, Member

JOHN WHARTON, Member

KENNTH KELLY, Member

SARAH GETZLAFF, Member

NEIL MCCURRY, Member

ANDREW WEST, Member

GILBERT NARVAEZ, JR., Member

BETSY JOHNSON, Member

STEPHEN HAYES, Member

MARGARET OLDNER, Member 

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 BRUCE LOWRY, Member

CINDY KITNER, Member

MIKE BOCK, Member

HAROLD HORVAT, Member

TERI MESSERSCHMITT, Member 

ALSO PRESENT:

 SHAYNA OLESIUK, Division of Insurance and

Research

 KRISTIE ELMQUIST, Dallas Region

FRANK HUGHES, New York Region

BETTY RUDOLPH, Minority and Community

Development Banking

SULTAN MEGHJI, Chief Innovation Officer

DOREEN EBERLEY, Division of Risk Management

Supervision

RAE-ANN MILLER, Division of Risk Management

Supervision

JOHN VOGEL, Division of Risk Management

Supervision

CHRIS FINNEGAN, Division of Depositor and

Consumer Protection

 JOHN ANDERLIK, Division of Insurance and

Research 

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 CONTENTS 

Introductory Remarks

Jelena McWilliams. . . . . . . . . . . . . . . . . 4 

Discussion of Local Banking Conditions

Members of the Advisory Committee. . . . . . . . .10

on Community Banking

Shayna Olesiuk . . . . . . . . . . . . . . . . . 106

Kristie Elmquist . . . . . . . . . . . . . . . . 111

Frank Hughes . . . . . . . . . . . . . . . . . . 112 

Update from the Minority Depository Institutions

Subcommittee 

Gilbert Narvaez, Jr. . . . . . . . . . . . . . . 130

Betty Rudolph. . . . . . . . . . . . . . . . . . 128 

FdiTech Update

Sultan Meghji. . . . . . . . . . . . . . . . . . 137 

Supervision Update 

Doreen Eberley . . . . . . . . . . . . . . . . . 164 

Rae-Ann Miller . . . . . . . . . . . . . . . . . 171 

John Vogel . . . . . . . . . . . . . . . . . . . 169 

G. Chris Finnegan. . . . . . . . . . . . . . . . 188 

Research Update: FDIC Community Banking Study and 

Agricultural Lending 

John Anderlik. . . . . . . . . . . . . . . . . . 213 

Closing Remarks 

Jelena McWilliams. . . . . . . . . . . . . . . . 242 

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P-R-O-C-E-E-D-I-N-G-S

 (1:04 p.m.)

 CHAIRMAN MCWILLIAMS: Good afternoon 

or good morning, for those of you on the West 

Coast. Welcome to this first meeting of 2020 of 

the FDIC Advisory Committee, I'm sorry, 2021, of 

the FDIC Advisory Committee on Community Banking. 

And thank you for making the time today to 

participate.

 A lot has happened since we met last 

October. Certainly I hope that you and your 

families are doing well, and I appreciate the 

time you dedicated to the last meeting and, 

again, this meeting as well.

 At the FDIC, we continue to focus on 

core safety and soundness principles, capital 

liquidity, and asset quality of our banks. We 

are pleased with our COVID response. In 2020 the 

bank regulators issued many rulemakings to ensure 

banks had the flexibility to support the economy 

in their communities.

 Though we're optimistic about the 

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economic outlook, we will continue to monitor 

economic conditions and the state of the banking 

industry and assess what is the appropriate 

regulatory response as we go forward.

 One of our primary focuses is to 

promote innovation and to create a regulatory 

environment that will make it easier for small 

banks to adopt new technologies and thrive in a 

rapidly changing and evolving environment.

 We have just hired our first Chief 

Innovation Officer to lead FDITech, Sultan 

Meghji. You will hear from him today. And we 

have already highlighted for you, but we will 

continue to talk about the FDITech initiatives.

 One of them is the rapid prototyping 

to replace call reports. And the second one is 

the proposal to create a standard setting 

organization to establish standards for due 

diligence of vendors and for the technologies 

they develop.

 We're also looking at innovation more 

holistically and whether or not we need 

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appropriate policy changes to remove barriers to 

innovation and how our banks utilize innovation, 

as well as we are focused on financial inclusion 

that has been frankly exacerbated by the 

pandemic, as well as the overall area of American 

competitiveness in making sure that our banking 

system remains the foremost banking system in the 

world. 

Before we get started on a lot of 

these topics, I would like to take a minute to 

welcome members of the committee who are here 

for their very first meeting.

 Mike Bock, CEO of Dairy State Bank in 

Rice Lake, Wisconsin. Harold Horvat, President, 

CEO and Chairman of Centreville Bank in West 

Warick, Rhode Island. Betsy Johnson, President 

and CEO of Solutions Bank in Forreston, Illinois. 

Cindy Kitner, President and CEO of Jefferson 

Security Bank in Shepherdstown, West Virginia. 

Bruce Lowry, President and CEO of Ireland Bank in 

Malad city, Idaho. Neil McCurry, Jr., President 

and CEO of Sabal Palm Bank in Sarasota, Florida. 

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Margaret Older, CEO of Stone Bank in Mountain 

View, Arkansas. Andrew West, President and CEO 

of Eagle Bank in Polson, Montana. And John 

Wharton, President and CEO of Yampa Valley Bank 

in Steamboat Springs, Colorado.

 While I wish I could welcome you all 

in person, I'm pleased we are having this 

important meeting, albeit electronically, and I 

look forward to our discussion today.

 So again, welcome, everybody. I will 

now turn the program over to Arleas Upton Kea who 

will serve as the moderator the today's meeting. 

Thank you.

 MS. KEA: Thank you so much, Chairman 

McWilliams. Before we begin with today's agenda, 

let me just ask, Director Gruenberg, do you have 

any comments or remarks that you would like to 

share with the members before we start?

 DIRECTOR GRUENBERG: Yes, Arleas, 

thank you. Let me just say a word of welcome to 

everybody, and thank you for taking the time 

today. I very much look forward to the 

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discussion we're going to have.

 I have to say, as I think back where 

we were a year ago, which was in the immediate 

aftermath of the pandemic's devastating impact on 

the economy, it seems to me we may have feared we 

would be in an even more severe situation today, 

a year later, than we actually are.

 And it seems to be a significant 

measure that community banks in particular have 

come through this period thus far in remarkably 

good shape. And you all have served your 

communities exceptionally well. And as I said, I 

very much look forward to your presentations 

today.

 And even though I think we have good 

reason for hopefulness looking forward, there 

clearly is still significant uncertainty and, I 

think, significant downside risk to the financial 

system that we need to be attentive to, most 

obviously in the area of commercial real estate 

in particular.

 So I think we have a lot to talk about 

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today. I very much look forward to hearing what 

you all are seeing in your local communities and 

local markets. And thanks again for taking the 

time to participate. Arleas, thank you.

 MS. KEA: Thank you, Director 

Gruenberg.

 We're going to start this afternoon by 

turning to the committee members for an update 

about their (Audio interference.) issues related 

to banking conditions in their individual 

communities.

 And then after that, we'll hear from 

the FDIC staff members as they will share their 

observations and touch upon items that likely 

will be relevant to the information that the 

committee members have shared.

 Then Shayna Olesiuk, Associate 

Director of our National and Regional Risk 

Analysis from our Division of Insurance and 

Research is going to cover some observations 

about the national economy and banking trends.

 We also have with us today Kristy 

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Elmquist, the FDIC's regional director from our 

Dallas region, and then Frank Hughes, the FDIC's 

regional director from our New York region, with 

us today. And they both will offer some local 

observations which we think will also be of 

interest to all of you as well.

 So at this time, I'd like to start our 

committee member discussion with Shaza Anderson,, 

the chief executive officer of Truststar Bank. 

Ms. Anderson will be followed by the other 

committee members.

 Ms. Anderson, you have the camera.

 MS. ANDERSON: Good afternoon, thank 

you so much Arleas. Can you guys hear me?

 MS. KEA: We can, yes.

 MS. ANDERSON: Thank you. It's great 

to be with you all. And thank you, Madam 

Chairman. And I'm really pleased to be leading 

the conversation and looking forward to listening 

to everybody as well. I hope that everybody has 

remained safe and healthy during this time.

 There is positive momentum in the 

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country in fighting COVID, and in our economic 

rebound. The greater Washington market is no 

exception. We live in a dynamic market with 

three jurisdictions, Virginia, Maryland, and DC, 

with each in their own state of readiness.

 However, commercial office vacancies 

remain very high, even though recent transaction 

prices have been near or at record highs. 

Businesses continue to be productive with most 

remaining at work from home default. Schools are 

reopening, and restaurants and businesses are 

beginning to return to fuller levels of activity.

 Our market is resilient. And having 

a workforce and economy anchored with the federal 

workforce via technology and services has helped 

to maintain some stability. Unemployment is 

steadily declining and is now around 5.7 percent.

 We continue to experience strong 

demand for our banking services and are 

forecasting strong growth for the fiscal year. 

Through Quarter One, our bank has achieved assets 

of $380 million. Remember, we opened a year and 

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a half ago.

 Since last quarter, we have had 

deposit growth of 164 percent and loan growth of 

217 percent, excluding PPP. We continue to 

process PPP applications, but demand for the 

program has slowed. We have also been fortunate 

not to have any charge offs during this time or 

past dues.

 I believe I mentioned the last time we 

were together that we acquired a mortgage 

company. We completed the integration and 

recently announced the branding of Truststar 

Mortgage. We have also entered the Maryland 

market and received our FDIC approval just 

recently on March 25th. Thank you, FDIC.

 We are seeing businesses and offices 

reopen while most people continue to work from 

home. The economy gets stronger every day with a 

confidence that things will continue to improve. 

I'm excited about the future and confident in the 

days to come.

 Thank you all so much. 

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MR. PITKIN: So good afternoon, all. 

I'm Mark Pitkin, President and CEO of Sugar River 

Bank, located in Newport, New Hampshire. We are 

a state chartered mutual institution founded in 

1895 with six branches spanning from the west 

central to the central part of the state.

 Current assets total $346 million. We 

provide hometown banking, primarily in small town 

environments, and our mission is to exceed the 

expectation of our customers.

 While the bank remains vigilant and 

focused on strict COVID-19 safety protocols for 

both customers and staff, the bank has called 

back all remote employees to the office. Working 

closely together, sharing ideas, and supporting 

each other on a daily basis has been, and will 

continue to be, a competitive advantage of the 

bank.

 Of all states, New Hampshire has the 

eighth lowest COVID-19 death rate per capita in 

the nation. As of April 19th, every Granite 

Stater 16 years of age and older is eligible for 

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the vaccine regardless of their residency.

 New Hampshire ranks first in the 

nature with 51 percent of New Hampshire residents 

receiving at least one dose. The national 

average is 36 percent. Likewise, 22 percent of 

residents are fully vaccinated which is also 

above the national average of 20 percent.

 The 2020 housing market was historic 

in terms of New Hampshire home sales. While much 

like 2019, the difference was the pandemic. 

However, the exploding market seemed to defy the 

crisis as single family residential unit sales, 

median price, and sales volume hit all-time 

highs.

 Sales far outpaced new listings and, 

as a result, inventory has hit its lowest point 

in at least 16 years. The medium price for 

single family residential properties in the state 

was $335,000, a 12 percent jump from the previous 

high of $300,000 which came just the year before 

in 2019.

 Overbidding on available inventory is 

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more common than not in this environment. With 

continued historically low interest rates and 

high demand, the bank's residential mortgage 

lending continues to be very strong with near 

record level refinance activity.

 2020 mortgage loan origination volumes 

increased a remarkable 86 percent over the volume 

in 2019. However, this robust finance activity 

has also contributed to the significant decline 

in the bank's net interest margin from 3.57 

percent at year end, 2019, to 3.19 percent at 

year end, 2020.

 The bank's investments, which also 

increased significantly by 31.7 percent year over 

year from 2019, has further contributed to the 

compressed margin due to decreasing reinvestment 

yields.

 Regarding small business lending, I am 

pleased to report Sugar River Bank's remarkable 

efforts in assisting local businesses that were 

faced with significant financial challenges due 

to the pandemic. We have originated $14.8 

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million in PPP loans to 379 small businesses 

saving 1,947 jobs as of March 31st, 2021.

 As a community bank, no loan request 

was too small. Our average loan was $39,000, 

ranging from a high of $578,000 to as little as 

$256. To date, we have accepted 191 forgiveness 

applications representing 5.4 percent of total 

PPP loans.

 On balance sheet liquidity range is 

very strong, bolstered primarily by increasing 

cash balances with continued strong consumer 

saving trends, multiple economic stimulus 

payments, and significant loan and investment 

cash flows.

 Cash balances as of March 31st, 2021, 

have increased 86 percent since year end 2020 and 

an astonishing 200 percent since year end 2019. 

The banks total assets have likewise grown by 4.3 

percent in the first quarter of 2021 and more 

than 12 percent since year end 2019.

 Despite the substantial asset growth, 

Tier One leverage remains strong at 13.7 percent. 

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As a mutual institution, the bank is well poised 

to accept continued deposits from our local 

communities.

 With that historically strong capital 

position, we ably stand to support future growth. 

However, I did receive a call from a local CEO 

who was concerned with continued regulatory 

flexibility in instances where Tier One leverage 

ratios have dropped below nine percent as a 

result of the unanticipated pandemic events.

 Sugar River Bank's asset quality 

remains strong. We have not had any borrowers 

requesting pandemic related loan modifications or 

deferrals since September 2020. Adversely 

classified assets to capital, non-performing 

assets, and delinquencies remain low.

 Our allowance for loan and losses 

remains more than adequate, ensuring future 

coverage of any latent credit losses stemming 

from the fallout of the pandemic.

 Our challenges continue to be managing 

a higher than average employee turnover, 

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addressing the ever-increasing complexities and 

costs of cybersecurity, and the technological 

expectations of consumers, and finding reasonable 

reinvestment opportunities for increasing cash 

balances.

 In conclusion, I thank you for 

allowing me the opportunity to share what's going 

on at Sugar River Bank in our market area and in 

the state.

 MS. MONGOLD: Good morning, for me 

it's morning. I know it's afternoon for you on 

the East Coast. But I'm Patty Mongold, President 

and CEO of Mt. McKinley Bank, a mutual bank in 

Fairbanks, Alaska.

 In 2020 Mt. McKinley Bank saw nearly 

19 percent growth in assets. We had a 34 percent 

growth in loans and a 21 percent growth in 

deposits. Our earnings out performed out budget, 

but that was primarily due to a robust mortgage 

activity. The mortgage side was the driver for 

the majority of our earnings. That (Audio 

interference.) 2021, but we do continue to see 

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strong margin compression.

 For an update on COVID-19, Alaska led 

the land and was the state to offer Corona virus 

vaccinations to anyone age 16 and older. At 

present, 27 percent of all eligible Alaskan's 

have been fully vaccinated. However, our alert 

level remains high for new cases.

 The state remains open. We have no 

restrictions on business operations and no mask 

mandates. Most organizations, however, are still 

holding their meetings virtually, or at least 

ensuring that social distancing can be 

maintained, and masks are being worn, primarily. 

Our hospitalization rate and death rate both 

remain low, which are all good things.

 Mt. McKinley Bank made 385 first round 

PPP loans for about $39 million. At year end, 

297 of those loans in the total amount $32 

million were still outstanding.

 The SBA forgiveness process remains 

slow, but it has improved quite a bit over the 

last few weeks. We have processed another 185 

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second round PPP loans for about $18 million. 

That's through March 2021. And we have several 

more sitting in our pipeline.

 We're closely monitoring our non-owner 

occupied commercial real estate loans, as we 

believe that this is an area of risk to the bank. 

But at present, our non-owner occupied commercial 

real estate portfolio has load delinquencies. 

The values are holding are holding steady and the 

cap rates are also holding steady. But we have 

adjusted our allowance for loan and lease losses 

to account for what we perceive to be an 

increased risk in that portfolio.

 The Alaskan economy is still showing 

the effects of the pandemic. Recently reported 

trends indicate the unemployment for the state is 

up 7.1 percent when you compare February 2021 to 

February of 2020.

 Crude oil prices, which drive much of 

the Alaskan economy, have gone up about 13.59 

percent which does mean more money in the state 

coffers from taxes. 

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Our inventory of homes for sale has 

hit an all-time low, due in large part from the 

increased movement in the military. We've had 

quite an influx of new military personnel. 

However, our overall population for the state has 

experienced a net loss due to outgoing migratory 

patterns.

 Tourism, that's an area of our economy 

that was hit hard by the pandemic. And at this 

time it remains to be seen what this season will 

bring. It has been compounded by a lack of 

cruise ships that are able to travel to Alaska, 

because the Canadian government has closed their 

borders both to cruise traffic as well as over 

the road travelers coming into the state.

 Hopefully, we'll see an increase in 

tourists flying into the state from last year. 

And most of our business customers in the tourist 

industry are guardedly optimistic.

 We continue to be concerned about 

providing a healthy, safe work environment for 

our employees and making sure that our customers 

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have the tools they need to be successful, 

whether that be with loans, or deposits, or 

buying a home, whatever their needs are.

 I appreciate the opportunity to speak 

to you today. And I appreciate the opportunity 

to participate on this committee. It's been a 

pleasure to be a part of it. Thank you very 

much.

 MR. WHARTON: Good morning, fellow 

community bankers. My name is PJ Wharton. I am 

in Steamboat Springs, Colorado. And I'm very, 

very pleased and honored to join such a wonderful 

group.

 Yampa Valley Bank was established 20 

years ago, and our mission is to put the 

community first. And if we flash back a year ago 

from now, it was really quite a scary time, and I 

think I speak for all of us. It was quite a 

scary time and one in which we were desperately 

worried about the future.

 Our ski area, Steamboat is a major ski 

area, so we are a resort community, very, very 

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heavily dependent upon our ski area. And it 

closed one month early. We lost two very, very 

key months in which we have folks flying in from 

all over the nation, all over the world for their 

spring breaks.

 So those last two weeks, four weeks to 

be total, put a great deal of stress on our 

community. The Yampa Valley Bank, in our efforts 

to lead, and following the FDIC and the Federal 

Reserve with PPP loans, again, as many of you, 

your communities and your bankers worked late, 

nights, weekends, holidays, et cetera.

 And for a bank that, again, a year ago 

we were $375 million, today we're at $469 

million. We were able to book 569 PPP-1 loans in 

four months of last year.

 So again, I'm sure I'm echoing the 

sentiment of all of you. It was very stressful, 

it was chaotic, but we got it done. And again, 

we received calls from business owners, 

restaurants, hotels, resorts, small businesses, 

contractors, et cetera. 

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And frankly, that was the silver 

lining to a horrible COVID crisis, is that 

community banks shined. Our bank, Yampa Valley 

Bank, did as many PPP-1 loans as our four major 

competitors combined. And I think for all of us, 

as community bank leaders, this really has been 

our opportunity to shine compared to the mega 

banks that really had 1-800 number or frankly 

referred customers our way to find their PPP-1 

loans.

 So in hindsight, as horrible as COVID 

has been, we are very, very grateful that we did 

not have any hospitalizations for any employees. 

Of course, we have had, you know, COVID 

positives, we've had people quarantined, et 

cetera. But thankfully, we have not had any 

hospitalizations in our community. Of 12,500 

people, we had a total of 20 deaths over the past 

year, most of those unfortunately in a retirement 

home.

 Back to the bank, again, similar to 

you, I think 2021 has been the most difficult 

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budgeting year we've ever established. With 

growth of 40 percent in the past 12 months, 

deposit growth of $150 million in the past 12 

months, it's been incredible to try to figure out 

how are we going to grow, if we will grow. And 

frankly, we budgeted our balance sheet to shrink 

in 2021. 

With a new administration and PPP-2, 

that has not occurred. And again, similar to 

you, we are up about seven percent year-to-date 

in terms of our balance sheet.

 PPP-2, we are projecting to be 

approximately 40 percent of PPP-1. And those 

dollars, coincidentally, are fee income, about 

$1.2 million, ironically. And it was not 

planned, but we funded our allowance for loan and 

lease losses approximately that exact same 

amount.

 Our allowance today stands at 2.2 

percent. We have not had any asset quality 

deterioration. We expected it probably the 

fourth quarter or first quarter of this year. 

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Thus far, that has not happened. And again, 

similar to your customers, our customers have 

been hoarding cash, been sitting on massive 

amounts of liquidity.

 We are hopeful, through a very busy 

summer for our resort community, with campers and 

other folks coming here to hike, ski, and fish, 

that some of that liquidity will be released.

 One other area that has been a 

concern, and an unintended consequence of the 

tremendous liquidity that's been provided by the 

stimulus and the PPP, has been the pressure on 

our leverage ratio.

 We're very grateful and glad that we 

have participated as a community bank in the 

leverage ratio for community banks. But I would 

really feel that this is an important item to be 

considered in 2021, as it has gone from 8 percent 

to 8.5 percent as a minimum. That pressure has 

not changed and, in fact, has increased in 2021 

due to the tremendous liquidity of the system.

 Overall, we are very, very excited as 

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we look forward. We are very grateful for the 

partnership with the FDIC. Madam Chairman, I've 

very pleased to announce, ironically, we just had 

our exit meeting with the FDIC for safety and 

soundness on Friday. We'll have our Board 

meeting this Thursday.

 And I'm very honored and pleased to 

present that the team was excellent. We view 

them as a partner, and we had wonderful 

conversations, a few debates, but overall the 

outcome was excellent for all parties involved.

 Overall, in conclusion, we're very, 

very pleased to be part of the FDIC, be part of a 

great community of bankers like you, and I look 

forward to meeting each of you in person 

hopefully in July. Thank you.

 MS. KEA: Thank you, PJ. Let me just 

check in. Ken Kelly is scheduled to be next. 

Ken, could you speak and let's see if we're ---

MR. KELLY: Yes. Can you hear me?

 MS. KEA: We have you. Thank you. 

Please go ahead. 

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MR. KELLY: Okay, great. I apologize 

for the technical difficulties. Let me say good 

afternoon and good morning to others, Madam 

Chair, and Director Gruenberg. Thank you all so 

much for convening this group in the way that you 

have. It has been a pleasure of mine to serve on 

this.

 And for those of you who I haven't 

met, I'm Kenneth Kelly. I serve as Chairman and 

CEO of First Independence Bank which is located 

in Detroit. We have been in business now for 51 

years. We were one of the positive outcomes of 

the 1967 riots in Detroit, serving predominately 

in the commercial market, residential market, and 

we also do commercial leasing.

 Many of the sentiments my colleagues 

have expressed are true for us in the Detroit 

market. We've been faced with challenges 

relative to now, challenges relative to 

residential mortgages, even though that is going 

up at this point in time. But I would say the 

outlook is still very positive and very bright 

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for us.

 So I won't get into the specifics of a 

lot of the hard numbers. But what I will tell 

you at a very high level is we are seeing many of 

the same trends that have been discussed by my 

peers. More specifically though, what is very 

positive, and Madam Chair, I want to give you 

some credit for this, is we're seeing a lot of 

interest in minority banking across this country.

 We had the announcement with Wells 

Fargo last March, before the pandemic, of an 

investment of $50 million coming into the MBI 

space. There's an announcement that actually 

just took place a few hours ago, the second phase 

of that investment is taking place into the MBI 

community. So we're very grateful to Wells.

 But there have been many other banks, 

such as Bank of America and many others, who have 

seen the need for MBIs having a foothold in 

reaching some of the capillary neighborhoods 

where many of the MBIs serve. So we're very 

grateful for that level of interest and the level 

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of supporting collaboration.

 I will tell you we are seeing the need 

for more collaboration to move forward in respect 

to the PPP. What we have seen in our polling has 

shown across not only the National Bankers 

Association but many of the other organizations 

like the Urban League, and the NAACP, that we did 

not see the fulfillment of the intention of PPP 

reaching into, really, the deepness of some of 

those communities.

 There are many reasons for that. I 

won't get into the details on this call. But 

what I do know is the efforts that we are seeing 

inside of the FDIC to look at standing up a fund 

to create support creates more capacity for 

collaboration and partnerships to reach to these 

deeply needed areas in the community.

 So I just want to say again thank you 

to Madam Chair for the efforts and pushing in 

that regard and helping corporates come to the 

area of ensuring that there is equality and 

inclusion in our financial system. 

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At a higher level, I would say again, 

I'll ask all of our colleagues to look at the 

data. I think anyone with a high level of 

education would understand that this data really 

demonstrates some of the disparities that we're 

seeing in home ownership across the country, and 

network across the country, et cetera.

 And I believe that we, as bankers, can 

take on a leadership role and make a big 

difference across the spectrum in tackling some 

of these long challenging statistics that show 

these disparities.

 So again, I bring you greetings from 

Detroit from First Independence Bank. And, Madam 

Chair, and Director Gruenberg, thank you so much 

for allowing us to have this opportunity to 

participate in this program.

 MS. GETZLAFF: I am Sarah Getzlaff. I 

am the CEO Security First Bank of North Dakota 

which is a $200 million bank in Central North 

Dakota. (Audio interference.) members that 

(Audio interference.) during that week peaked at 

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a 16 percent daily positivity rate.

 And we've dropped really quickly after 

that, and we've been under five percent since 

Christmas. And so our state has been very 

fortunate in that we have basically been really 

open since Christmas. And mask mandates ended in 

the middle of January.

 Schools have been open since last 

fall. In-person, some of them are even starting 

to unmask. We've had group sports, and bars, and 

restaurants, and everything has fairly reopened. 

And things really feel like they're getting back 

to normal here which hopefully will continue to 

spread across the country very soon.

 Overall, our loan portfolio is really 

clean, our ag Plus portfolio is doing really 

well. Government stimulus has definitely helped 

a lot. There's a really good crop in 2020. We 

haven't had a lot of moisture, rain or snow this 

winter so we're all a little worried about the 

2021 crop.

 Other areas of our economy, our 

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residential real estate portfolio is super 

strong. Our market is really strong, housingwise. On the commercial side, we're really 

concerned about the commercial market, because we 

have heard that a lot of businesses are going to 

keep people working from home long term. But 

like I said, overall our economy has been pretty 

well throughout COVID.

 As North Dakotans we get teased a lot 

about where we live, and the weather here and, 

oh, there's not much to do. But I heard person 

after person say it's been really good, a good 

time to be living in this area.

 And we have a lot of good help. 

Department of Commerce stepped up and did a lot 

of grants for shut-ins and owners of restaurants, 

because the hospitality industry as a whole. PPP 

loans are, of course, were a huge help. Last 

year we originated 160 of them, and since our 

economy has been slow we didn't think we'd do as 

many in the second round but we've actually done 

twice as many. We had 295 in this second round. 

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And of those 295, only a quarter of them are 

second jobs. Most of them have been first jobs 

to farmers which came about after the SBA changed 

the scheduling calculation which made more 

farmers eligible to apply.

 We also have the only state-owned bank 

in North Dakota, called the Bank of North Dakota. 

And they have sort of partnered with local 

community banks to offer additional one percent 

loans and other low interest rate loans to 

struggling businesses.

 They had required them to apply, and 

it does have to be paid back, for the most part. 

But that was really helpful. And through our 

local legislature, they also offered grants where 

they would help banks retroactively make interest 

payments that were made during COVID.

 And those interest payments went 

directly to our bank and to other banks in the 

state. And then we were able to refund money to 

our customers and help them, you know, with their 

cash flow which was huge. And so Bank of North 

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Dakota has been a huge help to us.

 And I think that kind of starts with 

interest in people owning a state-owned bank. 

I've had a lot of questions on it lately. And, 

you know, the effort has worked really well. 

They're really kind of the banker's bank in North 

Dakota. And I think that a banker's bank can do 

everything that Bank of North Dakota can do, for 

the most part.

 And they don't compete against us, 

they don't do any direct lending. They basically 

buy loans participations for us, and then they 

help us with loan programs that in other states 

community development entities offer or state 

agencies like the Department of Commerce might 

offer.

 And so I think that it's always great 

to be looking for a new way of doing things. 

Sometimes I think people are looking for this 

special charter or this special type of bank that 

will solve things that are a problem and they 

both sort of need that. It's actually already 

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being met or able to be met somewhere else.

 And so I just hope that, you know, 

some of these big companies where there's 

somebody looking for an ROC charter or maybe 

they're lobbying for a state-owned bank, really 

has, you know, the correct motive at heart and 

isn't going to put some sort of unnecessary risk 

on a banking system when the FDIC's charters are 

all tried and true charters.

 And I think that COVID proved more 

than ever that our banking system works really 

well and community banks especially are really 

strong. And they meet all the needs of our main 

street, and our communities, and there's really 

no need to mess with a good thing, in my opinion.

 Thank you for the time, and I really 

appreciate the opportunity.

 MR. MCCURRY: Hello, this is Neil 

McCurry with Sabal Palm Bank in Sarasota, 

Florida. It's an honor and privilege to meet 

everybody with the FDIC as well as my co-members 

of the Advisory Committee. 

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It's been a whirlwind of a year for us 

in the state of Florida at Sabal Palm Bank. And 

I'm pleased, as we sit here today, to tell you 

that, in our area, that most trends have improved 

significantly.

 Our unemployment rate has now dropped 

to where it was in pre-COVID levels, which is a 

very low rate. The housing market continues to 

be strong. Small businesses have by and large 

rebounded.

 Now, certain industries, hotels and 

restaurants, certainly had struggles through most 

of 2020. But with an uptick in tourism and the 

growing housing market, those sectors have done 

well, as the other businesses have.

 So as we sit here in the second 

quarter of 2021, you know, we feel very good 

about our outlook. That being said, a little 

over a year ago it was completely different.

 We, as a bank, started having COVID 

management meetings in February of last year. 

And as the days and weeks went on, we became 

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progressively concerned. Florida was severely 

hit during the last Great Recession. And I was 

concerned that we were looking at another 

scenario, Great Recession Number Two, and what 

the impact would be on our community, our 

businesses, individuals, and the banking sector.

 And we made a decision early on that 

we were going to be a leader when it had to do 

with COVID and supporting businesses. We didn't 

know what that meant, but we knew that we had to 

be out front.

 And I want to applaud the Atlanta FDIC 

Regional Office. I reached to them in early 

March of last year and asked them if we could 

have permission to proactively work with all of 

the bank's loan customers to modify their loans 

to interest only for all of 2020 with the idea 

that the businesses and the individuals would be 

better suited having some additional liquidity as 

we went into this crisis. They were outstanding 

to work with, and that program was very well 

received by our customers and the community as a 

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whole.

 We then, shortly thereafter, 

transitioned when we learned about the PPP 

program. We didn't know if it was a good 

program, or a bad program, but it was the only 

program. And we said we were all in on it.

 We completely restructured how the 

bank worked, working evenings, weekends, both 

ultimately to serve the customer. We were 

working through the middle of the night when 

there were the technology problems.

 And I feel extremely pleased that at 

this point we've provided over 1,500 PPP loans to 

businesses, small businesses in our local 

community, about $125 million worth of those 

loans. So we feel very proud that we've been 

able to accomplish that for the community.

 And we have also done, I think, a good 

job of reaching out to people in the community 

that were not only frustrated with other 

organizations that didn't have the same 

commitment to the program, but also to businesses 

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and individuals that were under banks, weren't 

sure about how to work through the program. We 

put on informational webinars throughout the year 

on how to apply for a PPP loan, how to do it 

specifically with Sabal Palm Bank.

 I want to mention to Mr. Kelly that we 

have, in Sarasota, an outstanding NAACP chapter 

with great leadership. And our bank and many 

other businesses worked hand-in-hand with them. 

And I think the whole community has made sure 

that everybody has been looked after during this 

crisis.

 We've noticed that, in the second 

round of PPP loans, our average loan size is 

approximately 30 percent of what it was the first 

time. Our first round it was loans that were 

approximately $90,000 average. And they're 

$25,000, $30,000, with loans down, in some cases, 

under $$1,000.

 And we actually continue to stay busy 

with the PPP loans. Because we are continuing to 

let our community know that they are available, 

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and we're here to help. And every day, we 

continue to have an active amount of new 

customers that need assistance.

 A surprising amount are first draw PPP 

loans, people that, for whatever reasons, did not 

receive a PPP loan in 2020. And we've helped 

them through that process as well and were glad 

and pleased to be able to help them as well.

 Certainly looking forward, we have 

some real concerns, cybersecurity, you know, the 

most recent events with Microsoft.

 We're learning, and I think that we 

need to continue to collaborate as an industry 

and regulators on how to protect the industry, 

the customers' information, everything involved 

that I think the challenge that every one of us 

has and need to partner together on and, again, 

continue to find ways to be innovative, to 

support the banking industry of the future.

 And with that said, I'll turn it back 

over. And thank you very much.

 MR. WEST: Hi, I'm Andrew West from 

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Eagle Bank in Polson, Montana. Eagle Bank is one 

of very few tribally-owned banks in the United 

States. We are $96 million in assets. We've 

been open for about 15 years. Our original 

mandate was to bank the underbanked and unbanked. 

And we continue to take that mission to heart 

today. We also operate as a state-chartered 

community bank, and we bank tribal members and 

non-tribal members as well.

 One of the interesting things that has 

happened during the COVID pandemic with Montana 

is that now that people have the opportunity to 

work remotely, there has been a tremendous influx 

of people moving from other places to Montana, 

particularly western Montana where I live and 

work.

 The results of this have been a 

housing shortage and increased mortgage amounts 

which has been very good for our bank. It's 

helped offset the reduced (Audio interference.) 

the margin (Audio interference.) compression 

resulting from the low interest rate environment. 

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But we are seeing cash offers on homes 

that are, I mean, essentially it becomes an 

option for people to buy homes. And this is 

driving the prices up to the point where Native 

Montanans can't really even afford a house 

anymore which is a little bit of an issue.

 These houses are being bought sight 

unseen, and construction costs are very high as 

well. When (Audio interference.) commercial 

activity it's moderate. And we, like everyone 

else, did a lot of PPP loans which I think helps 

not only our customers, but it also helps the 

banks. Because when the customers can continue 

to operate they are not, you know, they are not 

defaulting on their loans which also helps the 

banks.

 We are seeing a lot of multi-family 

construction in the larger, more urban parts of 

Montana, Bozeman, Missoula markets, Kalispell, 

those are all growing rapidly with a lot of new 

construction for a single family residence but 

also multifamily. 

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We're starting to see a comeback in 

the hospitality industry. The restaurants and 

hotels are doing better. Of course, the COVID-19 

forbearance agreements that we did for folks 

helped a lot and also the PPP loans. And Montana 

also had a Montana Board of Investments program 

that gave working capital loans where a portion 

was automatically forgiven by the state.

 So we are seeing a continual declining 

of consumer lending. This is primarily probably 

a function of our lobby is still closed. The 

tribe, the Confederated Salish and Kootenai 

Tribes, who own my bank, are very proactive and 

concerned about keeping people safe.

 And as such, they have supported me 

keeping the lobby closed on a single branch bank, 

so I can't lose anybody. So we just elected to 

be concerned and stay closed, which hasn't really 

affected our business negatively. We've had 

record years, like I'm sure, everyone has, large 

inflexible liquidity which gives us a lot of ammo 

to make loans. 

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With regard to agriculture, this is, 

in western Montana, agriculture is a declining 

operation, mostly because the price of real 

estate is so high that it makes it almost 

impossible for someone new to get into the 

business. And it makes it very difficult for a 

successful (Audio interference.) operation, 

because it just does not pencil.

 In eastern Montana agriculture is, 

they have had very little precipitation this 

year. And they're very concerned about drought 

activity. And then also there's been a spate of 

grasshoppers the last couple of years which 

really harms the crops. The government 

assistance though started to trickle down and is 

now helping the ag producers in the state.

 Overall, I'd say Montana typically 

lags the rest of the United States. Our 

unemployment is still low, around 3.8 percent. 

And, you know, overall the state's doing okay, 

outside of the fact that there's definitely a 

changing dynamic here. We have tons and tons of 

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people moving in, and as such, it's just changing 

the nature of this entire state, but primarily on 

the west side.

 Overall though, I think my outlook is 

cautiously optimistic. And I am hopeful that 

things will continue to rebound and that we will 

see a strong 2021. And thank you for the 

opportunity, I appreciate it.

 MR. NARVAEZ: Good morning to those of 

you on the West Coast, and good afternoon to 

everyone else. I'm Gilbert Narvaez, Jr. I am 

President and CEO of Falcon Bank.

 I'd like to thank Madam McWilliams, 

Chairman McWilliams, Director Gruenberg, Betty 

Rudolph, Arleas Kea, and the rest of the FDIC 

staff here today for the opportunity to 

participate and serve in the Advisory Committee. 

I'd also like to thank my fellow committee 

members for their time and efforts in 

participating today.

 Our bank is headquartered in Laredo, 

Texas, and we are celebrating our 35th year in 

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existence and we are fast approaching the $1.7 

million mark.

 We conduct a significant part of our 

business along the Texas/Mexico border. The 

bank's 17-branch footprint also extends into the 

south central Texas region which includes the San 

Antonio and Austin metropolitan areas.

 Our branches service communities that 

are comprised of predominately Hispanic 

population and also serve many customers in the 

low to moderate income areas.

 Being that Laredo is one of the 

largest ports of entry between the US and Mexico, 

international trade and transportation sectors 

continue to be very active and very important 

sectors of our operating environment. We are 

very grateful that throughout this pandemic, the 

international bridges have remained open for the 

international trade business.

 The local economy has improved to a 

level as close to business as usual as possible, 

with the exception of continued safety COVID-19 

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protocols which is pretty much the norm 

everywhere. The new number of COVID cases and 

hospitalization rates continue to decline to alltime low levels in our areas. This has been 

mostly attributed to the continuation of safety 

protocols and aggressive vaccination efforts.

 Percentages of the population in the 

areas we operate have received at least one dose 

of the vaccine ranging from 35 percent to close 

to 60 percent in some of the areas. I'm happy to 

report that over 75 percent of our bank staff is 

fully vaccinated. And we've actually had a very 

proactive approach in trying to get everybody 

vaccinated.

 Our customer and employee safety has 

always been of utmost importance to us. So we 

have fully opened up all the branches to normal 

hours. However, we continue to operate with the 

proper, safe social distancing protocols.

 We have only five percent of our 

workforce that is currently working, still 

working remotely. And that's from a high of 35 

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percent that we've had at the peak of the 

pandemic.

 Locally, in our areas, most grade 

schools have resumed in-person schooling. 

Universities and higher education programs still 

are being conducted in a hybrid model on campus 

and virtually.

 We continue to support our community. 

We continue to meet the banking needs of our 

customers. We continue to participate in the 

latest round of the PPP Program. The second, the 

most recent round has been about half of the 

dollars and the number of loan requests that have 

come in from the original round.

 So we continue to also assist the 

local food banks and other civic organizations on 

any pandemic-related relief efforts. So we've 

really been, we try to be one of the leaders also 

in the community to make sure that we are out 

there. We were the first economic responders.

 We continue also to assist our 

borrowers with the submission of the PPP note 

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forgiveness documentation to escalate, which has 

been a nightmare to some of our customers, you 

know, after the first round. But I think SBA has 

smoothed up the process now.

 Other areas and components that are 

being affected, earnings, our earnings at the 

bank have stabilized. But they still have been 

adversely affected from prior years. And that's 

a direct result of the further compression of our 

net interest margin caused by this zero interest 

rate environment.

 Liquidity continues to be plentiful, 

just like everybody else. Loan demand has slowed 

in most sectors but very competitive in those 

sectors with activity. So we're competing with 

the, you know, low rates. And we're competing 

also with fixed rate products that we've not seen 

in our banking career.

 Capital, we're strong and healthy 

despite the slight decrease in earnings. Our 

credit quality, we've seen a slight uptick of 

non-performing loans on some customers that are 

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struggling to get back on their feet. However, 

these trends are still far below our 

expectations, our earning expectations.

 Thank you for the opportunity to 

report on our local trends and conditions. I'd 

like to introduce our next scheduled committee 

member speaker, Betsy Johnson, President and CEO 

of Solutions Bank.

 MS. JOHNSON: Thank you, and good 

afternoon. I come to you from Illinois, land of 

Lincoln, Ulysses Grant, Ronald Regan, and don't 

forget the Fighting Illini which, I think, 

they're still licking their wounds from March 

Madness.

 So, like Gilbert said, Betsy Johnson, 

I'm in the middle of the list, so we might be 

half-way through, President and CEO of Solutions 

Bank. We're in northern rural Illinois and we've 

got locations in Forreston, Freeport, and Kent, 

two hours west of Chicago, about a quick half an 

hour from the Wisconsin's southern border.

 The history of our banks, two longNeal R. Gross and Co., Inc. 

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time banks brought back pre-Depression, two bank 

holding companies from '98 to 2014. We were 

merged with two charters and went to a service 

center with our core processor, Fiserv, due to 

changes in technology, cost of technology, and 

digital ranking services. And we also eliminated 

some shared employees we had between the banks 

due to, you know, continued regulatory 

obligations.

 And beginning in 2020, we just 

acquired a $100 million community bank with two 

more locations. And we merged those charters 

with our existing Forreston State Bank. And in 

September 2020, we branded with a name change and 

went through that process which is working out 

very well.

 We just recently announced another 

agreement to acquire a $120 million community 

bank with also two locations upon regulatory 

approval. And we'll merge those should 

everything be approved in first quarter of 2022. 

That puts us at seven locations in four very nice 

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counties in rural northern Illinois at about $407 

million.

 Solutions Bank is mainly an 

agricultural bank. We're gaining more in the 

commercial business area with those additional 

locations and larger communities. Our ag 

portfolio is about 90 percent crop farmers. So 

very little livestock.

 Land values, which, you know, are 

consistent with other bankers that I hear 

throughout the states, remain constant and, I 

think, at a very high level. It's a typical 

story, demand from the neighbors, a lot of 

generational farmers, of course, which is one of 

the reasons we felt we needed to grow the bank to 

keep up with our growing customers and to service 

them.

 Experiencing very little to no 

delinquencies, especially no delinquencies in the 

ag sector. And also another topic I know is 

carryover, we're seeing very little of that. Our 

customers are ag customers that have been, over 

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the years, become very sophisticated, not only 

with their equipment but handling of their 

commodities and products to be successful.

 COVID, like other banks, our staff has 

been extremely resilient as well as our 

customers, willing to be accommodated through 

appointments, drive through. They take advantage 

of the digital services, fortunately that we 

already had in place. And it's been then still a 

very successful year during 2020 for the bank. 

And we also look to continue that through '21. 

We anticipate moderate growth though.

 Communities in our area really didn't 

suffer financially as they did in other areas 

within our state. I can speak of Chicago which 

still seems to appear to be somewhat a ghost town 

compared to pre-COVID.

 Illinois struggled with a vaccine 

process. But as of the last several weeks, 

fortunately that has been made available to 

bankers as essential workers after a plea to our 

Governor. 

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We have people going, even retirees 

going up to Wisconsin borders to get that. So 

sorry about that. I speaking Wisconsin vaccines. 

But again, we do what we need to do and hope to 

get it done.

 State of Illinois unemployment rate is 

a high at 7.7, the last I have reported. A year 

ago it was just under four percent. State of 

Illinois itself has its own issues, you know, 

prior to COVID.

 Even though Illinois is still, well, 

it's still second to the state of big Texas in 

number of bank charters. Last report, I believe 

it was 396 charters in the state of Illinois, 

down approximately 13 percent. And I hear from 

brokers that number is going to continue to 

increase as a lot of acquisition mergers were 

held up due to COVID.

 State of Illinois still each year 

proposes their own bank, and I hope that never 

occurs. So as in the State of Illinois right 

now, I can't imagine them running a successful 

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bank as it is today. But that's probably not 

funded as State of Illinois.

 Examination processes though, our last 

state exam was held virtually and went very well. 

They have to utilize the FDIC's Connect. To 

thank you very much, because that is an excellent 

tool. A couple of years ago, our last FDIC exam, 

we were able to use the FIVE by Image Viewer for 

examinations of which we were a Beta 4.

 We had that opportunity, so I signed 

us up for our quarter. And I asked my staff if 

that was okay. And of course, fortunately, they 

said that sounded like a great idea. So our FDIC 

exam that we had, we went through that. And the 

examiner and both us, that was our first time 

using it, I hope it's still active and being 

used, it was fantastic.

 PPP loans were very much the same as 

other banks. Our numbers for PPPs from the time 

that it started, we did approximated 350 loans, 

$6.7 million, $4.8 million is still on our books. 

That equals to about 250 loans. 

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And the other, a very nice line item 

on many of our income statements was the income. 

So that was a very nice thing and helped, I 

believe, everybody out through 2020.

 Our PPPs ranged, I just want to 

comment about the associations. We were not an 

SBA lender, so we had to go through two different 

fintechs to be able to utilize that process. And 

every day was, we all know, it was different, 

things changed, especially when it first came 

out.

 Our bankers, our lenders were just 

amazing. The industry support through the 

associations, the 0IBA and the ABA, were 

extremely helpful. And like I --- I always tell 

everybody, bankers are problem solvers. And they 

reached out to other bankers, and it was just 

truly amazing. I'd like to see how that happens.

 Again, I think we are problem solvers, 

and I am glad to be on this committee. Chairman 

McWilliams, very pleased to tell you that I think 

have brought some great enthusiasm and energy to 

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your office. And I hope that's not only 

perception but a reality for the FDIC and your 

staff. I think they are wonderful, all that I 

have come into contact with.

 So I hope our -- our topics are 

sometimes dry, and the process regimented. So I 

appreciate your next attempt to lighten the mood 

in them. Thank you very much.

 MR. HAYES: Good afternoon. Can 

everybody hear me okay?

 MS. KEA: Yes, we hear you fine, thank 

you.

 I'm sorry, it does appear now that 

you've gone on mute, Steve?

 MR. HAYES: What, what now?

 MS. KEA: You're good.

 MR. HAYES: Okay, great. Again, thank 

you for this opportunity, Chairman McWilliams, 

and Director Gruenberg, and the staff for this 

opportunity. My name is, again, Steve Hayes. 

I'm President and CEO of Dakota Prairie Bank, 

located in central South Dakota. 

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I'd also like to reach out to our 

newest members who were just recently appointed. 

This is a tremendous group to be a part of. And 

hopefully, someday, we can all get together.

 Dakota Prairie Bank is third 

generation, family owned, established by my 

grandfather in 1906 with about $120 million, $125 

million in total assets, four locations. Three 

locations are in rural communities, populations 

of 500 to 800 people. And I would say we're 

probably 90 to 95 percent ag portfolio.

 Our main office is located just across 

the Missouri River next to our capital of South 

Dakota's Pierre. And that community is about 

25,000 to 30,000 people. But there is a nice 

diversity in the commercial and the consumer type 

lending. So that's nice compared to the other 

locations which, like I say, that's always been 

ag since inception.

 We talked a lot about COVID, and I 

think as mentioned about optimism but cautious, 

you know, we're seeing a lot of changes, some 

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positive changes moving forward here. All the 

staff, and our staff is back, back to work.

 And I think the majority of the banks 

in the state of South Dakota are open. And there 

might be a few that it's appointments only in 

drive-up facilities. But for the most part, 

we're open.

 I think overall it's going well. Our 

employees, I'd say the majority of our employees 

have had their shots and so forth. So really 

optimistic, but yet when I say that, I see 

there's an uptick of some COVID in that range, 19 

to 46, 47 year-olds. So hopefully the 

vaccinations continue on. And hopefully we can 

turn this around.

 You know, I mentioned earlier about 

the $120 million in assets. You know, part of 

the, a big part of the pandemic is obviously 

we've seen the increase in deposits and so forth.

 Well, for us, you know, we're talking 

about the PPP loans. Our first go around, PPP 

was targeted for our commercial. We did about $3 

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million at that time. And then a few months 

later we did the second round of PPP targeting 

the farmers and ranchers. And that's been over 

$6 million right there.

 And then there's the second draw of 

those PPP loans, you know, where they have to 

show a 25 percent decline in income from '19 to 

'20. So we're going to possibly see another $2.5 

million of second draw loans. So that's been a 

big part for us, is that the PPP loans, because, 

you know, our economy itself, the PPP loans, the 

government assistance, they have helped 

tremendously. They really have.

 Out here, we pretty much have the 

grain producers and the livestock producers. And 

our farm economy is going really well. I mean, 

we're seeing some nice changes in our equities. 

Our carry-over debt's been taken care of for the 

most part. You know, our livestock, obviously 

they've helped, tend to help as well. But, you 

know, it really has done very, very well. I 

mean, they really worked hard. 

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And as we're saying about resilient, 

they're really done a nice job. But it's helpful 

to have the government payments and so forth. 

But the commodity prices have really changed from 

a year ago. So we're excited about that.

 As far as our commercial activity, 

we're seeing improvement. But I just hope that, 

you know, is it going to tell, maybe six months 

to a year from now? Because a lot of them are 

using the PPPs, the grants from the state and so 

forth, to get through.

 So I'm hoping that this will start 

turning around in the restaurant and the hotel 

business here in South Dakota. Tourism, I think 

it's, we're seeing the uptick on bookings, 

especially out in the Blackhills, Mount Rushmore 

area. So that's really encouraging to see that.

 As far as our numbers, you know, we 

turned out fairly well. It's the same issues we 

talked before, liquidity, and managing our 

balance sheets, and margin compressions. Because 

right now there's such a tremendous competition 

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for, you know, the good quality of loans and 

trying to turn that cash into a little bit of 

return. So that's been a challenge.

 And I think the challenge moving 

forward is really just managing our balance sheet 

which is the same as we've heard before. And 

it's going to continue on.

 If there's one thing that I mention, 

and there was another gentleman that brought this 

up about our community bank leverage ratio, and I 

know that expired in March, I believe.

 You know, we just had our ALCO meeting 

this morning. And we were looking at the 

deposits coming in. And I see that more and more 

money is coming in from townships and counties, 

part of this last stimulus package. And so this 

is going to continue to grow, and grow, and grow.

 And I just, you know, that's a 

challenge. We need to, it is what it is, and 

we're excited to be a part of the community, and 

excited to help. That's what a community bank 

is, we're all aware of what we can do. But it 

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poses some challenges. And I'm just curious to 

see if the FDIC has looked at maybe extending 

that but, overall, pretty excited, pretty 

excited. I think, overall things are going well.

 I just want to conclude, for comment 

for Chairman McWilliams, in January of '21 we had 

a Safety Soundness IT and BSA all offsite. The 

crew from the Sioux Falls, South Dakota, office 

did a tremendous job. The communication, which I 

always say, both from the regulators and the 

bank, is number one. It needs to be there, and 

it was. It was really good. I mean, the 

communication was just super. They've been very 

accommodating.

 If there's one thing that I want to 

comment on, and you've heard that before, I know, 

and it was brought up at the last meeting in 

October, you know, offsite has worked really 

well. I was nervous about the process, but it 

really has worked well overall. It really did.

 But out here when you're looking at 

loans, sitting across a desk or a regulator, in 

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person would be very helpful. So I hope someday 

that we can at least get a part of our exam back 

to onsite.

 But overall, thank you. Our Sioux 

Falls crew, regulatory crew, did a fantastic job. 

So I appreciate that. That's about all I have. 

Thank you again for the opportunity to be on this 

Board. And I look forward to the rest of the 

meeting. Thank you.

 MS. OLDNER: Hello?

 MS. KEA: We hear you, Marnie.

 MS. OLDNER: Thank you very much. My 

name is Margaret Oldner on the schedule, but I do 

go by Marnie.

 I am very pleased and proud to join 

this committee. I thank you Chairman McWilliams 

and Director Gruenberg for joining us today and 

for including me in this discussion.

 I am the CEO and Director of Stone 

Bank, which is a $540 million Arkansas-based 

small business and ag bank.

 In addition, we originate about $100 

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million of government guaranteed loans annually 

and have a nearly $400 off-balance sheet 

portfolio of loans we service for others.

 This bank, although chartered in 1955, 

was bought by a group of people, private folks, 

in Mountainview, Arkansas, in 2009.

 At the time, the bank had dwindled to 

about $10 million in assets and was in a dying 

south Arkansas farm town where the population was 

moving away, as were business.

 So that bank, we really started over 

in 2009. I joined the bank in 2011. In 2015, we 

rebranded as Stone Bank and developed a growth 

plan to grow to a $500 million bank by 2020.

 We did reach that $500 million target 

before COVID hit, and then we kind of surged 

ahead to that $540 million rather quickly with 

the influx of deposits and with the origination 

of PPP loans.

 In the state of Arkansas, we've done, 

the banks have done about 84,000 loans totaling 

$4.7 billion. 

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At Stone Bank, we did almost 800 loans 

totaling about $70 million in PPP loans. And 

most recently, that included Schedule F loans to 

farmers, which I think has been very helpful to 

our farmers who do suffer from very tight margins 

anyway and with the pressures that have been on 

our poultry farmers in particular due to COVID, 

that was very helpful.

 In the state of Arkansas, I don't 

think we've suffered as significantly as other 

states as a result of the pandemic, but it has 

had an impact. 

Our economy was not shut down as 

strongly as in some places, and the trends 

recently have been very favorable.

 Right now, in the state of Arkansas, 

we have just over 1,600 active COVID cases. I 

think there's less than 200 hospitalized at this 

time.

 And the trend numbers are very good. 

And so, we hope that it stays that way and that 

things can open up more and more. 

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Like most banks, we are doing well. 

In the state of Arkansas, I think that we do 

outperform the nation as a whole when it comes to 

a return on assets and capital levels and 

earnings.

 And so earnings are strong for 

Arkansas banks this year and they are for us as 

well. Asset quality indicators are surprisingly 

good.

 I think Director Gruenberg mentioned 

that as well that that is a surprise. A year 

ago, we anticipated much more problems.

 We prepared a COVID-19 Impact Analysis 

and Plan among other things that meant we were 

moderating our growth rates and looking to 

preserve our capital and setting aside larger 

amounts of reserves for loan losses.

 We continued this approach through 

2/1/2021 but we still see no real significant 

signs of loan portfolio weakness.

 We are cautiously optimistic as well, 

but can't help but think struggling borrowers 

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will become more evident in the year ahead.

 We hope for continued regulatory 

patience and guidance, which has been so helpful 

over this past year as we continue to work with 

struggling businesses and farmers to get them 

through the post-COVID months and back on their 

feet.

 The cooperation between regulators, 

bankers, and borrowers could make a huge 

difference in the years ahead as we work to help 

our customers and communities through the postCOVID recovery period.

 In addition to the concerns that 

surround uncertainty at every level, we also are 

concerned about the fast pace of changing 

technology.

 We know that we are challenged to 

deliver services in a different way and that our 

customers do expect that.

 The pandemic accelerated that a good 

bit, but it was already on a very fast changing 

pace. 

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So as a community bank, we are looking 

at ways in which we can do that carefully, 

weighing the risks and the rewards.

 But there are so many fintech 

companies to work with. We're on Fiserv. I 

think about 71 percent of banks (video 

interference) Jack Henry.

 All of them are not known for being 

particularly nimble, and so as we try to deliver 

the types of services that consumers seem to want 

and need today, we do need the help of fintechs, 

but being able to vet them all is a very big 

challenge.

 We would love regulatory support and 

help in combining ways that we can do due 

diligence more in teams or in groups so that we 

can share that information with one another.

 We're also concerned about the ever 

growing cybersecurity threats, such as 

SolarWinds, Finastra, and Microsoft that we 

talked about earlier today.

 Managing fintechs is what I alluded to 

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as a concern for us and the threats to banks and 

consumers alike that are posed by special purpose 

charters.

 And we are hopeful that the trend at 

the state levels to designate special purpose 

charters does not take off and that the federal 

regulators will help us with that.

 I look forward to learning so much 

more from this committee. And again, I'm very 

thankful to be a part of it. I appreciate it 

very much.

 MR. LOWRY: Hello, my name is Bruce 

Lowry. I'm President and CEO of Ireland Bank in 

southeast Idaho, headquartered in Moab, Idaho, 

which is a small town just north of the Utah 

border.

 Our bank was founded in 1892 and we 

are currently the oldest state-chartered bank in 

the state of Idaho.

 We have $320 million in assets, 14 

branches, and about 108 employees. Five of our 

branches are located in communities where we are 

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the only financial institution, and so we're 

proud to be able to serve those kinds of 

communities.

 Historically, we've been an 

agricultural bank. Today, the agricultural 

sector represents about 25 to 30 percent of our 

portfolio.

 So we have diversified quite a bit in 

the last several years. Like everyone else in 

the last several months or a year, we've been 

dealing with COVID issues.

 We did have to have a temporary branch 

closure in one of our communities for about a 

week, week and a half, due to staffing problems 

because of COVID.

 We made it through that and worked 

through everything and now we're doing very well 

that way across our bank.

 I would just echo some of the comments 

that a lot of the peers here have made and the 

concerns that we have in our area center around 

the growth of our deposit base. 

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And the economy is doing very well in 

our part of the world. We're having difficulty 

with housing and continuing to try to find ways 

to help people find affordable housing and as 

we're having great population migration in Idaho 

and it's driving the cost of real estate fairly 

significant.

 We did do a lot of PPP loans, for us, 

anyway. We did around 270 of the first round PPP 

loans, $13.5 million of those.

 Second round is going to have a much 

higher number of loans, actually, which is a bit 

surprising, but a lot of that has to do with the 

Schedule F loans that others have mentioned.

 But the dollar volume is about half, 

is what we're seeing on average.

 I would just like to thank Director 

Gruenberg and Chairman McWilliams for having this 

forum for us and having the opportunity to serve 

on this committee.

 Two years ago, our western region, the 

San Francisco region, would do roundtable 

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discussions with CEOs and I really enjoyed those, 

participating in those, and having the chance to 

talk to FDIC staff about things that we were 

facing and the issues that we were seeing and at 

least letting them know how things are on our 

side of the desk.

 So with that, I look forward to the 

rest of the meeting and thank you very much.

 MS. KITNER: Good afternoon. My name 

is Cindy Kitner. I am the President and CEO of 

Jefferson Security Bank in Shepherdstown, West 

Virginia.

 I want to thank Chairman McWilliams 

and Director Gruenberg for your leadership and 

for this amazing opportunity.

 I appreciate your interest in hearing 

the successes and challenges that we as community 

bankers face every day, and appreciate all the 

work and efforts of all of the FDIC staff.

 Shepherdstown is located just across 

the state line from Maryland and with close 

proximity to Virginia. We are about 70 to 80 

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miles from Washington, D.C.

 Jefferson Security Bank was embargoed 

in 1869 and is the oldest operating corporation 

in the state of West Virginia.

 Our current asset size is just under 

$400 million. We have six locations, five of 

which are in West Virginia in the counties of 

Jefferson and Berkeley.

 These counties offer multiple banking 

options. Our share in recent unemployment levels 

of 4.2 and 4.9 percent, with growing populations 

and labor force participation rates that exceed 

the statewide and national averages.

 Our counties offer strong employment 

opportunities from a variety of small and midsized businesses as well as large manufacturing 

facilities and distribution centers that are just 

across the state line.

 Our sixth location is in Sharpsburg, 

Maryland, with a population of about 800. And in 

this case, we are the only bank in town.

 Many of our employees and others in 

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the area have begun the vaccination process and 

some have received their second dose.

 Our small businesses have done a 

remarkable job of adjusting during this pandemic. 

Some remained open throughout while others 

shifted to either online sales or carry-out 

options.

 Our local residents have the option to 

engage to their personal level of comfort with 

shopping or dining to full capacity, limited 

capacity, or with carry-out options.

 Our proximity to the 

Baltimore/Washington areas allowed some of our 

small businesses to expand their clientele during 

the pandemic, as many in the cities were looking 

for a close and safe getaway.

 We actively participated in the PPP 

lending with 325 loans in round one for a total 

of $15.4 million and an average of $47,000.

 Only 16 of those loans were over 

$150,000. So far, we have 157 round two loans, 

and about 30 percent of those are draw ones. 

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In total, when we factor in the 

increases for the round ones, we have originated 

a total of $24 million in PPP loans.

 We've remained focused on ensuring our 

small businesses that qualify have the 

opportunity for these loans, and we continue to 

see the recent activity with those loans.

 We all realize that this is a program 

that provided us a unique opportunity to support 

our small businesses, and like many others, we 

took that role seriously.

 We worked diligently with our 

customers to ensure an understanding of the everchanging rules.

 Financially, we've experienced the 

same trends as others with increased asset size, 

liquidity, and similar impacts on capital.

 We've also seen similar trends with 

our loan delinquencies. We will continue to 

focus on our allowance, our loan losses, and our 

capital loans.

 In the first quarter of this year, we 

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completed our compliance as well as our safety 

and soundness examinations.

 I appreciate the FDIC's efforts on a 

risk-based approach. I will say that it's not 

unusual for us to host a training team, but this 

training team was exceptionally large.

 We had a good bit of conversation, and 

I hope that it was mutually beneficial. I know 

that we certainly saw benefit, and the team did a 

great job.

 I want to quickly acknowledge the 

FDIC's academic challenge. Shepherdstown is home 

to Shepherd University, and one of my passions is 

working with our students.

 We currently have two interns, one 

undergrad and one grad student, both of whom have 

expressed career interest in community banking, 

which is very exciting to us.

 I also wanted to mention one 

regulatory matter, banking, and cannabis 

activities. I know this is not a new topic, and 

one that requires Congressional action, but this 

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is a growing concern for many of us in the area 

and others as the states proceed with 

legalization.

 This is not a matter of personal 

feeling or opinion, but a request for regulatory 

guidance to help ensure as bankers we are clear 

and consistent when faced with new customer 

activities.

 Thank you to Chairman McWilliams, 

Director Gruenberg, FDIC staff and others for 

your continued efforts on strengthening community 

banks.

 MR. BOCK: Good afternoon. My name is 

Mike Bock. I'm the CEO of Dairy State Bank in 

Rice Lake, Wisconsin.

 We are located up in Northwest 

Wisconsin, about 100 miles straight east of 

Minneapolis/St. Paul.

 Our locations are in a mixed market 

area. Down in our south side, we have some prime 

agriculture. We have some light industrial and 

some educational and medical centers. 

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And up in the north edge of our 

market, we are largely tourism, with lakes, 

resorts, lumbering. We do have some education 

centers and medical centers as well.

 When we started the COVID period, we 

were about a $515 million bank. We have now gone 

in excess of $650 million. 

Obviously, a lot of deposit growth 

taking place at that time, but we have not 

experienced the same level of loan traffic other 

than a lot of PPP work. Loans have been 

relatively flat.

 Wisconsin as a whole is fairing fairly 

well in the COVID challenges. Currently, 

statewide we have a 3.8 percent unemployment 

rate, which is almost back to the pre-COVID rate 

of 3.3 percent. So some positive trends going on 

there.

 Up north, we're still running about 5 

percent unemployment rate, but it's almost hard 

to believe at times because as we visit with our 

different businesses and industries around here, 

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virtually everyone is seeking help.

 And I think that is going to be one of 

our biggest challenges going forward for our 

business customers and businesses in even the 

summer months, is just finding the help they need 

to get their jobs done.

 COVID trends have been running pretty 

good up until last week. We had some negative 

trends as of late, still certainly within 

palatable levels.

 We have had lobbies open at all of our 

locations on a somewhat limited basis since last 

November, and we have had them open.

 We've had a few staff in and out with 

some quarantines, some positive tests, but 

overall, nothing serious.

 Current vaccination rates in the area 

are running about 15 percent, growing every day. 

Real estate prices in the area have been really 

interesting.

 It started on an upward trend early 

last summer, continued through the summer into 

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the fall, and it's being largely driven by people 

up in Minneapolis/St. Paul market.

 Those of you that watch the news, some 

dynamics in the Minneapolis/St. Paul market last 

summer, some of the rioting, et cetera, with the 

onset of working remotely and some of the 

challenges of the Minneapolis market, some of 

those folks have sought places on the lakes over 

here and they've relocated and they are starting 

to work remotely and just going to the Twin 

Cities on an occasional basis.

 So that's a great thing in terms of 

our area. We've got us some people. But it's 

obviously driving real estate prices. This was 

mentioned earlier by one of the people.

 It is getting to the point where it is 

hard for some of the local residents to buy a 

place that they can afford.

 And with our labor challenges, it 

becomes even more pronounced because affordable 

housing is almost a non-existent case right now.

 Construction costs continue to go up. 

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There have been some multi-family complexes that 

have tried to go up.

 They've run numbers and they're 

finding that the required monthly rental rate to 

make those things palatable is just not coming 

off very well, so that people in our markets with 

the employment that they're seeking is just not 

going to be able to afford that.

 So we're kind of in an interesting 

balance, challenged by COVID but at the same time 

most of our businesses are challenged by labor 

shortages while they still work through the 

challenges of COVID.

 2020, obviously, was an interesting 

year for everyone. Started out the COVID 

scenario, worst case scenario for everything and 

it turned out for some of our industries that 

they set new all-time records, both revenue, 

profit, right on down the line.

 Now it wasn't everybody that was that 

fortunate, hospitality, being bars, restaurants, 

hotels, those types of businesses, were 

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challenged.

 Bars and restaurants have bounced back 

relatively nicely but hotels continue to be 

challenged.

 We'll see how that changes as we move 

to the summer months and maybe people come on 

board to start heading back to northern Wisconsin 

again.

 Other areas that we've bumped into 

that has a few challenges is senior living 

facilities, not so much that they have occupancy 

issues or COVID issues, but we experienced some 

significant labor rate changes in that market 

around here, and most of those facilities, with 

the rentals that they do, take 12 to 18 months in 

order to adjust contracts for the residents that 

are there, to adjust for that.

 Delinquencies currently for us are in 

very good shape. We've got just a couple 

restructured loans that do exist in the hotel, 

restaurant, and senior living areas, but I think 

those are going to be coming back on a full 

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performance basis in the next couple months. So 

we're looking good from that standpoint.

 As we've talked to businesses as they 

finalize 2020 and receive financial statements, 

we're looking forward to 2021.

 Guarded optimism, I guess, the word I 

would say. A lot of positive things are 

happening but some of these businesses are 

starting to run into challenges on different 

fronts.

 Obviously, COVID still exists. I 

mentioned labor. We're running into a lot of 

supply chain issues over in this part of the 

country.

 Businesses that are trying to get the 

raw materials they need to get the products done 

and out the door, they're having a lot of 

difficulty.

 Pricing is good for about 24 hours. 

Most construction jobs will commit a 30-day price 

and it proceeds accordingly.

 And as I mentioned earlier, obviously, 

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we've got some challenges in the loan world right 

now in terms of competition. It's relatively 

flat.

 Liquidity is accessible over here, so 

we're starting to see some very, very competitive 

pricing and some very generous loan conditions 

that are being put together in terms of 

collateral rates and other underwriting issues 

that go with it.

 So as there's guarded optimism looking 

forward, we're just not quite sure where that's 

going to take us.

 A lot of businesses are saying six to 

nine months they feel very good about what's to 

come, but they're just not quite sure what's 

going to come beyond that.

 Mortgage activity has been phenomenal. 

Again, a lot of the business we've had are 

customers coming over from the Minneapolis/St. 

Paul market.

 Mortgage refinance continues to go on, 

but a lot of it is new purchase, a little 

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construction, but generally purchase work that's 

going on right now. And it's mostly out of state 

people that are buying our properties.

 Mortgage lenders and customers still 

are adapting to the new mortgage loan 

applications, being pretty much in sync with 

that, but it's taking a little bit of time.

 Like everybody else, we are very 

active in the PPP world. First round, we got up 

and running relatively quickly.

 We were not an SBA lender previous, 

but we got in the system relatively quickly and 

we started moving loans relatively fast.

 We did about 240 loans through the 

first wave, for a total of just short of $25 

million. We have most of that first wave through 

the forgiveness process.

 We're down to about 1,000 loans. 

We've got about six of those in the SBA black 

hole for different reasons.

 There's some questions, there's some 

issues and things we're trying to resolve. We 

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have most of the first wave done.

 We have basically doubled the number 

of loans in the second wave. The loan dollars 

are significantly less.

 The second wave is definitely going to 

what we call the truly small business, the selfemployed, the small farmers, those folks that 

really needed a lot of help through the whole 

system.

 So generally, in this neck of the 

woods, there's some guarded optimism with what's 

to come. All of our schools have been open in 

the area.

 Our four-year college has been open. 

Our tech school has been open. We're all just 

kind of waiting to get through the end of the 

school year to make sure everything continues on 

a positive pace and hope it doesn't speed back 

up.

 We have had some of the new strains of 

COVID pop up in the area, and it seems like the 

people that have been infected by the new strain 

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are getting sicker than those that went through 

the first wave.

 And some of those folks are getting 

the new strain even after they've gone through 

the vaccination process.

 So COVID has yet to be seen where it 

takes us in that area right now. It's 

controllable, but a few things are changing that 

keep us on our toes.

 So overall, things look positive in 

the area. Things at the bank look good. A lot 

of liquidity, like many others have addressed.

 Something we're going to have to keep 

tackling. But rather have too much liquidity 

than not enough as the rest of the world .

 So cautious optimism. Things look 

good in the area at this point. Hopefully, it'll 

get better in the summer.

 And again, to the FDIC, thank you very 

much for the invitation to join this group. I 

look forward to future meetings.

 MR. HORVAT: Good afternoon. My name 

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is Hal Horvat. I am the CEO and President of 

Senator Bank.

 We are a 192-year-old mutual settings 

institution based in West Warwick, Rhode Island. 

West Warwick is primarily, originally a mill town 

about 12 miles south of Providence, very much 

blue collar work area, very densely populated.

 We have 17 branches in Rhode Island 

and nearby eastern Connecticut. Nine of our 

branches are in Rhode Island, eight are in 

eastern Connecticut, and we are $1.9 billion in 

assets.

 Last year was certainly a challenging 

year, not just because of the pandemic but we 

also completed an acquisition in May of last year 

during the middle of the pandemic where we 

purchased for cash a bank in eastern Connecticut 

called Putnam Bank, approximately $550 million in 

assets.

 I would not recommend completing an 

acquisition in the middle of a pandemic. It 

created all kinds of challenges. But we got 

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through it fairly well.

 In addition to the acquisition, we 

also opened up two new branches in Rhode Island 

and a loan production office.

 In addition to that, we also did a 

core conversion in December, so we certainly had 

enough going on. But we came through it very 

well.

 We had record earnings for the year. 

We had improved efficiency. We had record loan 

growth, both on the commercial side and on the 

residential lending side.

 And deposit growth, and most people 

know across the country, has been pretty 

significant.

 In terms of PPP loans, we certainly 

were a participant. We did over 100,000 loans 

for over $100 million.

 Gave us an opportunity to really 

service customers but also differentiate 

ourselves from the larger competition in this 

area. 

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We really embarked pretty quickly on 

it and we're pretty successful. Overall, Rhode 

Island, the economic conditions are kind of a 

mixed bag.

 It's really the tale of two economies. 

Some industries continue to really struggle, 

certainly those in the hospitality sector.

 In Rhode Island, we have our share of 

those industries tied to tourism and tied to 

restaurants and hotels, et cetera. They have 

continued to struggle.

 We have other businesses that have 

really been going great guns. Anything tied to 

construction, et cetera.

 Our asset quality remains very strong. 

Deposits remain strong. And the housing market, 

as most people have said, is particularly robust.

 We've had a lot of influx of folks 

from cities, New York City and Boston, moving 

onto our coastline.

 Properties are going sight unseen. 

Generally, there are bidding wars for those type 

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of properties. And as many people have 

mentioned, inventory is very low, at the lowest 

levels it's been.

 We are a community bank. We're very 

proud of the fact that we have a foundation. 

Last year we were able to donate over $1 million 

into the community.

 It was particularly important last 

year because of all of the issues happening with 

regard to the pandemic, and we're very proud of 

being able to do that.

 In terms of where we look going 

forward, the refinance activities continues to be 

very strong and we anticipate that happening 

throughout the year.

 Commercial real estate is our bread 

and butter as well. As competition is fierce in 

that arena, as you can imagine.

 A lot of banks are looking to make use 

of that liquidity that they have. Very 

competitive. Margins are very thin.

 We've seen a lot of uptick in 

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industrial facilities and solar power in 

particular, which has been driving the market.

 And we're seeing insurance companies 

add to that market as well, which makes it a 

little more competitive.

 In terms of concerns, in Rhode Island 

it's a very competitive marketplace. We are 

overbanked.

 Recently had four or five 

Massachusetts institutions that have moved into 

this area. And Chase has opened up 16 locations 

within the past year in this state.

 And we also have three very large 

credit unions. So there's no lack of 

competition.

 Margin pressure continues to be an 

issue. And in particular, the hospitality 

industry recoveries is very concerning because we 

do have a concentration in hospitality loans.

 We have participated in deferred, a 

number of loans to the tune of about close to 

$100 million. 

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We continue to see some of those folks 

struggle, and that's a concern as we head into 

our exam, which is July of this year.

 Political climate in Rhode Island is 

not exactly the most business friendly, and 

that's a concern as we are a state of small 

businesses, primarily. We have very few Fortune 

500 companies.

 But overall, I think most people are 

optimistic as we reopen the economy. We 

certainly are optimistic and feel pretty bullish 

on Rhode Island and eastern Connecticut.

 It's my pleasure to be here and I 

really appreciate the opportunity to participate 

and look forward to participating in the future. 

Thank you.

 MS. MESSERSCHMITT: Good afternoon 

Chairman McWilliams, Director Gruenberg, and all 

the FDIC staff and fellow bankers.

 My name is Teri Messerschmitt. I'm 

the President and CEO of South Ottumwa Savings 

Bank in Ottumwa, Iowa, and located in Wapello 

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County, which is an agricultural community. And 

it's located in the southeastern part of the 

state.

 Ottumwa is headquartered here, and we 

are 117-year-old bank. And we have about $565 

million in assets.

 The unemployment rate in Wapello 

County usually runs a little higher than our 

state average. 

The Wapello County rate has been about 

5 percent, with the state average at about 3.5 

percent.

 Iowa has one of the lowest 

unemployment rates in the country and we also 

have one of the highest labor participation 

rates.

 And because of that, unfortunately, 

we've got Iowa with a declining population, and 

that's resulting in a shrinkage in our workforce.

 As businesses are continuing to open 

up and expand their capacity, many businesses are 

going to need to hire more employees. And that's 

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a major concern for our state.

 We are opening back up, like I said. 

The COVID situation in Iowa right now, Iowa does 

not require masks to be worn in public and we do 

not limit the size of indoor and outdoor 

gatherings.

 Over 1.6 million people in Iowa have 

received at least one dosage of the vaccine. And 

that amounts to about 50 percent of our 

population.

 We do have about 37 percent of our 

adult Iowans who are fully vaccinated. And 

anyone over the age of 16 is eligible for the 

vaccine.

 Positivity rates are running around 5 

percent. It is encouraging to see some of the 

venues start to open back up in Iowa.

 The Iowa State Fair was cancelled last 

year. They've announced that it will be held 

this year. And they have a few schedule of 

grandstand shows lined up for this year.

 The school districts, they're still 

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really all over the board with some of them 100 

percent in class and some of them still 100 

percent online.

 Our bank does continue to service our 

customers. All of our lobbies and drive ups 

continue to be open to serve the needs of all of 

our customers.

 One of the challenges that we found 

from the pandemic is access to high speed 

internet. Approximately a third of our Iowa 

counties do not have reliable internet services.

 And about 20 percent or less than 20 

percent of Iowans have access to affordable 

internet.

 And that internet needs to be 

accessible. It needs to be affordable. And the 

state is addressing that issue.

 And they have approved spending $450 

million over the next three years on broadband.

 I would say that 2020 was a very busy 

year for us in spite of COVID. I'm proud to say 

that we strongly supported our businesses and our 

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communities by participating in the PPP program.

 In 2020, we did originate around 300 

loans, and that was for a total of about $16 

million. 2021 has continued to be very busy with 

the PPP loans.

 And we have processed about 550 loans 

and that totals about $11 million on the second 

PPP funding that was approved.

 We are very committed to continue to 

offer the PPP funding with all of our customers 

as long as the funding continues to be available.

 The low mortgage rates also helped us 

significantly in 2020 with home refinances and 

home purchases. And we will see that continue 

and are continuing to see that during 2021.

 The fee income from both the PPP 

program and the residential real estate programs 

have generated significant fee income for our 

bank.

 They did that in 2020 and we see that 

trend continuing significantly in 2021 as well.

 This will help our bank continue with 

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the decreasing net interest margin. The net 

interest margin has been and continues to be a 

concern for our bank.

 Limited new loan demand in our area 

causes us to have about 40 percent of our assets 

invested in the investment portfolio.

 We also have increased competition for 

existing loans due to excess competition with 

other financial institutions in town.

 We have seen, like others, that 

there's some pretty competitive low interest 

rates being offered out there and for some really 

favorable terms.

 The low interest rates on the new 

investments also hurts on our margin, as well as 

our existing investments that continue to mature 

or either get called or continue to be paid down.

 And as a result of that, we've seen 

our net interest margin fall to about 2.7 

percent.

 On the deposit side, we're just like 

most banks. We've seen our deposit base continue 

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to grow with the PPP funding and the stimulus 

funding.

 Liquidity is not an issue for us, and 

actually is more of a challenge for us to get it 

invested.

 On the loan side, we have a 

concentration of ag credits with the ag portfolio 

greater than that of most of our capital.

 And this sector has benefited 

significantly during 2020 and into 2021.

 Due to that, increased FSA payments 

that our farmers received and the USDA Corona 

Food Assistance Program, the CAP program, that 

has helped significantly.

 Also, the increase in the commodity 

prices have benefited our ag sector very much.

 Farm real estate land values have 

stayed stable as well as the farm cash rents. 

Crop inputs for the most parts have remained 

relatively flat, with the exception of 

fertilizer.

 The outlook for 2021 is positive for 

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the ag sector at this time. We've still got the 

PPP program. We've got round three of the CAP 

payments and the current commodity prices.

 Farmers have taken advantage of the 

current commodity prices by selling their 

inventories of store grain at the current levels 

of pricing.

 They also are locking into some of 

their future pricing for some of the 2021 new 

crop production. 

Our loan quality continues to be 

strong with very little delinquencies. All of 

our customers that had modifications during the 

year that were made are back on a paying status 

except for three, which will end in the next 

three months.

 We continue to increase our provision 

for loan loss expenses with the uncertainly 

really of the COVID situation still ahead of us.

 We did segregate the hotel and the 

restaurant sectors out of our loan portfolio, and 

we are allocating more of our provision expense 

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to the sectors.

 In addition, we did place a few of 

those loans on our watch list. And we still 

continue, though, to monitor all of the sectors 

in our loan portfolio as we proceed with opening 

up of the economy and as the COVID situation 

continues.

 In January this past year, we 

completed an operational merger with the Peoples 

State Bank into one data processing system.

 Our legal merger took place about a 

year ago in January of 2020 and we operated two 

core systems for two years.

 During that time in January, during 

our conversion, we also had a State of Iowa 

Virtual Exam that started the day after our 

conversion weekend. 

We had great employees and I 

appreciate all their hard work to make such a 

smooth transition on our new conversion and also 

with working during the examiners during this 

process. 

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I also appreciate the examiners who 

were very helpful with providing suggestions and 

resources to us as we continue to fill the shoes 

of our long-time compliance officer who retired 

during 2020.

 The exam was very efficient and we 

were very happy with the process.

 I want to extend a continued thank you 

to the FDIC and the Iowa Department of Banking 

for all their system and support throughout the 

year.

 Thank you very much for your time and 

I appreciate this opportunity.

 MS. KEA: Teri, thank you so very much 

for wrapping us up at the end, and let me just 

say thank you to all of the members of the 

committee.

 I just really appreciate your candid 

sharing of your observations from your 

communities.

 And this is one of the main reasons 

why the chairman has convened this meeting, so 

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that we can hear from you all firsthand about 

what's going on in your communities.

 There were common themes that we 

heard. Many of you talked about the impact of 

COVID on your operations as well as on your local 

community.

 Many of you used the word guarded 

optimism in terms of your thinking for the 

future.

 You talked about the housing market, 

mortgage market, labor. You talked about your 

experience with the PPP loans.

 And many gave great updates on what's 

going on in the agricultural communities. You 

all gave examples of what you're doing to support 

your communities, or you talked about it, and 

that was very, very informative for us to hear.

 And then some of you gave some 

feedback to us in terms of your exchange with our 

staff as they are conducting examinations.

 And we heard you. We heard the 

compliments and we heard your continued need and 

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appreciation for collaboration and cooperation.

 Those were just some of the many 

themes that I heard from all of you.

 So I want to thank you for sharing 

your concerns. Thank you for talking about your 

challenges. And then thank you for sharing about 

your successes.

 At this point, I'd like to turn it 

over to our FDIC staff, Shayna, Kristie, and 

Frank, and ask them to engage you as they give 

some of their observations.

 Shayna, Kristie, and Frank.

 MS. OLESIUK: Great. Thank you, 

Arleas. And I echo the thank you to all of the 

participants.

 I find that hearing your information 

and hearing your insights is very useful for our 

work.

 So I will spend a few minutes talking 

about our team's observations from a national 

viewpoint on the economy and then I will turn it 

over to Frank and Kristie for their regional 

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perspectives.

 So in my view, things, the themes boil 

down to two main things, and these match very 

well with what I heard from you all.

 First, the improving economic 

conditions and the resilience of our banks during 

the last year.

 I agree that I would have that we 

would have been in a very different place one 

year into the pandemic, but things are actually 

much improved.

 But also, continued uncertainty on 

what the post-pandemic economy will look like and 

what the implications of that is for the major 

lending portfolios at our banks, particularly 

commercial real estate, which I heard many of you 

mention.

 So first on the national economy. So, 

economic conditions have definitely improved 

since we met last October.

 GDP growth for fourth quarter 2020 was 

4 percent. And the current consensus forecast 

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for the full year of 2021 is 6.3 percent growth, 

which is very strong.

 Of course, this is coming off of a 

relatively low base in 2020, and the expectations 

have been boosted by the fiscal stimulus.

 And we're already seeing stronger 

retail sales and stronger consumer confidence in 

the first couple months of the year.

 So the question of when will we reach 

pre-pandemic GPD levels? The consensus forecast 

says third quarter of this year, but some of the 

more positive outlooks put it at second quarter. 

So we're very close on an economic output basis.

 The story's a bit different, though, 

for employment. And I heard from many of you 

here talking about improving employment. And 

we're certainly seeing that at the national level 

as well.

 However, we still have a ways to go 

with the number of jobs that we still are below 

the February 2020 level.

 We're still about 8 million jobs below 

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the February 2020 level. And despite the fact 

that we saw strong gains in February and March, 

that's certainly a sizeable hole to fill.

 And it's particularly a concern for 

the leisure sector. The leisure sector was at 

the center of the labor market deterioration.

 And we've seen strong gains in that 

sector, but there are still about 3 million jobs 

below pre-pandemic levels.

 So still a ways to go in that sector 

as well.

 The unemployment rate has come down 

from a peak of 15 percent now to 6 percent in 

March. But despite the improvement that we've 

seen, no region is back to pre-pandemic levels.

 No FDIC region, that is. And 

unemployment remains particularly elevated in the 

northeast and the west.

 So just a few more comments about the 

commercial real estate sector. So like many 

mentioned, commercial real estate remains a 

challenge. 

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Many segments of CRE are facing 

challenges, pretty much everything except for the 

industrial sector which has actually benefitted 

from the boost in warehouse space demand and 

things like online shopping.

 One of the metrics that we pay close 

attention to is what property prices are doing. 

And we see that property prices are down about 10 

percent from pre-pandemic levels.

 And of course this is important given 

that this is the collateral protection for most 

CRE loans.

 So down 10 percent overall. For 

lodging and retail properties, prices are down 20 

to 25 percent, but most of that was a drop early 

in the pandemic. And it's been fairly flat since 

mid-summer.

 The good news, however, is, and 

relative to the great recession, these property 

price drops are not as severe.

 Back in the great recession, we saw 

commercial real estate property prices drop about 

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35 percent.

 So in other words, things don't look 

that bad given the data that we see. And given 

the improvements in the economy, we're hoping 

that things continue to improve for commercial 

real estate as well.

 So with that, I will turn it to Frank 

and Kristie.

 MS. ELMQUIST: Hi, good afternoon. 

I'm a director in the Dallas region. I guess I'd 

start by just saying going into the pandemic, the 

fact (video interference) position to handle 

adversity, really good financial metrics, 

including soft capital and solid (video 

interference) by year end (video interference) 

led by the state of Mississippi, Tennessee, and 

Arkansas by primarily because they have a larger 

share of manufacturing continuing to progress 

really well, and I (video interference) think 

that's really impressive to see because the 

challenges were not just focused on the pandemic 

but we also faced some (video interference) along 

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the Gulf Coast last summer and of course historic 

winter storms including the big freeze in 

February.

 MS. KEA: Kristie, pardon me. This is 

Arleas. You are dropping off at every other 

word. Perhaps if you turn your video off and 

just use your audio, that might assist. Kristie 

are you -- thank you.

 MS. ELMQUIST: Okay, so can you hear 

me now?

 MS. KEA: Say more. I think you 

dropped off at the last word, but continue, 

please. Kristie, I think we've lost you 

altogether. Are you there?

 Frank, are you there? Could you go 

ahead and speak and we will try to get Kristie 

back on?

 MR. HUGHES: Sure, I hope so. Can you 

hear me, Arleas?

 MS. KEA: We can, yes. Thank you.

 MR. HUGHES: Okay, great. I had a 

WebEx meeting earlier today and had some 

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problems, so that's good to hear.

 So I'll be quick. I know we're over 

on time. It was great to hear the comments from 

the bankers around the country. And I think what 

you're going to hear me say is similar to what 

much of you said.

 So by way of background, the New York 

region includes all states from Maine to Maryland 

and also includes the District of Columbia, 

Puerto Rico, and the Virgin Islands.

 And of course, the region was at the 

center of the initial COVID-19 outbreak, with 

many of the states among the first to close.

 Since last summer when I spoke in 

front of the Community Bank Advisory Committee, 

we have seen general economic improvement in the 

region, but at a slower pace than we've seen 

nationally.

 And 2021 regional activity is 

projected to be slightly below U.S. forecasts. 

Labor market recovery also trails 

national trends throughout most of the New York 

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region.

 Unemployment rates are still generally 

higher than the U.S. level, while job gains have 

also trailed.

 The slower pace of recovery in the 

region can be attributed to several factors, most 

notably the severity of the downturn at the onset 

of the pandemic, the public policy response, and 

then generally weak demographic trends that we 

were already experiencing here in the region 

before the pandemic.

 Prior to the pandemic, banks in the 

region had higher concentrations of commercial 

real estate or CRE than other parts of the 

country, with concentrations especially prevalent 

in the multi-family sector.

 Banks in the New York region also 

showed less on balance sheet liquidity. So as a 

result, we have been focusing supervisory efforts 

on risk management practices related to both 

these areas on our exams, visits, and outreach 

events. 

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CRE is showing signs of recovery in 

the region, although at a slower pace than the 

rest of the country.

 As many have mentioned, hotels 

continue to struggle in the major markets in the 

region, with overall performance well below U.S. 

levels despite a significant recovery as a result 

of the pace of vaccinations, the warmer weather, 

and pent up demand.

 Retail has seen significant recovery, 

though the recovery varies greatly by sector. 

The food and beverage category and e-retail are 

doing well, while restaurants, bars, and 

traditional retailers are still well below prepandemic levels.

 So interesting data on the commuter 

side, just for the New York City area. Through 

the first week of April, it does provide us some 

insight into economic activity.

 Subway ridership in the city is still 

65 percent below prior levels, bus ridership 50 

percent below, and ridership on the two major 

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commuter train services is 70 percent below prior 

levels.

 But we have seen an increase in bridge 

and tunnel traffic that's significantly closer to 

prior levels, but we think some of that is offset 

from rail commuters taking advantage of lower 

traffic into the city.

 The office space sector remains 

subject to uncertainty surrounding long-term 

trends and the acceptance of the distributed 

workforce model.

 As the commuter data I mentioned 

indicates, work from home is still significantly 

affecting the region in general and New York City 

more specifically, with occupancy levels well 

below national levels.

 On the multi-family front, data for 

cities like Baltimore, Hartford, Philadelphia, 

and Pittsburgh continue to show generally 

favorable dynamics, while major markets like New 

York City, Boston, and Washington, D.C. are 

forecast to lag regional and national 

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performance.

 Rental payment metrics show some 

strain. Renters behind on rent in New York City 

and Philadelphia are above national levels, while 

the numbers are more favorable in Boston and 

Washington, D.C.

 I know we talked quite a bit about 

residential real estate. So in the region, 

strong home price gains continue.

 Regionally, the northeast was the only 

major region to see a notable divergence in home 

sales between urban and suburban markets, with 

New York and New Jersey suburban markets causing 

most of the divergence, as we continue to see out 

migration from some of our larger cities.

 Real quick on banking conditions, in 

general, as Kristie said in her opening remarks, 

banks in the region entered the pandemic at 

overall strong condition with increasing levels 

of capital, strong asset quality, and 

satisfactory risk management practices and 

compliance management systems. 

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Banks have seen earnings negatively 

affected by the pandemic with strong growth in 

deposits that have increased balance sheets while 

loan yields have fallen.

 In addition, banks have increase 

provisions to account for the expected increase 

in credit losses due to economic weaknesses.

 Banks in the region were also very 

active in PPP, which did help earnings, did help 

offset some earnings pressure.

 I mentioned liquidity in the region 

prior to the pandemic. So median deposit growth 

in the region significantly outpaced the national 

rates.

 We saw 23 percent growth in the region 

versus 17 percent nationally, while loan growth 

was only up about 7 percent, and only slightly 

above the national trend.

 The positive there is that liquid 

assets did increase at a faster rate in the 

region than the nation. Again, as I mentioned, 

the New York region quickly had run with lower 

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levels of liquidity.

 The overall loan delinquency rate 

increased slightly but it ended 2020 just below 

the national rate.

 CRE loan delinquency rate also 

increased slightly and also ended just above the 

national rate. But it still remains historically 

low.

 Deferral and forbearance activity 

continues to decline. We're still seeing some of 

it, but it's declined quite a bit.

 And we are seeing some watch list 

movement down the credit rating scale at our 

institutions, but we're not seeing material 

downgrades or declines in asset quality at this 

point.

 We're also not seeing material 

downgrades or two component or composite ratings 

on the safety and soundness side, but along with 

asset quality, we'll continue to keep an eye on 

earnings performance.

 We also saw few changes in compliance 

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and CRA ratings. Banks continue to do a good job 

meeting the needs of their customers and 

communities in complying with consumer protection 

laws.

 At the outset of the pandemic, we did 

see some uptick in branch closings across the 

region.

 That seems to have moderated somewhat. 

And we also didn't see or are not seeing a 

significant increase in consumer complaints.

 So really in some way, the initial 

outbreak had a significant impact on the region 

and we continue to see that impact in industry 

metrics for some asset classes. 

Liquidity levels on average have 

improved across the region while earnings remain 

a challenge.

 And as noted, banks in general in the 

New York region entered the period of economic 

uncertainty with favorable financial metrics and 

satisfactory risk management and compliance 

programs. 

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So I don't know if Kristie is able to 

get back on.

 MS. KEA: Frank, I think I just saw 

Kristie's camera on a moment ago. So, Kristie, 

if you are on, would you please join us? Thank 

you, Frank.

 MS. ELMQUIST: Hi, can you hear me 

now?

 MS. KEA: We can, Kristie. Thank you. 

Please go ahead.

 MS. ELMQUIST: Perfect. I'll try to 

be (video interference) to compliment banks in 

the Dallas region, not only for being resilient 

during the (video interference) but also as they 

(video interference) during the hurricane season 

and then an unprecedented storm event that hit us 

in mid-February.

 And as Shayna and many of the bankers 

have already talked about, the (video 

interference) in the Dallas region, the recovery 

is doing well, led by states that have a 

concentration in manufacturing. 

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So we have recovered at least our jobs 

and many of our sectors are doing (video 

interference) including housing, agriculture, and 

energy has rebounded as well.

 We do still have some challenges and 

uncertainty with commercial real estate, and 

that's important to us because a good number of 

our (video interference) institutions in the 

Dallas region do have a -- or we are really 

paying attention to some potential challenges 

(video interference) particularly convention 

space in (video interference) areas, as well as 

office vacancy rates.

 We do have some markets that are at 

the high end as well as high volume of 

construction in process. So we'll be watching 

that pretty closely.

 For the bank, our banks were really 

well positioned going into the pandemic, and 

(video interference) have demonstrated resiliency 

and the ability to (video interference) from a 

financial performance perspective, we have 

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observed shifts in the balance sheet due to the 

high growth in deposits, mainly because of the 

PPP lending as well as mortgage lending.

 Composite rating, last year we 

conducted over (video interference) risk 

management (video interference) to the composite 

rating.

 That said, we have seen some liquidity 

ratings (video interference) to a better rating, 

increase in liquidity levels, but also notable 

improvements in funds management practices (video 

interference).

 On the flip side, we have seen some 

(video interference), but again, not in very many 

of our examinations.

 Our (video interference) component 

ratings are remaining relative to deferrals, but 

that's because I think our banks have done a very 

good job (video interference) --

MS. KEA: Kristie, this is Arleas. 

Pardon the interruption. We were hearing you 

fine and now all of a sudden we're hearing just 

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bits and pieces. Could you check --

MS. ELMQUIST: Am I cutting out again?

 MS. KEA: Yes, you're cutting out. I 

think that we are getting the gist of much of 

what you're saying, but it's cutting out more and 

more at this point. Are you able to make any 

adjustment to your audio settings?

 MS. ELMQUIST: Can you hear me now? I 

can just --

MS. KEA: It's very choppy, and in 

fact, Kristie, we're not -- we're hearing every 

other word.

 MS. ELMQUIST: I can try changing 

audio to the phone connection.

 MS. KEA: You could just try that 

quickly.

 MS. ELMQUIST: I guess since I'm at 

the end, should we just move on? I hate to --

MS. KEA: Hearing you fine now. Go 

ahead. We're hearing you. Well, I thought we 

were. Kristie?

 MS. ELMQUIST: Can you hear me? 

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MS. KEA: Yes. Now I think you're 

cutting out. Let me make this suggestion. Let 

us pause and let's see if any of the members have 

any questions.

 And you might be able to, as you're 

making some adjustments, and I'll ask the staff 

to call you or chat with you as you're making 

some adjustments.

 Let us see if any of the members have 

any questions based on what they've heard thus 

far.

 To the members, any questions or 

comments? You can either raise your hand or you 

can simply turn your camera on. And I'm just 

checking the chat.

 I'm not seeing any raised hands. And 

it could be that everybody is really ready for a 

comfort break.

 We are at 3:09. Let us do this. 

Let's take a 10-minute break. So let us come 

back just shortly before 3:15, if you would, and 

I'll turn it over to Shannon at this time. 

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Shannon, would you please give us 

instructions for the break?

 Shannon could be talking to Kristie. 

So let us break now for 10 minutes. We'll come 

back right, well, I said 10 minutes but, let us 

come back at about, why don't we say 3:20?

 (Whereupon, the foregoing matter went 

off the record at 3:10 p.m. and went back on the 

record at 3:20 p.m.)

 MS. KEA: Shannon, thank you very 

much. Hello, everyone, and welcome back from the 

break. Despite all of the slight difficulties 

that we've had, I think that we are all doing 

very good in terms of the meeting.

 So I appreciate everyone's patience 

and cooperation. Thank you very much.

 So I think that we are live now, 

Shannon. Thank you very much. We'll go ahead 

and get started.

 I'm sorry about the problems that 

we've had a little bit earlier in the meeting, 

but I think that we will still find time to make 

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sure that you all get the interaction that you 

need as we move forward in the agenda.

 I'd like to share now that on 

yesterday, we had a meeting of the Minority 

Depository Institution Subcommittee, and I do 

want to express my great appreciation to Gilbert 

Narvaez, Jr.

 You heard from him earlier. He serves 

on both this committee and the MDI committee. 

Gilbert and Betty, FDIC's National Director of 

Minority and Community Development Banking, are 

going to provide us with an update on yesterday's 

meeting.

 I think that they will briefly 

summarize key points from the MDI subcommittee 

meeting, which will include updates on the 

Mission Driven Bank Fund, the FDIC's 

implementation of the U.S. Treasury's Emergency 

Capital Investment Program, as well as our FDIC 

MDI program.

 So at this time, I'd like to turn it 

over to Betty Rudolph and then Gilbert Narvaez. 

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Thank you.

 MS. RUDOLPH: Thank you, Arleas. I 

wanted to briefly remind the committee that the 

FDIC established the MDI subcommittee under the 

authority of the Advisory Community on Community 

Banking, the CBAC, and the Federal Advisory 

Committee Act, FACA, requires that the 

subcommittees provide advisory recommendations to 

the agency, to the parent committee.

 So therefore, the MDI subcommittee 

actually reports directly to the CBAC to all of 

you and not to the FDIC. So that's why we're 

reporting to you today.

 There are three goals for the MDI 

subcommittee, and they include serving as a 

source of feedback for the FDIC on strategies to 

fulfill our statutory goals to preserve and 

promote minority depository institutions, to 

provide a platform for MDIs to promote 

collaboration, partnerships, and best practices, 

and to identify ways to highlight the work of 

MDIs in their communities. 

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The MDI subcommittee is comprised of 

nine executives representing a diversity of types 

of MDIs, including African American, Hispanic, 

Asian and Native American Banks, and a range of 

business models, size, and geographic mix.

 The nine members of the MDI 

subcommittee represent about 10 percent of all 95 

MDIs that the FDIC supervises.

 In addition, there are three MDIs 

represented on the CBAC and you heard from them 

today, Kenneth Kelly of First Independence Bank 

in Detroit, Michigan, Andrew West with Eagle Bank 

in Polson, Montana, and Gilbert Narvaez, Jr., 

with Falcon International Bank in Laredo, Texas.

 So at this time, the MDI subcommittee 

doesn't have any recommendations for the FDIC, 

but we do want to share a brief summary of our 

discussions yesterday.

 And I'll turn it over now to Gilbert 

who will walk you through these updates.

 MR. NARVAEZ: Thank you, Betty. 

During the roundtable, each MDI banker discussed 

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current banking conditions and unique issues 

facing their institution.

 And interestingly enough, we heard a 

lot of the same conditions, themes, and issues 

that some of the institutions are facing after 

this morning's reports.

 Many bankers discussed their cautious 

optimism about the pandemic and the economic 

outlook over the near to medium term.

 Some general themes bankers reported 

included abundant liquidity due to government 

stimulus programs, pressure on net interest 

margins, some dampened loan demand, continued PPP 

funding and forgiveness, and in some cases, low 

housing inventories and higher construction 

costs.

 Also at each MDI subcommittee meeting, 

there is an MDI spotlight segment to showcase the 

work of an MDI or a group of MDIs.

 The MDI spotlight explores best 

practices or lessons learned that might be 

insightful for other MDIs. 

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Yesterday, we heard from Robert James 

II, who is the Director of Strategic Initiatives 

and board member of Carver State Bank in 

Savannah, Georgia.

 Mr. James discussed collaboration best 

practices by a group of 12 black MDIs that came 

together to syndicate a $35 million loan to 

refinance the Atlanta Hawk's Emory Sports 

Medicine Complex.

 Mr. James also serves as chairman of 

the National Bankers Association, and he spoke 

about the MDI trade organization's emphasis on 

collaboration. So that was a very interesting 

presentation.

 We also heard an update on the 

formation of the Mission Driven Bank Fund. The 

FDIC hired a financial advisor and two law firms 

to develop the framework, structure, and concept 

of the operations of this fund that will provide 

investments in about 250 eligible FDIC-insured 

MDIs and community development financial 

institutions. 

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The fund is designed to generate funds 

from corporate, philanthropic, and bank investors 

into MDIs and CFIs to support growth and to serve 

the communities.

 Earlier this year, each of the nine 

executives of the MDI subcommittee and about 70 

executives of MDIs and CFIs in total, had the 

opportunity to provide their input regarding the 

needs of the mission driven banking sector.

 Yesterday, we had the opportunity to 

review the work of the financial advisor and law 

firms. The presentation included several aspects 

that I'll briefly summarize.

 One was the fund design consideration, 

including how the fund manager will balance the 

needs of the investors and mission driven banks.

 Another was the investing universe and 

the types of asset classes the fund will 

consider. The conceptual portfolio design, how 

the investments will be sourced. And the 

proposed fund governments in terms of the fund.

 The next steps in the stand up of the 

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fund, including the hiring by investors of the 

fund manager.

 Another note is that the subcommittee 

had a briefing on the regulatory aspects of the 

U.S. Treasury's Emergency Capital Investment 

Program.

 Since our last meeting, Congress 

appropriated approximately $9 billion for 

treasury investments in FDIC-insured MDIs and 

CDFIs and credit unions that source minority and 

low to moderate income neighborhoods that were 

disproportionately affected by COVID-19 pandemic.

 The Treasury has issued a rule 

outlining the program and banks are currently 

submitting applications.

 Currently, we have an update on the 

recent MDI program initiatives. In early March, 

the FDIC hosted a webinar for MDIs that are not 

already CDFIs.

 Congress recently provided $3 billion 

for CDFIs that are serving minority and lowincome communities that were disproportionately 

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affected by COVID-19 pandemic.

 Of this amount, $1.2 billion is set 

aside for CDFIs that are minority lending 

institutions.

 The FDIC conducted a webinar to help 

MDIs understand the requirements for becoming a 

CDFI an accessing CDFI fund financial assistance 

programs.

 The webinar was well attended and 

received very positive feedback.

 Tomorrow, the FDIC will host an 

interagency webinar to demonstrate a new tool for 

MDIs and CDFIs to estimate the impact of the 

capital ratios of new investments coming into the 

mission driven bank sector.

 These new investments include millions 

of dollars of direct investment from large 

financial institutions, the new Treasury ECIP 

Investment Program, the CDI grant funds, and 

other potential sources of funds.

 The capital estimator tool will enable 

mission driven banks to create various scenarios 

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to estimate the impact of new funding on various 

capital ratios.

 Finally, FDIC also updated us on 

training that they are developing for examiners. 

The training supports the FDIC's proposed 

statement of policy regarding minority deposit 

institutions that was issued for public comment 

last year.

 That policy restates interagency 

examination standards that require examiners to 

recognize the distinctive characteristics and 

core objectives of each financial institution and 

to consider those unique factors when evaluating 

the institution's financial condition and risk 

management practices.

 This includes taking into account the 

size and sophistication and the nature and 

complexity of the business activities and risk 

profile of each institution.

 This concludes the report from the MDI 

subcommittee, and Betty and welcome any questions 

that you have. 

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MS. KEA: Let us just pause for a 

moment in case there are some questions, 

especially for our new members.

 This is a very important subcommittee, 

and we're happy that Gilbert and Betty were able 

to report out to you this afternoon on our 

meeting yesterday.

 Are there any questions or comments? 

I don't see any hands raised in the chat. If 

anyone would just simply like to turn their 

camera on and jump in, that would be fine, also.

 Okay, Betty and Gilbert, thank you 

very much. I would like to move on in our 

agenda. One of the other consistent topics that 

many of you talked about involved technology, 

dealing with the fintechs.

 And we're very fortunate to have 

FDIC's recently appoint Chief Innovation Officer 

Sultan Meghji with us this afternoon.

 Sultan is a recognized expert in 

financial technology and he joined us, I think, 

Sultan, it was just about two months ago. 

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But he's going to talk about what you 

can expect to see going forward with regard to 

technology and innovation here at the FDIC. 

Sultan, you have the camera.

 MR. MEGHJI: Thank you so much, 

Arleas. It's great to be here and thank you so 

much for the invitation and the opportunity to 

stick in and listen on and off throughout the day 

as I've been able to. This is absolutely 

fantastic.

 For those on the committee I haven't 

met yet, it's great to meet you and I encourage 

all of you to reach out to me at your 

convenience. I'd love to find time to chat with 

each of you.

 As Arleas said, I think Thursday is 

officially my two-month anniversary here. And 

I've gotten a lot of questions about joining and 

everything.

 And I thought it'd be useful to spend 

a few seconds just mentioning why I'm in banking 

at all and why the FDIC, which is the, I grew up 

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in a cornfield in the middle of Illinois.

 And it's that small town sense of 

community that's anchored by the local community 

bank that really drew me in initially.

 And I have these great memories of 

walking to the local diner to get pie with my 

grandfather and I would walk by the bank. And it 

was a key, integral part of the community.

 Now, obviously, the old Main Street 

ideals of decades ago, far too many decades ago 

for me, anyway, are changing a little bit.

 And as we think about that change, the 

ability to come into FDIC right now and sit in 

this new role was an opportunity I couldn't pass 

up.

 And so let me talk a little bit about 

what's been going on and what you're going to 

start hearing more and more for us.

 And the first thing I'd say is, I, of 

course, am very happy to take any questions, so 

please throw any into the chat or be prepared or 

raise your hand and we'll get to it at the end of 

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my little speech here.

 But one of the biggest things in 

talking to the chairman and going on my listening 

tour where I spoke to a number of bankers, I 

spoke to people throughout the ecosystem, was a 

couple of things.

 Number one is that American 

competitiveness is something that we want to 

protect and expend, and that we want to do it in 

an inclusive way.

 We want to open the door to thoughtful 

innovation. We want to be able to let the new 

technologies in, but do it in a thoughtful way.

 We wanted to make things easier for 

people, not harder. And we wanted to have a view 

to the future.

 And we've come up with a couple themes 

that you'll hear those of us here at FDIC speak a 

little bit more about, but I'm happy to summarize 

them for you.

 The first is around inclusion. We 

need to build an inclusive, diverse, and 

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equitable future of banking here in the United 

States.

 And that's not just at the consumer 

level, although there's a tremendous amount we 

can do there. And I think you guys, most of you 

saw the recent bank initiative, which has been a 

really great first step, and there's more to come 

in that area. 

But also inclusivity from the 

perspective of minority women owned businesses. 

Small businesses are the backbone of this country 

and it's a wonderful opportunity for us to help 

leverage that amazing capability and do more for 

them.

 The second is around resilience, and 

whether or not we're talking about things like 

the SolarWinds hacks or the Microsoft hacks or 

the pressures against the system from unregulated 

entities or the increased competition from the 

big banks, we need to build into this ecosystem a 

more resilient capability set.

 And that's everything from 

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cybersecurity to availability to interoperability 

and standards.

 I'm sure those, some of you remember 

last year, we put out an RFI on a standards 

setting organization and that work continues as 

well.

 But we really do need to get to a 

point where we are engineering for resilience. 

We have to make sure that we're being thoughtful 

about this.

 And it's everything from the due 

diligence of third-party fintechs to 

understanding the technical debt that exists 

inside the banking sector and what we can do to 

help clean that up.

 The third one is around amplification. 

I've spent a lot of time inside of community 

banks and some of them very small.

 It's just four or five people. And 

everybody's kind of wearing a bunch of different 

hats.

 But one thing I've noticed is that a 

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lot of people are fighting the process, they're 

fighting technology, they're fighting their 

regulatory requirements.

 And instead of being bankers and being 

amazing at that, they're fighting an Excel 

spreadsheet.

 Now I get inside of FDIC and I see the 

exact same thing. I see amazing people 

throughout the organization, economists, 

examiners, people from our technology 

organization, our legal division, policy, and 

there's all this friction in their daily lives.

 And so I think it's important for us, 

if we have all these amazing experts throughout 

the ecosystem, they should be spending (video 

interference) of every hour being an expert.

 And then finally, we have to protect 

the future. And here's where I come back to my 

comment about American competitiveness globally.

 In the face of an ascending People's 

Republic of China, in the face of massive global 

competition, in the face of competition from 

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traditionally non-competitive sectors of the U.S. 

economy, the American banking system has never 

been under more pressure than it is currently 

under. And there's an amazing opportunity.

 And again, you'll hear me say this, an 

opportunity for us to build a banking system of 

the future that exceeded what we could do in the 

20th century, American power both domestically 

and globally in the 20th century sat on the back 

of our economic system, sat on the back of free 

market capitalism, and sat on the back of our 

banks.

 If we're going to be the number one 

country in the 21st century, we have to reinvest 

in that. We have to refocus on that.

 And that's what I want to do. I want 

to protect the future, whether or not it's 

against foreign actors or whether or not it's 

continuing to ensure that our banks are offering 

the best products and services, or if Mr. Musk 

gets that bank on Mars that he wants.

 That bank will still have to 

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interoperate with our system. And we want to 

make sure there's a way for that to work, a 

thoughtful, seamless, safe, and secure way.

 And we want to do all this while 

fundamentally being more efficient. So we have a 

lot of work to do.

 And as we go through this year and 

next year, you'll start seeing a bunch of 

different programs around these four themes that 

I've discussed.

 We've already got a lot of great work 

going on internally. We're starting to touch 

some places where we're trying to enhance some of 

the cybersecurity standards and work on finding 

ways to create new opportunities to work 

together. And you'll see more and more of that 

as we go through the year.

 But most importantly, I wanted to make 

sure you all heard about our email address, 

innovation@fdic.gov.

 This is an opportunity for us to kind 

of preach to the choir. If we're going to be 

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open and transparent, here's how you do it.

 That email hits my inbox. So please 

do, if you have thoughts, ideas, want to engage 

with us, please do reach out. We would love to 

hear from you.

 And so with that, I don't have 

anything else specifically to add here, but I 

will pause for a moment and see if there are any 

questions.

 I don't see any, but very happy to 

take any if there are any. Otherwise, I will 

turn it back over to Arleas.

 MS. ANDERSON: I have a question.

 MS. KEA: Okay, let's take a moment. 

Yes, go ahead.

 MS. ANDERSON: Hi, I'm Shaza Anderson, 

Trust Star Bank, and my question is really more 

generic.

 You probably all have read that the 

OCC has approved the first fintech company to 

have a banking charter.

 And I'm not really sure yet how it's 

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going to affect us, how it's going to affect the 

FDIC, or banking in general.

 Do you have any sort of thoughts on 

that? It's been something that we've been 

bombarded with all these fintech companies. 

There's one every day, it seems like.

 But to get an approval from the OCC, 

would that be FDIC insurance? I mean, it's a 

charter, it's a banking charter. So tell me a 

little bit about your thoughts.

 MR. MEGHJI: Well, first off, I can 

only speak for myself and the FDIC. I can't 

really speak to the OCC at all. And certainly, 

some of the different things they are doing are 

far outside my purview.

 But I will say I'm a big fan of 

innovation. I'm a big fan of innovation in the 

banking sector.

 And we see across FDIC insured 

institutions tremendous innovation. In some 

cases, the bank is just being innovated.

 In some cases, they're partnering with 

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fintechs, of which there are many thousands. 

Make no mistake.

 And in some cases, it's banks working 

together. And I'm a big fan of that. I like 

seeing entities that are what I call regulatory 

forward.

 They're engaging with groups like us 

early and often and finding ways to work inside 

of the system instead of just ignoring this and 

just doing whatever they feel like and kind of 

lone wolfing it out there.

 So all I can say is I encourage 

greatly people to work with us. I hope we can 

continue to do that.

 And I look forward to seeing what 

innovations all of you come up with. They get me 

excited.

 MS. ANDERSON: Thank you.

 MR. MEGHJI: Thank you. Arleas, back 

you.

 MR. PITKIN: Actually, Sultan, Mark 

Pitkin from Sugar River Bank. If you don't mind 

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me, just a comment and a question.

 So coming from the first community 

bank that partnered with Lending Club, who is the 

largest unsecured lender in the nation many, many 

years ago, I am very pleased to see sort of the 

openness toward banks now working with these 

fintechs, because I can assure you that back 

then, there wasn't the openness and 

transparencies with banks sort of going outside 

of the box.

 But we profess, certainly as a smaller 

community bank in an area that didn't have a 

whole lot of population growth, that we had to 

look at different areas of innovation in order to 

be sustainable and survive.

 So we have certainly come full circle 

with regards to do that. So I guess my question 

is, what are you and/or what is the FDIC doing to 

sort of pass your energy, your openness, and your 

transparency for banks thinking out of the box 

when it comes to examiners that come in our doors 

and we are sharing certain things? 

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Is that something that is being passed 

down? Because if that is the case, having an 

open mind is going to be incredibly refreshing 

when banks are doing these things that you find 

are very helpful, thought provoking, and 

necessary in the future.

 MR. MEGHJI: Yes, that is such a great 

question, Mark. And you know what I've 

discovered in my time in this industry is that 

some of the most interesting innovations, the 

most thoughtful dialogs I've had have not been 

from the biggest banks out there.

 It's been from the community banks 

that are, you've got guys dirty fingernails on 

the street trying to sell a loan or something 

like that and you guys are thinking of new and 

interesting ways of making that case.

 So I'm, A, not surprised to hear what 

you just said, and B, excited to hear it.

 Two days shy of my two-month 

anniversary, there's only so much megaphone I've 

been able to cover thus far, but you'll certainly 

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see a lot more of that.

 Tomorrow, you'll see the first in a 

series of new podcasts where I interview the 

chairman, where we have an entirely unscripted 

discussion, a very open and transparent one, I 

might add, about innovation.

 You'll hear us talking about some of 

the things I've already said today. But you'll 

get to hear from her directly.

 I've done three speeches today. I met 

with two members of Congress today. And that's 

kind of a normal day for me. So there's a lot of 

this going on. So that's number one.

 Number two, you're going to see a lot 

of what I call programmatic functions. So what 

does that mean?

 It means everything from tech springs 

to opening up to RFIs and anything we can think 

of.

 And I certainly encourage anyone 

hearing my voice right now, if you've got an 

idea, I want to hear about it. 

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And then third is, FDIC is 

approximately 6,000 employees across the country 

and there's going to take a little bit of time 

for us to get all the messages across and the 

interview across.

 So I would beg a little bit of 

patience. But you don't bring a guy with nearly 

30 years of private sector experience building 

companies and transforming large institutions 

from his own startups to large public equities, 

infrastructures, in here to have me sit on my 

hands. So don't be surprised when you hear more.

 MR. PITKIN: Thank you.

 MR. MEGHJI: Thank you.

 MS. KEA: Sultan, we have just a 

couple more questions. First, Neil McCurry and 

then Steve Hayes.

 MR. MCCURRY: Hi, Sultan. Neil 

McCurry in Sarasota, Florida. First, welcome to 

the FDIC. Your enthusiasm is refreshing on this 

area.

 And I'm a big fan of the concept of 

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technology, but I want to get your thoughts on 

what really keeps me up at night when I think 

about banking. And I best describe that with a 

short story I've shared with our shareholders.

 In the year 2000, we were introducing 

internet banking, which was revolutionary at the 

time.

 And I told everybody how great it is, 

but I said be careful because right now there's a 

14-year-old kid living in a basement in Europe 

and he's trying to hack into your system.

 So you have to be careful with it. 

That was 20-plus years ago. I recently said that 

story again.

 I said, the difference is that 14-

year-old is grown up and now works in a wellfunded factory, maybe for some government that is 

trying to do detrimental things to our industry, 

our country, and our institutions.

 We've seen core providers that have 

had meaningful, successful cyberattacks. I 

believe that a potential cyberattack on your bank 

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very well could be death by a thousand cuts, when 

you look at the reputational risk and everything 

involved.

 And as we speak right now, someone on 

this panel might be in the process of someone 

trying to hack into their system, and we might 

not know about that for months or a year from 

now.

 So it's scary. So how do we adopt and 

innovate and embrace this technology, which 

ultimately relies on partnering with other 

organizations that are now susceptible because 

they have access to your systems? How do we 

protect ourselves against these very smart, wellfunded groups?

 And how do we do that in a 

collaboration as opposed to, ah, they got you? 

As opposed to, we're all in this together and 

making sure that our system is safe and is 

perceived to be safe by the customers in the 

country?

 MR. MEGHJI: Well, Neil, it's a great 

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comment and question and I like the story, too. 

I relate to that.

 I would say a few things. Number one 

is, we are all in this together. No one bank, no 

one regulator, no one member of our banking 

system stands alone.

 It's not a bunch of islands. We're 

all part of a community and so we need to act 

that way.

 I'll also say that cybersecurity, like 

innovation, is fundamentally not primarily a 

technology discussion.

 It's people, it's processing, and it's 

technology. And so just like any well run bank 

has a top focused management program, which I'm 

sure everyone here who runs a bank has something 

like that, we need to extend the definition of 

that.

 We need to make sure our people are 

trained. We need to make sure it's communicated, 

we need to make sure our processes are being 

evaluated and continually kind of poke that. 

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We are far past the time when you 

implement something, you put something in place 

and just leave it alone for years at a time.

 The static mainframe system's view of 

the world doesn't exist anymore. That's just not 

how it works. Say, like, batch systems.

 I've been very fortunate for the last 

few years to work on something called the Fin 

Cyber Program at the Carnegie Endowment for 

International Peace.

 It's specifically talking about how to 

secure the global financial system. And we have 

a capacity building toolkit that included, one of 

the first things we put out there, and I share 

this because it's meaningful to your question, 

Neil, a communications and education program, 

because absolutely, from every significant 

shareholder to your board of directors to your C 

suite to the most junior person in your 

organization, cybersecurity is something that 

needs to be taken very seriously and it needs to 

be part of the ongoing discussion. 

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So that's kind of one comment. The 

second is, this is such a concern that you heard 

me talk about resilience as our second theme, and 

this is absolutely part of that, SolarWinds, the 

Microsoft hack, the various customized Ransomware 

technologies and Ransomware's a service that's 

out there right now.

 These are all out there and I agree 

with you and I can also say I agree with Chairman 

Powell who thinks that cybersecurity is probably 

the greatest threat to our banking system.

 So I can't say it more strongly than 

that.

 MR. MCCURRY: Well, thank you for that 

comment. Prior to you joining us, Gilbert made 

some comments about the committee he's on for 

minority institution subcommittee, and I'd 

recommend the FDIC consider some type of 

subcommittee where a group of bankers across the 

country work with your group as a team to address 

these.

 So everybody has different 

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perspectives on it, because ultimately, we all 

either fail or succeed together.

 So I think that as much as we can look 

like we're joined together and talk and feel that 

it's not a bank and a regulator relationship, 

it's more of, we have to do this if we're going 

to survive.

 And I think that there might be some 

merit to that idea. And maybe you can put some 

deliberation to that concept.

 MR. MEGHJI: I think that's a 

fantastic idea, Neil, and I'm going to ask if 

you've hacked my email. Can I ask that we table 

that and we'll get back to you very quickly?

 MR. MCCURRY: Fantastic.

 MR. MEGHJI: Thanks so much, Neil.

 MS. KEA: Great. That's great. So is 

Steve still on? And then PJ Wharton.

 MR. HAYES: Can you hear me?

 MR. MEGHJI: Yes.

 MR. HAYES: Thank so much. I 

appreciate it. This is Steve Hayes from South 

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Dakota.

 Earlier you made the comment about 

small banks fighting technology. And out here in 

South Dakota, we're probably, the majority of our 

banks are $50 million to $100 million, I suppose.

 And I agree, rural communities, we 

need to wear several hats and we need to embrace 

technology, but what else are you hearing out 

there?

 Is it these people are fighting, and 

you just made the comment, but is it due to the 

education component part of it or what?

 And I'm just curious because I know 

that we face that out here as well. It's a 

comment or question, so --

MR. MEGHJI: Yeah, Steve, I was just 

about to ask. I'll say a couple of words and you 

tell me if it's useful, how's that?

 So as I said, you talk about 

innovation in cybersecurity as being about people 

and processing and technology.

 I think if you're going to be 

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implementing technology in a bank, you've got to 

think about all three of those.

 You've got to not only make sure 

you're getting the right technology that's fit 

for purpose, that's kind of the right price point 

and the right kind of features and all that other 

good stuff, and also recognize that for, 

especially for smaller institutions, your 

technology expense in many cases are after your 

annual interest expense, the largest expense 

you've got.

 And that's a big pill to swallow 

sometimes. So there's a financial component 

there that can't be ignored.

 I would say, though, that investing in 

people is absolutely where I would start. So if 

you say, Sultan, you're running this $50 million, 

$100 million, $150 million bank, and just for 

background, I've been living in Missouri for a 

while now, so the kinds of banks you're talking 

about in South Dakota, I recognize that strongly.

 And I would be investing in my people. 

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I would be making sure that they have the 

opportunities to hear about things like the Fin 

Cyber Program or continuing education and all of 

that.

 I mean, that's a challenge we see 

facing the banking sector is hiring and 

recruiting great people, and technology is even 

the biggest one.

 I mean, the second one is making sure 

that you're thinking about your processes. Your 

process that came from 20 years ago that predates real time payments, you probably want to 

spend some time looking at that.

 There are some amazing resources out 

there, whether it's other institutions or trade 

associations or a variety of other agencies and 

organizations that can support there.

 And then the other one is, think about 

the strategy where you're taking the 

organization. I mean, if I was, if you said to 

me, Sultan, what tech should I use for problem X, 

I wouldn't know how to answer that until I 

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understood what you were trying to do with your 

organization, what you're trying to do. There is 

no one size fits all anymore.

 MR. HAYES: Okay. Great. Thank you.

 MR. MEGHJI: Good. Fantastic.

 MS. KEA: Let's go to PJ.

 MR. WHARTON: Sultan, PJ Wharton, 

Yampa Valley Bank in Steamboat Springs, Colorado. 

Yes, I think for most of us, going through COVID, 

we've all faced the reality that technology, tech 

is no longer a luxury but a requirement.

 And with that, many of us are members 

of Independent Community Bankers of America. 

With what we went through and seeing when our 

core provider was down the first business day in 

January and I didn't have remote deposit capture 

and I didn't have my ATM and I didn't have online 

bill pay, we had lines around the bank.

 As a result, I participated in the 

ICBA Thinktech Accelerator Program, which is in 

the great state of Arkansas, Margaret's home 

state, the ICBA. 

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My question is, do you have any 

interaction with our friends at Independent 

Community Bankers of America?

 Again, the Thinktech Accelerator is an 

amazing program where by volunteering you are 

able to see up to 12 companies in a single day 

making their pitch.

 And I think it'd be great if there was 

interaction between the FDIC and the ICBA as it 

relates to this vital program.

 So I was just curios if you've had 

interaction yet and what your impression is.

 MR. MEGHJI: I have. In fact, I spoke 

at the event a few weeks ago. So, yes, I have. 

There are a number of amazing resources out 

there, whether it's fraternity associations or 

others.

 But no, it's fantastic. You're 

absolutely right. It is no longer optional.

 MR. WHARTON: Thank you.

 MS. KEA: We have a few more minutes 

if there are other questions or thoughts. And in 

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the meantime, Sultan, I think your email is 

innovation@fdic.gov. We want to make sure 

everybody takes that away.

 MR. MEGHJI: Yes.

 MS. KEA: I think I see, did I see 

another hand go up? Let me just double check. 

Actually, I don't see any more hands.

 But I think everybody would say, 

Sultan, that this is the beginning of a very long 

conversation that will continue to go on.

 So we just thank you very much. There 

will be many more opportunities. We appreciate 

the recommendations that have come out of this 

talk.

 And I'm sure that the members will be 

hearing more from you and from us at the FDIC 

around this. So, Sultan, thank you so very much.

 MR. MEGHJI: Thank you, Arleas, and 

thank you to the members for having me here 

today. I look forward to continuing to engage 

with you.

 MS. KEA: Thank you, Sultan. So next, 

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what we'd like to do on the agenda is to provide 

you all with a few supervisory matter updates.

 And we do have with us today from the 

Division of Risk Management Supervision, our 

Director, Doreen Eberley.

 And she's joined by Rae-Ann Miller, 

who is our Senior Deputy Director of Supervisory 

Examinations, as well as John Vogel, who is 

Deputy Director for Operations.

 And then they are joined by Chris 

Finnegan, who is from the Division of Depositor 

and Consumer Protection.

 And Chris serves as the acting Deputy 

Director of Compliance and CRA Examinations.

 So for Doreen and the team, I'd like 

to turn it over to you.

 MS. EBERLEY: Okay, thanks so much, 

Arleas. Well, we do have a number of topics to 

cover during our supervision panel today, 

including an overview of our supervisory response 

to the pandemic, an overview of the broker 

deposit and interest rate restriction fund, and 

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an introduction to our streamlined consumer 

compliance examination pilot program.

 John Vogel and I will start us off 

with an overview of the FDIC supervisory response 

to the pandemic.

 And on the slide here, we've provided 

a link to a short video that appears on FDIC.gov 

that I would encourage you to take a look at 

after the meeting.

 Within days of the declaration of the 

pandemic by the World Health Organization, we 

encouraged financial institutions to work with 

their customers and communities affected by 

COVID-19 and we provided them the flexibility to 

do so.

 Specifically, we stated that an 

institution's prudent efforts to modify terms on 

existing loans for affected customers would not 

be subject to examiner criticism, and we 

committed to working with affected financial 

institutions to reduce burden when scheduling 

exams. 

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We also established a dedicated 

coronavirus webpage to house our relevant 

guidance, rule makings, and answers to questions 

frequently asked by bankers and consumers, and 

that's where you'll find that video that I just 

mentioned.

 Couple of weeks later, we clarified 

that certain loan modifications made in response 

to COVID-19 are not troubled debt restructurings.

 We provided flexibility to enable 

mortgage servicers to work with struggling 

consumers.

 We also made it easier for banks to 

make home equity accessible to consumers by 

allowing for delayed receipt of appraisals and 

clarifying that interior inspections are not 

required.

 We encouraged institutions to use 

their capital and liquidity buffers to support 

small businesses and households, and community 

banks delivered, playing an outsized role in 

pandemic-related government stimulus program, 

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like the Paycheck Protection Program, or PPP.

 As of the second quarter of 2020, 

community banks held a significant 31 percent of 

all PPP loans, compared to 12 percent of total 

industry assets and 15 percent of total industry 

loans. Talk about punching above your weight.

 We've supported banks' participation 

in PPP by arranging webinars for the SBA to 

answer bankers' questions, by posting responses 

to the most frequently asked questions on our 

coronavirus webpage, and by providing regulatory 

clarifications and temporary regulatory relief.

 And we'll get to the question that was 

raised in the first session this morning about 

that temporary relief. We can cover that in the 

Q&A.

 We moved all supervisory activities 

offsite. So that's another thing you mentioned 

earlier today, and we can talk about this in the 

Q&A as well.

 For the first couple of weeks of the 

national emergency, we completely paused our 

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examination program to give bankers flexibility, 

recognizing they were busy responding to the 

needs of their customers, employees, and 

families.

 After that, we offered additional 

options to pause as needed. These pauses were 

well received and we were happy to provide the 

needed flexibility.

 Even with these significant changes to 

our operations, we've maintained our supervisory 

programs for both safety and soundness in 

consumer protection, and we've continued to meet 

all associated statutory requirements and 

internal goals.

 We were able to make the pivot to 

offsite work quickly because of both our prior 

efforts to leverage technology and examinations 

and because of your coordination and cooperation.

 So let me take this opportunity to say 

thank you.

 We increased our communication 

frequency, sharing updates on the guidance we 

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were issuing and answering your questions.

 And we used the feedback that regional 

directors shared from their regular meetings with 

state commissioners and trade associations to 

shape our policy response.

 And because of that, we issued a 

number of rule makings and guidance statements to 

address temporary needs and to implement the 

CARES Act.

 We provided, just as some highlights 

here on the slide, just a few of them.

 We've included a link to our 

coronavirus webpage, where you'll find the FAQs 

and the pandemic-related guidance and 

rulemakings, including those listed here.

 And I'll turn it over to John now to 

give you a more behind the scenes look at our 

conversion to offsite supervision. John?

 MR. VOGEL: Thanks, Doreen. Prior to 

the pandemic, we had already been conducting a 

significant portion of our examination work 

offsite. 

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And because of that, we were able to 

pivot very quickly to our mandatory telework and 

were able to conduct our exams fully offsite.

 We made sure that our team was 

equipped to work offsite, and we provided 

enhancements to the enterprise file exchange that 

facilitated the increased number and size of our 

electronic files.

 The FDIC also provided employees 

flexibilities with their schedule to make 

accommodations for the increased or changing 

responsibilities that our team members had. 

Mike, next slide.

 We also at the beginning of the 

pandemic initiated a number of our continuity 

planning protocols.

 So to make sure that we had enough 

examiner hours to complete our examination work, 

we offered our examination team a leave buy-back, 

which was very successful.

 And it allowed us to complete all of 

our exams on time, as many mentioned. 

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We hired additional entry-level staff 

for conducting loan review, and also to help on 

our IT exams.

 We also rehired some of the folks that 

had previously retired to help us train our newly 

hired examiners in field offices where we had a 

high percentage of precommissioned examiners.

 So, off to Rae-Ann, I think.

 MS. MILLER: Thank you very much, 

John. Mike, can you go to the next slide, 

please? Sorry, guys, I'm having a hard time 

here.

 So I'm going to talk to you guys about 

a few highlights and recent changes to our broker 

deposit regulations and rate restrictions.

 It's important to remember that the 

restrictions on broker deposits and interest 

rates do not apply to well capitalized 

institutions.

 It's also helpful to know that this 

regulation features a lot of changes. It's hard 

to do it justice in the brief time we have. 

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So I'm going to do my best to cover 

it. But I do encourage you to review the reg, 

the preamble, and we've also recently posted some 

Q&As.

 And if you have questions about 

specific arrangements, you can submit them to our 

dedicated mailbox and Mike, we're going to stay 

on this slide for just a minute.

 Our new regulations were approved by 

our board in December of last year. And it 

became effective on April 1, 2021.

 We also provided what we call a full 

compliance date, and that runs through year-end 

2021.

 And the purpose for this full 

compliance date was to allow for those who are 

relying on existing staff advisory opinions and 

FAQs time to change their documents and systems 

to comply with the new rule.

 So after January 1, 2022, those past 

staff opinions and the FAQs will be moved to 

inactive status. 

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We will also point out that with the 

April 1 effective date of the new regulations, 

banks are going to begin to report changes with 

the way deposits are categorized in fall reports 

in the June filings.

 The call is for interagency, and there 

is an interagency process underway to update 

those instructions now.

 So if you could please move to the 

next slide, Mike.

 So this slide summarizes section 29, 

requirements, section 29 of the FDI Act. And it 

really has a broad definition of what is a 

deposit broker.

 And it's important to know that the 

law hasn't changed. And as a very high level 

summary of the restrictions that work in the law, 

remember that well capitalized institutions are 

not subject to restrictions, as I mentioned, 

adequately capitalized banks have to apply to the 

FDIC for a waiver to accept broker deposits, 

undercapitalized banks cannot accept broker 

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deposits, and in addition, banks that are less 

than well capitalized are limited in the interest 

rates that they can offer on deposits.

 So all of these restrictions remain in 

effect, but you're going to see in the next few 

slides, we've changed some interpretations of the 

law. So please move to the next slide.

 So as you know, broker deposit is a 

deposit received from or facilitated by a deposit 

broker.

 So we begin our analysis with 

determining who is a deposit broker. And we made 

some revisions there.

 A deposit broker analysis is now based 

on the relationship between the person placing or 

facilitating the placement of the deposit and its 

customer, not the relationship between the person 

and the IDI.

 And under the revised rule, if an 

entity has an exclusive deposit arrangement with 

only one bank, including one affiliate, and is 

not placing or facilitating the placement of 

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deposits at any other bank, it is not a deposit 

broker.

 However, if the entity has a deposit 

arrangement with more than one bank, the entity 

is a deposit broker unless it's excluded under 

other parts of the definition of deposit broker.

 If the entity has an exclusive deposit 

arrangement for one business line with one bank 

or places deposits at other banks in another 

business line, it is also a deposit broker, but 

may be eligible for a Primary Purpose Exception. 

I'm going to discuss that in a few slides.

 And if an entity uses multiple 

entities, placing deposits at different banks in 

an effort to evade this rule, it will be 

classified as deposit broker.

 So another change in the deposit 

broker analysis is that to be a deposit broker, 

the person must have a business relationship with 

its customers and be engaged in the business of 

placing or facilitating the placement of deposits 

as part of that relationship. 

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So the FDIC is no longer focusing on 

the relationship between the third party and the 

bank.

 So even if the bank is paying the 

third party, that's not necessarily indicative, 

that reason alone, that would cause the deposits 

to be broker.

 So the revised rule now defines 

facilitating the placement of deposits. And a 

person is facilitating the placement of deposits 

if the person has legal authority, contractual or 

otherwise, to close the account or move the 

customer's funds to another bank, the person is 

involved in negotiation or setting rates, fees, 

terms, or conditions for one or more specific 

deposit account, but that doesn't including 

marketing or consulting services that help a bank 

determine rates that are applicable to deposit 

accounts generally, and then the third prong is 

that the person engages in matchmaking.

 Matchmaking is defined as proposing 

deposit allocations at or between banks based 

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upon both a particular deposit objective of a 

specific depositor and the particular deposit 

objective of specific banks.

 And so matchmaking does not include 

deposits placed by a depositor's agent with a 

bank affiliate or with a depositor's agent, which 

would include depositors' subsidiaries, parents, 

and other affiliates.

 Matchmaking also does not include 

third parties that provide administrative 

services as part of a deposit sweep program 

between a depositor broker/dealer and 

unaffiliated banks.

 That is, a third party may assist in 

the placement of sweep deposits with unaffiliated 

banks, but does not propose deposit allocations.

 So matchmaking does include an 

affiliated third party that meets a deposit 

broker definition that places deposits with 

assistance of another person engaging in 

matchmaking activities.

 So for example, if a third party with 

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a Primary Purpose Exception sweeps deposits to 

unaffiliated banks, those sweep deposits would 

not be brokered if the same third party uses and 

intermediate that fits the definition of deposit 

broker to place the deposits at unaffiliated 

banks.

 Excuse me. If the same third party 

uses an intermediary debt fix, the definition of 

deposit broker who placed deposits with 

unaffiliated banks, those deposits would be 

brokered.

 So let's move to the next slide, 

please. Make sure I'm on the same slide here. 

Yes. Thank you, Mike.

 So we're going to talk about the 

Primary Purpose Exception. We call this the PPE. 

So in the law, there are still nine statutory 

exceptions. And we created one regulatory 

exception to the definition of a deposit broker 

some time ago.

 So the new rule has only affected 

interpretation of the statutory Primary Purpose 

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Exception.

 And so remember that the Primary 

Purpose Exception is only applicable if an entity 

fits the definition of a deposit broker and no 

other regulatory (video interference) applies.

 So by the statute, a Primary Purpose 

Exception is only permitted when the primary 

purpose of the agent or nominee's business 

relationship with its customer is not a placement 

of fund with depository institutions.

 So under the revised rule, the PPE is 

applied separately to each business line, and the 

rule now includes a list of designated 

exceptions, we created that terminology, that 

automatically will receive PPE.

 So as you see on this slide, for two 

of the designated exceptions for PPE. The rule 

has created new notice process.

 And so an entity should submit a 

notice if the entity wants to provide a PPE, 

either under the designated exceptions, 25 

percent of assets test, or the enabling 

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transactions test.

 So the 25 percent of assets test 

designated exception is applicable to an entity 

that has less than 25 percent of its total 

assets, if the agent or nominee has an under 

administration towards customers placed at 

depository institutions.

 For example, a broker/dealer's sweep 

programs may qualify. And entities qualifying 

under this exception are required to submit 

quarterly reports to demonstrate that they 

continue to qualify for the PPE.

 Now, the enabling transaction test is 

the other designated exception that requires a 

notice.

 This test, this exception applies to 

entities for which 100 percent of the depositor's 

funds that the agent or nominee places or assists 

in placing at depository institutions, are placed 

into transactional accounts that do not pay any 

fees, interest, or other remuneration to the 

deposit. 

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For example, accounts set up by 

prepaid card program managers may qualify for 

these enabling transactions exceptions.

 Entities qualifying under this 

exemption are required to submit annual 

certifications. Now, please move to the next 

slide.

 So this slide shows the other 

designated exceptions, and these don't require a 

notice and would not be considered brokered so 

long as a third party is not involved in placing 

the deposits.

 It's important to know that if an 

entity does not fit one of these PPE designated 

exceptions we just talked about in these two 

slides, it may file an application seeking to 

obtain a PPE.

 For example, a situation where 

placement of deposits does not fit the enabling 

transactions designated exception, because the 

bank pays interest to the underlying depositor, 

in this case the third party or bank on behalf of 

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a third party, could submit an application if it 

wanted to rely on the PPE designations.

 Two more things I wanted to talk about 

before I move to interest rate restrictions that 

are application for less than well capitalized 

banks.

 There is a lot of information here, 

and we would refer you to our website for the 

notice and application filing procedures.

 We debuted a new website on April 1, 

and we're also working on a more streamlined 

process for the notices and applications.

 And I wanted to note that the changes 

in the regulations do not impact broker's fees. 

They are still brokered.

 The rules also do not change our 

supervisory process. It is true that the changes 

in the regulation may mean that some deposits 

that are currently reported as brokered will not 

be reported as brokered going forward.

 But examiners will still review the 

funding structured banks to the extent there's 

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concerns, including concentrations concerns. 

They will be noted as part of the supervisory 

process.

 And the rule also doesn't affect our 

enforcement authorities under section 8 or 

section 39 of the FDI Act.

 Now, let's go to the next slide, and 

we'll talk a little bit about the interest rate 

restrictions that are applicable for less than 

well capitalized banks.

 So the revised rule also changed the 

interest rate restrictions. We also created a 

new section of our regulations, 337.7, and split 

out the broker deposits from the interest rate 

restrictions.

 The first change is to the national 

rate. So the national rate has changed based on 

market share versus branches, and now includes 

credit unions in the calculation.

 The national rate cap has also 

changed. So for CDs and other deposits with a 

maturity date, the national rate cap is the 

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higher of, one, the national rate of 75 basis 

points or the U.S. Treasury security rate (video 

interference) plus 75 basis points.

 For non-maturity products, the weight 

cap is now the higher of the national rate plus 

75 basis points or the Fed Funds rate plus 75 

basis points.

 So let's move to the next slide, and 

this slide is dealing with the local rate. I 

would say first of all, we anticipate that far 

fewer institutions have become less than well 

capitalized that will rely on the local rate 

because the national rate is intended to be much 

more flexible.

 But the FDIC simplified the process 

for banks that do wish to use a local rate. So 

banks will no longer have to request and the 

addressee will no longer make high rate 

determinations.

 And banks won't need to calculate 

averages from all IDIs in their market area and 

calculate a local rate cap. 

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Instead, as a local rate, the bank can 

offer up to 90 percent of the rate of another IDI 

with a physical presence in its market area is 

offering for local deposits.

 As part of this local rate 

determination, the bank must notify their 

regional office that it's using a local rate, 

needs to recalculate the local rates monthly, and 

maintain records for at least two examination 

cycles as part of a regulation.

 So moving to the next slide, just a 

point that another change affecting both national 

and local rates is that interpolation or 

extrapolation of rates for off-tenor maturities 

is no longer needed.

 If there is no national rate posted 

and no local rate with the same maturity, the 

bank by regulation is required to use the next 

lower posted or offered maturity.

 So moving to the next slide, I'll just 

cover this quickly. This is our reminder that 

the rate caps are not applicable to less than 

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well capitalized banks.

 And moving to the first slide talking 

about non-maturity deposits. So the revised rule 

clarified restrictions related to the treatment 

of non-maturity deposits, which non-maturity 

deposits were contemplated when the law was 

written.

 And under the law, remember that a 

less than well capitalized institution may not 

solicit deposits by offering a rate above its 

rate cap or accepting broker deposits.

 So for non-maturity deposits, the rule 

clarified that an institution solicits a nonmaturity deposit when it opens a non-maturity 

account, raises the rate paid on a non-maturity 

account existing when the institutions was last 

well capitalized, or credits funds for a new 

depositor for a non-maturity account existing 

when the IDI was last well capitalized.

 So moving on to the next slide. This 

is talking about accepting. So an IDI that is 

less than well capitalized accepts a non-maturity 

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broker deposit from a particular deposit broker 

when they're opening any new account, nonmaturity account, when the account balance 

exceeds the account balance at the time the 

institution was last well capitalized. 

And then for agency or nominee 

accounts, when the institution credits any funds 

for a new depositor to a non-maturity account.

 So let's move to the next slide. This 

is talking about institutions with a waiver. A 

less than well capitalized institution with a 

waiver to accept broker deposits may not pay 

interest in excess of the appropriate rate cap.

 Again, for particular deposit broker 

on any new non-maturity accounts or for any 

amount of funds exceeding the account balance at 

the time the institution fell to less than well 

capitalized.

 And then for agency and nominee 

accounts, similarly, any funds for a new 

depositor.

 And so slide 25 is our list of 

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resources. I went through this very quickly, as 

I mentioned, but this is certainly our effort to 

modernize the regulations and streamline them and 

clarify some issues where we received a lot of 

questions.

 And so as we go through this 

implementation, I encourage you to, like I said, 

look at this list of resources and look at our 

website.

 And if you have any questions, please 

submit them through the website. We're happy to 

answer them.

 So with that, I think I'm going to 

turn it over to Chris.

 MR. FINNEGAN: Okay, well, thank you, 

Rae-Ann. And what I'm going to discuss with you 

all today just real quickly is to give you some 

insight on our reported exam on the consumer 

compliance side, because you might be receiving 

communication from us differently going forward, 

particularly involving how we're going to 

actually write and present the consumer 

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compliance findings to banks.

 And so first, I want to say that while 

we are actually changing the way we do our 

consumer compliance report, and the reason we're 

doing it and testing it out in this pilot that 

I'm going to go over, is we're always looking for 

ways to improve the way we communicate with our 

banks, to make ourselves more efficient, and make 

sure, well, the biggest thing is that you get 

something out of that report, that the findings 

of the exams and any recommendations that might 

come out of it, we want to make sure that it is 

helpful to you as we go through that process.

 So, and this is what this is going to 

be. And so what had happened was, we've had a 

kind of one standard report that we've had for a 

while.

 And we got some feedback and we 

noticed that some of these reports were quite 

lengthy, even for our lower risk institutions 

that hadn't had much changes since the last exam.

 So we looked at it and we decided to 

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move forward with perhaps changing the way we'll 

do our reports for certain low risk institutions 

going forward.

 But again, with the point being to 

have effective communication with our 

institutions. So, Mike, if you could go to the 

next slide, please.

 So what we're going to do, and I want 

to point out before I get into the things that 

are on this slide here, that this is, I'm just 

talking about the way the report's going to look, 

the way the findings will come back to your 

institution.

 It's not going to change the way we're 

doing our exams. We're still going to do our 

consumer compliance exams the way we always have.

 They're going to be risk scoped, where 

we'll focus in on the highest risk areas for 

potential consumer harm. That's not going to 

change as part of that.

 Also what's not going to change is 

your CRA public evaluation. That will still be 

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the same format that we used historically.

 This is dealing with our consumer 

compliance report. And so what we're going to 

do, we had a pilot last year that we did.

 So some of your banks may have 

actually even received a streamline report back 

there. And so we got some feedback, both from 

our examiners as well as from banks that were 

part of the program.

 The phase one was basically a letter 

that we sent to certain institutions. It wasn't 

really in a report format.

 It was more of just a combined letter 

that we sent, a couple pages long. And the 

feedback that we got, we probably would want more 

of a report, actually, versus just a letter.

 That was the feedback we actually got 

from the banks as well.

 So what we're going to do is we're 

going to pilot another version of this starting 

with exams that start May 1 through June 30. So 

about a couple weeks from now, we're going to 

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start this.

 Again, what the purpose is to have 

exam efficiency and more timely turnaround. We 

want to make sure we're getting that report out 

as soon after the exam as we can.

 And we believe that this will help. 

But again, we also want that report to have good 

information in there for you. So it's a balance 

there that we're going to have through that.

 Again, I want to mention that there's 

going to be no changes in our exam process. The 

way we're going to do it again is just the format 

of the report going forward to hopefully again be 

more timely, efficient, and to get the 

information we need to you as quickly as we can.

 So, Mike, if you can go to the next 

slide, please.

 These, I did mention there was going 

to be, for certain low risk institutions, this is 

what we're going to be using during this phase 

two of the pilot.

 The ratings have to be satisfactory 

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for both compliance and CRA, no what we call the 

level three, those are our most severe 

violations, no UDAPs, anything like that when we 

do our standard reports, would not be eligible 

for a streamlined report.

 No civil money penalties, no repeat 

level two violations. There could be some 

violations that are level two, but if there's 

repeat in there, it would not be eligible.

 And if there's restitution of more 

than $1,000. So those are some of the 

eligibility criteria that we'll have for this 

report going forward for this pilot. Mike, if 

you'd go to the next slide.

 Again, like I mentioned earlier, it's 

just mainly going to be the format change on 

there. Our first phase, we did it as a letter.

 This new phase, this new pilot, is 

actually going to look more like a report. It's 

going to have a cover.

 It's going to have a compliance 

management description in there. There'll be a 

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transmittal letter.

 But it will be much more concise than 

what our standard report would be. Again, this 

is for our lower risk institutions that haven't 

had much change since the last exam.

 We feel that this will be a good way 

of still getting the exam findings out to you in 

an effective manner, but just in a different 

format. So, Mike, next slide, please.

 So I mentioned that this was going to 

be a pilot. And so part of that is we'll be 

getting feedback from our examiners.

 But the most important feedback, of 

course, that we'll have is from the bankers and 

the banks that participate during this couple 

month period that we're going to have.

 So we have a process that we'll be 

asking for to see how the report is taken by the 

institution.

 Does it provide enough information to 

the bank about the consumer compliance exam that 

we did? 

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So we're going to encourage that 

throughout that process. And then once we get 

that, then we'll decide whether or not we're 

going to make this a permanent part of our tools 

that we use for our reports going forward.

 And we should know that hopefully some 

time later this summer after we get that 

feedback.

 Now, at the same time that we're doing 

the streamline report, we're also looking at our 

standard report.

 That is something that we have not 

changed in several years. So we have a project 

going on right now that we're looking at that to 

see, in the cases where it's not going to be a 

streamline report, is our standard report getting 

the feedback and communicating back to you the 

results of your exam, any recommendations or 

findings?

 Is it effective? And so we're looking 

at that as well at the same time. So once we get 

the feedback from the streamline report and this 

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project that we're doing for the standard report, 

we'll be able to see what our report's going to 

look like going forward.

 So again, we always encourage to 

provide us any feedback. This is your report 

that comes out after a long process from pre-exam 

planning to the onsite that we do, from where 

we're actually looking at things during an exam.

 We're pulling the report together. 

This is a key part of that written document that 

we provide back to you, so we want to make sure 

we get whatever feedback on that.

 So that was a quick highlight. Some 

of you all might get this report going forward 

during this pilot.

 And if we do implement this on a 

permanent basis, you may see this going forward. 

So we always ask for your feedback on that.

 All right, Mike, I think we go to the 

next slide. I think now it's time for questions.

 MS. KEA: Thank you to Doreen and the 

team. I would invite the members, if you have 

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any questions at this time, please either raise 

your hand or you can just turn your camera on.

 MS. EBERLEY: Arleas, maybe while 

we're waiting I can as Bobby Bean to address the 

comments that were raised in the opening session 

on the community bank leverage ratio.

 MS. KEA: Thank you, Doreen. Bobby?

 MR. BEAN: Yes, can you hear me?

 MR. EBERLEY: Yes, we can.

 MR. BEAN: Yes, there was some 

questions concerning how the FDIC and the other 

agencies are thinking about the CBLR, 

particularly as there's a large amount of deposit 

growth and a kind of increase in PPP lending.

 And we understand that deposit growth 

and participation in PPP lending has led to us a 

significant balance sheet growth across community 

banking organizations.

 And that has a potential compliance 

challenge to CBLR requirement, particularly as it 

transitions back to 9 percent.

 The FDIC along with the other agencies 

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will actively monitor banking conditions, 

including assessing balance sheet dynamics, 

reserve levels, and the potential strain on 

community banking organizations.

 Now, we want to ensure that the CBLR 

framework serves to reduce regulatory burden for 

qualifying community banking organizations.

 But we want to make sure that it does 

so in a manner that is consistent with safety and 

soundness principles and the goal of providing 

credit to household and businesses over a range 

of economic conditions.

 So we will be continuing to monitor 

conditions and the issues as it progresses and 

will consider actions from there.

 MS. KEA: There was a question from 

Steve Hayes. Steve, did Bobby answer your 

question or is there more information that you 

would like?

 MR. HAYES: No, he answered my 

question. Can you hear me okay?

 MS. KEA: Yes. 

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MR. HAYES: Yes, I asked the question, 

so, from my understanding now, it's considered 

expired as of March 31 and you're just going to 

the situation? As of today, it has expired. Is 

that correct?

 MR. BEAN: Yes, as of today, we are 

back into the transitioning provision, back to 

the 9 percent, and we will continue to monitor 

conditions and the situation as we move forward.

 MR. HAYES: Okay. Thank you.

 MS. KEA: Doreen, I think there was 

also a question, one more question from Bruce 

Lowry. Bruce?

 MR. LOWRY: Hello, thank you. I just 

was curious, back on the broker deposit 

discussion, and let me just start off by thanking 

the FDIC for looking into that topic and for the 

changes that were made.

 But I think there's some thought, 

especially with some community banks, that 

perhaps things didn't go far enough, and 

particularly in the area of looking at the 

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national banks and the weighted portion of the 

deposit that they make up.

 I don't know the exact numbers but 

it's somewhere in the neighborhood of 80 percent 

of deposits are held by the largest national 

banks.

 Community banks have something like 20 

percent. And so that's heavily weighted. And 

when you really look at rate offerings by 

national banks versus credit unions and community 

banks, there's a large disparity.

 So I was just curious if that was a 

topic that would ever be looked at again in 

something similar to that light or maybe have 

more comment period for banks to be able to input 

on that.

 MS. MILLER: Yes, I appreciate that. 

We did look at those issues and we also worked 

with our economists, of course, on this 

regulation.

 It's quite a heavy lift. The law 

requires a market rate and it is true that the 

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larger institutions control more of the market.

 Make some changes based on comments 

received. So in my area, we added credit unions, 

which was a big comment.

 And we also, the national rate is just 

one piece of the puzzle, right? What attaches 

when institutions become less than well 

capitalized is the rate cap.

 And so we created additional 

flexibility within the rate cap of providing for 

the higher of the national rate plus 75 basis 

points or a comparable treasury rate plus 75 

basis points.

 So we felt that those things combined 

provide a very robust way for institutions that 

are less than well capitalized to, within the 

law, compete while still being restricted.

 There's also a much more flexible 

local rate cap for those institutions that wish 

to compete locally with specials and different 

types of maturities and things of that nature. 

So hopefully, that answered your question. 

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MR. LOWRY: I just express that part 

of the concern of that comes from the definition 

of well capitalized is a bit subjective in an 

exam.

 I mean, you can meet the statutory 

numbers and still be deemed not well capitalized. 

So there's a subjective nature to that that could 

be problematic.

 Right now, we all have more liquidity 

than we need, so it's not really an issue at the 

moment, but --

MS. MILLER: Just so you know, it 

should not be subjective to what well capitalized 

is. Well capitalized is well capitalized.

 It's what your capital ratios are. 

They're defined by regulation. There is a quirk 

in the PCA with respect to enforcement actions, 

but it is not a subjective calculation.

 And if you're finding subjectivity 

with respect to your capital calculations and 

your deposit, we would want to know about that 

because that's not appropriate. 

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MS. KEA: I think I saw one additional 

hand from Hal Horvat.

 MR. HORVAT: Yes, thank you. My 

question is more I think for Doreen and John. I 

certainly agree that the FDIC did a great job 

when the pandemic hit, and particularly in terms 

of the guidance that were issued.

 We had a great relationship with the 

Boston office here. They reached out to us and 

we had some significant conversations.

 Since that time, or do you anticipate 

any further guidance happening now that we're a 

year into this or more than a year into this?

 And can you give us any insight into 

how exams are being handled specifically with 

regard to asset quality?

 Because we're now starting to see 

financial statements from last year showing 

reduced income and companies not meeting their 

financial covenants.

 And just curious as to what you're 

seeing relative to exams and how those are being 

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treated.

 MS. EBERLEY: Sure. I'm happy to 

start and I'll ask Rae-Ann to weigh in. We're 

not seeing significant asset quality 

deterioration.

 There are certainly some. And we're 

seeing, as Camille noted earlier in the day, we 

are seeing some institutions, we're seeing some 

DOW rates and internal rating systems.

 So institutions themselves are 

recognizing increased risk among some borrowers 

for some of the situations that you named.

 And so we're seeing a little bit of 

that migration. Not a meaningful amount. Not 

anything that's leading to significant changes in 

composite ratings.

 There's always a one off, but there's 

no trends, no discernible trends, I guess would 

be the best way to say it, coming from all that.

 That said, we have to continue to look 

at assets the way we've always looked at assets, 

right? 

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You have to recognize if a loan's not 

going to be repaid or if you don't expect full 

payment, regardless of whether you're calling it 

a troubled debt restructuring or not, if those 

facts bear out, if you don't expect to get full 

repayment, you need to put the loan on amount 

accrual, you may need to take a partial charge 

off.

 You may need to rework the note. And 

so those are the kinds of things we're hearing a 

little bit about from our examiners, that bankers 

are going through some of those conversations 

now.

 We do want to update some existing 

guidance on commercial real estate workouts, and 

that's a topic interagency that we are working on 

that we think may be of some need later on this 

year or as time continues to pass.

 But those are the sorts of things that 

we're talking about. And I'll ask Rae-Ann to 

weigh in with anything more she may have.

 MS. MILLER: I think you did a good 

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job, Doreen. Remember, we issue guidance to you 

guys, but we also issue instructions to our 

examiners and we conduct training for our 

examiners.

 We're used to examining during crises. 

We've had hurricanes and wildfires and things 

that affect local areas. This is obviously a 

much bigger issue.

 So our instructions to examiners, 

they're publicly available. You can read them, 

go through them, and get an idea of what they're 

looking at.

 But essentially, they're looking at 

risk management and risk assessment. And even in 

the case where loans might meet the definition of 

substandard or worse, there's some longer-term 

situations that may not improve in the term, as 

long as risk management is doing what they need 

to do to improve the situation, that's a good 

thing for both the bank and the borrower. 

So that's what we instruct our 

examiners. We train them, we go through 

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nationwide training programs, we use scenario 

analysis, we return to questions, we talk in 

small groups with them.

 So we do what we can to try and keep 

up with how things are going. But I would say 

one thing that really boded well, Shayna alluded 

to this, that we were sitting here a year ago, we 

thought things would have been much worse.

 Banks went into the crisis I think 

with pretty strong risk management frameworks, 

healthy levels of capital and strong earnings.

 And so all of those things sort of 

served the system very well when these troubles 

hit. So that's all I have to add, Doreen.

 MS. KEA: Doreen, we do have one more 

question. Mark Pitkin. Mark, just checking in 

with you. Did you have a question?

 MR. PITKIN: I was on mute. I am so 

sorry. First and foremost, I want to thank all 

the folks in supervision for their supportive 

attitudes and supportive tact toward banks the 

last 12 to 18 months. 

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I sit on a number of local as well as 

national committees and organizations and I have 

not spoken with one banker that wasn't basically 

impressed with the way that their examinations 

went.

 So again, thank you so much for that. 

My question may or may not necessarily be to you, 

Doreen, but I didn't see anywhere else in the 

agenda to ask the question.

 And it may be more of a policy 

question. And I think Sarah hit this topic. But 

it's the topic of these Fed accounts.

 So this is a significant concern, 

certainly for myself and other local community 

banks, that we've worked so hard to make sure 

that we avail our accounts to each and every 

person in our rural communities and we make every 

effort to make sure that they have the 

availability to be banked.

 And one of our biggest concerns is 

this discussion about sort of these competing Fed 

accounts. Certainly, if it's from postal 

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delivery.

 So most of our branches, like I 

indicated, are in small communities, and 

unfortunately, right next door is the postal 

service.

 So I am just wondering if someone had 

any thoughts, and again, Doreen, it may be you or 

maybe someone in supervision as it affects sort 

of risk, or it may be more on the policy side.

 But what are the thoughts of the 

corporation with regards to the possibility of 

these competing Fed accounts, and how do you see 

that affecting community banks going forward 

that, again, worked so hard in order to get and 

retain those deposits of our localities to each 

and every individual?

 MS. EBERLEY: Thanks for the question. 

I think I can't give you an answer to that. I 

can just say that the competitive landscape is 

always changing for community banks and there's 

always a new competitor around the corner.

 And I think one of the strengths that 

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community banks bring to the table is the true 

focus on the community and the consumers in the 

community and the range of services that are 

provided.

 So it's not just a depository account. 

It's the opportunity to create a relationship 

where the consumer can get borrowings, maybe 

other products and services from the institution, 

but truly that relationship with the institution 

for the full range of services that are available 

that are a real competitive strength for 

community banks and have been.

 MR. PITKIN: Okay. Thank you. I just 

was curious as to, again, all your thoughts on 

community banks competing with the federal 

government in some of these instances. So, thank 

you.

 MS. KEA: Thank you, Mark. And thank 

you. Let's see. Mark Pearce.

 MR. PEARCE: Thank you. If I could 

just add on, Arleas, to Doreen's comments about 

community banks serving the banking needs of 

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their customers.

 I wanted to just mention for this 

group's awareness, we have been working pretty 

hard here at the FDIC to help consumers be aware 

of their options, be part of the business with 

them and have an account at an insured 

institution.

 So just in the last week or so, have 

launched what we're calling a Get Banked 

campaign. We have a website that is directed to 

consumers to help them understand what are the 

benefits of having a bank loan with an insured 

institution and help them think through what 

their options are related to that.

 Many banks have been offering accounts 

that are low cost, without some of the fees that 

maybe have not been successful for people living 

paycheck to paycheck in the past.

 And so now I think it's probably the 

best time for consumers to take a look at what 

options are available for them now, especially in 

a time when we have had a lot of federal 

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benefits, economic impact payments, and other 

things that are being directed to consumers and 

recognizing that if you have a bank account and 

that account is part of the tax information with 

the IRS, you can get your funds direct deposited 

into that account much quicker than you would if 

you're going to rely on paper checks or a card or 

things sent by mail.

 So there are more benefits than ever 

around having an account at an insured 

institution. So that's something that we've been 

trying to do our part to increase awareness of.

 MS. KEA: Thank you, Mark. That's 

very helpful information. Thank you. I don't 

see any additional hands.

 And like so many of the conversations 

that we've started this afternoon, they are the 

beginning of conversations and could go on for 

more. But we will move on in the agenda at this 

time.

 Let me just say, it does appear that 

we are running possibly about 10 to 15 minutes 

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behind.

 We would like to be able to complete 

the other information that we have to give to 

you. So if you all don't mind, please forgive us 

if we run just a few minutes over.

 We'll try to turn it over to the 

chairman for her closing remarks at about 5:10 or 

5:15.

 So at this time, I'd like to present 

to you John Anderlik, who is our Assistant 

Director of National and Regional Risk Analysis 

from the Division of Insurance and Research.

 And John is going to share a research 

update, which focuses on the FDIC's Community 

Bank Study and Agriculture Lending. So John, the 

camera is yours.

 MR. ANDERLIK: Thanks, Arleas. So, 

yes, today I'm going to be discussing a couple 

projects from the FDIC's Division of Insurance 

and Research.

 The Community Banking Study, which we 

published in December, and the FDIC Quarterly 

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Paper on Agriculture, which we published last 

month.

 Today I'll cover both of these 

projects at a fairly high level. Mike, let's 

turn to the first slide.

 We'll start with the Community Banking 

Study. The FDIC's first Community Banking Study 

was published in 2012.

 That study had two primary goals, to 

define community banks beyond the simple asset 

size, such as $1 billion, and compare the 

characteristics and performance of community 

banks with those of non-community banks.

 That paper, a long study period from 

1984 to year end 2011. This study builds on 

several of the themes from the original study, 

bringing them forward through year end 2019.

 It also includes two issues that were 

not covered in the original study, regulatory 

change and technology, and their effects on 

community banks.

 I'm going to take a quick walk through 

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each of the study's six chapters today. But one 

thing before we get to Chapter One.

 Though the study goes through year end 

2019, we felt it would be remiss if we didn't 

mention 2020's pandemic.

 So each chapter includes an inset box 

that discusses the pandemic and its community 

bank effects on the issue studied. Next slide.

 Chapter One covers the financial 

performance of community banks from 2012 through 

2019.

 Overall, community banks have 

performed pretty well. We begin the chapter by 

showing that community have banks have reported 

steadily increase pre-tax ROA since the 

conclusion of the prior study, reaching 1.44 

percent in 2019, up from 1.05 percent in 2012.

 However, similar to the conclusion 

that was reached in the original study, noncommunity banks continue to report higher 

earnings overall than community banks, primarily 

because non-community banks have a large 

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advantage of generating non-interest income. 

But the gap in pre-tax ROAs narrowed 

to just 22 basis points by year end 2019, down 

from 43 basis points when we started this study 

in 2012.

 Community banks do have two advantages 

of financial performance over non-community 

banks. First is higher net interest margins.

 As you can see from the chart, 

community banks have had an advantage over noncommunity banks since 2010.

 Second is credit quality, as measured 

by credit losses. The full year charge off rate 

reported by community banks reached a post-crisis 

low of 0.13 percent in 2019, which was 45 basis 

points below the rate reported by non-community 

banks. Let's turn the slide.

 Chapter Two focuses on the structure 

of community banks. Consolidation continued 

between 2012 and 2019, with non-community banks 

consolidating at a faster rate than community 

banks. Consolidation was led my voluntary 

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mergers by unaffiliated institutions.

 Two differences stand out in the 

examination of consolidation trends in this study 

versus that of the prior study.

 First, from 2012 through 2019, the 

number of new banks formed each year declined to 

post-1984 lows. 

Second were fewer new institutions 

replaced those that were acquired or closed. The 

rate of net consolidation increased from 3.2 

percent annually from 1984 to 2011 to 4.3 percent 

between 2012 and 2019.

 The chart shows over two-thirds of the 

community banks that closed between 2012 and 2019 

was because of merger, failure, or other 

voluntary closing, did so because they were 

acquired by another community bank.

 The smallest community banks were 

those under $100 million in assets, were highly 

likely to stop operating because they were 

acquired by another community bank.

 But even among community banks with $1 

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billion to $10 billion in assets, nearly one of 

every five that ceased operation did so because 

they were acquired by another community bank. 

Next slide.

 Chapter Three examines demographic 

change. This is an important issue to assess 

because as demographics change, community banks 

see changes in their client bases and loan 

demands.

 The two major demographic factors 

considered in this study are median age and net 

migration flows.

 True to these metrics, we looked at 

the counties in the highest and lowest quartiles 

for each metric.

 The map shows both counties, I'm 

sorry, the map shows those counties that were in 

either the highest or the lowest quartiles for 

both of the measures we studied.

 Dark blue counties are the youngest 

median ages and the highest net population 

inflows. These counties tend to be located in 

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metro areas.

 Our study found that community banks 

headquartered in such counties experience faster 

asset and loan growth rates, are more profitable, 

and have larger shares of business loans than 

other community banks.

 At the other end of the spectrum, the 

dark gold counties were in the oldest quartile 

and had the lowest net inflows, actual net 

outflows of about 0.4 percent per year. These 

counties tend to be rural.

 Community banks headquartered in these 

areas grew more slowly and lower commercial 

lending portfolios. They also have higher 

deposit to asset ratios.

 The chapter also includes a large 

inset box on rural population, which is a key 

topic for the dark gold counties.

 The FDIC has published two papers on 

that topic since 2004. Next slide, please.

 Chapter Four discusses three notable 

lending strengths of community banks. At year 

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end 2019, community banks in aggregate held small 

shares of the banking industry's assets and 

loans.

 Just 12 percent of the total industry 

assets and 15 percent of total industry loans. 

Yet community banks are key providers of CRE 

loans, small business loans, and agricultural 

loans. The next three slides cover these areas.

 We'll start with CRE. Community banks 

hold 30 percent of the banking industry's CRE 

loans.

 The chart shows how community bank CRE 

lending overall is outsized compared to their 

assets.

 CRE lending is widely distributed 

among community banks, with almost all of them 

holding some amount of CRE loans and many holding 

substantial portfolios.

 Community banks are active lenders to 

a wide range of industries, including industrial, 

retail, and hotels.

 And community bank multi-family 

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lending grew in the years between 2011 and 2019. 

If it is the lending across industry types, 

community banks have been active CRE lenders 

across all sizes of markets as well.

 In 2019, community banks headquartered 

in rural and small metro areas held more than 

two-thirds of CRE loans held by all banks 

headquartered in those small geographic areas.

 In larger metro areas, community 

banks' share of loans was smaller but still 

material.

 One final note on this topic, the 

share of community banks that the FDIC considers 

CRE specialists increased over the study period.

 These CRE specialists are particularly 

important providers of CRE loans in small 

communities. Next slide, please.

 The second area of lending strategy 

for community banks is small business lending. 

At year end 2019, community banks held 36 percent 

of the banking industry's small business loans.

 During the period covered by the 

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study, community banks' share of small business 

loans declined per call report data.

 You can see in the chart that noncommunity banks grew their business loans across 

loan sizes while community banks' business 

lending remained flat across the lending 

spectrum.

 But call reports don't tell the whole 

story. Call reports are based on the size of the 

loan, not the size of the borrower.

 In response to the 2018 FDIC Small 

Business Lending Survey, many bankers said their 

CNI loans were extended predominantly to small 

businesses regardless of the size of the loans.

 This supports the widely held belief 

that at community banks, many CNI loans above $1 

million are in fact loans to small businesses.

 Another data source that supports that 

community banks continue to be active lenders to 

small businesses is the SBA.

 The SBA 7(a) program guarantees loans 

originating up to $5 million. Community banks' 

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share of loan originations increased from 38 

percent of total originations in 2012 to 46 

percent in 2019, and many of those loans were 

above the $1 million call report threshold. Next 

slide, please.

 The third area of lending strength for 

community banks is agricultural lending. 

Community banks play a key role in financing the 

U.S. agricultural sector, funding roughly 31 

percent of total U.S. farm sector debt in 2019.

 About a half of community bank 

agricultural lending is held by community bank 

agricultural specialists, and we focus on these 

institutions in the chapter.

 These banks tend to be small and 

rural, with a median asset size of just $128 

million. 75 percent have total assets of less 

than $250 million.

 An important point we make in this 

chapter is that community bank agricultural 

specialists have shown a strong commitment to 

such lending over the years. 

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The chart shows that most agricultural 

specialists have a long history in that role. Of 

these institutions that were in operation from 

January 1990 through year old 2019, over 55 

percent of them were classified as an 

agricultural specialist in at least 28 of the 30 

years.

 In addition, agricultural specialists 

have been community lending to farmers through 

cycles in the agricultural sector.

 From first quarter 2000 to fourth 

quarter 2019, in only two quarters, the community 

bank agricultural specialists as a group saw an 

annual decline in aggregate agricultural 

production loans.

 And they never reported a quarterly 

decline in aggregate farmland secure loans over 

that 20-year period. Next slide, please.

 We'll turn now to Chapter Five on 

regulatory change. The chapter describes 

regulatory changes from the onset of the 

financial crisis in 2008 through 2019 that were 

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relevant to community banks and the effects these 

changes may have had on those banks.

 As shown in Chapter One, community 

banks in aggregate have been performing well, but 

it is often said that regulatory compliance may 

be relatively more expensive for smaller 

institutions.

 In that respect, three issues stand 

out in our research. First, running a small 

residential loan function appears to be becoming 

less economical over time.

 The chart shows that the percentage of 

small mortgage lenders with sustained reductions 

in balance sheet mortgages has been increasing, 

especially since the crisis.

 The chapter examines this issue under 

three different definitions of a small mortgage 

lender.

 The other two trends, the record pace 

at which community banks have been exiting the 

industry since 2014, and what appears to be the 

increase in target asset size of new small banks 

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based on their initial equity, are consistent 

with the presence of scale economies.

 In principle, the need for a 

compliance function is a potential source of 

scale economies. The study makes it clear that 

policy benefits of regulation and how well they 

are achieved are beyond the scope of this 

analysis.

 So nothing in the chapter should be 

viewed as a criticism of the regulations.

 The bottom line of the chapter is 

support for the idea of achieving regulatory 

goals while accommodating, as appropriate, the 

business models of community banks. Next slide, 

please.

 The last chapter in this study is on 

community banks' use of technology, which ties in 

really well with the conversation you had with 

Sultan earlier this afternoon.

 Community banks have adopted different 

technologies, including newer technologies such 

as mobile banking, online loan underwriting, and 

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online loan applications at different rates.

 According to research and community 

banks' own descriptions of opportunities and 

challenges, factors such as banks' 

characteristics, the economic and competitive 

environment, and the attitudes and expectations 

of bank leadership, all play an important role in 

community banks' adoption in technologies.

 The chapter examines how technology 

haves, or those with high adoptions of 

technology, differ from have-nots, or those with 

low adoption.

 The purpose was to shed light on the 

potential motivators, failures, and outcomes 

associated with technology adoption.

 The study uses the results from the 

2019 CSBS Annual Community Bank Survey. Survey 

responses suggest that cost is a significant 

challenge to technology adoption.

 Almost half of community banks used 

the word cost at least one when describing 

challenges. As the chart shows, larger community 

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banks are more likely to have adopted technology 

than smaller banks.

 Just 6 percent of community banks with 

less than $100 million are considered high 

adopters of technology, while 70 percent of 

community banks with assets over $1 billion are 

high adopters.

 In addition, relative to low adopting 

banks, high adopting banks have a higher loan to 

assets ratio, had faster loan and deposit growth, 

face greater competition within their local 

markets, and had more positive outlooks on 

profitability, business conditions, and 

regulatory burdens. Next slide, please.

 Let's turn to the FDIC Quarter article 

on Agriculture that was published last month. In 

the paper, we've taken an extended look at the 

U.S. agricultural sector and the condition of 

farm banks.

 In the first half of the paper, we 

examine the unusually long boom in farm income 

from 2004 to 2013, the period following the boom 

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from 2014 to 2019, and then the turbulent 2020 

that ended up as a positive for the sector.

 In this analysis, we focus on 12 

states in the upper Midwest where everything was 

magnified.

 The farm income boom was more 

substantial in the states, as was the downturn 

that followed the boom.

 In the second half of the paper, we 

examine how the changes in the agricultural 

sector affected farm bank conditions, how bankers 

responded, especially during the boom years, and 

the challenges that persist. Next slide, please.

 While some of the chart that shows 

inflation adjusted U.S. net farm income going all 

the way back to 1960, the chart shows that two 

income boom periods, from 1972 through 1975 and 

then from 2004 through 2013. 

The recent boom didn't reach the pique 

of 1973's income level, but it was far longer. 

During that 10-year period, U.S. net farm income 

averaged $102 billion per year, well above the 

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$77 billion annual average from 1987 to 2003.

 During this period, the sector saw 

substantial price increases across several 

important commodities, including corn, soybeans, 

wheat, cattle, dairy, and hogs.

 Production expenses for things such as 

fertilizer and seed increased during this time. 

And farmland became more expensive to rent.

 But commodity prices rose much more 

than expenses, leading to the higher net farm 

incomes.

 The long period of prosperity ended in 

2014, and strong returns incentivized heavy 

growing in the U.S. and around the globe, putting 

pressure on commodity prices.

 By 2016, average annual prices farmers 

received for corn and wheat were down nearly 50 

percent for their needs, and prices for hogs, 

milk, and soybeans were down by a third.

 Production expenses declined during 

this period, but slowly. The result was a large 

drop in farming, comes from those achieved during 

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the boom.

 By 2019, the sector had stabilized, 

though at somewhat a weak level. Then 2020's 

pandemic initially roiled the sector with 

significant disruptions to food demand and supply 

chains.

 Commodity prices, especially for corn, 

plummeted in April and May. But record 

governmental support combined with late in the 

year recoveries and export and commodity prices 

helped the sector achieve strong overall incomes 

in 2020. Next slide, please.

 Let's turn now to farmland values. 

And I know a few of you mentioned that in your 

opening remarks.

 Farmland represents the largest 

portion of most farmers' assets and net worth. 

You see in the chart the dramatic rise in 

farmland price in the 1970s that preceded the 

agricultural crisis of the 1980s.

 Farmland prices dropped precipitously 

during the crisis and did not begin to grow again 

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until the mid-1990s.

 Not surprisingly, farmland prices grew 

to record levels during the farm income boom that 

began in 2004.

 In contrast to the farmland price boom 

in the 1970s, farmland prices did not fall 

beginning in 2014 when farm incomes declined.

 The combination of low interest rates, 

tight supplies, and a steady demand for farmland 

kept farmland values relatively flat since the 

farm income reminded. 

There was another big difference in 

the farmland price boom of the 1970s and the 

recent boom.

 In the 1970s, the price gains were 

widespread. Farmland values in 20 states at 

least doubled, and another 22 states saw prices 

go up at least 50 percent.

 But in the recent boom, farmland price 

increases were more isolated. Though farmland 

prices rose 81 percent overall between 2005 and 

2015, less than half of all states experienced a 

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run up of 50 percent or more. 

This time, only eight states saw 

farmland prices more than double during the boom, 

and all eight of these states are what we call 

the upper Midwest in our paper.

 I'll get into the upper Midwest more 

in the next slide, but it's the combination of 

three USDA economic regions, the Corn Belt, the 

Lake States, and the Northern Plains. Next 

slide, please.

 In this chart, we focus on the upper 

Midwest and contrast it with the farm income 

performance of the other USDA economic regions.

 This chart shows net farming incomes 

indexed so that the 1987-2003 average is 100. 

The dark blue line represents the upper Midwest.

 The bottom blue line is the aggregate 

of all the USDA economic regions and the shaded 

area marks the range of the other regions.

 In the early 2000s when overall U.S. 

agricultural conditions were weak, upper Midwest 

states had among the lowest net incomes of the 

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USDA regions.

 But then during the farm income boom, 

incomes in the upper Midwest quickly rose and 

outperformed all other regions during that 

period.

 When the farm income boom ended, 

incomes in the upper U.S. swung again, this time 

downward to among the lowest in the USDA regions.

 As the slide shows, incomes in the 

upper Midwest peaked in 2011 and 2013, in which 

aggregate income was nearly 2.5 times its longterm pre-boom average.

 Incomes in the upper Midwest then fell 

by more than two-thirds to reach their bottom in 

2016.

 The swings in income in the upper 

Midwest track the swings in prices of major 

agricultural commodities during that time.

 Corn and soybeans generate the largest 

share of cash receipts in these 12 states, and 

hog and cattle production are also important.

 Prices for all of these commodities 

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increased significantly during the farm income 

boom, and then fell sharply when it ended. Next 

slide, please.

 In the paper, we then turn to the 

condition of farm banks through the farm income 

boom and the subsequent downturn.

 The FDIC has long defined farm banks 

as banks with 25 percent or more of their total 

loans concentrated in agriculture.

 As of year end 2020, there are 1,163 

farm banks in the country representing about a 

quarter of all commercial banks.

 The map shows where the nation's farm 

banks are located, and also that the majority, 

more than 78 percent, are headquartered in the 

upper Midwest.

 It's not surprising that farm banks 

performed very well during the farm income boom. 

You may have noticed that the dates of the boom 

ran over the great recession.

 Since the U.S. agricultural sector was 

so strong during that time, most farm banks 

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continued to report strong earnings and capital 

levels and low levels of past due loans.

 An area that farm banks found 

challenging during the boom was loan growth. 

Since the sector was so flushed with cash, 

farmers began to pay down debt or even selffinance their operations rather than taking out 

bank loans.

 Banks also had to deal with rising 

deposit balance during that time. Next slide, 

please.

 One point we highlighted in the paper 

was how different the behavior of farm bankers 

was during the recent farm income boom compared 

with the 1970s boom.

 In the 1970s, farm bankers responded 

to surging farmland prices by dramatically 

increasing lending to fund expanded farms.

 You can see that in the left panel. 

Farm banks increase agricultural loan 

concentrations in tandem with increases in 

farmland values throughout most of the 1970s. 

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It wasn't until 1979, after several 

years of lower farm incomes and on the cusp of 

the agricultural crisis, that banks reigned in 

their agricultural lending.

 Now contrast that to the more recent 

period shown on the right panel. The median farm 

bank agricultural loan concentration ratio, which 

was already lower than before the boom of the 

1970s, remained low even when farmland values 

soared.

 This was true even in the upper 

Midwest, where farmland values rose higher and 

piqued later. Part of this more muted lending 

reaction to the farm income boom and rising 

farmland values would see as many farmers selffinancing, as I mentioned earlier. 

But farm bankers were also more 

cautious, not wanting to repeat the mistakes made 

a few decades earlier.

 This sentiment has been a common theme 

for farm bankers at outreach meetings conducted 

by the FDIC over the past 15 years. Next slide, 

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please.

 My final slide of the afternoon has to 

do with credit conditions of farm banks. The 

left slide shows the past due an accrual ratios 

for farm banks in the upper Midwest and the rest 

of the country.

 The solid lines are the 90th 

percentiles for both sets of banks and the dotted 

lines are the medians.

 The right chart is similar, but shows 

the net charge off rate. You can see from the 

charts that credit conditions improved 

substantially during the two decades following 

agricultural crisis.

 Then the farm income boom drove 

delinquencies and charge off measures to historic 

lows.

 Though median delinquencies and charge 

offs have edged higher since 2014, they've 

generally remained at or below levels seen 

immediately before the boom.

 Where we have seen increases is in the 

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tail of agricultural banks. The first quarter of 

2020, 90th percentile delinquency rate in the 

upper Midwest was the highest first quarter rate 

since 2003.

 FDIC examiners also noted an increase 

in levels of carrier debt at farm banks in recent 

years.

 Overall, though, farm bank credit 

quality has been resilient since the farm income 

boom ended.

 I'll conclude my agricultural remarks 

with this. Even though the second half of 2020 

and the USDA's 2021 outlook are reasons to be 

cautiously optimistic about the sector, we still 

see some challenges for borrowers.

 For one, overall debt levels are very 

high, but this area so far has been moderated by 

low interest rates.

 In addition, a subset of borrowers, 

what USDA refers to as high leverage borrowers, 

remains at risk.

 It's too early to tell if a strong 

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2020 will be enough to bring these farmers to a 

strong financial position.

 And with that, it's 5:07 Eastern time. 

And I can take any questions you might have.

 MS. KEA: Thank you, John. If you all 

have one or two questions, we have time for that. 

Okay, John, I think that your information does 

contain some contact information for you.

 So we want to thank you for that very 

informative presentation.

 MR. ANDERLIK: Thank you.

 MS. KEA: Let me just turn quickly, 

and as I've said, we've started so many 

conversations that could go on and on, but we 

have come to the end of our, and we are fairly 

late in the day.

 I would like to turn first to Director 

Gruenberg just to see if you have any thoughts 

that you'd like to share before we close.

 DIRECTOR GRUENBERG: Thank you, 

Arleas. Almost everybody, I'll be very brief. 

It's been a long afternoon. 

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I just want to thank you for your 

participation. This committee has now been in 

existence for quite a while and has really proven 

itself to be a valuable asset to the FDIC and our 

supervision of community banks.

 We are the lead federal supervisor for 

the majority of community banks. And community 

banking in many ways is central to the mission of 

the FDIC.

 And you and this committee really have 

contributed in a meaningful way to our ability to 

do our job, never more so than during this 

pandemic.

 So just wanted to say thanks to your 

participation today. Look forward to the next 

meeting of this group.

 And really, thank you for your 

service, both to the FDIC and to your 

communities. Arleas, thanks a lot.

 MS. KEA: Thank you, Director 

Gruenberg. I'd like to now move to Madam 

Chairman and ask you to give us some closing 

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comments.

 CHAIRMAN MCWILLIAMS: Thank you so 

much, Arleas. I'll be very, very brief. Thank 

you all. Your time has been exceptionally 

valuable to us, as has your feedback.

 Before we adjourn, I'd like to thank 

two people whose terms on the committee came to a 

close last month.

 Dick Beshear, Chairman of the Board of 

First Security Bank and Trust Company in Oklahoma 

City, Oklahoma, and Cathy Stuchlik, Chairman and 

President of Clackamas County Bank in Sandy, 

Oregon.

 On behalf of everyone in the FDIC, I 

would like to thank Dick and Cathy for the time 

and effort they devoted to this committee. I 

wish them all the best and look forward to seeing 

the rest of you in July.

 Thank you so much and I hope you can 

get some rest after a very long video meeting. 

Thank you. Bye bye.

 MS. KEA: Thank you, Madam Chairman. 

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Thank you to all of our members. We'll see you 

in July. Bye bye.

 (Whereupon, the meeting in the aboveentitled matter was concluded at 5:10 p.m.) 

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ABA 57:14 

ability 122:21 138:13 

241:11 

able 21:12 23:15 34:20 

36:1 39:17 41:8 56:8 

57:8 70:12 72:2 83:8 

93:6,11 121:1 124:6 

125:5 136:5 137:9 

139:12 149:22 162:6 

168:15 170:1,3 196:2 

200:15 213:2 

ably 17:5 

above- 243:3 

absolutely 137:9 

155:17 156:4 159:16 

162:19 

abundant 130:11 

academic 78:12 

accelerated 69:20 

Accelerator 161:20 

162:4 

accept 17:2 173:21,22 

187:12 

acceptance 116:10 

accepted 16:6 

accepting 186:11,21 

accepts 186:22 

access 98:9,13 153:13 

accessible 86:4 98:16 

166:14 

accessing 134:7 

accommodated 54:6 

accommodating 64:14 

226:13 

accommodations

170:11 

accomplish 39:17 

account 20:12 118:6 

135:16 176:12,16 

186:15,16,18 187:2,3 

187:3,4,8,16 210:5 

211:6 212:3,4,6,10 

accounts 176:19 

180:20 181:1 187:7 

187:15,20 208:12,16 

208:22 209:12 211:15 

accrual 205:7 238:4 

achieve 231:11 

achieved 11:21 226:7 

230:22 

achieving 226:12 

acknowledge 78:11 

acquire 52:18 

acquired 12:10 52:11 

217:9,17,21 218:3 

acquisition 55:17 90:15 

90:21 91:2 

act 128:7 154:8 169:9 

173:12 183:6 

acting 164:13 

action 78:22 

actions 198:15 202:17 

active 41:2 47:15 56:16 

67:17 87:9 118:9 

220:19 221:3 222:19 

actively 76:17 198:1 

activities 78:21 79:8 

93:13 135:18 167:17 

177:21 

activity 11:12 15:5,8 

18:20 43:10 45:12 

50:15 62:6 77:7 86:17 

113:19 115:19 119:9 

actors 143:18 

actual 219:9 

adapting 87:5 

add 94:4 145:7 150:6 

207:14 210:21 

added 201:3 

addition 65:22 69:13 

91:2,5 103:2 118:5 

129:9 174:1 224:8 

228:8 239:19 

additional 34:9 38:19 

53:5 168:5 171:1 

201:9 203:1 212:15 

address 144:19 156:20 

169:8 197:4 

addressed 89:12 

addressee 184:18 

addressing 18:1 98:17 

adequate 17:18 

adequately 173:20 

adjourn 242:6 

adjust 84:16,17 

adjusted 20:11 229:15 

adjusting 76:4 

adjustment 124:7 

adjustments 125:6,8 

administration 25:8 

180:6 

administrative 177:10 

adopt 5:8 153:9 

adopted 226:20 228:1 

adopters 228:5,7 

adopting 228:8,9 

adoption 227:8,12,15 

227:19 

adoptions 227:10 

adult 97:12 

advantage 13:17 54:7 

102:4 116:6 216:1,10 

advantages 216:6 

adversely 17:14 50:8 

adversity 111:13 

advisor 131:17 132:11 

advisory 1:3 3:4 4:6,7 

36:22 46:17 113:15 

128:5,6,8 172:17 

Affairs 1:16 

affect 146:1,1 183:4 

206:7 

affiliate 174:21 177:6 

affiliated 177:18 

affiliates 177:8 

afford 43:5 82:18 83:8 

affordable 73:4 82:20 

98:13,16 

African 129:3 

aftermath 8:4 

afternoon 4:3 9:7 10:13 

13:1 18:11 28:3 46:10 

51:10 58:9 74:9 79:13 

89:22 95:17 111:9 

136:6,19 212:17 

226:19 238:2 240:22 

ag 32:16 45:16 53:6,20 

53:22 59:11,19 65:21 

101:7,7,16 102:1 

age 13:22 19:4 97:13 

218:11 

agencies 35:15 160:16 

197:12,22 

agency 128:9 187:6,19 

agenda 7:15 127:2 

136:14 164:1 208:9 

212:19 

agent 177:5,6 179:8 

180:5,18 

ages 218:21 

aggregate 220:1 224:14 

224:17 225:4 233:17 

234:11 

aggressive 48:6 

ago 8:3 12:1 22:15,16 

23:13 29:14 37:19 

55:8 56:7 62:5 68:12 

73:21 103:12 121:4 

136:22 138:10,10 

148:5 152:13 160:11 

162:14 178:20 207:7 

agree 107:8 156:8,9 

158:6 203:5 

agreement 52:18 

agreements 44:4 

agricultural 3:18 53:4 

72:5,5 96:1 105:14 

220:7 223:7,9,12,13 

223:20 224:1,6,8,10 

224:13,14 228:18 

229:10 231:20 233:21 

234:18 235:21 236:20 

237:3,4,7 238:14 

239:1,11 

agriculture 45:1,2,9 

79:21 122:3 213:15 

214:1 228:16 235:9 

ah 153:17 

ahead 27:22 66:17 69:1 

69:10 102:19 112:16 

121:10 124:20 126:18 

145:15 

Alaska 18:14 19:2 

21:12 

Alaskan 20:14,20 

Alaskan's 19:5 

albeit 7:8 

ALCO 63:12 

alert 19:6 

alike 71:2 

all- 48:3 

all-time 14:13 21:2 

83:18 

allocating 102:22 

allocations 176:22 

177:16 

allow 172:16 

allowance 17:17 20:11 

25:16,19 77:20 

allowed 76:13 170:21 

allowing 18:7 31:16 

166:15 

alluded 70:22 207:6 

altogether 112:14 

amazing 57:13,18 

74:15 140:13 142:5,8 

142:14 143:4 160:14 

162:5,15 

America 29:18 161:13 

162:3 

American 6:5 129:3,4 

139:7 142:19 143:2,8 

ammo 44:21 

amount 19:18 25:18 

41:2,4 134:2 140:4 

187:16 197:13 204:14 

205:6 220:17 

amounts 26:4 42:18 

68:17 97:9 

amplification 141:16 

analysis 9:19 68:13 

174:11,14 175:18 

207:2 213:11 226:8 

229:3 

anchored 11:14 138:3 

and/or 148:18 

Anderlik 2:13 3:19 

213:10,17 240:11 

Anderson 1:16 10:8,10 

10:12,13,16 145:13 

145:16,16 147:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
245 

Andrew 1:20 7:2 41:22 

129:12 

anniversary 137:17 

149:21 

announce 27:3 

announced 12:12 52:17 

97:19 

announcement 29:10 

29:13 

annual 159:10 181:5 

224:14 227:17 230:1 

230:16 

annually 66:1 217:11 

answer 160:22 167:9 

188:12 198:17 209:18 

answered 198:20 

201:22 

answering 169:1 

answers 166:3 

anticipate 54:12 93:14 

184:10 203:11 

anticipated 68:12 

Antonio 47:7 

anybody 44:17 

anymore 43:6 155:5 

161:3 

anyway 67:6 73:9 

138:11 

apologize 28:1 

appear 54:16 58:13 

212:21 

appears 165:7 225:10 

225:21 

applaud 38:12 

applicable 176:18 

179:3 180:3 183:9 

185:22 

application 181:16 

182:1,5,9 

applications 12:5 16:7 

87:6 133:15 182:12 

227:1 

applied 179:12 

applies 179:5 180:16 

apply 34:5,12 40:4 

171:18 173:20 

appoint 136:18 

appointed 59:2 

appointments 54:7 

60:5 

appraisals 166:15 

appreciate 4:12 22:4,5 

36:17 46:8 58:7 65:6 

71:10 74:16,18 78:3 

95:14 103:19 104:1 

104:13,18 126:15 

157:22 163:12 200:17 

appreciation 106:1 

127:6 

approach 48:13 68:18 

78:4 

approaching 47:1 

appropriate 5:3 6:1 

187:13 202:22 226:13 

appropriated 133:8 

approval 12:14 52:20 

146:7 

approved 52:21 98:18 

99:8 145:20 172:9 

approximated 56:20 

approximately 25:13 

25:17 40:15,17 55:15 

90:18 98:10 133:8 

151:2 

April 1:8 13:21 115:18 

172:11 173:2 182:10 

231:8 

area 6:5 8:20 18:8 20:6 

21:8 22:21,22 23:1 

26:9 30:21 33:13 37:4 

53:5 54:13 62:17 

72:21 76:1 79:1,20 

81:17,19 82:13 88:13 

88:21 89:7,11,17 90:7 

91:22 94:11 100:4 

115:17 140:8 148:12 

151:21 184:21 185:3 

199:22 201:3 221:18 

223:6 233:19 236:3 

239:17 

areas 30:17 32:22 47:7 

47:11 48:4,8,10 49:3 

50:5 54:14 76:13 84:9 

84:21 114:21 122:12 

148:14 190:18 206:7 

219:1,13 220:8 221:6 

221:8,9 

arena 93:18 

Arkansas 7:2 66:6,9,20 

67:9,16 68:2,7 111:17 

161:21 

Arkansas-based 65:20 

Arleas 1:15 7:11,19 9:4 

10:14 46:15 106:14 

112:5,19 123:20 

128:2 137:6,16 

145:12 147:19 163:18 

164:18 197:3 210:21 

213:17 240:21 241:19 

242:3 

arrangement 174:20 

175:4,8 

arrangements 172:6 

arranging 167:8 

article 228:15 

ascending 142:20 

Asian 129:4 

aside 68:16 134:3 

asked 38:14 56:11 

166:4 167:10 199:1 

asking 194:18 

aspects 132:12 133:4 

assess 5:3 218:6 

assessing 198:2 

assessment 206:14 

asset 4:17 16:21 17:11 

25:20 68:8 75:5 77:16 

92:15 117:20 119:15 

119:20 120:14 132:18 

203:16 204:4 214:10 

219:4,15 223:16 

225:22 241:4 

assets 11:21 13:7 16:18 

17:15,16 18:16 42:3 

59:8 60:17 66:8 68:4 

71:20 90:12,19 96:6 

100:5 118:20 167:5 

179:22 180:2,5 

204:21,21 217:19 

218:1 220:2,5,14 

223:17 228:6,10 

231:17 

assist 49:15,21 112:7 

177:14 

assistance 41:3 45:15 

61:12 101:13 134:7 

177:20 

Assistant 213:10 

assisting 15:20 

assists 180:18 

Associate 9:17 

associated 168:13 

227:15 

Association 30:6 

131:11 

associations 57:6,14 

160:16 162:16 169:4 

assure 148:7 

astonishing 16:17 

Atlanta 38:12 131:8 

ATM 161:17 

attaches 201:6 

attempt 58:7 

attended 134:9 

attention 110:7 122:10 

attentive 8:19 

attitudes 207:21 227:6 

attributed 48:5 114:6 

audio 9:9 18:21 31:21 

31:22 42:20,21 43:9 

45:7 112:7 124:7,14 

Austin 47:7 

authorities 183:5 

authority 128:5 176:11 

automatically 44:8 

179:15 

avail 208:16 

availability 141:1 

208:19 

available 14:22 40:22 

54:20 99:11 206:10 

210:10 211:21 

average 14:5,7 16:4 

17:22 40:14,17 73:16 

76:19 96:9,11 120:15 

230:1,16 233:15 

234:12 

averaged 229:22 

averages 75:13 184:21 

aware 63:22 211:4 

awareness 211:3 

212:12 

B

B 149:19 

back 8:2 13:14 22:16 

24:21 32:12 34:13 

41:20 51:1 52:1 60:2 

60:2 65:2 69:6 80:16 

84:2,7,22 88:18 97:2 

97:17 102:14 109:15 

110:21 112:17 121:2 

125:21 126:5,6,8,11 

142:18 143:9,10,11 

145:12 147:19 148:7 

157:14 190:12 191:6 

195:17 196:11 197:21 

199:7,7,15 229:16 

backbone 140:11 

background 113:7 

159:19 

bad 39:5 111:3 

bag 92:4 

balance 16:9 25:6,11 

62:21 63:5 83:10 

114:18 118:3 123:1 

132:15 187:3,4,16 

192:8 197:17 198:2 

225:14 236:10 

balances 16:11,15 18:5 

Baltimore 116:18 

Baltimore/Washington

76:13 

bank's 15:3,10,13,19 

17:11 38:16 47:5 

banked 208:19 211:9 

banker 129:22 208:3 

banker's 35:6,7 

bankers 22:10 23:11 

27:14 30:5 31:8 53:10 

54:21 57:12,16,17 

69:9 74:18 79:6 95:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
246 

113:4 121:18 130:7 

130:10 131:11 139:4 

142:4 156:19 161:13 

162:3 166:4 168:1 

194:14 205:11 222:12 

229:11 236:13,16 

237:17,21 

bankers' 167:9 

banking 1:3 2:8 3:3,4 

3:17 4:7 5:2 6:6,7 

9:10,21 11:19 13:8 

29:9 36:8,11 38:6 

41:19 49:9 50:18 75:9 

78:17,20 104:9 

117:16 127:11 128:6 

130:1 132:9 137:21 

140:1 141:14 143:2,6 

145:21 146:2,9,18 

152:3,6 154:5 156:11 

160:6 197:18 198:1,4 

198:7 210:22 213:21 

214:6,7 220:2,10 

221:21 226:22 241:8 

banks' 167:7 221:10 

222:1,5,22 226:17 

227:3,4,8 

barriers 6:1 

bars 32:10 83:21 84:2 

115:13 

base 72:22 100:22 

108:4 

based 90:4 125:10 

174:14 176:22 183:17 

201:2 222:9 226:1 

basement 152:10 

bases 218:8 

basically 32:5 35:11 

88:2 191:10 208:3 

basis 13:16 81:12 82:11 

85:1 108:13 184:1,3,6 

184:7 196:17 201:11 

201:13 216:3,4,15 

batch 155:6 

Bean 197:4,8,10 199:6 

bear 205:5 

becoming 134:6 225:10 

beg 151:6 

began 232:4 236:6 

beginning 11:12 52:10 

163:9 170:14 212:18 

232:7 

begun 76:1 

behalf 181:22 242:14 

behavior 236:13 

belief 222:15 

believe 12:9 20:6 31:8 

55:13 57:4 63:11 

80:21 152:22 192:6 

Belt 233:8 

beneficial 78:8 

benefit 78:9 

benefited 101:9,16 

benefits 211:12 212:1,9 

226:6 

benefitted 110:3 

Berkeley 75:8 

Beshear 242:9 

best 128:20 130:20 

131:5 143:20 152:3 

172:1 204:19 211:20 

242:17 

Beta 56:9 

Betsy 1:21 6:16 51:7,15 

better 38:19 44:3 89:18 

123:9 

Betty 2:7 3:8 46:14 

127:10,22 129:21 

135:21 136:5,12 

beverage 115:12 

beyond 86:16 214:10 

226:7 

bidding 92:22 

big 31:9 36:3 55:12 

60:18 61:10 70:12 

112:2 140:20 146:16 

146:17 147:4 151:22 

159:12 201:4 232:12 

bigger 206:8 

biggest 81:3 139:2 

149:12 160:8 189:9 

208:20 

bill 161:18 

billion 66:22 90:11 

133:8,20 134:2 

214:11 218:1,1 228:6 

229:22 230:1 

bit 19:21 43:6 63:2 

69:21 72:8 73:12 78:7 

87:7 108:14 117:7 

119:11 126:21 138:11 

138:16 139:19 146:10 

151:3,6 183:8 202:3 

204:13 205:11 

bits 124:1 

black 87:19 131:6 

Blackhills 62:16 

blue 90:7 218:20 

233:16,17 

board 1:10 27:5 44:6 

65:8 84:7 98:1 131:3 

155:18 172:10 242:9 

Bobby 197:4,7 198:17 

Bock 2:2 6:13 79:13,14 

boded 207:6 

boil 107:2 

bolstered 16:10 

bombarded 146:5 

book 23:15 

bookings 62:15 

books 56:21 

boom 228:21,22 229:6 

229:8,12,17,19 231:1 

232:3,5,13,14,19 

233:3 234:2,6 235:2,6 

235:18,19 236:4,14 

236:15 237:8,14 

238:15,21 239:10 

boost 110:4 

boosted 108:5 

border 47:4 51:21 

71:16 

borders 21:14 55:2 

borrower 206:20 

222:10 

borrowers 17:12 49:22 

68:22 69:9 204:11 

239:15,19,20 

borrowings 210:7 

Boston 92:19 116:21 

117:5 203:9 

bottom 226:11 233:17 

234:14 

bought 43:7 66:5 

bounced 84:2 

box 148:10,20 215:6 

219:17 

Bozeman 43:19 

branch 44:16 72:12 

120:6 

branches 13:5 47:8 

48:17 71:21,22 90:8 

90:10 91:3 183:18 

209:2 

branded 52:14 

branding 12:12 

bread 93:16 

break 125:18,20 126:2 

126:4,12 

breaks 23:5 

bridge 116:3 

bridges 47:18 

brief 129:17 171:22 

240:21 242:3 

briefing 133:4 

briefly 127:14 128:3 

132:13 

bright 28:22 

bring 21:11 31:13 151:7 

210:1 240:1 

bringing 214:17 

broad 173:13 

broadband 98:19 

broker 164:21 171:14 

171:17 173:14,21,22 

174:8,10,12,14 175:2 

175:5,6,10,16,18,18 

176:7 177:19 178:5,9 

178:19 179:4 183:14 

186:11 187:1,1,12,14 

199:15 

broker's 182:14 

broker/dealer 177:12 

broker/dealer's 180:8 

brokered 178:3,11 

181:10 182:15,19,20 

brokers 55:16 

brought 52:1 57:22 

63:9 64:17 

Bruce 2:1 6:20 71:12 

199:12,13 

BSA 64:7 

budget 18:18 

budgeted 25:6 

budgeting 25:1 

buffers 166:19 

build 139:22 140:20 

143:6 

building 151:8 155:13 

builds 214:15 

bullish 95:11 

bumped 84:9 

bunch 141:20 144:8 

154:7 

burden 165:21 198:6 

burdens 228:14 

bus 115:21 

business 15:18 19:9 

21:18 23:20 28:11 

44:19 45:6 47:4,19,21 

53:5 62:14 65:21 

66:10 81:4 86:18 88:6 

95:5 129:5 135:18 

161:15 175:8,10,19 

175:20 179:8,12 

211:5 219:5 220:7 

221:19,21 222:1,4,5 

222:12 226:14 228:13 

businesses 11:9,11 

12:16 15:20 16:1 

23:21 33:5 34:11 37:9 

37:15 38:6,9,18 39:14 

39:14,22 40:9 69:5 

75:16 76:3,14 77:5,10 

80:22 81:4 83:11,22 

85:3,8,15 86:13 92:12 

95:7 96:20,21 98:22 

140:10,11 166:20 

198:11 222:14,17,20 

busy 26:5 40:20 98:20 

99:4 168:2 

butter 93:17 

buy 35:12 43:3 82:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
247 

buy-back 170:19 

buying 22:3 87:3 

bye 242:21,21 243:2,2 

C

C 155:18 

calculate 184:20,22 

calculation 34:4 183:19 

202:18 

calculations 202:20 

call 5:16 17:6 30:12 

88:6 125:7 147:5 

150:15 172:12 173:6 

178:16 193:1 222:2,8 

222:9 223:4 233:4 

called 13:13 34:7 90:18 

100:17 155:8 

calling 205:3 211:9 

calls 23:20 

camera 10:12 121:4 

125:14 136:11 137:4 

197:2 213:16 

Camille 204:7 

campaign 211:10 

campers 26:6 

campus 49:6 

Canadian 21:13 

cancelled 97:18 

candid 104:18 

cannabis 78:20 

cap 20:10 101:13 102:2 

183:20,22 184:5,22 

186:11 187:13 201:8 

201:10,19 

capability 140:13,21 

capacity 30:15 76:10 

76:11 96:21 155:13 

capillary 29:20 

capita 13:20 

capital 4:16 17:4,15 

44:7 50:19 59:13 68:4 

68:16 77:17,21 101:8 

111:14 117:20 127:19 

133:5 134:14,21 

135:2 166:19 202:15 

202:20 207:11 236:1 

capitalism 143:11 

capitalized 171:18 

173:18,20 174:2 

182:5 183:10 184:12 

186:1,9,17,19,22 

187:5,11,18 201:8,16 

202:3,6,13,14,14 

caps 185:22 

capture 161:16 

card 181:2 212:7 

care 61:18 

career 50:18 78:17 

careful 152:9,12 

carefully 70:2 

CARES 169:9 

Carnegie 155:9 

carrier 239:6 

carry-out 76:6,11 

carry-over 61:18 

carryover 53:21 

Carver 131:3 

case 75:21 82:21 83:16 

136:2 149:2,17 

181:22 206:15 

cases 19:7 40:18 48:2 

67:17 130:14 146:21 

146:22 147:3 159:9 

195:15 

cash 16:11,14,15 18:4 

26:3 34:22 43:1 63:2 

90:17 101:18 234:20 

236:5 

categorized 173:4 

category 115:12 

Cathy 242:11,15 

cattle 230:5 234:21 

cause 176:6 

caused 50:10 

causes 100:5 

causing 117:13 

cautious 59:21 89:16 

130:7 237:18 

cautiously 46:5 68:21 

239:14 

CBAC 128:6,11 129:10 

CBLR 197:12,20 198:5 

CDFI 134:7,7 

CDFIs 133:10,19,21 

134:3,13 

CDI 134:19 

CDs 183:21 

ceased 218:2 

celebrating 46:22 

center 52:4 72:21 109:6 

113:12 

centers 75:17 79:22 

80:4,4 

central 13:6,6 31:20 

47:6 58:22 241:8 

Centreville 6:15 

century 143:8,9,14 

CEO 6:13,15,17,18,20 

6:22 7:1,2,4 13:2 17:6 

18:13 28:10 31:19 

46:12 51:7,17 58:21 

65:19 71:13 74:10 

79:14 90:1 95:21 

CEOs 74:1 

certain 37:11 148:22 

166:8 190:2 191:11 

192:19 

certainly 4:11 37:12 

41:9 78:9 81:9 90:13 

91:6,16 92:7 95:11 

108:17 109:3 146:13 

148:11,16 149:22 

150:20 188:2 203:5 

204:6 208:14,22 

certifications 181:6 

cetera 23:12,22 24:16 

31:7 82:5 92:10,14 

CFIs 132:3,7 

chain 85:13 

chains 231:6 

Chair 28:4 29:7 30:19 

31:15 

chairman 1:11,13,15 

4:3 6:15 7:14 10:18 

27:2 28:9 46:14 57:20 

58:18 64:6 65:16 

73:18 74:13 79:9 

95:18 104:22 131:10 

139:3 150:4 156:9 

213:7 241:22 242:2,9 

242:11,22 

challenge 41:16 63:3,4 

63:19 70:13 78:12 

101:4 109:22 120:17 

160:5 197:20 227:19 

challenged 69:17 83:10 

83:11 84:1,4 

challenges 15:21 17:21 

28:18,19 64:1 74:17 

80:14 81:3 82:7,19 

83:13 84:10 85:9 86:1 

90:22 98:8 106:6 

110:2 111:21 122:5 

122:10 227:4,22 

229:13 239:15 

challenging 31:11 

90:13 236:4 

chance 74:2 

change 52:14 138:12 

172:18 175:17 182:16 

183:16 185:12 190:14 

190:20,21 193:16 

194:5 214:20 218:6,7 

224:20 

changed 26:20 34:3 

57:10 62:4 173:16 

174:6 183:11,17,21 

195:13 

changes 6:1 52:5 59:22 

60:1 61:17 84:5,13 

119:22 168:9 171:14 

171:21 173:3 182:13 

182:17 189:21 192:11 

199:18 201:2 204:15 

218:8 224:21 225:2 

229:10 

changing 5:9 45:22 

46:1 69:15,21 77:14 

89:8 124:13 138:11 

170:11 189:3 190:1 

209:20 

chaotic 23:19 

chapter 40:7 215:2,6,9 

215:13 216:18 218:5 

219:16,21 223:14,20 

224:19,20 225:3,16 

226:9,11,16 227:9 

chapters 215:1 

characteristics 135:11 

214:12 227:5 

charge 12:7 205:7 

216:13 238:11,16,18 

chart 216:9 217:13 

220:12 222:3 224:1 

225:12 227:22 229:14 

229:16 231:18 233:11 

233:14 238:10 

charter 35:20 36:4 

145:21 146:9,9 

chartered 13:4 66:4 

charters 36:8,9 52:3,12 

55:13,14 71:3,6 

charts 238:12 

Chase 94:11 

chat 125:7,15 136:9 

137:14 138:21 

check 27:18 124:1 

163:6 

checking 125:15 

207:16 

checks 212:7 

Chicago 51:20 54:15 

chief 2:8 5:10 10:9 

136:18 

China 142:21 

choir 144:22 

choppy 124:10 

Chris 2:12 3:15 164:10 

164:13 188:14 

Christmas 32:4,6 

Cindy 2:1 6:18 74:10 

circle 148:16 

cities 76:15 82:11 92:19 

116:18 117:15 

city 6:21 92:19 115:17 

115:20 116:7,14,21 

117:3 242:11 

civic 49:16 

civil 193:6 

Clackamas 242:12 

clarifications 167:12 

clarified 166:7 186:4,13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
248 

clarify 188:4 

clarifying 166:16 

class 98:2 

classes 120:14 132:18 

classified 17:15 175:16 

224:5 

clean 32:16 141:15 

clear 79:6 226:5 

clearly 8:17 

client 218:8 

clientele 76:14 

climate 95:4 

close 47:21 48:9 74:21 

76:16 94:21 108:13 

110:6 113:13 176:12 

240:19 242:8 

closed 21:13 23:2 

44:11,16,18 217:9,14 

closely 13:15 20:4 

122:17 

closer 116:4 

closing 3:21 213:7 

217:16 241:22 

closings 120:6 

closure 72:13 

Club 148:3 

CNI 222:13,16 

co-members 36:21 

Coast 4:5 18:12 46:10 

112:1 

coastline 92:20 

coffers 20:22 

coincidentally 25:14 

collaborate 41:13 

collaboration 30:1,3,16 

106:1 128:20 131:5 

131:13 153:17 

collar 90:7 

collateral 86:8 110:11 

colleagues 28:16 31:2 

college 88:14 

Colorado 7:5 22:11 

161:8 

Columbia 113:9 

combination 232:8 

233:7 

combined 24:5 191:13 

201:14 231:9 

combining 70:15 

come 8:10 12:21 30:20 

49:14 51:10 58:4 84:6 

86:15,16 88:12 

109:12 125:20 126:4 

126:6 138:13 139:17 

140:7 142:18 147:16 

148:16,21 163:13 

189:12 190:12 240:15 

comeback 44:1 

comes 68:3 148:21 

196:6 202:2 230:22 

comfort 76:9 125:18 

coming 21:15 26:7 

29:12 63:14,15 83:5 

84:22 86:19 108:3 

134:14 148:2 204:19 

comment 57:6 64:5,16 

135:7 142:19 148:1 

154:1 156:1,15 158:2 

158:11,15 200:15 

201:4 

comments 7:17 72:19 

109:19 113:3 125:13 

136:8 156:16 197:5 

201:2 210:21 242:1 

Commerce 33:15 35:15 

commercial 8:20 11:6 

20:5,7 28:14,15 33:3 

33:4 43:9 53:5 59:16 

60:22 62:6 91:11 

93:16 107:16 109:20 

109:21 110:22 111:5 

114:13 122:6 205:15 

219:13 235:12 

commissioners 169:4 

commit 85:20 

commitment 39:22 

223:21 

committed 99:9 165:20 

committee 1:3 3:4 4:6,7 

6:11 9:8,16 10:8,11 

22:6 36:22 46:17,18 

51:6 57:20 65:16 71:9 

73:20 104:17 113:15 

127:9,9 128:3,7,9 

137:11 156:16 241:2 

241:10 242:7,16 

committees 208:2 

commodities 54:3 

230:4 234:18,22 

commodity 62:4 101:15 

102:3,5 230:9,15 

231:7,10 

common 15:1 105:3 

237:20 

communicate 189:7 

communicated 154:20 

communicating 195:17 

communication 64:9 

64:13 168:21 188:20 

190:5 

communications

155:16 

communities 4:21 8:12 

9:2,11 17:3 23:11 

30:10 36:14 47:8 53:6 

54:13 59:9 69:11 

71:22 72:3,13 99:1 

104:20 105:2,14,16 

120:3 128:22 132:4 

133:22 158:6 165:13 

208:17 209:3 221:17 

241:19 

commuter 115:16 

116:1,12 

commuters 116:6 

companies 36:3 52:2 

70:5 94:3 95:8 146:5 

151:9 162:6 203:19 

company 12:11 145:20 

242:10 

comparable 201:12 

compare 20:17 214:11 

compared 24:7 54:17 

59:17 167:4 220:13 

236:14 

compete 35:10 201:17 

201:20 

competing 50:15,16 

208:21 209:12 210:15 

competition 62:22 86:2 

91:21 93:17 94:15 

100:7,8 140:19 

142:22,22 228:11 

competitive 13:17 

50:14 86:5 93:21 94:5 

94:7 100:11 209:19 

210:11 227:5 

competitiveness 6:6 

139:8 142:19 

competitor 209:21 

competitors 24:5 

complaints 120:10 

complete 170:18,21 

213:2 

completed 12:11 78:1 

90:15 103:9 

completely 37:19 39:7 

167:22 

completing 90:20 

Complex 131:9 

complexes 83:1 

complexities 18:1 

complexity 135:18 

compliance 78:1 104:4 

117:22 119:22 120:21 

164:14 165:2 172:13 

172:16 188:19 189:1 

189:4 190:16 191:3 

193:1,21 194:21 

197:19 225:5 226:4 

compliment 121:12 

compliments 105:22 

comply 172:19 

complying 120:3 

component 119:18 

123:16 158:12 159:13 

components 50:5 

composite 119:18 

123:4,6 204:16 

compounded 21:11 

compressed 15:16 

compression 19:1 

42:21 50:9 

compressions 62:21 

comprised 47:9 129:1 

concentrated 235:9 

concentration 94:19 

101:7 121:22 237:7 

concentrations 114:13 

114:15 183:1 236:21 

concept 131:18 151:22 

157:10 

conceptual 132:19 

concern 26:10 71:1 

79:1 95:2,6 97:1 

100:3 109:4 156:2 

202:2 208:13 

concerned 17:7 21:20 

33:4 38:1,3 44:14,18 

45:11 69:15 70:18 

concerning 94:18 

197:11 

concerns 41:10 69:13 

72:21 94:6 106:5 

183:1,1 208:20 

concise 194:2 

conclude 64:5 239:11 

concluded 243:4 

concludes 135:20 

conclusion 18:6 27:12 

215:16,18 

condition 117:19 

135:14 228:18 235:5 

conditions 3:3 5:2 9:10 

51:5 86:6 92:3 107:6 

107:19 117:16 130:1 

130:4 176:15 198:1 

198:12,14 199:9 

228:13 229:11 233:21 

238:3,12 

conduct 47:3 170:3 

206:3 

conducted 49:6 123:5 

134:5 237:21 

conducting 105:20 

169:20 171:2 

Confederated 44:12 

confidence 12:19 108:7 

confident 12:20 

Congress 133:7,20 

150:11 

Congressional 78:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
249 

Connect 56:5 

Connecticut 90:9,11,17 

95:12 

connection 124:14 

consensus 107:22 

108:10 

consequence 26:10 

consider 132:19 135:13 

156:18 198:15 

consideration 132:14 

considered 26:18 

181:10 199:2 218:11 

228:4 

considers 221:13 

consistent 53:10 79:7 

136:14 198:9 226:1 

consolidating 216:21 

consolidation 216:19 

216:22 217:3,10 

constant 53:11 

construction 43:8,18 

43:21 82:22 85:20 

87:1 92:14 122:16 

130:15 

consulting 176:17 

consumer 2:12 16:11 

44:10 59:16 108:7 

120:3,10 140:3 

164:12 165:1 168:12 

188:18,22 189:4 

190:16,19 191:2 

194:21 210:7 

consumers 18:3 70:10 

71:2 166:4,12,14 

210:2 211:4,11,20 

212:2 

contact 58:4 240:8 

contain 240:8 

contemplated 186:6 

CONTENTS 3:1 

continual 44:9 

continually 154:22 

continuation 48:5 

continue 4:15 5:1,14 

11:9,18 12:4,17,19 

13:17 17:21 18:22 

21:20 32:13 40:20 

41:2,13,18 42:6 43:13 

46:6 47:15 48:3,18 

49:8,9,10,15,21 54:11 

55:16 60:14 63:7,17 

69:4 77:6,19 82:22 

84:3 92:6 95:1 98:4,6 

99:9,14,22 100:16,17 

100:22 102:17 103:4 

104:3 111:5 112:12 

115:5 116:19 117:9 

117:14 119:20 120:1 

120:13 147:14 163:10 

180:12 199:8 204:20 

215:20 222:19 

continued 15:2 16:11 

17:2,7 47:22 52:8 

68:18 69:2 79:11 

81:22 92:11 99:4 

104:8 105:22 107:12 

130:13 168:12 216:19 

236:1 

continues 15:4 37:8 

50:12 86:21 88:17 

93:13 94:16 99:11 

100:2 102:11 103:7 

119:10 141:5 205:18 

continuing 40:21 73:3 

96:20 99:15,21 

111:18 143:19 160:3 

163:20 198:13 

continuity 170:15 

contractors 23:22 

contracts 84:16 

contractual 176:11 

contrast 232:5 233:12 

237:5 

contributed 15:9,15 

241:11 

control 201:1 

controllable 89:8 

convened 1:10 104:22 

convenience 137:14 

convening 28:5 

convention 122:11 

conversation 10:19 

78:7 163:10 226:18 

conversations 27:10 

203:10 205:12 212:16 

212:18 240:14 

conversion 91:6 103:15 

103:17,20 169:18 

cooperation 69:8 106:1 

126:16 168:18 

coordination 168:18 

core 4:16 52:4 91:6 

103:13 135:12 152:20 

161:15 

corn 230:4,17 231:7 

233:8 234:19 

corner 209:21 

cornfield 138:1 

Corona 19:3 101:12 

coronavirus 166:2 

167:11 169:13 

corporate 132:2 

corporates 30:20 

corporation 1:1,14,15 

75:3 209:11 

correct 36:6 199:5 

cost 52:5 73:6 211:16 

227:18,21 

costs 18:2 43:8 82:22 

130:16 

counties 53:1 63:15 

75:7,9,14 98:11 

218:14,16,17,20,22 

219:3,8,11,18 

country 11:1 29:9 31:6 

31:7 32:14 85:14 

91:14 96:14 113:4 

114:15 115:3 140:11 

143:14 151:2 152:19 

153:21 156:20 235:11 

238:6 

County 96:1,8,10 

242:12 

couple 45:13 56:7 

84:19 85:1 108:8 

139:6,17 151:16 

158:17 166:7 167:21 

191:14,22 194:15 

213:18 

course 24:14 33:18 

44:3 53:14 56:12 

108:3 110:10 112:1 

113:11 138:20 194:14 

200:19 

covenants 203:20 

cover 9:20 149:22 

164:19 167:15 172:1 

185:21 193:20 214:3 

220:8 

coverage 17:19 

covered 214:19 221:22 

covers 215:9 

COVID 4:18 11:1 24:2 

24:11,14 33:8 34:17 

36:10 37:20 38:9 

42:11 48:2 54:4 55:10 

55:18 59:20 60:12 

66:16 67:7,17 69:12 

72:11,15 80:5,14 81:7 

83:10,13,15 84:12 

85:11 88:21 89:6 97:3 

98:21 102:19 103:6 

105:5 161:9 

COVID-19 13:12,20 

19:2 44:3 47:22 68:13 

113:12 133:12 134:1 

165:14 166:9 

CRA 120:1 164:14 

190:22 193:1 

CRE 110:1,12 114:14 

115:1 119:5 220:6,9 

220:10,12,15,17 

221:3,7,14,15,16 

create 5:6,17 30:15 

134:22 144:15 210:6 

created 90:22 178:18 

179:14,18 183:12 

201:9 

creates 30:15 

credit 17:19 29:8 50:21 

94:14 118:7 119:13 

133:10 183:19 198:11 

200:10 201:3 216:12 

216:13 238:3,12 

239:8 

credits 101:7 186:17 

187:7 

crew 64:8 65:5,5 

crises 206:5 

crisis 14:12 24:2 38:20 

40:12 207:9 224:22 

225:15 231:20,22 

237:3 238:14 

criteria 193:12 

criticism 165:19 226:10 

crop 32:18,21 53:7 

101:19 102:10 

crops 45:14 

Crude 20:19 

cruise 21:12,14 

CSBS 227:17 

curios 162:11 

curious 64:1 158:13 

199:15 200:12 203:21 

210:14 

current 13:7 75:5 81:17 

102:3,5,6 107:22 

130:1 

currently 48:21 71:18 

78:15 80:14 84:18 

133:14,16 143:3 

182:19 

cusp 237:2 

customer 39:9 48:15 

79:7 174:17 179:9 

customer's 176:13 

customers 13:10,13 

21:18,22 24:9 26:2,2 

34:21 38:16,22 41:3 

43:12,13 47:10 49:10 

50:2,22 53:16,22,22 

54:6 69:11,19 77:13 

81:4 86:19 87:4 91:20 

98:5,7 99:10 102:13 

120:2 153:20 165:13 

165:18 168:3 175:20 

180:6 211:1 

customers' 41:15 

customized 156:5 

cuts 153:1 

cutting 124:2,3,5 125:2 

Cyber 155:9 160:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
250 

cyberattack 152:22 

cyberattacks 152:21 

cybersecurity 18:2 

41:10 70:19 141:1 

144:14 154:10 155:20 

156:10 158:20 

cycles 185:10 224:10 

D

D.C 75:1 116:21 117:6 

daily 13:16 32:1 142:12 

dairy 6:13 79:14 230:5 

Dakota 31:19,21 34:7,7 

35:1,7,8 58:21,22 

59:5 60:4 62:14 64:8 

158:1,4 159:21 

Dakota's 59:14 

Dakotans 33:9 

Dallas 2:6 10:2 111:10 

121:13,20 122:9 

dampened 130:13 

dark 218:20 219:8,18 

233:16 

data 31:3,4 103:10 

111:3 115:16 116:12 

116:17 222:2,18 

date 16:6 172:13,16 

173:2 183:22 

dates 160:12 235:19 

day 12:18 41:1 57:9 

74:18 81:18 103:16 

137:8 146:6 150:12 

161:15 162:6 204:7 

240:16 

days 12:21 37:22 

149:20 165:10 

DC 11:4 

deal 23:7 236:9 

dealing 72:11 136:16 

184:9 191:2 

death 13:20 19:14 

153:1 

deaths 24:18 

debates 27:10 

debt 141:13 166:9 

178:8 205:4 223:10 

236:6 239:6,16 

debt's 61:18 

debuted 182:10 

decades 138:10,10 

237:19 238:13 

December 91:6 172:10 

213:22 

decide 195:3 

decided 189:22 

decision 38:7 

declaration 165:10 

decline 15:9 48:3 61:7 

119:10 224:14,17 

declined 119:11 217:6 

222:2 230:20 232:7 

declines 119:15 

declining 11:17 44:9 

45:2 96:18 

decrease 50:20 

decreasing 15:16 100:1 

dedicated 4:13 166:1 

172:7 

deemed 202:6 

deeply 30:17 

deepness 30:9 

default 11:10 

defaulting 43:15 

Deferral 119:9 

deferrals 17:14 123:17 

deferred 94:20 

define 214:10 

defined 176:21 202:16 

235:7 

defines 176:8 

definitely 32:17 45:21 

88:5 107:19 

definition 154:17 

173:13 175:6 177:19 

178:4,8,19 179:4 

202:2 206:15 

definitions 225:17 

defy 14:11 

delayed 166:15 

deliberation 157:10 

delinquencies 17:16 

20:8 53:19,19 77:19 

84:18 102:12 238:16 

238:18 

delinquency 119:2,5 

239:2 

deliver 69:18 70:9 

delivered 166:21 

delivery 209:1 

demand 11:19 12:5 

15:3 50:13 53:13 

100:4 110:4 115:9 

130:13 231:5 232:9 

demands 218:9 

demographic 114:9 

218:5,10 

demographics 218:7 

demonstrate 134:12 

180:11 

demonstrated 122:20 

demonstrates 31:5 

densely 90:7 

Department 33:15 

35:15 104:9 

dependent 23:1 

deposit 1:1,13,15 12:3 

25:3 72:22 80:8 91:13 

100:21,22 118:12 

135:6 161:16 164:22 

171:15 173:14 174:8 

174:9,9,12,14,16,20 

175:1,3,5,6,7,10,16 

175:17,18 176:16,18 

176:22 177:1,2,11,16 

177:18 178:4,9,19 

179:4 180:22 186:14 

187:1,1,14 197:13,15 

199:15 200:2 202:21 

219:15 228:10 236:10 

deposited 212:5 

depositor 2:12 164:11 

177:2,12 181:21 

186:18 187:8,21 

depositor's 177:5,6 

180:17 

depositors' 177:7 

depository 3:7 127:5 

128:18 179:10 180:7 

180:19 210:5 

deposits 17:2 18:18 

22:2 60:19 63:14 

66:18 92:16 118:3 

123:2 171:17 173:4 

173:21 174:1,3 175:1 

175:9,14,21 176:6,9 

176:10 177:5,15,19 

178:1,2,5,9,10 181:12 

181:19 182:18 183:14 

183:21 185:4 186:3,5 

186:6,10,11,12 

187:12 200:5 209:15 

Deputy 1:15 164:7,9,13 

describe 152:3 

describes 224:20 

describing 227:21 

description 193:22 

descriptions 227:3 

design 132:14,19 

designate 71:5 

designated 179:13,17 

179:21 180:3,14 

181:9,14,20 

designations 182:2 

designed 132:1 

desk 64:22 74:6 

desperately 22:19 

despite 16:21 50:20 

109:1,14 115:7 

126:12 

details 30:12 

deterioration 25:21 

109:6 204:5 

determination 185:6 

determinations 184:19 

determine 176:18 

determining 174:12 

detrimental 152:18 

Detroit 28:11,13,17 

31:14 129:12 

devastating 8:4 

develop 5:20 131:18 

developed 66:13 

developing 135:4 

development 2:8 35:14 

127:11 131:21 

devoted 242:16 

dialogs 149:11 

Dick 242:9,15 

differ 227:11 

difference 14:10 31:10 

69:10 152:15 232:12 

differences 217:2 

different 37:19 57:7,9 

69:18 80:22 85:9 

87:20 107:9 108:14 

141:20 144:9 146:14 

148:14 156:22 175:14 

194:8 201:20 225:17 

226:20 227:1 236:13 

differentiate 91:20 

differently 188:20 

difficult 24:22 45:6 

difficulties 28:2 126:12 

difficulty 73:2 85:18 

digital 52:6 54:8 

diligence 5:19 70:16 

141:12 

diligently 77:12 

diner 138:6 

dining 76:10 

direct 35:11 50:9 

134:17 212:5 

directed 211:10 212:2 

directly 34:19 128:11 

150:9 

director 1:14 7:16,19 

9:5,18 10:1,3 28:4 

31:15 46:14 58:19 

65:17,19 68:10 73:17 

74:14 79:10 95:18 

111:10 127:10 131:2 

164:5,7,9,14 213:11 

240:17,20 241:20 

directors 155:18 169:3 

dirty 149:14 

discernible 204:18 

discovered 149:9 

discuss 175:12 188:16 

discussed 29:5 129:22 

130:7 131:5 144:10 

discusses 215:7 

219:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
251 

discussing 213:18 

discussion 3:3 7:9 8:1 

10:8 65:18 150:5 

154:12 155:22 199:16 

208:21 

discussions 74:1 

129:18 

disparities 31:5,12 

disparity 200:11 

disproportionately

133:12,22 

disruptions 231:5 

distancing 19:12 48:19 

distinctive 135:11 

distributed 116:10 

220:15 

distribution 75:17 

District 113:9 

districts 97:22 

divergence 117:11,14 

diverse 139:22 

diversified 72:8 

diversity 59:16 129:2 

division 2:5,9,10,11,12 

2:13 9:19 142:11 

164:4,11 213:12,19 

document 196:10 

documentation 50:1 

documents 172:18 

doing 4:12 32:16 35:18 

44:3 45:20 68:1 72:17 

73:1 105:15 110:7 

115:13 121:21 122:2 

126:13 146:14 147:10 

148:18 149:4 189:5 

190:15 195:9 196:1 

206:18 

dollar 73:15 

dollars 25:14 49:13 

88:3 134:17 

domestically 143:8 

donate 93:6 

door 85:17 139:11 

209:4 

doors 148:21 

Doreen 2:9 3:12 164:5 

164:15 169:19 196:21 

197:7 199:11 203:4 

206:1 207:14,15 

208:8 209:7 

Doreen's 210:21 

dosage 97:8 

dose 14:4 48:8 76:2 

dotted 238:8 

double 163:6 233:3 

doubled 88:2 232:17 

DOW 204:9 

downgrades 119:15,18 

downside 8:18 

downturn 114:7 229:7 

235:6 

downward 234:8 

dramatic 231:18 

dramatically 236:17 

draw 41:4 61:5,9 76:22 

drew 138:4 

drive 20:19 54:7 98:5 

drive-up 60:6 

driven 82:1 127:17 

131:16 132:9,16 

134:15,22 

driver 18:20 

driving 43:4 73:6 82:14 

94:2 

drop 110:15,22 230:22 

dropped 17:9 32:2 37:6 

112:12 231:21 

dropping 112:5 

drops 110:20 

drought 45:11 

drove 238:15 

dry 58:6 

due 5:18 15:16,21 

18:19 21:2,6 26:21 

52:4,8 55:18 67:7 

70:15 72:14 100:8 

101:11 118:7 123:1 

130:11 141:11 158:11 

236:2 238:4 

dues 12:8 

dwindled 66:7 

dying 66:8 

dynamic 11:3 45:22 

dynamics 82:4 116:20 

198:2 

E

e-retail 115:12 

Eagle 7:3 42:1,1 129:12 

earlier 60:16 70:21 

82:15 85:22 112:22 

126:21 127:8 132:5 

158:2 167:19 193:15 

204:7 226:19 237:16 

237:19 

early 23:2 38:7,13 

81:21 110:15 133:17 

147:8 233:20 239:22 

earning 51:3 

earnings 18:18,21 50:6 

50:6,20 68:5,6 91:9 

118:1,9,10 119:21 

120:16 207:11 215:21 

236:1 

easier 5:7 139:14 

166:13 

east 18:12 79:17 

eastern 45:9 90:9,11,17 

95:12 240:3 

Eberley 2:9 3:12 164:5 

164:17 197:3,9 204:2 

209:17 

echo 72:19 106:14 

echoing 23:17 

ECIP 134:18 

economic 5:1,2 11:1 

16:12 49:20 92:3 

107:5,19 108:13 

113:16 115:19 118:7 

120:19 130:8 143:10 

198:12 212:1 227:5 

233:8,13,18 

economical 225:11 

economies 92:5 226:2 

226:5 

economists 142:9 

200:19 

economy 4:20 8:5 9:21 

11:14 12:18 20:14,20 

21:8 32:22 33:7,20 

47:20 61:11,16 67:13 

73:1 95:10 103:6 

106:21 107:13,18 

111:4 143:2 

ecosystem 139:5 

140:20 142:15 

edge 80:1 

edged 238:19 

education 31:4 49:5 

80:3 155:16 158:12 

160:3 

educational 79:22 

effect 174:5 

effective 172:11 173:2 

190:5 194:8 195:20 

effects 20:15 214:20 

215:8 225:1 

efficiency 91:10 192:3 

efficient 104:6 144:5 

189:8 192:14 

effort 35:5 175:15 188:2 

208:18 242:16 

efforts 15:20 23:8 30:13 

30:19 46:19 48:6 

49:17 74:19 78:3 

79:11 114:19 165:17 

168:17 

eight 90:10 233:2,4 

eighth 13:20 

either 76:6 100:17 

125:13 157:2 179:21 

197:1 218:18 

elected 44:17 

electronic 170:8 

electronically 7:8 

elevated 109:17 

eligibility 193:12 

eligible 13:22 19:5 34:5 

97:13 131:20 175:11 

193:4,9 

eliminated 52:6 

Elmquist 2:6 3:5 10:1 

111:9 112:9 121:7,11 

124:2,8,13,17,22 

email 144:19 145:2 

157:13 163:1 

embargoed 75:2 

embarked 92:1 

embrace 153:10 158:7 

emergency 127:18 

133:5 167:22 

Emory 131:8 

emphasis 131:12 

employed 88:7 

employee 17:22 48:15 

employees 13:14 21:22 

24:13 52:7 60:9,9 

71:21 75:22 96:22 

103:18 151:2 168:3 

170:9 

employment 75:14 83:7 

108:15,16 

enable 134:21 166:10 

enabling 179:22 180:13 

181:3,19 

encourage 137:12 

147:12 150:20 165:8 

172:2 188:7 195:1 

196:4 

encouraged 165:12 

166:18 

encouraging 62:17 

97:16 

ended 32:6 119:3,6 

229:2 230:12 234:6 

235:2 239:10 

Endowment 155:9 

energy 57:22 122:4 

148:19 

enforcement 183:5 

202:17 

engage 76:9 106:10 

145:3 163:20 

engaged 175:20 

engages 176:20 

engaging 147:7 177:20 

engineering 141:8 

enhance 144:13 

enhancements 170:6 

enjoyed 74:1 

ensure 4:19 77:13 79:6 

143:19 198:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
252 

ensuring 17:18 19:12 

30:21 77:4 

entered 12:13 117:18 

120:19 

enterprise 170:6 

enthusiasm 57:22 

151:20 

entire 46:2 

entirely 150:4 

entities 35:14 140:19 

147:5 175:14 180:9 

180:17 181:4 

entitled 243:4 

entity 174:20 175:3,4,7 

175:13 179:3,19,20 

180:3 181:14 

entry 47:13 

entry-level 171:1 

environment 5:7,9 15:1 

21:21 42:22 47:16 

50:11 227:6 

environments 13:9 

equality 30:21 

equals 56:22 

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equipped 170:5 

equitable 140:1 

equities 61:17 151:10 

equity 166:14 226:1 

escalate 50:1 

especially 36:12 53:19 

57:10 62:16 114:15 

136:3 159:8 199:20 

211:21 225:15 229:12 

231:7 

essential 54:21 

essentially 43:2 206:13 

EST 1:10 

establish 5:18 

established 22:14 25:1 

59:6 128:4 166:1 

estate 8:20 20:5,8 33:1 

45:4 73:6 81:19 82:14 

93:16 99:17 101:17 

107:16 109:20,21 

110:22 111:6 114:14 

117:8 122:6 205:15 

estimate 134:13 135:1 

estimator 134:21 

et 23:12,22 24:15 31:7 

82:5 92:10,14 

Europe 152:10 

evade 175:15 

evaluated 154:22 

evaluating 135:13 

evaluation 190:22 

evenings 39:8 

event 121:16 162:14 

events 17:10 41:11 

114:22 

ever- 77:13 

ever-increasing 18:1 

everybody 7:10,21 

10:20,20 36:21 40:11 

48:13 50:13 57:4,16 

58:10 83:20 87:8 

125:17 152:8 156:22 

163:3,8 240:21 

everybody's 141:20 

everyone's 126:15 

evident 69:1 

evolving 5:9 

exacerbated 6:4 

exact 25:17 142:8 200:3 

exactly 95:5 

exam 56:4,7,14 65:2 

95:3 103:16 104:6 

188:18 189:21 192:3 

192:5,11 194:5,7,21 

195:18 196:8 202:4 

examination 56:3 

135:10 165:2 168:1 

169:21 170:18,19 

185:9 217:3 

examinations 56:9 78:2 

105:20 123:15 164:8 

164:14 168:17 208:4 

examine 228:21 229:10 

examiner 56:15 165:19 

170:18 

examiners 103:21 

104:1 135:4,10 

142:10 148:21 171:6 

171:7 182:21 191:8 

194:12 205:11 206:3 

206:4,9,22 239:5 

examines 218:5 225:16 

227:9 

examining 206:5 

example 177:22 180:8 

181:1,18 

examples 105:15 

exams 114:21 165:22 

170:3,22 171:3 

189:11 190:15,16 

191:21 203:15,22 

exceed 13:9 75:12 

exceeded 143:7 

exceeding 187:16 

exceeds 187:4 

Excel 142:5 

excellent 27:8,11 56:6 

exception 11:3 47:22 

101:20 175:11 178:1 

178:16,19 179:1,3,7 

180:3,10,14,16 

181:20 

exceptionally 8:12 78:6 

242:4 

exceptions 178:18 

179:14,17,21 181:3,9 

181:15 

excess 80:7 100:8 

187:13 

exchange 105:19 170:6 

excited 12:20 26:22 

62:5 63:20,21 64:3,4 

147:17 149:19 

exciting 78:18 

excluded 175:5 

excluding 12:4 

exclusive 174:20 175:7 

Excuse 178:7 

executive 10:9 

executives 129:2 132:6 

132:7 

exemption 181:5 

exist 84:20 155:5 

existence 47:1 241:3 

existing 52:13 100:8,16 

165:18 172:17 186:16 

186:18 205:14 

exists 85:11 141:13 

exit 27:4 

exiting 225:20 

expand 76:14 96:21 

expanded 236:18 

expect 69:19 137:2 

205:2,5 

expectation 13:10 

expectations 18:3 51:3 

51:3 108:4 227:6 

expected 25:21 118:6 

expend 139:9 

expense 102:22 159:9 

159:10,10 

expenses 102:18 230:6 

230:10,20 

expensive 225:6 230:8 

experience 11:18 

105:12 151:8 219:3 

experienced 21:6 77:15 

80:10 84:12 232:22 

experiencing 53:18 

114:10 

expert 136:20 142:16 

experts 142:14 

expired 63:11 199:3,4 

exploding 14:11 

explores 130:20 

export 231:10 

express 127:6 202:1 

expressed 28:17 78:17 

extend 104:8 154:17 

extended 222:13 

228:17 

extending 64:2 

extends 47:5 

extent 182:22 

External 1:16 

extrapolation 185:14 

extremely 39:12 54:5 

57:15 

eye 119:20 

F

F 67:3 73:14 

FACA 128:7 

face 74:18 142:20,21,22 

158:14 228:11 

faced 15:21 28:18 79:7 

111:22 161:10 

facilitated 170:7 174:9 

facilitating 174:16,22 

175:21 176:9,10 

facilities 60:6 75:17 

84:11,14 94:1 

facing 74:4 110:1 130:2 

130:5 160:6 

fact 26:20 45:21 93:5 

109:1 111:12 124:11 

162:13 222:17 

factor 77:1 

factors 114:6 135:13 

218:10 227:4 

factory 152:17 

facts 205:5 

fail 157:2 

failure 217:15 

failures 227:14 

Fair 97:18 

Fairbanks 18:14 

fairing 80:13 

fairly 32:11 62:19 73:6 

80:13 91:1 110:16 

214:4 240:15 

Falcon 46:12 129:14 

fall 32:9 82:1 100:19 

173:4 232:6 

fallen 118:4 

fallout 17:20 

Falls 64:8 65:5 

families 4:12 168:4 

family 14:12,18 43:21 

59:6 

fan 146:16,17 147:4 

151:22 

fantastic 56:17 65:5 

137:10 157:12,15 

161:5 162:18 

FAQs 169:13 172:18,21 

far 8:10 14:15 26:1 51:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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62:6,18 76:21 125:11 

138:10 146:15 149:22 

155:1 184:10 199:21 

229:20 239:17 

Fargo 29:11 

farm 61:16 66:9 101:17 

101:18 223:10 228:19 

228:21 229:6,11,15 

229:21 230:10 232:3 

232:7,11 233:12 

234:2,6 235:1,5,5,7 

235:11,13,17,18,22 

236:3,13,14,16,20 

237:2,6,14,17,21 

238:3,5,15 239:6,8,9 

farmers 34:3,5 53:7,14 

61:3 67:4,5,7 69:5 

88:7 101:12 102:4 

224:9 230:16 236:6 

237:15 240:1 

farmers' 231:17 

farming 230:22 233:14 

farmland 224:17 230:8 

231:13,16,19,21 

232:2,5,6,9,10,13,16 

232:19,20 233:3 

236:17,22 237:9,12 

237:15 

farms 236:18 

fast 47:1 69:15,21 

87:13 

faster 118:20 216:21 

219:3 228:10 

favorable 67:15 100:13 

116:20 117:5 120:20 

FDI 173:12 183:6 

FDIC 3:17 4:6,7,15 9:13 

12:14,15 23:9 27:2,4 

27:13 30:14 36:21 

38:12 46:15 56:7,13 

58:2 64:2 74:3,19 

79:10 89:19 95:19 

104:9 106:9 109:16 

127:19 128:4,12,16 

129:8,16 131:17 

133:18 134:5,11 

135:3 137:3,22 

138:13 139:18 142:7 

146:2,8,12,19 148:18 

151:1,20 156:18 

162:9 163:16 165:4 

170:9 173:21 176:1 

184:15 197:11,22 

199:17 203:5 211:4 

213:22 219:19 221:13 

222:11 228:15 235:7 

237:22 239:5 241:4,9 

241:18 242:14 

FDIC's 10:1,2 36:8 56:5 

78:3,12 127:10,17 

135:5 136:18 213:14 

213:19 214:7 

FDIC-insured 131:20 

133:9 

FDIC.gov 165:7 

FdiTech 3:9 5:11,14 

feared 8:5 

features 159:6 171:21 

February 20:17,18 

37:21 108:21 109:1,2 

112:3 

Fed 184:6 208:12,21 

209:12 

federal 1:1,13,14 11:14 

23:9 71:6 128:6 

210:15 211:22 241:6 

fee 25:14 99:16,18 

feedback 105:19 

128:16 134:10 169:2 

189:18 191:7,15,17 

194:12,13 195:8,17 

195:22 196:5,12,18 

242:5 

feel 26:17 32:12 37:17 

39:12,16 86:14 95:11 

147:10 157:4 194:6 

feeling 79:5 

fees 176:14 180:21 

182:14 211:16 

feet 51:1 69:7 

fell 187:17 234:13 235:2 

fellow 22:9 46:18 95:19 

felt 53:15 201:14 215:4 

fertilizer 101:21 230:7 

fewer 184:11 217:8 

field 171:6 

fierce 93:17 

fighting 11:1 51:12 

142:1,2,2,5 158:3,10 

figure 25:4 

file 170:6 181:16 

files 170:8 

filing 182:9 

filings 173:5 

fill 104:3 109:3 

Fin 155:8 160:2 

final 221:12 238:2 

finalize 85:4 

finally 135:3 142:17 

finance 15:8 236:7 

financial 6:3 8:18 15:21 

30:22 72:1 85:4 100:9 

111:13 120:20 122:22 

131:17,21 132:11 

134:7,18 135:12,14 

136:21 155:12 159:13 

165:12,20 203:18,20 

215:9 216:7 224:22 

240:2 

financially 54:14 77:15 

financing 223:8 237:16 

Finastra 70:20 

find 24:9 41:18 73:3,4 

106:16 126:22 137:14 

149:4 166:5 169:13 

finding 18:3 81:5 83:4 

144:14 147:8 202:19 

findings 189:1,10 

190:12 194:7 195:19 

fine 58:11 123:22 

124:19 136:11 

fingernails 149:14 

Finnegan 2:12 3:15 

164:11 188:15 

fintech 70:4 145:20 

146:5 

fintechs 57:8 70:11,22 

136:16 141:12 147:1 

148:7 

firms 131:17 132:12 

first 4:5 5:10 6:12 14:2 

16:19 19:16 22:16 

25:22 28:10 31:14,19 

34:2 40:15,16 41:4 

49:20 50:3 52:21 

56:15 57:10 60:21 

73:9 77:22 87:9,15,16 

88:1 89:2 107:5,18 

108:8 113:13 115:18 

129:11 138:19 139:21 

140:7 145:20 146:11 

148:2 150:2 151:16 

151:19 155:14 161:15 

167:14,21 183:16 

184:10 186:2 189:2 

193:17 207:19 214:5 

214:7 216:8 217:5 

224:11 225:9 228:20 

239:1,3 240:17 

242:10 

firsthand 105:1 

fiscal 11:20 108:5 

Fiserv 52:4 70:5 

fish 26:7 

fit 159:4 181:14,19 

fits 161:3 178:4 179:4 

five 32:3 48:20 56:8 

71:21 75:6 94:9 

141:19 218:2 224:19 

fix 178:8 

fixed 50:17 

flash 22:16 

flat 80:12 86:3 101:20 

110:16 222:6 232:10 

flexibilities 170:10 

flexibility 4:20 17:8 

165:14 166:10 168:1 

168:8 201:10 

flexible 184:14 201:18 

flip 123:13 

Florida 6:22 36:20 37:2 

38:1 151:19 

flow 34:22 

flows 16:14 218:12 

flushed 236:5 

flying 21:17 23:3 

focus 4:15 77:20 

190:18 210:2 223:13 

229:3 233:11 

focused 6:3 13:12 77:4 

111:21 154:15 

focuses 5:5 213:14 

216:18 

focusing 114:19 176:1 

folks 23:3 26:7 44:4 

66:5 82:8 88:7 89:3 

92:18 95:1 171:4 

207:20 

followed 10:10 229:8 

following 23:9 228:22 

238:13 

food 49:16 101:13 

115:12 231:5 

foothold 29:19 

footprint 47:5 

forbearance 44:4 119:9 

force 75:12 

forecast 107:22 108:10 

116:22 

forecasting 11:20 

forecasts 113:20 

foregoing 126:7 

foreign 143:18 

foremost 6:7 207:19 

forget 51:12 

forgive 213:4 

forgiven 44:8 

forgiveness 16:6 19:20 

50:1 87:17 130:14 

format 191:1,12 192:12 

193:16 194:9 

formation 131:16 

formed 217:6 

Forreston 6:17 51:19 

52:13 

forth 60:10,19 62:3,11 

fortunate 12:6 32:5 

83:21 136:17 155:7 

fortunately 54:8,20 

56:12 

Fortune 95:7 

forum 73:19 

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(202) 234-4433 Washington DC www.nealrgross.com 
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forward 5:4 7:9,22 8:13 

8:16 9:1 10:19 27:1 

27:15 30:3 41:9 60:1 

63:5 65:8 71:8 74:7 

81:3 85:5 86:11 89:21 

93:13 95:15 127:2 

137:2 147:6,15 

163:20 182:20 188:20 

190:1,3 192:13 

193:13 195:5 196:3 

196:14,17 199:9 

209:13 214:17 241:15 

242:17 

found 98:8 219:2 236:3 

foundation 93:5 

founded 13:4 71:17 

four 23:6,16 24:4 52:22 

55:8 59:8 94:9 141:19 

144:9 219:21 

four-year 88:14 

fourth 25:22 107:21 

224:11 

framework 131:18 

198:6 

frameworks 207:10 

Francisco 73:22 

Frank 2:7 3:6 10:2 

106:10,12,22 111:7 

112:15 121:3,6 

frankly 6:4 24:1,8 25:6 

fraternity 162:16 

free 143:10 

Freeport 51:19 

freeze 112:2 

frequency 168:22 

frequently 166:4 

167:10 

friction 142:12 

Friday 27:5 

friendly 95:5 

friends 162:2 

front 38:11 113:15 

116:17 

fronts 85:10 

frustrated 39:20 

FSA 101:11 

fulfill 128:17 

fulfillment 30:8 

full 76:10 84:22 108:1 

148:16 172:12,15 

205:2,5 210:10 

216:13 

fuller 11:12 

fully 14:6 19:6 48:12,17 

97:12 170:3 

function 44:11 225:10 

226:4 

functions 150:15 

fund 30:14 127:17 

131:16,19 132:1,14 

132:15,18,21,21 

133:1,2 134:7 164:22 

179:10 236:18 

fundamentally 144:5 

154:11 

funded 25:16 56:2 

152:17 153:15 

funding 99:8,10,11 

101:1,2 130:14 135:1 

182:22 223:9 

funds 123:11 132:1 

134:19,20 176:13 

180:18 184:6 186:17 

187:7,16,20 212:5 

further 15:15 50:9 

203:12 

future 12:20 17:5,18 

22:20 41:19 89:21 

95:15 102:9 105:9 

139:16 140:1 142:18 

143:7,17 149:6 

G

G 3:15 

gaining 53:4 

gains 109:2,7 114:3 

117:9 232:15 

gap 216:2 

gatherings 97:6 

GDP 107:21 

general 113:16 116:14 

117:17 120:18 130:10 

146:2 

generally 87:1 88:10 

92:22 114:2,9 116:19 

176:19 238:20 

generate 132:1 234:19 

generated 99:18 

generating 216:1 

generation 59:6 

generational 53:14 

generic 145:18 

generous 86:6 

gentleman 63:9 

geographic 129:5 

221:8 

Georgia 131:4 

getaway 76:16 

getting 32:12 82:16 

89:1,3 124:4 159:4 

192:4 194:7,12 

195:16 

Getzlaff 1:19 31:18,18 

ghost 54:16 

Gilbert 1:20 3:8 46:11 

51:15 127:6,10,22 

129:13,19 136:5,12 

156:15 

gist 124:4 

give 29:7 106:10 126:1 

168:1 169:17 188:17 

203:14 209:18 213:3 

241:22 

given 110:10 111:3,3 

gives 44:21 

glad 26:14 41:7 57:20 

global 142:21 155:12 

globally 142:19 143:9 

globe 230:14 

goal 198:10 

goals 128:14,17 168:14 

214:9 226:13 

gold 219:8,18 

gotten 137:18 

government 21:13 

32:17 45:14 61:12 

62:3 66:1 130:11 

152:17 166:22 210:16 

governmental 231:9 

governments 132:21 

Governor 54:22 

GPD 108:10 

grad 78:16 

grade 49:3 

grain 61:15 102:6 

grandfather 59:7 138:7 

grandstand 97:21 

Granite 13:21 

grant 51:11 134:19 

grants 33:16 34:15 

62:10 

grasshoppers 45:13 

grateful 24:12 26:14 

27:1 29:16,22 47:17 

greater 11:2 101:8 

228:11 

greatest 156:11 

greatly 115:11 147:13 

greetings 31:13 

grew 137:22 219:13 

221:1 222:4 232:2 

group 22:13 28:5 32:10 

59:3 66:5 89:20 

130:19 131:6 156:19 

156:20 224:13 241:16 

group's 211:3 

groups 70:16 147:7 

153:15 207:3 

grow 25:5,5 53:15 

63:17,17,17 66:14 

101:1 231:22 

growing 37:14 43:20 

53:16 70:19 75:11 

79:1 81:18 230:14 

grown 16:18 152:16 

growth 11:20 12:3,3 

16:21 17:5 18:16,17 

18:17 25:2,3 54:12 

66:13 68:15 72:22 

80:8 91:11,13 107:21 

108:1 118:2,12,15,16 

123:2 132:3 148:13 

197:14,15,17 219:4 

228:10 236:4 

Gruenberg 1:14 7:16 

7:19 9:6 28:4 31:15 

46:14 58:19 65:17 

68:10 73:18 74:14 

79:10 95:18 240:18 

240:20 241:21 

guaranteed 66:1 

guarantees 222:21 

guarded 85:6 86:10 

88:11 105:7 

guardedly 21:19 

guess 85:6 111:10 

124:17 148:17 204:18 

guidance 69:3 79:6 

166:3 168:22 169:7 

169:14 203:7,12 

205:15 206:1 

Gulf 112:1 

guns 92:13 

H

hack 152:11 153:6 

156:5 

hacked 157:13 

hacks 140:17,17 

Hal 90:1 203:2 

half 12:1 49:12 51:20 

72:14 73:15 223:11 

227:20 228:20 229:9 

232:22 239:12 

half-way 51:17 

Hampshire 13:3,19 

14:2,3,9 

hand 125:13 138:22 

163:6 197:2 203:2 

hand-in-hand 40:9 

handle 111:12 

handled 203:15 

handling 54:2 

hands 125:16 136:9 

151:12 163:7 212:15 

happened 4:10 26:1 

42:11 189:15 

happening 85:8 93:9,14 

203:12 

happens 57:18 

happy 48:10 104:7 

136:5 138:20 139:19 

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145:10 168:7 188:11 

204:2 

hard 21:9 29:3 61:22 

80:20 82:17 103:19 

171:11,21 208:15 

209:14 211:4 

harder 139:15 

harm 190:19 

harms 45:14 

Harold 2:2 6:14 

Hartford 116:18 

hate 124:18 

hats 141:21 158:7 

have-nots 227:11 

haves 227:10 

Hawk's 131:8 

Hayes 1:21 58:9,15,17 

58:20 151:17 157:19 

157:21,22 161:4 

198:17,20 199:1,10 

head 95:2 

heading 84:7 

headquartered 46:21 

71:14 96:4 219:3,12 

221:5,8 235:15 

Health 165:11 

healthy 10:21 21:21 

50:19 207:11 

hear 5:12 9:12 10:14 

27:20 53:10 55:15 

58:10,11 65:11 105:1 

105:17 112:9,19 

113:1,3,5 121:7 124:8 

124:22 139:18 143:5 

145:5 149:18,19 

150:7,9,22 151:12 

157:19 160:2 197:8 

198:21 

heard 33:5,11 63:6 

64:16 105:4,21,21,22 

106:3 107:4,16 

108:15 125:10 127:8 

129:10 130:3 131:1 

131:15 144:19 156:2 

hearing 9:1 74:16 

106:16,17 123:21,22 

124:11,19,20 138:18 

150:21 158:8 163:16 

205:10 

heart 36:6 42:6 

heavily 23:1 200:8 

heavy 200:21 230:13 

held 55:18 56:4 97:19 

167:3 200:5 220:1 

221:6,7,20 222:15 

223:12 

Hello 36:18 65:10 71:12 

126:11 199:14 

help 33:14,18 34:16,21 

35:1,13 41:1,8 61:20 

63:21 68:22 69:10 

70:11,15 71:7 73:4 

79:6 81:1,5 88:8 

99:22 118:9,9 134:5 

140:12 141:15 171:2 

171:5 176:17 192:6 

211:4,11,13 

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41:6 42:20 44:5 57:3 

61:12,20 99:12 

101:14 231:11 

helpful 34:14 57:15 

62:2 65:1 67:4,8 69:3 

104:2 149:5 171:20 

189:13 212:14 

helping 30:20 45:16 

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Henry 70:7 

Hi 41:22 111:9 121:7 

145:16 151:18 

high 11:7 14:20 15:3 

16:5 19:7 29:4 31:3 

43:8 45:4 48:22 53:12 

55:7 98:9 122:15,15 

123:2 171:7 173:16 

184:18 214:4 227:10 

228:4,7,9 239:17,20 

higher 17:22 31:1 49:5 

73:12 96:8 114:3,13 

130:15 184:1,5 

201:11 215:20 216:8 

219:14 228:9 230:10 

237:12 238:19 

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218:14,18,21 239:3 

highlight 128:21 196:13 

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236:12 

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171:14 

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hindsight 24:11 

hire 96:22 

hired 5:10 131:17 171:1 

171:6 

hiring 133:1 160:6 

Hispanic 47:9 129:3 

historic 14:8 112:1 

238:16 

historically 15:2 17:4 

72:4 119:7 191:1 

history 51:22 224:2 

hit 14:13,16 21:2,9 38:2 

66:16 121:16 203:6 

207:14 208:11 

hits 145:2 

hoarding 26:3 

hog 234:21 

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hold 220:10 

holding 19:11 20:9,9,10 

52:2 220:17,17 

hole 87:20 109:3 

holidays 23:12 

holistically 5:22 

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78:12 99:13,14 

116:13 117:9,11 

161:21 166:14 

homes 21:1 43:1,3 

hometown 13:8 

honor 36:20 

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hope 4:11 10:20 36:2 

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62:7 65:1 67:21 69:2 

78:8 88:18 112:18 

147:13 242:19 

hopeful 26:5 46:5 71:4 

hopefully 21:16 27:16 

32:13 59:4 60:13,14 

89:17 192:13 195:6 

201:22 

hopefulness 8:16 

hoping 62:12 111:4 

horrible 24:2,11 

Horvat 2:2 6:14 89:22 

90:1 203:2,3 

hospitality 33:17 44:2 

83:21 92:7 94:17,19 

hospitalization 19:14 

48:3 

hospitalizations 24:13 

24:17 

hospitalized 67:18 

host 78:5 134:11 

hosted 133:18 

hotel 62:13 84:20 

102:20 

hotels 23:21 37:11 44:3 

83:22 84:3 92:10 

115:4 220:21 

hour 51:21 142:16 

hours 29:14 48:18 

51:20 85:19 170:18 

house 43:5 166:2 

household 198:11 

households 166:20 

houses 43:7 

housing 14:8 37:8,14 

42:18 73:3,4 82:21 

92:16 105:10 122:3 

130:15 

housing- 33:2 

how's 158:18 

huge 33:18 34:22 35:1 

69:9 

Hughes 2:7 3:6 10:2 

112:18,21 

hurricane 121:15 

hurricanes 206:6 

hurts 100:15 

hybrid 49:6 

I

ICBA 161:20,22 162:9 

Idaho 6:21 71:14,14,19 

73:5 

idea 38:17 56:13 150:22 

157:9,12 206:11 

226:12 

ideals 138:10 

ideas 13:15 145:3 

identify 128:21 

IDI 174:18 185:2 186:19 

186:21 

IDIs 184:21 

ignored 159:14 

ignoring 147:9 

II 131:2 

Illini 51:12 

Illinois 6:17 51:10,18 

53:1 54:18 55:6,9,11 

55:14,19,21 56:2 

138:1 

Image 56:8 

imagine 55:22 93:18 

immediate 8:3 

immediately 238:21 

impact 8:4 38:5 67:12 

68:13 105:4 120:12 

120:13 134:13 135:1 

182:14 212:1 

impacts 77:17 

implement 155:2 169:8 

196:16 

implementation 127:18 

188:7 

implementing 159:1 

implications 107:14 

importance 48:16 

important 7:8 26:17 

47:15 93:8 110:10 

122:7 136:4 142:13 

171:16 173:15 181:13 

194:13 218:6 221:16 

223:19 227:7 230:4 

234:21 

importantly 144:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
256 

impossible 45:5 

impressed 208:4 

impression 162:12 

impressive 111:20 

improve 12:19 111:5 

189:7 206:17,19 

improved 19:21 37:4 

47:20 91:10 107:11 

107:19 120:16 238:12 

improvement 62:7 

109:14 113:16 

improvements 111:4 

123:11 

improving 107:5 

108:16 

in-person 32:9 49:4 

inactive 172:22 

inbox 145:2 

incentivized 230:13 

inception 59:19 

include 127:16 128:15 

134:16 177:4,7,9,17 

included 67:3 130:11 

132:12 155:13 169:12 

includes 47:6 113:8,9 

135:16 179:13 183:18 

214:18 215:6 219:16 

including 65:18 111:14 

112:2 122:3 129:3 

132:15 133:1 164:20 

169:15 174:21 176:16 

183:1 198:2 220:20 

226:21 230:4 

inclusion 6:3 30:22 

139:21 

inclusive 139:10,22 

inclusivity 140:9 

income 25:14 47:11 

57:2,2 61:7 99:16,18 

133:11,22 203:19 

216:1 228:21 229:6 

229:15,17,20,21 

232:3,11 233:12 

234:2,6,11,16 235:1,5 

235:18 236:14 237:14 

238:15 239:9 

incomes 230:11 231:11 

232:7 233:14,22 

234:3,7,9,13 237:2 

increase 21:16 55:17 

60:19 101:15 102:17 

116:3 118:5,6,20 

120:10 123:10 197:14 

212:12 215:15 225:22 

236:20 239:5 

increased 15:7,14 

16:16 20:13 21:3 

26:20 42:18 77:16 

100:7 101:11 118:3 

119:3,6 140:19 

168:21 170:7,11 

204:11 217:10 221:14 

223:1 230:7 235:1 

increases 77:2 230:3 

232:20 236:21 238:22 

increasing 16:10 18:4 

117:19 225:14 236:18 

incredible 25:4 

incredibly 149:3 

Independence 28:10 

31:14 129:11 

Independent 161:13 

162:2 

indexed 233:15 

indicate 20:16 

indicated 209:3 

indicates 116:13 

indicative 176:5 

indicators 68:8 

individual 9:10 209:16 

individuals 38:6,18 

40:1 

indoor 97:5 

industrial 79:21 94:1 

110:3 220:20 

industries 37:11 80:22 

83:17 92:6,9 220:20 

industry 5:3 21:19 

33:17 41:13,14,19 

44:2 57:13 94:18 

120:13 149:9 152:18 

167:5,5 220:4,5 221:2 

225:21 

industry's 220:2,10 

221:21 

infected 88:22 

inflation 229:15 

inflexible 44:21 

inflows 218:22 219:9 

influx 21:4 42:13 66:18 

92:18 

information 9:15 41:15 

70:17 106:16 182:7 

192:8,15 194:20 

198:18 212:4,14 

213:3 240:7,8 

informational 40:3 

informative 105:17 

240:10 

infrastructures 151:11 

initial 113:12 120:11 

226:1 

initially 138:4 231:4 

initiated 170:15 

initiative 140:6 

initiatives 5:14 131:2 

133:17 

innovate 153:10 

innovated 146:21 

innovation 2:8 5:6,11 

5:21 6:2,2 136:18 

137:3 139:12 146:17 

146:17,20 148:14 

150:6 154:11 158:20 

innovation@fdic.gov

144:20 163:2 

innovations 147:16 

149:10 

innovative 41:18 

input 132:8 200:15 

inputs 101:19 

inset 215:6 219:17 

inside 30:14 141:14,17 

142:7 147:8 

insight 115:19 188:18 

203:14 

insightful 130:22 

insights 106:17 

inspections 166:16 

instances 17:8 210:16 

institution 13:4 17:1 

72:1 90:4 127:5 130:2 

135:12,19 156:17 

186:9,13 187:5,7,11 

187:17 190:13 194:19 

210:8,9 211:7,13 

212:11 

institution's 135:14 

165:17 

institutions 3:7 94:10 

100:9 119:14 122:8 

128:18 130:5 131:22 

134:4,18 135:7 

146:20 151:9 152:19 

159:8 160:15 165:12 

165:21 166:18 171:19 

173:18 179:10 180:7 

180:19 184:11 186:16 

187:10 189:20 190:2 

190:6 191:11 192:19 

194:4 201:1,7,15,19 

204:8,10 217:1,8 

223:14 224:3 225:7 

instruct 206:21 

instructions 126:2 

173:8 206:2,9 

insurance 1:1,14,15 2:5 

2:13 9:19 94:3 146:8 

213:12,19 

insured 146:19 211:6 

211:12 212:10 

integral 138:8 

integration 12:11 

intended 184:13 

intention 30:8 

interaction 127:1 162:2 

162:9,12 

interagency 134:12 

135:9 173:6,7 205:16 

interest 10:6 15:2,10 

29:9,22 34:10,16,18 

35:3 38:17 42:22 

50:10,10 74:16 78:17 

100:1,2,11,14,19 

130:12 159:10 164:22 

171:17 174:2 180:21 

181:21 182:4 183:8 

183:12,14 187:13 

216:8 232:8 239:18 

interesting 42:10 81:20 

83:9,14 115:16 

131:13 149:10,17 

interestingly 130:3 

interference 9:9 18:22 

31:21,22 42:20,21 

43:9 45:7 70:7 111:12 

111:15,15,19,22 

121:12,14,15,20 

122:3,8,11,12,20,21 

123:5,6,9,12,14,16,19 

142:16 179:5 184:3 

interior 166:16 

intermediary 178:8 

intermediate 178:4 

internal 168:14 204:9 

internally 144:12 

international 47:14,18 

47:19 129:14 155:10 

internet 98:10,11,14,15 

152:6 

interns 78:15 

interoperability 141:1 

interoperate 144:1 

interpolation 185:13 

interpretation 178:22 

interpretations 174:6 

interruption 123:21 

interview 150:3 151:5 

introduce 51:6 

introducing 152:5 

introduction 165:1 

Introductory 3:2 

inventories 102:6 

130:15 

inventory 14:16,22 21:1 

93:2 

invested 100:6 101:5 

investing 132:17 

159:15,22 

investment 16:13 29:12 

29:15 100:6 127:19 

133:5 134:17,19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
257 

investments 15:13 44:6 

100:15,16 131:20 

132:20 133:9 134:14 

134:16 

investors 132:2,16 

133:1 

invitation 89:20 137:7 

invite 196:22 

involved 27:11 41:15 

136:15 153:3 176:14 

181:11 

involving 188:21 

Iowa 95:22 96:13,18 

97:3,3,7,17,18 98:10 

103:15 104:9 

Iowans 97:12 98:13 

Ireland 6:20 71:13 

ironically 25:15 27:3 

IRS 212:5 

Island 6:16 90:4,8,10 

91:3 92:3,8 94:6 95:4 

95:12 

islands 113:10 154:7 

isolated 232:20 

issue 43:6 94:17 98:17 

101:3 202:10 206:1,2 

206:8 215:8 218:6 

225:16 

issued 4:19 133:13 

135:7 169:6 203:7 

issues 9:9 55:9 62:19 

72:11 74:4 84:12,12 

85:13 86:8 87:22 93:9 

130:1,4 188:4 198:14 

200:18 214:18 225:8 

issuing 169:1 

it'd 137:20 162:8 

it'll 89:17 

item 26:17 57:1 

items 9:14 

J

J 1:14 

Jack 70:7 

James 131:1,5,10 

January 32:7 64:6 

103:8,12,14 161:16 

172:20 224:4 

Jefferson 6:18 74:11 

75:2,8 

Jelena 1:10,13 3:2,22 

Jersey 117:13 

job 39:19 62:2 64:9 

65:5 76:4 78:10 114:3 

120:1 123:19 203:5 

206:1 241:12 

jobs 16:2 34:2,2 81:6 

85:20 108:20,22 

109:8 122:1 

John 1:18 2:11,13 3:14 

3:19 7:3 164:8 165:3 

169:16,18 171:10 

203:4 213:10,13,15 

240:5,7 

Johnson 1:21 6:16 51:7 

51:9,15 

join 22:12 65:15 89:20 

121:5 

joined 66:12 136:21 

157:4 164:6,10 

joining 65:17 137:18 

156:15 

Jr 1:20 3:8 6:21 46:11 

127:7 129:13 

July 27:16 95:3 242:18 

243:2 

jump 14:19 136:11 

June 173:5 191:21 

junior 155:19 

jurisdictions 11:4 

justice 171:22 

K

Kalispell 43:19 

Kea 1:15 7:11,14 9:5 

10:15 27:17,21 46:15 

58:11,16 65:11 

104:14 112:4,11,20 

121:3,9 123:20 124:3 

124:10,15,19 125:1 

126:10 136:1 145:14 

151:15 157:17 161:6 

162:21 163:5,22 

196:21 197:7 198:16 

198:22 199:11 203:1 

207:15 210:18 212:13 

240:5,12 241:20 

242:22 

keep 33:6 53:16 89:9,13 

119:20 207:4 

keeping 44:14,16 

keeps 152:2 

Kelly 1:18 27:18,20 

28:1,9 40:6 129:11 

Ken 27:18,19 

Kenneth 28:9 129:11 

KENNTH 1:18 

Kent 51:19 

kept 232:10 

key 23:3 127:15 138:8 

196:10 219:17 220:6 

223:8 

kid 152:10 

kinds 72:2 90:22 

159:20 205:10 

Kitner 2:1 6:18 74:9,10 

knew 38:10 

known 70:8 

Kootenai 44:12 

Kristie 2:6 3:5 106:9,12 

106:22 111:8 112:4,7 

112:13,16 117:17 

121:1,4,9 123:20 

124:11,21 126:3 

Kristie's 121:4 

Kristy 9:22 

L

labor 75:12 82:19 83:11 

84:13 85:12 96:15 

105:11 109:6 113:21 

lack 21:11 94:14 

lag 116:22 

lags 45:18 

Lake 6:14 79:15 233:9 

lakes 80:2 82:8 

land 19:3 51:10 53:9 

101:17 

landscape 209:19 

Laredo 46:21 47:12 

129:14 

large 21:2 37:9 44:20 

75:16 78:6 94:13 

134:17 151:9,10 

197:13 200:11 215:22 

219:16 230:21 

largely 80:2 82:1 

larger 43:18 53:6 68:16 

91:21 111:17 117:15 

201:1 219:5 221:9 

227:22 

largest 47:13 148:4 

159:10 200:5 231:16 

234:19 

late 23:11 81:9 231:9 

240:16 

lately 35:4 

latent 17:19 

latest 49:11 

launched 211:9 

law 131:17 132:11 

173:16,17 174:7 

178:17 186:6,8 

200:21 201:17 

laws 120:4 

lead 5:11 23:9 241:6 

leader 38:8 

leaders 24:6 49:18 

leadership 31:9 40:8 

74:14 227:7 

leading 10:18 204:15 

230:10 

League 30:7 

learned 39:3 130:21 

learning 41:12 71:8 

lease 20:11 25:17 

leasing 28:15 

leave 155:3 170:19 

led 19:2 111:16 121:21 

197:16 216:22 

left 236:19 238:4 

legal 103:11 142:11 

176:11 

legalization 79:3 

legislature 34:15 

leisure 109:5,5 

lender 57:7 87:11 148:4 

225:18 

lenders 57:12 87:4 

220:19 221:3 222:19 

225:13 

lending 3:18 15:4,18 

35:11 44:10 59:17 

76:18 91:12 107:15 

123:3,3 134:3 148:3 

197:14,16 213:15 

219:14,22 220:13,15 

221:1,2,18,19 222:6,6 

222:12 223:6,7,12,22 

224:9 236:18 237:4 

237:13 

lengthy 189:20 

lessons 130:21 

let's 27:19 125:3,20 

145:14 161:6 178:12 

183:7 184:8 187:9 

210:19 214:4 216:17 

228:15 231:13 

letter 191:10,13,16 

193:17 194:1 

letting 74:5 

level 15:5 19:7 29:4,22 

29:22 31:1,3 47:21 

53:12 69:14 76:9 

80:10 108:17,21 

109:1 114:3 140:4 

173:16 193:2,7,8 

214:4 229:20 231:3 

levels 11:12 37:7 48:4 

68:4 71:5 75:10 81:10 

93:3 102:6 108:10 

109:9,15 110:9 115:7 

115:15,21 116:2,5,15 

116:16 117:4,19 

119:1 120:15 123:10 

198:3 207:11 232:3 

236:2,2 238:20 239:6 

239:16 

leverage 16:22 17:8 

26:13,16 63:10 

140:13 168:17 197:6 

239:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
258 

licking 51:13 

lift 200:21 

light 79:21 200:14 

227:13 

lighten 58:7 

likewise 14:5 16:18 

limit 97:5 

limited 76:10 81:12 

100:4 174:2 

Lincoln 51:11 

line 57:1 74:21 75:18 

83:19 175:8,10 

179:12 226:11 233:16 

233:17 

lined 97:21 

lines 161:18 238:7,9 

lining 24:2 

link 165:7 169:12 

liquid 118:19 

liquidity 4:17 16:9 26:4 

26:8,11,21 38:19 

44:21 50:12 62:20 

77:17 86:4 89:12,14 

93:20 101:3 114:18 

118:11 119:1 120:15 

123:8,10 130:11 

166:19 202:9 

list 51:16 103:3 119:12 

179:13 187:22 188:8 

listed 169:15 

listen 137:8 

listening 10:19 139:3 

listings 14:15 

little 16:5 32:20 37:18 

43:6 45:10 53:8,18,21 

63:2 86:22 87:7 94:5 

96:8 102:12 126:21 

138:11,16 139:1,19 

146:10 151:3,6 183:8 

204:13 205:11 

live 11:3 33:10 42:15 

126:17 

lives 142:12 

livestock 53:8 61:15,19 

living 33:13 84:10,21 

152:10 159:19 211:17 

load 20:8 

loan 12:3 15:6 16:3,4 

16:13 17:13,17 20:11 

25:16 32:15 35:13 

38:16 40:4,14 41:6 

49:13 50:13 68:17,20 

77:19,20 80:10 86:1,6 

87:5 88:3 91:4,10 

100:4 101:6 102:11 

102:18,21 103:5 

118:4,16 119:2,5 

130:13 131:7 149:15 

166:8 171:2 205:6 

211:12 218:8 219:4 

222:5,10 223:1 

225:10 226:22 227:1 

228:9,10 236:4,20 

237:7 

loan's 205:1 

lobbies 81:11 98:5 

lobby 44:11,16 

lobbying 36:5 

local 3:3 9:2,3 10:4 

15:20 17:2,6 34:8,15 

39:14 47:20 49:16 

51:5 76:8 82:17 105:5 

138:3,6 184:9,12,16 

184:22 185:1,4,5,7,8 

185:13,17 201:19 

206:7 208:1,14 

228:11 

localities 209:15 

locally 49:3 201:20 

located 13:3 28:10 

58:22 59:12 71:22 

74:20 79:16 95:22 

96:2 218:22 235:14 

location 75:19 

locations 51:19 52:12 

52:19,22 53:6 59:8,9 

59:18 75:6 79:19 

81:12 94:11 

locking 102:8 

lodging 110:14 

lone 147:11 

long 31:11 33:6 99:11 

163:9 181:11 191:14 

196:6 206:18 214:14 

224:2 228:21 230:12 

235:7 240:22 242:20 

long- 51:22 234:11 

long-term 116:9 

long-time 104:4 

longer 161:11 162:19 

176:1 184:17,18 

185:15 229:20 

longer-term 206:16 

look 7:9,22 8:13 9:1 

27:1,14 30:14 31:2 

54:11 65:8 71:8 74:7 

89:10,11,16,21 93:12 

95:15 107:13 111:2 

147:15 148:14 153:2 

157:3 163:20 165:8 

169:17 188:8,8 

190:11 193:19 196:3 

200:9,18 204:20 

211:20 228:17 241:15 

242:17 

looked 40:11 64:2 

189:22 200:13 204:21 

218:13 

looking 5:21 8:16 10:19 

35:18,19 36:4 38:3 

41:9 63:13 64:21 

68:15 70:1 76:15 85:2 

85:5 86:10 93:19 

160:13 189:6 195:10 

195:14,20 196:8 

199:17,22 206:12,13 

lose 44:17 

loss 21:6 102:18 

losses 17:17,19 20:11 

25:17 68:17 77:20 

118:7 216:13 

lost 23:2 112:13 

lot 4:10 6:9 8:22 29:3,8 

32:18,19 33:5,9,14,15 

35:4 43:11,17,20 44:5 

44:21 53:13 55:17 

59:20,22 62:9 72:20 

73:8,13 80:8,11 85:7 

85:12,17 86:13,18,22 

88:8 89:11 92:18 

93:19,22 130:4 

137:18 141:17 142:1 

144:6,11 148:13 

150:1,12,14 171:21 

182:7 188:4 211:22 

241:19 

love 70:14 137:14 145:4 

low 15:2 17:16 19:15 

21:2 34:10 37:8 42:22 

45:19 47:11 48:4 

50:16 93:2 99:12 

100:11,14 108:4 

119:8 130:14 133:11 

190:2 192:19 211:16 

216:15 227:12 228:8 

232:8 236:2 237:9 

239:18 

low- 133:21 

lower 116:6 118:22 

185:19 189:20 194:4 

219:13 237:2,8 

lowest 13:20 14:16 93:2 

96:13 218:14,18 

219:9 233:22 234:8 

Lowry 2:1 6:20 71:12 

71:13 199:13,14 

202:1 

lows 217:7 238:17 

lumbering 80:3 

luxury 161:11 

M

Madam 10:17 27:2 28:3 

29:7 30:19 31:14 

46:13 241:21 242:22 

Madness 51:14 

magnified 229:5 

mail 212:8 

mailbox 172:7 

main 36:13 59:12 

104:21 107:3 138:9 

Maine 113:8 

mainframe 155:4 

maintain 11:16 185:9 

maintained 19:13 

168:10 

major 22:21 24:4 97:1 

107:14 115:5,22 

116:20 117:11 218:10 

234:17 

majority 18:21 60:3,9 

158:4 235:14 241:7 

making 4:8 6:6 21:22 

125:6,7 149:17 

153:19 160:1,9 162:7 

makings 166:3 169:7 

Malad 6:21 

management 2:9,10,11 

37:21 114:20 117:21 

117:22 120:21 123:6 

123:11 135:15 154:15 

164:4 193:22 206:14 

206:18 207:10 

manager 132:15 133:2 

managers 181:2 

managing 17:21 62:20 

63:5 70:22 

mandate 42:5 

mandates 19:10 32:6 

mandatory 170:2 

manner 194:8 198:9 

manufacturing 75:16 

111:18 121:22 

map 218:16,17 235:13 

March 12:15 16:2,15 

20:2 29:11 38:14 

51:13 63:11 109:2,14 

133:17 199:3 

Margaret 1:22 7:1 65:13 

Margaret's 161:21 

margin 15:10,16 19:1 

42:21 50:10 62:21 

94:16 100:1,2,15,19 

margins 67:5 93:21 

130:13 216:8 

mark 1:17 13:2 47:2 

147:21 149:8 207:16 

207:16 210:18,19 

212:13 

market 11:2,3,13 12:14 

14:8,11 18:8 28:14,14 

28:18 33:2,4 37:8,14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
259 

79:19 80:2 82:2,4,7 

84:13 86:20 92:16 

94:2,4 105:10,11 

109:6 113:21 143:11 

183:18 184:21 185:3 

200:22 201:1 

marketing 176:17 

marketplace 94:7 

markets 9:3 43:19 83:6 

115:5 116:20 117:12 

117:13 122:14 221:4 

228:12 

marks 233:19 

Marnie 65:11,14 

Mars 143:21 

MARTIN 1:14 

Maryland 11:4 12:13 

74:21 75:20 113:8 

mask 19:9 32:6 

masks 19:13 97:4 

Massachusetts 94:10 

massive 26:3 142:21 

match 107:3 

matchmaking 176:20 

176:21 177:4,9,17,21 

material 119:14,17 

221:11 

materials 85:16 

matter 78:20 79:4 126:7 

164:2 243:4 

mature 100:16 

maturities 185:14 

201:21 

maturity 183:22 185:17 

185:19 186:14 187:3 

MBI 29:12,15 

MBIs 29:19,21 

McCurry 1:19 6:21 

36:18,19 151:16,18 

151:19 156:14 157:15 

McKinley 18:13,15 

19:16 

McWilliams 1:10,13 3:2 

3:22 4:3 7:15 46:13 

46:14 57:21 58:18 

64:6 65:16 73:18 

74:13 79:9 95:18 

242:2 

MDI 127:9,15,20 128:4 

128:10,14 129:1,6,15 

129:22 130:17,18,19 

130:20 131:12 132:6 

133:17 135:20 

MDIs 128:19,22 129:3,8 

129:9 130:19,22 

131:6,21 132:3,7 

133:9,18 134:6,13 

mean 20:21 43:2 61:16 

61:22 64:12 146:8 

150:16 160:5,9,20 

182:18 202:5 

meaningful 152:21 

155:15 204:14 241:11 

means 150:17 

meant 38:10 68:14 

measure 8:9 

measured 216:12 

measures 218:19 

238:16 

median 14:13 118:12 

218:11,21 223:16 

237:6 238:18 

medians 238:9 

medical 79:22 80:4 

Medicine 131:9 

medium 14:17 130:9 

meet 36:13,20 49:9 

137:12 168:12 202:5 

206:15 

meeting 1:3 4:5,13,14 

6:12 7:8,12 27:4,6,15 

63:12 64:17 65:9 74:8 

104:22 112:22 120:2 

126:14,21 127:4,13 

127:16 130:17 133:7 

136:7 165:9 203:19 

241:16 242:20 243:3 

meetings 19:11 37:21 

89:21 169:3 237:21 

meets 177:18 

mega 24:7 

megaphone 149:21 

Meghji 2:8 3:10 5:12 

136:19 137:5 146:11 

147:19 149:7 151:14 

153:22 157:11,16,20 

158:16 161:5 162:13 

163:4,18 

member 1:16,17,17,18 

1:18,19,19,20,20,21 

1:21,22 2:1,1,2,2,3 

10:8 51:7 131:3 154:5 

members 3:4 6:11 7:18 

9:8,13,16 10:11 31:21 

42:8,9 46:19 59:2 

104:16 125:3,9,12 

129:6 136:3 150:11 

161:12 163:15,19 

170:12 196:22 243:1 

memories 138:5 

mention 40:6 63:8 

78:19 107:17 192:10 

192:18 211:2 215:5 

mentioned 12:9 59:21 

60:16 68:10 73:14 

82:15 85:12,22 93:2 

109:21 115:4 116:12 

118:11,21 166:6 

167:18 170:22 173:19 

188:2 193:15 194:10 

231:14 237:16 

mentioning 137:21 

merge 52:20 

merged 52:3,12 

merger 103:9,11 217:15 

mergers 55:17 217:1 

merit 157:9 

mess 36:15 

messages 151:4 

Messerschmitt 2:3 

95:17,20 

met 4:10 28:9 36:1,1 

107:20 137:12 150:10 

metric 218:15 

metrics 110:6 111:13 

117:2 120:14,20 

218:13 

metro 219:1 221:6,9 

metropolitan 47:7 

Mexico 47:13 

Michigan 129:12 

Microsoft 41:11 70:20 

140:17 156:5 

mid- 75:15 

mid-1990s 232:1 

mid-February 121:17 

mid-summer 110:17 

middle 32:7 39:10 

51:16 90:16,21 138:1 

Midwest 229:4 233:5,6 

233:12,16,21 234:3 

234:10,13,17 235:16 

237:12 238:5 239:3 

migration 73:5 117:15 

204:14 218:12 

migratory 21:6 

Mike 2:2 6:13 79:14 

170:13 171:10 172:7 

173:10 178:14 190:6 

192:16 193:13 194:9 

196:19 214:4 

miles 75:1 79:17 90:6 

military 21:3,4 

milk 230:19 

mill 90:5 

Miller 2:10 3:13 164:6 

171:9 200:17 202:12 

205:22 

million 11:22 13:7 16:1 

19:17,19 20:1 23:14 

23:15 25:3,15 29:12 

31:20 39:15 42:3 47:2 

52:11,18 53:2 56:21 

56:21 59:7,8 60:17 

61:1,4,9 65:20 66:1,8 

66:14,15,17 67:2 

71:20 73:10 75:6 

76:19 77:3 80:6,7 

87:16 90:18 91:18 

93:6 94:22 96:6 97:7 

98:19 99:4,7 108:22 

109:8 131:7 158:5,5 

159:17,18,18 217:19 

222:17,22 223:4,17 

223:18 228:4 

millions 134:16 

mind 147:22 149:3 

213:4 

mine 28:6 

minimum 26:19 

Minneapolis 82:7 

Minneapolis/St 79:18 

82:2,4 86:19 

minority 2:7 3:7 29:9 

127:4,11 128:18 

133:10,21 134:3 

135:6 140:10 156:17 

minute 6:10 172:8 

minutes 106:19 126:4,5 

162:21 212:22 213:5 

mission 13:9 22:15 

42:6 127:17 131:16 

132:9,16 134:15,22 

241:8 

Mississippi 111:16 

Missoula 43:19 

Missouri 59:13 159:19 

mistake 147:2 

mistakes 237:18 

mix 129:5 

mixed 79:19 92:4 

Moab 71:14 

mobile 226:22 

model 49:6 116:11 

models 129:5 226:14 

moderate 43:10 47:11 

54:12 133:11 

moderated 120:8 

239:17 

moderating 68:15 

moderator 7:12 

modernize 188:3 

modifications 17:13 

102:13 166:8 

modify 38:16 165:17 

moisture 32:19 

moment 121:4 136:2 

145:8,14 202:11 

momentum 10:22 

money 20:21 34:20 

63:15 193:6 

Mongold 1:17 18:10,12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
260 

monitor 5:1 103:4 

198:1,13 199:8 

monitoring 20:4 

Montana 7:3 42:1,11,14 

42:15 43:19 44:5,6 

45:2,9,17 129:13 

Montanans 43:5 

month 23:2 194:16 

214:2 228:16 242:8 

monthly 83:4 185:8 

months 23:3,16 25:2,4 

61:1 62:8 69:6 72:10 

81:5 84:6,15 85:1 

86:14 102:16 108:8 

136:22 153:7 207:22 

mood 58:7 

morning 4:4 18:10,11 

22:9 28:3 46:9 63:13 

167:14 

morning's 130:6 

mortgage 12:10,13 

15:3,6 18:19,20 42:18 

86:17,21 87:4,5 99:12 

105:11 123:3 166:11 

225:13,17 

mortgages 28:20 

225:14 

motivators 227:14 

motive 36:6 

Mount 62:16 

Mountain 7:1 

Mountainview 66:6 

move 30:3 84:5 124:18 

127:2 136:13 173:9 

174:7 176:12 178:12 

181:6 182:4 184:8 

187:9 190:1 199:9 

212:19 241:21 

moved 94:10 167:17 

172:21 

movement 21:3 119:13 

moving 42:14 46:1 60:1 

63:4 66:10 87:13 

92:19 185:11,20 

186:2,20 

Mt 18:13,15 19:16 

multi-family 43:17 83:1 

114:16 116:17 220:22 

multifamily 43:22 

multiple 16:12 75:9 

175:13 

Musk 143:20 

mute 58:14 207:18 

muted 237:13 

mutual 13:4 17:1 18:13 

90:3 

mutually 78:8 

N

NAACP 30:7 40:7 

name 22:10 52:14 

58:20 65:13 71:12 

74:9 79:13 89:22 

95:20 

named 204:12 

narrowed 216:2 

Narvaez 1:20 3:8 46:9 

46:11 127:7,22 

129:13,21 

nation 13:21 23:4 68:3 

118:21 148:4 

nation's 235:13 

national 9:18,21 14:4,7 

30:5 75:13 106:20 

107:18 108:17 113:22 

116:16,22 117:4 

118:13,18 119:4,7 

127:10 131:11 167:22 

183:16,17,20,22 

184:1,5,13 185:12,16 

200:1,5,10 201:5,11 

208:2 213:11 

nationally 113:18 

118:16 

nationwide 207:1 

Native 43:4 129:4 

nature 14:3 46:2 135:17 

201:21 202:7 

near 11:8 15:4 130:9 

nearby 90:9 

nearly 18:15 66:2 151:7 

218:1 230:17 234:11 

necessarily 176:5 

208:7 

necessary 149:6 

neck 88:10 

need 5:22 8:19 22:1 

29:19 30:2 35:22 

36:15 41:3,13,17 55:4 

63:19 70:11,11 81:5 

85:16 96:22 105:22 

127:2 139:22 140:20 

141:7 154:8,17,19,20 

154:21 158:7,7 

184:20 192:15 202:10 

205:6,7,9,17 206:18 

226:3 

needed 30:17 53:15 

88:8 168:6,8 185:15 

needs 22:3 36:13 49:9 

64:11 98:6,15,16 

120:2 132:9,16 

155:21,21 168:3 

169:8 185:8 210:22 

230:18 

negative 81:8 

negatively 44:19 118:1 

negotiation 176:14 

neighborhood 200:4 

neighborhoods 29:20 

133:11 

neighbors 53:13 

Neil 1:19 6:21 36:18 

151:16,18 153:22 

155:16 157:12,16 

nervous 64:19 

net 15:10 21:6 50:10 

100:1,1,19 130:12 

216:8 217:10 218:11 

218:21 219:9,9 

229:15,21 230:10 

231:17 233:14,22 

238:11 

network 31:7 

never 55:20 143:2 

224:16 241:12 

new 2:7 5:8 10:3 13:3 

13:19 14:2,3,9,15 

19:7 21:4 25:8 35:18 

41:2 43:20 45:5 48:2 

78:21 79:7 83:18 

86:22 87:5 88:20,22 

89:4 91:3 92:19 100:4 

100:14 102:9 103:20 

113:7,22 114:17 

115:17 116:14,20 

117:3,13,13 118:22 

120:19 134:12,14,16 

134:18 135:1 136:3 

138:14 139:12 144:15 

149:16 150:3 172:9 

172:19 173:2 178:21 

179:18 182:10 183:13 

186:17 187:2,8,15,20 

193:18,18 209:21 

217:6,8 225:22 

newer 226:21 

newest 59:2 

newly 171:5 

Newport 13:3 

news 82:3 110:18 

nice 52:22 57:1,3 59:15 

59:17 61:17 62:2 

nicely 84:3 

night 39:10 152:2 

nightmare 50:2 

nights 23:12 

nimble 70:9 

nine 17:9 86:14 90:9 

129:2,6 132:5 178:17 

nominee 180:5,18 

187:6,19 

nominee's 179:8 

non- 186:13 187:2 

215:19 216:10 222:3 

non-community 214:13 

215:22 216:7,16,20 

non-competitive 143:1 

non-existent 82:21 

non-interest 216:1 

non-maturity 184:4 

186:3,5,5,12,14,15,18 

186:22 187:8,15 

non-owner 20:4,7 

non-performing 17:15 

50:22 

non-tribal 42:9 

norm 48:1 

normal 32:13 48:17 

150:12 

north 31:19,20 33:9 

34:7,7,22 35:6,8 

71:15 80:1,19 

northeast 109:18 

117:10 

northern 51:18 53:1 

84:7 233:9 

Northwest 79:16 

notable 117:11 123:10 

219:21 

notably 114:7 

note 49:22 133:3 

182:13 205:9 221:12 

noted 120:18 183:2 

204:7 239:5 

notice 179:18,20 

180:15 181:10 182:9 

noticed 40:13 141:22 

189:19 235:19 

notices 182:12 

notify 185:6 

November 81:13 

number 24:8 38:4 48:2 

49:13 55:13,16 64:11 

73:12 88:2 94:21 

108:20 122:7 139:4,7 

143:13 150:13,14 

154:3 162:15 164:18 

169:7 170:7,15 208:1 

217:6 

numbers 29:3 56:19 

62:18 67:20 83:3 

117:5 200:3 202:6 

O

objective 177:1,3 

objectives 135:12 

obligations 52:9 

OBSERVATION 1:5 

observations 9:14,20 

10:5 104:19 106:11 

106:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
261 

observed 123:1 

obtain 181:17 

obviously 8:20 60:18 

61:19 80:8 82:14 

83:14 85:11,22 138:9 

206:7 

OCC 145:20 146:7,13 

occasional 82:11 

occupancy 84:11 

116:15 

occupied 20:5,7 

occurred 25:9 

occurs 55:21 

October 4:11 64:18 

107:20 

off-balance 66:2 

off-tenor 185:14 

offer 10:4 19:3 34:9 

35:14,16 75:9,14 

99:10 174:3 185:2 

offered 34:15 100:12 

168:5 170:19 185:19 

offering 143:19 185:4 

186:10 211:15 

offerings 200:9 

offers 43:1 

office 11:6 13:14 38:13 

58:1 59:12 64:8 91:4 

116:8 122:13 185:7 

203:9 

officer 2:8 5:11 10:9 

104:4 136:18 

offices 12:16 171:6 

officially 137:17 

offs 12:7 238:19 

offset 42:20 116:5 

118:10 

offsite 64:7,18 167:18 

168:16 169:18,22 

170:3,5 

oil 20:19 

Oklahoma 242:10,11 

old 138:9 224:4 

older 7:1 13:22 19:4 

oldest 71:18 75:3 219:8 

Oldner 1:22 65:10,12 

65:13 

Olesiuk 2:5 3:5 9:17 

106:13 

once 195:2,21 

ones 76:22 77:2 

ongoing 155:22 

online 76:6 98:3 110:5 

161:17 226:22 227:1 

onset 82:6 114:7 

224:21 

onsite 65:3 196:7 

open 1:5 19:8 32:6,8 

42:4 47:18 60:4,7 

67:22 76:5 81:11,13 

88:12,14,15 96:20 

97:17 98:6 139:11 

145:1 149:3 150:5 

opened 11:22 48:17 

91:3 94:11 

opening 97:2 103:5 

117:17 150:18 187:2 

197:5 231:15 

openness 148:6,8,19 

opens 186:14 

operate 42:7 43:14 48:8 

48:18 

operated 103:12 

operating 47:16 75:3 

217:20 

operation 45:3,7 218:2 

224:3 

operational 103:9 

operations 19:9 105:5 

131:19 164:9 168:10 

236:7 

opinion 36:15 79:5 

opinions 172:17,21 

opportunities 18:4 

75:15 144:15 160:2 

163:12 227:3 

opportunity 18:7 22:4,5 

24:7 31:16 36:17 

42:12 46:8,16 51:4 

56:10 58:18,20 65:7 

73:19 74:15 77:6,9 

91:19 95:14 104:13 

132:8,10 137:7 

138:14 140:12 143:4 

143:6 144:21 168:19 

210:6 

opposed 153:17,18 

optimism 59:21 85:6 

86:10 88:11 89:16 

105:8 130:8 

optimistic 4:22 21:19 

46:5 60:11 68:21 

95:10,11 239:14 

option 43:3 76:8 

optional 162:19 

options 75:10 76:7,11 

168:6 211:5,14,21 

order 84:16 148:14 

209:14 

Oregon 242:13 

organization 5:18 

141:5 142:9,11 

155:20 160:20 161:2 

165:11 

organization's 131:12 

organizations 19:10 

30:6 39:21 49:16 

153:12 160:17 197:18 

198:4,7 208:2 

original 42:4 49:14 

214:16,19 215:19 

originally 90:5 

originate 65:22 99:2 

originated 15:22 33:19 

77:2 

originating 222:22 

origination 15:6 66:18 

originations 223:1,2 

Ottumwa 95:21,22 96:4 

outbreak 113:12 120:12 

outcome 27:11 

outcomes 28:12 227:14 

outdoor 97:5 

outflows 219:10 

outgoing 21:6 

outlining 133:14 

outlook 5:1 28:22 37:18 

46:4 101:22 130:9 

239:13 

outlooks 108:12 228:12 

outpaced 14:15 118:13 

outperform 68:3 

outperformed 234:4 

output 108:13 

outreach 114:21 237:21 

outset 120:5 

outside 45:21 146:15 

148:9 

outsized 166:21 220:13 

outstanding 19:19 

38:20 40:7 

overall 6:5 21:5 26:22 

27:10,12 32:15 33:7 

45:17,20 46:4 60:8 

64:3,4,20 65:4 81:16 

89:10 92:2 95:9 

110:13 115:6 117:19 

119:2 215:12,21 

220:13 231:11 232:21 

233:20 239:8,16 

overbanked 94:8 

Overbidding 14:22 

overview 164:20,21 

165:4 

owned 59:6 140:10 

owners 23:20 33:16 

ownership 31:6 

owning 35:3 

P

P-R-O-C-E-E-D-I-N-G-S

4:1 

p.m 1:10 4:2 126:8,9 

243:4 

pace 69:15,22 88:18 

113:17 114:5 115:2,8 

225:19 

package 63:16 

pages 191:14 

paid 34:13 100:17 

186:15 

palatable 81:10 83:5 

Palm 6:22 36:19 37:2 

40:5 

pandemic 6:5 14:10 

15:22 17:10,13,20 

20:15 21:9 29:11 

42:11 47:17 49:2 

60:18 67:11 69:20 

76:4,15 90:14,16,21 

93:10 98:9 107:10 

110:16 111:11,21 

114:8,11,12 115:15 

117:18 118:2,12 

120:5 122:19 130:8 

133:12 134:1 164:21 

165:5,11 169:20 

170:15 203:6 215:5,7 

231:4 241:13 

pandemic's 8:4 

pandemic-related

49:17 166:22 169:14 

panel 153:5 164:19 

236:19 237:6 

paper 212:7 214:1,14 

228:17,20 229:9 

233:5 235:4 236:12 

papers 219:19 

pardon 112:4 123:21 

parent 128:9 

parents 177:7 

part 13:6 21:2 22:7 

27:13,13 34:13 35:9 

47:3 59:3 60:6,17,18 

61:10,19 63:16,20 

65:2 71:10 73:2 85:13 

96:2 138:8 154:8 

155:22 156:4 158:12 

175:22 177:11 183:2 

185:5,10 190:20 

191:9 194:11 195:4 

196:10 202:1 211:5 

212:4,12 237:13 

partial 205:7 

participant 91:17 

participants 106:15 

participate 4:9 9:4 22:6 

31:17 46:17 49:10 

95:14 194:15 

participated 26:15 

76:17 94:20 161:19 

participating 46:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
262 

74:2 95:15 99:1 

participation 75:12 

96:15 167:7 197:16 

241:2,15 

participations 35:12 

particular 8:9,21 67:7 

94:2,17 177:1,2 187:1 

187:14 

particularly 42:15 70:9 

92:17 93:8 107:15 

109:4,17 122:11 

188:21 197:13,20 

199:22 203:6 221:15 

parties 27:11 177:10 

partner 27:9 41:17 

partnered 34:8 148:3 

partnering 146:22 

153:11 

partnership 27:2 

partnerships 30:16 

128:20 

parts 43:18 101:19 

114:14 175:6 

party 176:2,5 177:14,18 

177:22 178:3,7 

181:11,22 182:1 

pass 138:14 148:19 

205:18 

passed 149:1 

passions 78:13 

patience 69:3 126:15 

151:7 

patterns 21:7 

Patty 1:17 18:12 

Paul 79:18 82:2,4 86:20 

pause 125:3 136:1 

145:8 168:6 

paused 167:22 

pauses 168:6 

pay 110:6 161:18 

180:20 187:12 236:6 

paycheck 167:1 211:18 

211:18 

paying 102:14 122:10 

176:4 

payment 117:2 205:3 

payments 16:13 34:17 

34:18 62:3 101:11 

102:3 160:12 212:1 

pays 181:21 

PCA 202:17 

Peace 155:10 

peak 49:1 109:13 

peaked 31:22 234:10 

Pearce 210:19,20 

peers 29:6 72:20 

penalties 193:6 

pencil 45:8 

pent 115:9 

people 12:17 24:15,18 

33:6 35:3,19 39:19 

41:5 42:12,14 43:3 

44:14 46:1 55:1 59:10 

59:15 66:5 73:4 82:1 

82:13,15 83:6 84:6 

87:3 88:22 91:13 

92:17 93:1 95:9 97:7 

139:5,15 141:19 

142:1,8,10 147:13 

154:13,19 158:10,20 

159:16,22 160:7 

211:17 242:7 

People's 142:20 

Peoples 103:9 

perceive 20:12 

perceived 153:20 

percentage 171:7 

225:12 

Percentages 48:7 

percentile 239:2 

percentiles 238:8 

perception 58:2 

Perfect 121:11 

performance 85:1 

115:6 117:1 119:21 

122:22 214:12 215:10 

216:7 233:13 

performed 18:18 

215:13 235:18 

performing 225:4 

period 8:10 69:12 80:5 

120:19 194:16 200:15 

214:14 221:14,22 

224:18 228:22 229:21 

230:2,12,21 234:5 

237:6 

periods 229:17 

permanent 195:4 

196:17 

permission 38:15 

permitted 179:7 

persist 229:13 

person 7:7 27:15 33:11 

33:12 65:1 155:19 

174:15,17 175:19 

176:10,11,13,20 

177:20 208:17 

personal 76:9 79:4 

personnel 21:4 

perspective 122:22 

140:10 

perspectives 107:1 

157:1 

phase 29:14 191:10 

192:20 193:17,18 

phenomenal 86:17 

Philadelphia 116:18 

117:4 

philanthropic 132:2 

phone 124:14 

physical 185:3 

pie 138:6 

piece 201:6 

pieces 124:1 

Pierre 59:14 

pill 159:12 

pilot 165:2 189:5 191:4 

191:20 192:21 193:13 

193:18 194:11 196:15 

pipeline 20:3 

pique 229:19 

piqued 237:13 

pitch 162:7 

Pitkin 1:17 13:1,2 

147:21,22 151:13 

207:16,18 210:13 

Pittsburgh 116:19 

pivot 168:15 170:2 

PJ 22:10 27:17 157:18 

161:6,7 

place 29:14,15 54:9 

80:9 82:18 103:2,11 

107:9 155:2 178:5 

placed 177:5 178:9 

180:6,19 

placement 174:16,22 

175:21 176:9,10 

177:15 179:9 181:19 

places 42:14 67:14 82:8 

144:13 175:9 177:19 

180:18 

placing 174:15,22 

175:14,21 180:19 

181:11 

Plains 233:9 

plan 66:14 68:14 

planned 25:16 

planning 170:16 196:7 

platform 128:19 

play 223:8 227:7 

playing 166:21 

plea 54:21 

please 27:22 112:13 

121:5,10 126:1 

138:21 145:2,4 

171:11 173:9 174:7 

178:13 181:6 188:10 

190:7 192:17 194:9 

197:1 213:4 219:20 

221:17 223:5 224:18 

226:15 228:14 229:13 

231:12 233:10 235:3 

236:11 238:1 

pleased 4:18 7:7 10:18 

15:19 22:12 27:3,7,13 

37:3 39:12 41:8 57:21 

65:15 148:5 

pleasure 22:7 28:6 

95:13 

plentiful 50:12 

plummeted 231:8 

plus 32:16 184:3,5,6 

201:11,12 

podcasts 150:3 

point 14:16 28:21 39:13 

43:4 82:16 89:17 

106:8 119:16 124:6 

141:8 159:5 173:1 

185:12 190:4,9 

223:19 236:12 

points 127:15 184:2,3,6 

184:7 201:12,13 

216:3,4,16 

poised 17:1 

poke 154:22 

policy 6:1 114:8 135:6 

135:9 142:11 169:5 

208:10 209:9 226:6 

Political 95:4 

polling 30:4 

Polson 7:3 42:1 129:13 

pop 88:21 

populated 90:7 

population 21:5 47:10 

48:7 66:9 73:5 75:20 

96:18 97:10 148:13 

218:21 219:17 

populations 59:9 75:11 

portfolio 20:8,13 32:15 

32:16 33:1 53:7 59:11 

66:3 68:20 72:7 100:6 

101:7 102:21 103:5 

132:19 

portfolios 107:15 

219:14 220:18 

portion 44:7 169:21 

200:1 231:17 

ports 47:13 

posed 71:2 

poses 64:1 

position 17:5 111:12 

240:2 

positioned 122:19 

positive 10:22 28:12,22 

29:7 60:1 80:17 81:15 

85:7 88:18 89:10 

101:22 108:12 118:19 

134:10 228:12 229:2 

positives 24:15 

positivity 32:1 97:15 

possibility 209:11 

possible 47:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
263 

possibly 61:8 212:22 

post- 69:11 

post-1984 217:7 

post-COVID 69:6 

post-crisis 216:14 

post-pandemic 107:13 

postal 208:22 209:4 

posted 172:3 185:16,19 

posting 167:9 

potential 122:10 134:20 

152:22 190:19 197:19 

198:3 226:4 227:14 

poultry 67:7 

Powell 156:10 

power 94:1 143:8 

PPE 178:16 179:11,15 

179:17,20 180:12 

181:14,17 182:2 

PPP 12:4,5 16:1,8 19:17 

20:1 23:10 26:12 30:4 

30:8 33:17 39:3,13 

40:4,14,21 41:4,6 

43:11 44:5 49:11,22 

56:18 60:21,21 61:2,6 

61:10,11 66:19 67:2 

73:8,9 76:17 77:3 

80:11 87:9 91:16 99:1 

99:5,8,10,16 101:1 

102:2 105:12 118:9 

123:3 130:13 167:1,4 

167:8 197:14,16 

PPP-1 23:15 24:4,9 

25:13 

PPP-2 25:8,12 

PPPs 56:19 57:5 62:10 

practices 114:20 

117:21 123:11 128:20 

130:21 131:6 135:15 

Prairie 58:21 59:5 

pre- 115:14 160:11 

pre-boom 234:12 

pre-COVID 37:7 54:17 

80:16 

pre-Depression 52:1 

pre-exam 196:6 

pre-pandemic 108:10 

109:9,15 110:9 

pre-tax 215:15 216:2 

preach 144:22 

preamble 172:3 

preceded 231:19 

precipitation 45:10 

precipitously 231:21 

precommissioned

171:7 

predominantly 222:13 

predominately 28:13 

47:9 

prepaid 181:2 

prepared 68:13 138:21 

presence 185:3 226:2 

present 1:12 2:4 19:5 

20:7 27:8 188:22 

213:9 

presentation 131:14 

132:12 240:10 

presentations 8:13 

preserve 68:16 128:17 

President 6:14,16,18 

6:20,21 7:2,4 13:2 

18:12 46:12 51:7,17 

58:21 71:13 74:10 

90:1 95:21 242:12 

presiding 1:11 

pressure 26:12,19 

94:16 118:10 130:12 

143:3 230:15 

pressures 67:6 140:18 

pretty 33:7 48:1 61:14 

64:3,3 81:7 87:6 

91:14 92:1,2 95:11 

100:11 110:2 122:17 

207:10 211:3 215:13 

prevalent 114:15 

previous 14:19 87:11 

previously 171:5 

price 14:13,17 45:3 

85:20 110:20 117:9 

159:5 230:3 231:19 

232:5,13,15,19 

prices 11:8 20:19 43:4 

62:4 81:19 82:14 

101:16 102:3,5 110:7 

110:8,14,22 230:9,15 

230:16,18 231:7,10 

231:21 232:2,6,17,21 

233:3 234:17,22 

236:17 

pricing 85:19 86:6 

102:7,9 

primarily 13:8 16:10 

18:19 19:13 44:10 

46:2 90:5 95:7 111:17 

154:11 215:21 

primary 5:5 175:11 

178:1,16,22 179:2,6,7 

214:9 

prime 79:20 

principle 226:3 

principles 4:16 198:10 

prior 50:8 55:10 114:12 

115:21 116:1,5 

118:12 156:15 168:16 

169:19 215:16 217:4 

private 66:5 151:8 

privilege 36:20 

proactive 44:13 48:13 

proactively 38:15 

probably 25:21 44:10 

56:1 59:11 145:19 

156:10 158:4 160:12 

191:15 211:19 

problem 35:21 57:16,19 

160:21 

problematic 202:8 

problems 39:11 68:12 

72:14 113:1 126:20 

procedures 182:9 

proceed 79:2 103:5 

proceeds 85:21 

process 12:5 19:20 

41:7 50:4 52:15 54:19 

57:8 58:6 64:19 76:1 

87:17 89:5 103:22 

104:7 122:16 142:1 

153:5 160:11 173:7 

179:18 182:12,17 

183:3 184:15 189:13 

192:11 194:17 195:2 

196:6 

processed 19:22 99:6 

processes 56:3 154:21 

160:10 

processing 103:10 

154:13 158:21 

processor 52:4 

producers 45:16 61:15 

61:15 

production 91:4 102:10 

224:15 230:6,20 

234:21 

productive 11:9 

products 50:17 54:3 

85:16 143:20 184:4 

210:8 

profess 148:11 

profile 135:19 

profit 83:19 

profitability 228:13 

profitable 219:4 

program 7:11 12:6 

31:17 38:21 39:4,5,5 

39:6,22 40:2 44:6 

49:11 77:8 99:1,17 

101:13,13 102:2 

127:19,20 133:6,14 

133:17 134:19 154:15 

155:9,16 160:3 

161:20 162:5,10 

165:2 166:22 167:1 

168:1 177:11 181:2 

191:9 222:21 

programmatic 150:15 

programs 35:13 49:5 

99:17 120:22 130:12 

134:8 144:9 168:11 

180:9 207:1 

progress 111:18 

progresses 198:14 

progressively 38:1 

project 195:13 196:1 

projected 113:20 

projecting 25:12 

projects 213:19 214:4 

promote 5:6 128:18,19 

prong 176:19 

pronounced 82:20 

proper 48:19 

properties 14:18 87:3 

92:21 93:1 110:14 

property 110:7,8,19,22 

proposal 5:17 

propose 177:16 

proposed 132:21 135:5 

proposes 55:20 

proposing 176:21 

prosperity 230:12 

protect 41:14 139:9 

142:17 143:17 153:14 

protection 2:12 110:11 

120:3 164:12 167:1 

168:12 

protocols 13:12 48:1,6 

48:19 170:16 

prototyping 5:15 

proud 39:16 65:15 72:2 

93:5,10 98:21 

proved 36:10 

proven 241:3 

provide 13:8 115:18 

127:12 128:8,19 

131:19 132:8 164:1 

168:7 177:10 179:20 

194:20 196:5,11 

201:15 

provided 26:11 39:13 

77:9 133:20 165:6,14 

166:10 169:10 170:5 

170:9 172:12 210:4 

Providence 90:6 

provider 161:15 

providers 152:20 220:6 

221:16 

providing 21:21 104:2 

167:11 198:10 201:10 

provision 102:17,22 

199:7 

provisions 118:6 

provoking 149:5 

proximity 74:22 76:12 

prudent 165:17 

public 1:5 97:4 114:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
264 

135:7 151:10 190:22 

publicly 206:10 

published 213:22 214:1 

214:8 219:19 228:16 

Puerto 113:10 

pulling 196:9 

punching 167:6 

purchase 86:22 87:1 

purchased 90:17 

purchases 99:14 

purpose 71:2,5 159:5 

172:15 175:11 178:1 

178:16,22 179:3,6,8 

192:2 227:13 

purview 146:15 

pushing 30:19 

put 22:15 23:7 36:7 

40:3 86:7 108:12 

141:4 155:2,14 157:9 

205:6 

Putnam 90:18 

puts 52:22 

putting 230:14 

puzzle 201:6 

Q

Q&A 167:16,20 

Q&As 172:4 

qualify 77:5 180:9,12 

181:2 

qualifying 180:9 181:4 

198:7 

quality 4:17 17:11 

25:20 50:21 63:1 68:8 

92:15 102:11 117:20 

119:15,20 203:16 

204:4 216:12 239:9 

quarantined 24:15 

quarantines 81:15 

quarter 11:21 12:2 

16:19 25:22,22 34:1 

37:17 52:21 56:11 

77:22 107:21 108:11 

108:12 167:2 224:11 

224:12 228:15 235:12 

239:1,3 

quarterly 180:11 

213:22 224:16 

quarters 224:12 

quartile 219:8 

quartiles 218:14,18 

question 108:9 145:13 

145:17 148:1,17 

149:8 154:1 155:15 

158:15 162:1 167:13 

198:16,18,21 199:1 

199:12,12 201:22 

203:4 207:16,17 

208:7,9,11 209:17 

questions 35:4 87:21 

125:4,10,12 135:21 

136:2,8 137:18 

138:20 145:9 151:16 

162:22 166:3 167:9 

167:10 169:1 172:5 

188:5,10 196:20 

197:1,11 207:2 240:4 

240:6 

quick 51:20 113:2 

117:16 196:13 214:22 

quicker 212:6 

quickly 32:2 66:17 

78:11 87:10,12 92:1 

118:22 124:16 157:14 

168:16 170:2 185:21 

188:1,17 192:15 

234:3 240:12 

quirk 202:16 

quite 19:21 21:4 22:17 

22:18 72:8 86:11,15 

117:7 119:11 189:19 

200:21 241:3 

R

Rae-Ann 2:10 3:13 

164:6 171:8 188:16 

204:3 205:20 

rail 116:6 

rain 32:19 

raise 125:13 138:22 

197:1 

raised 125:16 136:9 

167:14 197:5 

raises 186:15 

ran 235:20 

ranchers 61:3 

range 16:9 60:12 129:4 

198:11 210:3,10 

220:20 233:19 

ranged 57:5 

ranging 16:5 48:9 

ranking 52:6 

ranks 14:2 

Ransomware 156:5 

Ransomware's 156:6 

rapid 5:15 

rapidly 5:9 43:20 

rate 13:20 19:14,14 

32:1 34:10 37:6,8 

42:22 50:11,17 55:6 

80:16,16,20 83:4 

84:13 96:7,10 109:12 

118:20 119:2,4,5,7 

164:22 171:15 182:4 

183:8,12,14,17,17,20 

183:22 184:1,2,5,6,9 

184:12,13,16,18,22 

185:1,2,5,7,16,17,22 

186:10,11,15 187:13 

200:9,22 201:5,8,10 

201:11,12,19 216:13 

216:16,21 217:10 

238:11 239:2,3 

rates 15:2 20:10 48:3 

50:16 68:15 75:12 

81:17 86:8 96:14,16 

97:15 99:12 100:12 

100:14 114:2 118:14 

122:13 171:18 174:3 

176:14,18 185:8,13 

185:14 204:9 219:4 

227:1 232:8 239:18 

rating 119:13 123:4,7,9 

204:9 

ratings 119:18 120:1 

123:9,17 192:22 

204:16 

ratio 26:13,16 63:10 

197:6 228:10 237:7 

ratios 17:9 134:14 

135:2 202:15 219:15 

238:4 

raw 85:16 

reach 30:16 59:1 66:15 

108:9 137:13 145:4 

229:19 234:14 

reached 38:13 57:17 

203:9 215:19 216:14 

reaching 29:20 30:9 

39:19 215:16 

reaction 237:14 

read 145:19 206:10 

readiness 11:5 

ready 125:17 

real 8:20 20:5,8 33:1 

41:10 45:3 68:19 73:6 

81:19 82:14 93:16 

99:17 101:17 107:16 

109:20,21 110:22 

111:6 114:14 117:8 

117:16 122:6 160:12 

188:17 205:15 210:11 

reality 58:2 161:10 

realize 77:8 

reason 8:16 176:6 

189:4 

reasonable 18:3 

reasons 30:11 41:5 

53:15 87:20 104:21 

239:13 

rebound 11:2 46:6 

rebounded 37:10 122:4 

rebranded 66:13 

recalculate 185:8 

receipt 166:15 

receipts 234:20 

receive 17:6 41:6 85:4 

179:15 

received 12:14 23:20 

38:22 48:8 76:2 97:8 

101:12 134:10 168:7 

174:9 188:4 191:6 

201:3 230:17 

receiving 14:4 188:19 

recession 38:2,4 

110:19,21 235:20 

recognize 135:11 159:7 

159:21 205:1 

recognized 136:20 

recognizing 168:2 

204:11 212:3 

recommend 90:20 

156:18 

recommendations

128:8 129:16 163:13 

189:11 195:18 

record 11:8 15:5 44:20 

91:9,10 126:8,9 

225:19 231:8 232:3 

records 83:18 185:9 

recovered 122:1 

recoveries 94:18 

231:10 

recovery 69:12 113:21 

114:5 115:1,7,10,11 

121:20 

recruiting 160:7 

reduce 165:21 198:6 

reduced 42:20 203:19 

reductions 225:13 

refer 182:8 

referred 24:9 

refers 239:20 

refinance 15:5 86:21 

93:13 131:8 

refinances 99:13 

refocus 143:15 

refreshing 149:3 

151:20 

refund 34:20 

reg 172:2 

Regan 51:11 

regard 30:20 45:1 93:10 

137:2 203:16 

regarding 15:18 132:8 

135:6 

regardless 14:1 205:3 

222:14 

regards 148:17 209:11 

regimented 58:6 

region 2:6,7 10:2,3 47:6 

73:21,22 109:15,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
265 

111:10 113:8,11,17 

114:1,6,10,13,17 

115:2,6 116:14 117:8 

117:11,18 118:8,11 

118:13,15,21,22 

120:7,12,16,19 

121:13,20 122:9 

regional 9:18 10:1,3 

38:13 106:22 113:19 

116:22 169:2 185:7 

213:11 

Regionally 117:10 

regions 233:8,13,18,19 

234:1,4,8 

regular 169:3 

regulation 171:21 

182:18 185:10,18 

200:20 202:16 226:6 

regulations 171:15 

172:9 173:2 182:14 

183:13 188:3 226:10 

regulator 64:22 154:5 

157:5 

regulators 4:19 41:14 

64:10 69:8 71:7 

regulatory 5:4,6 17:7 

52:8,19 65:5 69:2 

70:14 78:20 79:5 

133:4 142:3 147:5 

167:11,12 178:18 

179:5 198:6 214:19 

224:20,21 225:5 

226:12 228:14 

rehired 171:4 

reigned 237:3 

reinvest 143:14 

reinvestment 15:16 

18:4 

relate 154:2 

related 9:9 17:13 

114:20 186:4 211:14 

relates 162:10 

relationship 157:5 

174:15,17 175:19,22 

176:2 179:9 203:8 

210:6,9 

relative 28:19,19 

110:19 123:17 203:22 

228:8 

relatively 80:12 84:3 

86:2 87:10,12,13 

101:20 108:4 225:6 

232:10 

released 26:8 

relevant 9:15 166:2 

225:1 

reliable 98:11 

relief 49:17 167:12,15 

relies 153:11 

relocated 82:9 

rely 182:2 184:12 212:7 

relying 172:17 

remain 11:7 17:16 

19:15 53:11 92:16 

120:16 174:4 

remained 10:21 47:18 

76:5 77:4 101:19 

222:6 237:9 238:20 

remaining 11:10 123:17 

remains 6:7 13:11 

16:22 17:12,18 19:7,8 

19:20 21:10 92:15 

109:17,21 116:8 

119:7 239:21 

remarkable 15:7,19 

76:4 

remarkably 8:10 

remarks 3:2,21 7:17 

117:17 213:7 231:15 

239:11 

remember 11:22 141:3 

171:16 173:18 179:2 

186:8 206:1 

remind 128:3 

reminded 232:11 

reminder 185:21 

remiss 215:4 

remote 13:14 161:16 

remotely 42:13 48:22 

82:6,10 

remove 6:1 

remuneration 180:21 

rent 117:3 230:8 

rental 83:4 117:2 

rentals 84:15 

Renters 117:3 

rents 101:18 

reopen 12:17 95:10 

reopened 32:11 

reopening 11:11 

repaid 205:2 

repayment 205:6 

repeat 193:6,9 237:18 

replace 5:16 

replaced 217:9 

report 15:19 48:11 51:5 

55:13 135:20 136:6 

173:3 189:4,10,16 

191:3,6,12,16 192:4,7 

192:13 193:5,13,19 

194:3,18 195:10,11 

195:16,16,22 196:1,5 

196:9,14 215:20 

222:2 223:4 236:1 

report's 190:11 196:2 

reported 20:15 55:7 

130:10 182:19,20 

188:18 215:14 216:14 

216:16 224:16 

reporting 128:13 

reports 5:16 128:11 

130:6 173:4 180:11 

189:19 190:2 193:4 

195:5 222:8,9 

represent 129:7 

represented 129:10 

representing 16:7 

129:2 235:11 

represents 72:6 231:16 

233:16 

Republic 142:21 

reputational 153:2 

request 16:3 79:5 

184:17 

requesting 17:13 

requests 49:13 

require 97:4 135:10 

181:9 

required 34:12 83:4 

166:17 180:10 181:5 

185:18 

requirement 161:11 

197:20 

requirements 134:6 

142:3 168:13 173:12 

requires 78:22 128:7 

180:14 200:22 

research 2:6,13 3:17 

9:20 213:12,13,20 

225:9 227:2 

reserve 23:10 198:3 

reserves 68:17 

residence 43:21 

residency 14:1 

residential 14:12,18 

15:3 28:14,20 33:1 

91:12 99:17 117:8 

225:10 

residents 14:3,6 76:8 

82:17 84:16 

resilience 107:6 140:15 

141:8 156:3 

resiliency 122:20 

resilient 11:13 54:5 

62:1 121:13 140:21 

239:9 

resolve 87:22 

resort 22:22 26:6 

resorts 23:21 80:3 

resources 104:3 160:14 

162:15 188:1,8 

respect 30:3 202:17,20 

225:8 

responded 229:12 

236:16 

responders 49:20 

responding 168:2 

response 4:18 5:4 

114:8 164:20 165:4 

166:8 169:5 222:11 

responses 167:9 

227:18 

responsibilities 170:12 

rest 45:18 46:15 65:8 

74:8 89:15 115:3 

238:5 242:18,20 

restates 135:9 

restaurant 62:13 84:21 

102:21 

restaurants 11:11 

23:21 32:11 33:16 

37:12 44:2 83:21 84:2 

92:10 115:13 

restitution 193:10 

restricted 201:17 

restriction 164:22 

restrictions 19:9 

171:15,17 173:17,19 

174:4 182:4 183:9,12 

183:15 186:4 

restructured 39:7 84:20 

restructuring 205:4 

restructurings 166:9 

result 14:16 17:10 50:9 

67:11 100:18 114:19 

115:7 161:19 230:21 

resulting 42:22 96:19 

results 42:17 195:18 

227:16 

resumed 49:4 

retail 108:7 110:14 

115:10 220:21 

retailers 115:14 

retain 209:15 

retired 104:4 171:5 

retirees 55:1 

retirement 24:19 

retroactively 34:16 

return 11:12 63:3 68:4 

207:2 

returns 230:13 

revenue 83:18 

review 132:11 171:2 

172:2 182:21 

revised 174:19 176:8 

179:11 183:11 186:3 

revisions 174:13 

revolutionary 152:6 

rewards 70:3 

rework 205:9 

RFI 141:4 

RFIs 150:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
266 

Rhode 6:16 90:4,8,10 

91:3 92:2,8 94:6 95:4 

95:12 

Rice 6:14 79:15 

Rico 113:10 

ridership 115:20,21,22 

rioting 82:5 

riots 28:13 

rise 231:18 

rising 236:9 237:14 

risk 2:9,10,11 8:18 9:18 

20:6,13 36:7 114:20 

117:21 120:21 123:5 

135:14,18 153:2 

164:4 189:20 190:2 

190:17,18 192:19 

194:4 204:11 206:14 

206:14,18 207:10 

209:9 213:11 239:21 

risk-based 78:4 

risks 70:3 

River 13:2 15:19 17:11 

18:8 59:13 147:22 

ROA 215:15 

road 21:15 

ROAs 216:2 

Robert 131:1 

robust 15:8 18:19 92:17 

201:15 

ROC 36:4 

roiled 231:4 

role 31:9 77:11 138:14 

166:21 223:8 224:2 

227:7 

Ronald 51:11 

rose 230:9 232:21 

234:3 237:12 

roughly 223:9 

round 19:16 20:1 33:21 

33:22 40:14,16 49:11 

49:12,14 50:3 61:2 

73:9,11 76:18,21 77:2 

87:9 102:2 

roundtable 73:22 

129:22 

Rudolph 2:7 3:8 46:15 

127:22 128:2 

rule 133:13 166:3 169:7 

172:19 174:19 175:15 

176:8 178:21 179:11 

179:13,17 183:4,11 

186:3,12 

rulemakings 4:19 

169:15 

rules 77:14 182:16 

run 83:3 85:9 118:22 

154:14 213:5 233:1 

running 55:22 80:19 

81:7,18 85:12 87:10 

97:15 159:17 212:22 

225:9 

runs 96:8 154:16 

172:13 

rural 51:18 53:1 59:9 

158:6 208:17 219:11 

219:17 221:6 223:16 

Rushmore 62:16 

S

Sabal 6:22 36:19 37:2 

40:5 

safe 10:21 21:21 44:14 

48:19 76:16 144:3 

153:19,20 

safety 4:16 13:12 27:4 

47:22 48:5,15 64:7 

78:1 119:19 168:11 

198:9 

sale 21:1 

sales 14:9,12,13,15 

76:6 108:7 117:12 

Salish 44:12 

San 47:6 73:22 

Sandy 242:12 

Sarah 1:19 31:18 

208:11 

Sarasota 6:22 36:19 

40:7 151:19 

sat 143:9,10,11 

satisfactory 117:21 

120:21 192:22 

Savannah 131:4 

saving 16:2,12 

Savings 95:21 

saw 18:15 78:9 109:2 

110:21 118:15 119:22 

121:3 140:6 203:1 

224:13 230:2 232:17 

233:2 

saying 62:1 86:13 

111:11 124:5 

says 108:11 

SBA 19:20 34:3 50:3 

57:7 87:11,19 167:8 

222:20,21 

scale 119:13 226:2,5 

scary 22:17,19 153:9 

scenario 38:4 83:16,16 

207:1 

scenarios 134:22 

scenes 169:17 

schedule 65:13 67:3 

73:14 97:20 170:10 

scheduled 27:18 51:6 

scheduling 34:4 165:21 

school 88:15,17 97:22 

schooling 49:4 

schools 11:10 32:8 

49:4 88:12 

scope 226:7 

scoped 190:17 

seamless 144:3 

season 21:10 121:15 

second 5:16 20:1 29:14 

33:21,22 34:2 37:16 

40:13 49:11 55:12 

61:2,5,9 73:11 76:2 

88:3,5 99:7 108:12 

140:15 156:2,3 160:9 

167:2 216:12 217:8 

221:18 229:9 239:12 

seconds 137:21 

section 173:11,12 

183:5,6,13 

sector 38:6 53:20 72:6 

92:7 101:9,16 102:1 

109:5,5,8,10,20 110:3 

114:16 115:11 116:8 

132:9 134:15 141:14 

146:18 151:8 160:6 

223:9,10 224:10 

228:18 229:2,11 

230:2 231:2,4,11 

235:21 236:5 239:14 

sectors 37:14 47:14,16 

50:14,15 102:21 

103:1,4 122:2 143:1 

secure 144:3 155:12 

224:17 

security 6:19 31:19 

74:11 75:2 184:2 

242:10 

seed 230:7 

seeing 9:2 12:16 29:4,8 

30:2,13 31:6 43:1,17 

44:9 53:21 59:22 

61:17 62:7,15 73:16 

74:4 94:3 108:6,17 

119:10,12,14,17 

120:9 125:16 144:8 

147:5,15 161:14 

203:22 204:4,7,8,8,13 

242:17 

seeking 81:1 83:7 

181:16 

seen 21:10 29:19 30:4 

50:17,21 60:19 77:18 

89:6 93:22 100:10,18 

100:22 109:7,15 

113:16,17 115:10 

116:3 118:1 123:8,13 

152:20 238:20,22 

segment 130:18 

segments 110:1 

segregate 102:20 

self- 88:6 236:6 237:15 

sell 149:15 

selling 102:5 

Senator 90:2 

senior 84:10,21 164:7 

sense 138:2 

sent 191:11,14 212:8 

sentiment 23:18 237:20 

sentiments 28:16 

separately 179:12 

September 17:14 52:14 

series 150:3 

serious 81:16 

seriously 77:11 155:21 

serve 7:12 28:6,9 29:21 

39:9 46:17 47:10 72:2 

73:19 98:6 132:3 

served 8:11 207:13 

serves 127:8 131:10 

164:13 198:6 

service 47:8 52:3 53:16 

66:3 91:20 98:4 156:6 

209:5 241:18 

servicers 166:11 

services 11:15,19 52:6 

54:8 69:18 70:10 

98:11 116:1 143:20 

176:17 177:11 210:3 

210:8,10 

serving 28:13 128:15 

133:21 210:22 

session 167:14 197:5 

set 83:18 134:2 140:21 

181:1 

sets 238:8 

setting 5:17 68:16 

141:5 176:14 

settings 90:3 124:7 

seven 25:10 52:22 

severe 8:6 110:20 

193:2 

severely 38:1 

severity 114:7 

shaded 233:18 

Shannon 125:22 126:1 

126:3,10,18 

shape 8:11 84:19 169:5 

share 7:18 9:13 18:7 

70:17 75:10 92:8 

111:18 127:3 129:17 

155:14 183:18 213:13 

221:10,13 222:1 

223:1 234:20 240:19 

shared 9:16 52:7 152:4 

169:3 

shareholder 155:18 

shareholders 152:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
267 

shares 219:5 220:2 

sharing 13:15 104:19 

106:4,6 148:22 

168:22 

sharply 235:2 

Sharpsburg 75:19 

Shayna 2:5 3:5 9:17 

106:9,12 121:18 

207:6 

Shaza 1:16 10:8 145:16 

shed 227:13 

sheet 16:9 25:6,11 63:5 

66:2 114:18 123:1 

197:17 198:2 225:14 

sheets 62:21 118:3 

Shepherd 78:13 

Shepherdstown 6:19 

74:11,20 78:12 

shifted 76:6 

shifts 123:1 

shine 24:7 

shined 24:3 

ships 21:12 

shoes 104:3 

shopping 76:10 110:5 

short 87:15 152:4 165:7 

shortage 42:18 

shortages 83:12 

shortly 39:2 125:21 

shots 60:10 

show 31:11 61:7 116:19 

117:2 

showcase 130:18 

showed 114:18 

showing 20:14 115:1 

203:18 215:14 

shown 30:5 223:21 

225:3 237:6 

shows 97:21 181:8 

217:13 218:16,17 

220:12 224:1 225:12 

227:22 229:14,16 

233:14 234:9 235:13 

238:4,10 

shrink 25:6 

shrinkage 96:19 

shut 67:13 

shut-ins 33:16 

shy 149:20 

sicker 89:1 

side 18:20 33:3 46:3 

74:6 79:20 91:11,12 

100:21 101:6 115:17 

119:19 123:13 188:19 

209:9 

sight 43:7 92:21 

signed 56:10 

significant 8:8,17,18 

15:9,21 16:13 47:3 

68:19 73:7 84:13 

91:15 99:18 115:7,10 

120:10,12 155:17 

167:3 168:9 169:21 

197:17 203:10 204:4 

204:15 208:13 227:18 

231:5 

significantly 15:14 37:5 

67:10 88:4 99:13,21 

101:10,14 116:4,13 

118:13 235:1 

signs 68:20 115:1 

silver 24:1 

similar 24:21 25:9 26:2 

77:17,18 113:5 

200:14 215:18 238:10 

similarly 187:20 

simple 214:10 

simplified 184:15 

simply 125:14 136:10 

single 14:12,18 43:21 

44:16 162:6 

Sioux 64:8 65:4 

sit 37:3,16 138:13 

151:11 208:1 

sitting 20:3 26:3 64:22 

207:7 

situation 8:6 97:3 

102:19 103:6 181:18 

199:4,9 206:19 

situations 204:12 

206:17 

six 13:5 62:8 75:6 86:13 

87:19 215:1 

sixth 75:19 

size 40:14 75:5 77:16 

97:5 129:5 135:17 

161:3 170:7 214:11 

222:9,10,14 223:16 

225:22 

sizeable 109:3 

sized 75:16 

sizes 221:4 222:5 

ski 22:21,21 23:1 26:7 

slide 165:6 169:11 

170:13 171:10 172:8 

173:10,11 174:7 

178:12,13 179:16 

181:7,8 183:7 184:8,9 

185:11,20 186:2,20 

187:9,22 190:7,10 

192:17 193:14 194:9 

196:20 214:5 215:8 

216:17 218:4 219:20 

221:17 223:5 224:18 

226:14 228:14 229:13 

231:12 233:7,10 

234:9 235:3 236:10 

237:22 238:2,4 

slides 174:6 175:12 

181:16 220:8 

slight 50:20,21 126:12 

slightly 113:20 118:17 

119:3,6 

slow 19:21 33:20 

slowed 12:6 50:13 

slower 113:17 114:5 

115:2 

slowly 219:13 230:21 

small 5:7 13:8 15:18 

16:1,4 23:21 37:9 

39:14 65:21 71:15 

75:15 76:3,14 77:5,10 

88:6,7 95:6 138:2 

140:11 141:18 158:3 

166:20 207:3 209:3 

220:1,7 221:6,8,16,19 

221:21 222:1,11,13 

222:17,20 223:15 

225:9,13,17,22 

smaller 148:11 159:8 

221:10 225:6 228:2 

smallest 217:18 

smart 153:14 

smooth 103:20 

smoothed 50:4 

snow 32:19 

soared 237:10 

social 19:12 48:19 

soft 111:14 

solar 94:1 

SolarWinds 70:20 

140:17 156:4 

solicit 186:10 

solicits 186:13 

solid 111:14 238:7 

Solutions 6:17 51:8,17 

53:3 

solve 35:21 

solvers 57:16,19 

somebody 36:4 

someday 59:4 65:1 

somewhat 54:16 81:12 

120:8 231:3 

soon 32:14 192:5 

sophisticated 54:1 

sophistication 135:17 

sorry 4:6 55:3 58:13 

126:20 171:11 207:19 

218:17 

sort 34:8 35:22 36:7 

146:3 148:5,9,19 

207:12 208:21 209:8 

sorts 205:19 

sought 82:8 

sounded 56:13 

soundness 4:16 27:5 

64:7 78:2 119:19 

168:11 198:10 

source 128:16 133:10 

222:18 226:4 

sourced 132:20 

sources 134:20 

south 47:6 58:22 59:13 

60:4 62:14 64:8 66:9 

79:20 90:6 95:21 

157:22 158:4 159:21 

southeast 71:14 

southeastern 96:2 

southern 51:21 

soybeans 230:4,19 

234:19 

space 29:13 110:4 

116:8 122:12 

spanning 13:5 

spate 45:12 

speak 22:4,18 27:19 

54:15 112:16 139:18 

146:12,13 153:4 

speaker 51:7 

speaking 55:3 

special 35:20,20 71:2,5 

specialist 224:6 

specialists 221:14,15 

223:13,21 224:2,8,13 

specials 201:20 

specific 172:6 176:15 

177:2,3 

specifically 29:6 40:5 

116:15 145:7 155:11 

165:16 203:15 

specifics 29:2 

spectrum 31:10 219:7 

222:7 

speech 139:1 

speeches 150:10 

speed 88:18 98:9 

spend 106:19 137:20 

160:13 

spending 98:18 142:15 

spent 141:17 

spite 98:21 

split 183:13 

spoke 113:14 131:11 

139:4,5 162:13 

spoken 208:3 

sports 32:10 131:8 

spotlight 130:18,20 

spread 32:14 

spreadsheet 142:6 

spring 23:5 

springs 7:5 22:11 

150:17 161:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
268 

stability 11:16 

stabilized 50:7 231:2 

stable 101:18 

staff 9:13 13:13 46:16 

48:11 54:4 56:11 58:3 

58:19 60:2,2 74:3,19 

79:10 81:14 95:19 

105:20 106:9 125:6 

171:1 172:17,21 

staffing 72:14 

stand 17:5 132:22 

217:2 225:8 

standard 5:17 189:16 

193:4 194:3 195:11 

195:16 196:1 

standards 5:18 135:10 

141:2,4 144:14 

standing 30:14 

standpoint 85:2 

stands 25:19 154:6 

Star 145:17 

start 7:18 9:7 10:7 

62:12 84:7 97:17 

111:11 138:18 144:8 

159:16 165:3 191:21 

192:1 199:16 204:3 

214:6 220:9 

started 6:9 37:20 45:15 

56:20 66:11 80:5 

81:21 83:15 87:13 

103:16 126:19 212:17 

216:4 240:13 

starting 32:9 44:1 82:9 

85:9 86:5 144:12 

191:20 203:17 

starts 35:2 

startups 151:10 

state 5:2 6:13 11:5 13:4 

13:6 14:18 18:9 19:3 

19:8 20:16,21 21:5,15 

21:17 32:4 34:20 

35:14 37:2 44:8 45:16 

46:2 52:13 54:15 55:6 

55:8,12,14,19,21 56:2 

56:4 60:4 62:10 66:20 

67:9,16 68:2 71:5,19 

74:21 75:4,18 79:14 

87:2 94:12 95:6 96:3 

96:9,11 97:1,18 98:17 

103:10,15 111:16 

131:3 161:21,22 

169:4 

state's 45:20 

state-chartered 42:7 

71:18 

state-owned 34:6 35:3 

36:5 

stated 165:16 

statement 135:6 

statements 57:2 85:4 

169:7 203:18 

Stater 13:22 

states 13:19 35:13 42:3 

45:18 53:11 67:11 

79:2 113:8,13 121:21 

140:2 229:4,7 232:16 

232:17,22 233:2,4,9 

233:22 234:20 

statewide 75:13 80:15 

static 155:4 

statistics 31:11 

status 102:14 172:22 

statute 179:6 

statutory 128:17 

168:13 178:17,22 

202:5 

stay 40:20 44:18 172:7 

stayed 101:18 

stays 67:21 

steadily 11:17 215:15 

steady 20:9,10 232:9 

Steamboat 7:5 22:11 

22:21 161:8 

stemming 17:19 

step 140:7 

STEPHEN 1:21 

stepped 33:15 

steps 132:22 

Steve 58:14,20 151:17 

157:18,22 158:16 

198:17,17 

stick 137:8 

stimulus 16:12 26:12 

32:17 63:16 101:1 

108:5 130:12 166:22 

Stone 7:1 65:19 66:13 

67:1 

stop 217:20 

store 102:6 

storm 121:16 

storms 112:2 

story 53:13 152:4,14 

154:1 222:9 

story's 108:14 

straight 79:17 

strain 88:22 89:4 117:3 

198:3 

strains 88:20 

Strategic 131:2 

strategies 128:16 

strategy 160:19 221:18 

streamline 188:3 191:6 

195:10,16,22 

streamlined 165:1 

182:11 193:5 

street 36:14 138:9 

149:15 

strength 210:11 223:6 

strengthening 79:11 

strengths 209:22 

219:22 

stress 23:7 

stressful 23:18 

strict 13:12 

strong 11:18,20 15:4 

16:10,11,22 17:4,12 

19:1 33:2,2 36:13 

37:9 46:7 50:19 68:6 

75:14 92:15,16 93:14 

102:12 108:2 109:2,7 

117:9,19,20 118:2 

207:10,11 223:21 

230:13 231:11 235:22 

236:1 239:22 240:2 

stronger 12:18 108:6,7 

strongly 67:14 98:22 

156:12 159:21 

structure 131:18 

216:18 

structured 182:22 

struggle 92:6,11 95:2 

115:5 

struggled 54:18 

struggles 37:12 

struggling 34:11 51:1 

68:22 69:5 166:11 

Stuchlik 242:11 

student 78:16 

students 78:14 

studied 215:8 218:19 

study 3:17 213:15,21 

214:7,7,9,14,15,16,19 

215:3,16,19 216:4 

217:3,4 218:11 219:2 

221:14 222:1 226:5 

226:16 227:16 

study's 215:1 

stuff 159:7 

subcommittee 3:7 

127:5,15 128:4,10,15 

129:1,7,15 130:17 

132:6 133:3 135:21 

136:4 156:17,19 

subcommittees 128:8 

subject 116:9 165:19 

173:19 

subjective 202:3,7,13 

202:18 

subjectivity 202:19 

submission 49:22 

submit 172:6 179:19 

180:10 181:5 182:1 

188:11 

submitting 133:15 

subsequent 235:6 

subset 239:19 

subsidiaries 177:7 

substandard 206:16 

substantial 16:21 

220:18 229:7 230:3 

substantially 238:13 

suburban 117:12,13 

Subway 115:20 

succeed 157:2 

successes 74:17 106:7 

successful 22:1 45:7 

54:3,10 55:22 92:2 

152:21 170:20 211:17 

sudden 123:22 

suffer 54:14 67:5 

suffered 67:10 

Sugar 13:2 15:19 17:11 

18:8 147:22 

suggest 227:18 

suggestion 125:2 

suggestions 104:2 

suite 155:19 

suited 38:19 

Sultan 2:8 3:10 5:11 

136:19,20,22 137:4 

147:21 151:15,18 

159:17 160:21 161:7 

163:1,9,17,22 226:19 

summarize 127:15 

132:13 139:19 

summarizes 173:11 

summary 129:17 

173:17 

summer 26:6 81:5,22 

81:22 82:5 84:6 89:18 

112:1 113:14 195:7 

super 33:1 64:13 

supervises 129:8 

supervision 2:9,10,11 

3:11 164:4,19 169:18 

207:20 209:8 241:5 

supervisor 241:6 

supervisory 114:19 

164:2,7,20 165:4 

167:17 168:10 182:17 

183:2 

supplies 232:9 

supply 85:13 231:5 

support 4:20 17:5 

30:15 41:19 49:8 

57:13 70:14 77:9 

104:10 105:15 132:3 

160:17 166:19 226:12 

231:9 

supported 44:15 98:22 

167:7 

supporting 13:15 30:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
269 

38:9 

supportive 207:20,21 

supports 135:5 222:15 

222:18 

suppose 158:5 

surged 66:16 

surging 236:17 

surprise 68:11 

surprised 149:18 

151:12 

surprising 41:4 73:13 

235:17 

surprisingly 68:8 232:2 

surround 69:14 

surrounding 116:9 

Survey 222:12 227:17 

227:17 

survive 148:15 157:7 

susceptible 153:12 

sustainable 148:15 

sustained 225:13 

swallow 159:12 

sweep 177:11,15 178:2 

180:8 

sweeps 178:1 

swings 234:16,17 

swung 234:7 

sync 87:6 

syndicate 131:7 

system 6:7,7 8:19 

26:21 30:22 36:8,11 

87:12 88:9 103:10 

104:10 140:18 143:2 

143:6,10 144:1 147:9 

152:11 153:6,19 

154:6 155:12 156:11 

207:13 

system's 155:4 

systems 103:13 117:22 

153:13 155:6 172:18 

204:9 

T

table 157:13 210:1 

tackling 31:10 89:14 

tact 207:21 

tail 239:1 

taken 61:18 102:4 

155:21 194:18 228:17 

takes 89:7 163:3 

tale 92:5 

talk 5:14 8:22 74:3 

137:1 138:16 156:3 

157:4 158:19 163:14 

167:6,19 171:13 

178:15 182:3 183:8 

207:2 

talked 59:20 62:20 

70:21 85:3 105:4,10 

105:11,16 117:7 

121:19 136:15 181:15 

talking 60:20 106:5,19 

108:16 126:3 139:3 

140:16 150:7 155:11 

159:20 186:2,21 

187:10 190:11 205:20 

tandem 236:21 

target 66:15 225:22 

targeted 60:22 

targeting 61:2 

tax 212:4 

taxes 20:22 

team 27:8 78:5,6,9 

156:20 164:15 170:4 

170:12,19 196:22 

team's 106:20 

teams 70:16 

teased 33:9 

tech 88:15 150:17 

160:21 161:10 

technical 28:2 141:13 

technological 18:2 

technologies 5:8,19 

139:13 156:6 226:21 

226:21 227:8 

technology 11:15 39:11 

52:5,5 69:16 136:15 

136:21 137:3 142:2 

142:10 152:1 153:10 

154:12,14 158:3,8,21 

159:1,4,9 160:7 

161:10 168:17 214:20 

226:17 227:9,11,15 

227:19 228:1,5 

Teleconference 1:10 

telework 170:2 

tell 29:3 30:2 37:3 57:15 

57:21 62:8 146:9 

158:18 222:8 239:22 

temporary 72:12 

167:12,15 169:8 

tend 61:20 218:22 

219:11 223:15 

Tennessee 111:16 

Teri 2:3 95:20 104:14 

term 33:6 130:9 206:17 

234:12 

terminology 179:14 

terms 14:9 25:11 82:12 

86:2,7 91:16 93:12 

94:6 100:13 105:8,19 

126:14 132:21 165:17 

176:15 203:6 242:7 

test 179:22 180:1,2,13 

180:16 

testing 189:5 

tests 81:15 

Texas 46:22 47:6 55:12 

129:14 

Texas/Mexico 47:4 

thankful 71:10 

thankfully 24:16 

thanking 199:16 

thanks 9:3 157:16 

164:17 169:19 209:17 

213:17 241:14,19 

theme 156:3 237:20 

themes 105:3 106:3 

107:2 130:4,10 

139:17 144:9 214:16 

thin 93:21 

things 12:19 19:15 

32:12 35:18,21 42:10 

46:6 57:10 64:4 67:22 

68:14 74:3,5 83:5 

85:7 87:22 89:8,10,11 

89:16 107:2,3,10 

110:5 111:2,5 139:2,6 

139:14 140:16 146:14 

148:22 149:4 150:8 

152:18 154:3 155:14 

160:2 182:3 190:9 

196:8 199:21 201:14 

201:21 205:10,19 

206:6 207:5,8,12 

212:2,8 230:6 

thinks 156:10 

Thinktech 161:20 162:4 

third 59:5 98:10 108:11 

141:16 151:1 176:2,5 

176:19 177:10,14,18 

177:22 178:3,7 

181:11,22 182:1 

223:6 230:19 

third-party 141:12 

thought 124:20 137:20 

149:5 199:19 207:8 

thoughtful 139:11,13 

141:9 144:3 149:11 

thoughts 145:3 146:3 

146:10 152:1 162:22 

209:7,10 210:14 

240:18 

thousand 153:1 

thousands 147:1 

threat 156:11 

threats 70:19 71:1 

three 11:4 59:8 94:13 

98:19 102:2,15,16 

128:14 129:9 150:10 

159:2 193:2 218:5 

219:21 220:8 225:8 

225:17 233:8 

threshold 223:4 

thrive 5:8 

throw 138:21 

Thursday 27:6 137:16 

tied 92:9,9,13 

Tier 16:22 17:8 

ties 226:17 

tight 67:5 232:9 

timely 192:3,14 

times 80:21 234:11 

today 4:8 5:12 7:9,22 

8:6,14 9:1,22 10:4 

22:5 23:14 25:19 37:3 

42:7 46:16,20 56:1 

65:17 70:11,21 72:5 

112:22 128:13 129:11 

150:8,10,11 163:20 

164:3,19 167:19 

188:17 199:4,6 

213:18 214:3 215:1 

241:15 

today's 7:12,15 

toes 89:9 

told 152:8 

Tomorrow 134:11 

150:2 

tons 45:22,22 

tool 56:7 134:12,21 

toolkit 155:13 

tools 22:1 195:4 

top 154:15 

topic 53:20 78:21 

199:17 200:13 205:16 

208:11,12 219:18,20 

221:12 

topics 6:10 58:5 136:14 

164:18 

total 13:7 16:7,18 19:18 

23:7 24:18 59:8 76:18 

77:1,3 87:15 99:3 

132:7 167:4,5 180:4 

220:4,5 223:2,10,17 

235:8 

totaling 66:21 67:2 

totals 99:7 

touch 9:14 144:12 

tour 139:4 

tourism 21:8 37:13 

62:14 80:2 92:9 

tourist 21:18 

tourists 21:17 

town 13:8 54:16 66:9 

71:15 75:21 90:5 

100:9 138:2 

townships 63:15 

track 234:17 

trade 47:14,19 131:12 

160:15 169:4 

traditional 115:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
270 

traditionally 143:1 

traffic 21:14 80:10 

116:4,7 

trailed 114:4 

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train 116:1 171:5 

206:22 

trained 154:20 

training 78:5,6 135:4,5 

206:3 207:1 

transaction 11:7 

180:13 

transactional 180:20 

transactions 180:1 

181:3,20 

transforming 151:9 

transition 103:20 

transitioned 39:3 

transitioning 199:7 

transitions 197:21 

transmittal 194:1 

transparencies 148:9 

transparency 148:20 

transparent 145:1 

150:5 

transportation 47:14 

travel 21:12 

travelers 21:15 

treasury 133:9,13 

134:18 184:2 201:12 

Treasury's 127:18 

133:5 

treated 204:1 

treatment 186:4 

tremendous 26:11,21 

42:13 59:3 62:22 64:9 

140:4 146:20 

tremendously 61:13 

trend 67:20 71:4 81:21 

99:21 118:18 

trends 9:21 16:12 20:16 

29:5 37:4 51:2,5 

67:14 77:16,18 80:17 

81:7,9 113:22 114:9 

116:10 204:18,18 

217:3 225:19 

tribal 42:8 

tribally-owned 42:2 

tribe 44:12 

Tribes 44:13 

trickle 45:15 

tried 36:9 83:2 

troubled 166:9 205:4 

troubles 207:13 

true 28:17 36:9 182:17 

200:22 210:1 218:13 

237:11 

truly 57:18 88:6 210:9 

Trust 145:17 242:10 

Truststar 10:9 12:12 

try 25:4 49:18 70:9 73:3 

112:16 121:11 124:13 

124:15 207:4 213:6 

trying 48:13 63:2 85:15 

87:22 144:13 149:15 

152:11,18 153:6 

161:1,2 212:12 

TUESDAY 1:7 

tune 94:21 

tunnel 116:4 

turbulent 229:1 

turn 7:11 41:20 60:15 

63:2 106:8,21 111:7 

112:6 125:14,22 

127:21 129:19 136:10 

145:12 164:16 169:16 

188:14 197:2 213:6 

214:5 216:17 224:19 

228:15 231:13 235:4 

240:12,17 

turnaround 192:3 

turned 62:19 83:17 

turning 9:8 62:13 

turnover 17:22 

twice 33:22 

Twin 82:10 

two 23:2,6 38:4 51:20 

51:22 52:1,3,11,19 

57:7 73:21 76:21 

78:15 91:3 92:5 

103:12,13 107:3 

115:22 119:18 131:17 

136:22 149:20 150:11 

150:14 179:16 181:15 

182:3 185:9 192:21 

193:7,8 214:9,18 

216:6,18 217:2 

218:10 219:19 224:12 

225:19 229:16 238:13 

240:6 242:7 

two-month 137:17 

149:20 

two-thirds 217:13 

221:7 234:14 

type 35:20 59:16 92:22 

156:18 

types 70:10 83:22 

129:2 132:18 201:21 

221:2 

typical 53:12 

typically 45:17 

U

U.S 113:20 114:3 115:6 

127:18 133:5 143:1 

184:2 223:9,10 

228:18 229:15,21 

230:14 233:20 234:7 

235:21 

UDAPs 193:3 

ultimately 39:9 153:11 

157:1 

Ulysses 51:11 

unaffiliated 177:13,15 

178:2,5,10 217:1 

unanticipated 17:10 

unbanked 42:5 

uncertainly 102:18 

uncertainty 8:17 69:14 

107:12 116:9 120:20 

122:6 

underbanked 42:5 

undercapitalized

173:22 

undergrad 78:16 

underlying 181:21 

understand 31:4 134:6 

197:15 211:11 

understanding 77:13 

141:13 199:2 

understood 161:1 

underway 173:7 

underwriting 86:8 

226:22 

unemployment 11:16 

20:16 37:6 45:19 55:6 

75:10 80:15,20 96:7 

96:14 109:12,17 

114:2 

unfortunately 24:19 

96:17 209:4 

unintended 26:10 

unions 94:14 133:10 

183:19 200:10 201:3 

unique 77:9 130:1 

135:13 

unit 14:12 

United 42:2 45:18 140:1 

universe 132:17 

Universities 49:5 

University 78:13 

unmask 32:10 

unnecessary 36:7 

unprecedented 121:16 

unregulated 140:18 

unscripted 150:4 

unsecured 148:4 

unseen 43:8 92:21 

unusual 78:5 

unusually 228:21 

update 3:7,9,11,17 9:8 

19:2 127:12 131:15 

133:16 173:7 205:14 

213:14 

updated 135:3 

updates 105:13 127:16 

129:20 164:2 168:22 

upper 229:4 233:5,6,11 

233:16,21 234:3,7,10 

234:13,16 235:16 

237:11 238:5 239:3 

ups 98:5 

uptick 37:13 50:21 

60:12 62:15 93:22 

120:6 

Upton 1:15 7:11 

upward 81:21 

urban 30:7 43:18 

117:12 

USDA 101:12 233:8,13 

233:18 234:1,8 

239:20 

USDA's 239:13 

use 56:8 93:19 112:7 

160:21 166:18 184:16 

185:18 195:5 207:1 

226:17 

useful 106:17 137:20 

158:18 

uses 175:13 178:3,8 

227:16 

usual 47:21 

usually 96:8 

Utah 71:15 

utilize 6:2 56:5 57:8 

utmost 48:16 

V

vacancies 11:6 

vacancy 122:13 

vaccinated 14:6 19:6 

48:12,14 97:12 

vaccination 48:6 76:1 

81:17 89:5 

vaccinations 19:4 

60:14 115:8 

vaccine 14:1 48:9 54:18 

97:8,14 

vaccines 55:3 

Valley 7:4 22:14 23:8 

24:3 161:8 

valuable 241:4 242:5 

values 20:9 53:9 101:17 

231:13 232:10,16 

236:22 237:9,12,15 

varies 115:11 

variety 75:15 160:16 

various 134:22 135:1 

156:5 

vendors 5:19 

venues 97:17 

version 191:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
271 

versus 118:16 183:18 

191:16 200:10 217:4 

vet 70:12 

video 1:10 70:6 111:12 

111:14,15,19,22 

112:6 121:12,14,15 

121:19 122:2,8,11,12 

122:20,21 123:5,6,9 

123:11,14,16,19 

142:15 165:7 166:5 

179:5 184:2 242:20 

view 7:2 27:8 107:2 

139:15 155:4 

viewed 226:10 

Viewer 56:8 

viewpoint 106:21 

vigilant 13:11 

violations 193:3,7,8 

Virgin 113:10 

Virginia 6:19 11:4 74:12 

74:22 75:4,7 

Virtual 103:16 

virtually 19:11 49:7 

56:4 81:1 

virus 19:3 

visit 80:21 

visits 114:21 

vital 162:10 

Vogel 2:11 3:14 164:8 

165:3 169:19 

voice 150:21 

volume 14:13 15:7 

73:15 122:15 

volumes 15:6 

voluntary 216:22 

217:16 

volunteering 162:5 

W

waiting 88:16 197:4 

waiver 173:21 187:10 

187:12 

walk 129:20 138:7 

214:22 

walking 138:6 

wanted 78:19 128:3 

139:14,15 144:18 

182:2,3,13 211:2 

241:14 

wanting 237:18 

wants 143:21 179:20 

Wapello 95:22 96:7,10 

warehouse 110:4 

Warick 6:16 

warmer 115:8 

wars 92:22 

Warwick 90:4,5 

Washington 11:2 75:1 

116:21 117:6 

wasn't 83:20 148:8 

191:11 208:3 237:1 

watch 82:3 103:3 

119:12 

watching 122:16 

wave 87:15,16 88:1,3,5 

89:2 

way 24:9 28:5 35:18 

67:21 69:18 72:18 

113:7 120:11 139:10 

139:13 144:2,3 154:9 

173:4 189:3,7 190:1 

190:11,12,14,16 

192:12 194:6 201:15 

204:19,21 208:4 

229:16 241:11 

ways 41:18 70:2,15 

73:3 108:19 109:10 

128:21 144:15 147:8 

149:17 189:7 241:8 

weak 114:9 231:3 

233:21 

weakness 68:20 

weaknesses 118:7 

wear 158:7 

wearing 141:20 

weather 33:10 115:8 

WebEx 112:22 

webinar 133:18 134:5,9 

134:12 

webinars 40:3 167:8 

webpage 166:2 167:11 

169:13 

website 182:8,10 188:9 

188:11 211:10 

week 31:22 72:14,14 

81:8 115:18 211:8 

weekend 103:17 

weekends 23:12 39:8 

weeks 19:22 23:6,6 

37:22 54:19 162:14 

166:7 167:21 191:22 

weigh 204:3 205:21 

weighing 70:3 

weight 167:6 184:4 

weighted 200:1,8 

welcome 4:5 6:11 7:6 

7:10,20 126:11 

135:21 151:19 

well- 152:16 153:14 

Wells 29:10,16 

went 34:18 37:22 38:20 

52:3,15 56:4,14 89:1 

126:7,8 161:14 188:1 

207:9 208:5 

weren't 40:1 

west 1:20 4:4 6:15,19 

7:2 13:5 41:22,22 

46:3,10 51:20 74:11 

75:4,7 90:4,5 109:18 

129:12 

western 42:15 45:2 

73:21 

Wharton 1:18 7:4 22:9 

22:10 157:18 161:7,7 

162:20 

wheat 230:5,17 

whirlwind 37:1 

wide 220:20 

widely 220:15 222:15 

widespread 232:16 

wildfires 206:6 

willing 54:6 

winter 32:20 112:2 

Wisconsin 6:14 55:2,3 

79:15,17 80:13 84:7 

Wisconsin's 51:21 

wise 33:3 

wish 7:6 184:16 201:19 

242:17 

wolfing 147:11 

women 140:10 

wonderful 22:12 27:9 

58:3 140:12 

wondering 209:6 

woods 88:11 

word 7:20 85:6 105:7 

112:6,12 124:12 

227:21 

words 111:2 158:17 

work 11:10 12:17 21:21 

38:15,21 40:2 42:13 

42:16 60:2 69:4,10 

70:5 74:19 80:11 

82:10 83:12 87:1 90:7 

103:19 106:18 116:13 

128:21 130:19 132:11 

141:5 144:2,6,11,14 

144:15 147:8,13 

155:8 156:20 165:12 

166:11 168:16 169:21 

170:5,18 173:17 

worked 23:11 35:5 39:8 

40:9 61:22 64:18,20 

72:16 77:12 200:18 

208:15 209:14 

workers 54:21 

workforce 11:14,15 

48:21 96:19 116:11 

working 13:14 33:6 

39:8,10 44:7 48:21,22 

52:15 78:14 82:6 

103:21 147:3 148:6 

165:20 182:11 205:16 

211:3 

workouts 205:15 

works 36:11 152:16 

155:6 

world 6:8 23:4 73:2 

86:1 87:9 89:15 155:5 

165:11 

worn 19:13 97:4 

worried 22:20 32:20 

worse 206:16 207:8 

worst 83:16 

worth 39:15 231:17 

wouldn't 160:22 

wounds 51:13 

wrapping 104:15 

write 188:22 

written 186:7 196:10 

X

X 160:21 

Y

Yampa 7:4 22:14 23:8 

24:3 161:8 

year 8:3,7 11:20,22 

14:20 15:11,12,14,15 

16:16,17,20 19:17 

21:17 22:16 23:13,16 

24:19 25:1,22 33:19 

37:1,19,21 38:14 40:3 

45:11 46:22 54:10 

55:7,19 62:5,9 68:7 

68:11 69:1,4 72:10 

77:22 83:15 88:17 

90:13,14,15 91:9 93:6 

93:9,15 94:12 95:3 

97:19,20,21 98:21 

102:14 103:8,12 

104:11 107:7,10 

108:1,8,11 111:15 

123:4 132:5 135:8 

141:4 144:7,8,17 

152:5 153:7 172:10 

191:4 203:13,13,18 

205:18 207:7 214:15 

214:17 215:3 216:3 

216:13 217:6 219:10 

219:22 221:20 224:4 

229:22 231:10 235:10 

year-end 172:13 

year-old 152:16 

year-olds 60:13 

year-to-date 25:10 

years 13:22 14:17 

22:15 28:12 42:4 

44:20 45:13 50:8 54:1 

56:7 69:10 72:9 73:21 

98:19 103:13 148:5 

151:8 152:13 155:3,8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
272 

160:11 195:13 221:1 

223:22 224:7 229:12 

237:2,22 239:7 

yesterday 127:4 129:18 

131:1 132:10 136:7 

yesterday's 127:12 

yields 15:17 118:4 

York 2:7 10:3 92:19 

113:7,22 114:17 

115:17 116:14,21 

117:3,13 118:22 

120:19 

youngest 218:20 

Z

zero 50:10 

0

0.13 216:15 

0.4 219:10 

0IBA 57:14 

1

1-800 24:8 

1,000 40:19 87:18 

193:11 

1,163 235:10 

1,500 39:13 

1,600 67:17 

1,947 16:2 

1.05 215:17 

1.2 25:15 134:2 

1.44 215:16 

1.6 97:7 

1.7 47:1 

1.9 90:11 

1:00 1:10 

1:04 4:2 

10 3:4 66:8 110:8,13 

126:4,5 129:7 212:22 

218:1 

10-minute 125:20 

10-year 229:21 

100 52:11 65:22 79:17 

91:18 94:22 98:1,2 

158:5 159:18 180:17 

217:19 228:4 233:15 

100,000 91:17 

102 229:22 

106 3:5 

108 71:21 

11 99:7 

111 3:5 

112 3:6 

117-year-old 96:5 

12 14:19 16:20 25:2,3 

84:15 90:6 131:6 

162:6 167:4 207:22 

220:4 229:3 234:20 

12,500 24:17 

120 52:18 59:7 60:17 

125 39:15 59:7 

128 3:8 223:16 

13 1:8 55:15 

13.5 73:10 

13.59 20:20 

13.7 16:22 

130 3:8 

137 3:10 

14 71:20 

14- 152:15 

14-year-old 152:10 

14.8 15:22 

15 42:4 81:18 109:13 

167:5 212:22 220:5 

237:22 

15.4 76:19 

150 25:3 159:18 

150,000 76:21 

157 76:21 

16 13:22 14:17 19:4 

32:1 76:20 94:11 

97:13 99:3 

160 33:19 

164 3:12 12:3 

169 3:14 

17 90:8 118:16 

17-branch 47:5 

171 3:13 

18 20:1 84:15 207:22 

185 19:22 

1869 75:3 

188 3:15 

1892 71:17 

1895 13:5 

19 18:16 60:12 61:7 

1906 59:7 

191 16:6 

192-year-old 90:3 

1955 66:4 

1960 229:16 

1967 28:13 

1970s 231:19 232:6,13 

232:15 236:15,16,22 

237:9 

1972 229:17 

1973's 229:20 

1975 229:17 

1979 237:1 

1980s 231:20 

1984 214:15 217:11 

1987 230:1 

1987-2003 233:15 

1990 224:4 

19th 13:21 

2

2.2 25:19 

2.5 61:8 234:11 

2.7 100:19 

2/1/2021 68:19 

20 14:7 22:14 24:18 

61:8 98:12,12 110:14 

160:11 200:7 232:16 

20-plus 152:13 

20-year 224:18 

200 16:17 31:20 67:18 

2000 152:5 224:11 

2000s 233:20 

2003 230:1 239:4 

2004 219:20 228:22 

229:18 232:4 

2005 232:21 

2008 224:22 

2009 66:6,12 

2010 216:11 

2011 66:12 214:15 

217:11 221:1 234:10 

2012 214:8 215:10,17 

216:5,20 217:5,12,14 

223:2 

2013 228:22 229:18 

234:10 

2014 52:2 225:21 229:1 

230:13 232:7 238:19 

2015 66:12 232:22 

2016 230:16 234:15 

2018 222:11 

2019 14:10,21 15:8,11 

15:15 16:17,20 

214:17 215:4,11,17 

216:3,15,20 217:5,12 

217:14 220:1 221:1,5 

221:20 223:3,10 

224:4,12,22 227:17 

229:1 231:2 

2020 4:5,18 14:8 15:6 

15:12 16:16 17:14 

18:15 20:18 32:18 

37:13 38:17 41:6 

52:10,14 54:10 57:4 

66:14 83:14 85:4 

98:20 99:2,13,20 

101:10 103:12 104:5 

107:21 108:4,21 

109:1 119:3 167:2 

229:1 231:12 235:10 

239:2,12 240:1 

2020's 215:5 231:3 

2021 1:8 4:6 16:2,15,19 

18:22 20:2,17 24:22 

25:7 26:18,20 32:21 

37:17 46:7 85:5 99:4 

99:15,21 101:10,22 

102:9 108:1 113:19 

172:11,14 239:13 

2022 52:21 172:20 

20th 143:8,9 

21 18:17 54:11 64:6 

213 3:19 

217 12:4 

21st 143:14 

22 14:5 216:3 232:17 

23 118:15 

24 77:3 85:19 

240 87:14 

242 3:22 

25 61:7 72:6 87:15 

110:15 179:21 180:2 

180:4 187:22 235:8 

25,000 40:18 59:15 

250 56:22 131:20 

223:18 

256 16:6 

25th 12:15 

27 19:5 

270 73:9 

28 224:6 

29 173:11,12 

295 33:22 34:1 

297 19:18 

3

3 60:22 109:8 133:20 

3.19 15:11 

3.2 217:10 

3.3 80:17 

3.5 96:11 

3.57 15:10 

3.8 45:19 80:15 

3:09 125:19 

3:10 126:8 

3:15 125:21 

3:20 126:6,9 

30 40:15 72:6 76:22 

151:8 191:21 220:10 

224:6 

30-day 85:20 

30,000 40:18 59:15 

300 99:2 

300,000 14:20 

31 167:3 199:3 223:9 

31.7 15:14 

31st 16:2,15 

32 19:18 

320 71:20 

325 76:18 

335,000 14:19 

337.7 183:13 

34 18:16 

346 13:7 

35 48:9,22 111:1 131:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
273 

350 56:20 

35th 46:22 

36 14:5 221:20 

37 97:11 

375 23:14 

379 16:1 

38 223:1 

380 11:22 

385 19:16 

39 19:17 183:6 

39,000 16:4 

396 55:14 

4

4 3:2 56:9 107:22 

4.2 75:11 

4.3 16:18 217:11 

4.7 66:22 

4.8 56:21 

4.9 75:11 

40 25:2,13 100:5 

400 66:2 75:6 

407 53:1 

43 216:4 

45 216:15 

450 98:18 

46 60:13 223:2 

469 23:14 

47 60:13 

47,000 76:19 

5

5 80:19 96:11 97:15 

222:22 

5.4 16:7 

5.7 11:17 

5:07 240:3 

5:10 213:7 243:4 

5:15 213:8 

50 29:12 97:9 115:21 

158:5 159:17 230:17 

232:18 233:1 

500 59:10 66:14,15 95:8 

51 14:3 28:11 

515 80:6 

540 65:20 66:17 

55 224:4 

550 90:18 99:6 

565 96:5 

569 23:15 

578,000 16:5 

6

6 61:4 109:13 228:3 

6,000 151:2 

6.3 108:1 

6.7 56:21 

60 48:10 

65 115:21 

650 80:7 

7

7 118:17 

7(a) 222:21 

7.1 20:17 

7.7 55:7 

70 67:2 74:22 116:1 

132:6 228:5 

71 70:6 

75 48:11 184:1,3,6,6 

201:11,12 223:17 

77 230:1 

78 235:15 

8

8 26:18 108:22 183:5 

8.5 26:19 

80 74:22 200:4 

800 59:10 67:1 75:20 

81 232:21 

84,000 66:21 

86 15:7 16:16 

9

9 133:8 197:21 199:8 

90 53:7 59:11 185:2 

90,000 40:17 

90th 238:7 239:2 

95 59:11 129:7 

96 42:3 

98 52:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
 

274

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Advisory Committee

on Community Banking

Before: FDIC

Date: 04-13-21

Place: teleconference

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com