The Company accounts for credit losses on loans in accordance with ASC 326 - Financial Instruments - Credit Losses, to determine the ACL. ASC 326 requires the Company to recognize estimates for lifetime losses on loans and unfunded loan commitments at the time of origination or acquisition. The recognition of losses at origination or acquisition represents the Company’s best estimate of the lifetime expected credit loss associated with a loan given the facts and circumstances associated with the particular loan, and involves the use of significant management judgement and estimates, which are subject to change based on management’s on-going assessment of the credit quality of the loan portfolio and changes in economic forecasts used in the model. The Company uses a discounted cash flow model when determining estimates for the ACL for commercial real estate loans and commercial loans, which comprise the majority of the loan portfolio, and uses a historical loss rate model for retail loans. The Company also utilizes proxy loan data in its ACL model where the Company’s own historical data is not available.

The discounted cash flow model is applied on an instrument-by-instrument basis, and for loans with similar risk characteristics, to derive estimates for the lifetime ACL for each loan. The discounted cash flow methodology relies on several significant components essential to the development of estimates for future cash flows on loans and unfunded commitments. These components consist of: (i) the estimated probability of default, (ii) the estimated loss given default, which represents the estimated severity of the loss when a loan is in default, (iii) estimates for prepayment activity on loans and (iv) the estimated exposure to the Company at default (“EAD”). These components are also heavily influenced by changes economic forecasts employed in the model over a reasonable and supportable period. The Company’s ACL methodology for unfunded loan commitments also includes assumptions concerning the probability an unfunded commitment will be drawn upon by the borrower. These assumptions are based on the Company’s historical experience.

The Company’s discounted cash flow ACL model for commercial real estate and commercial loans uses internally derived estimates for prepayments in determining the amount and timing of future contractual cash flows to be collected. The estimate of future cash flows also incorporates estimates for contractual amounts the Company believes may not be collected, which are based on assumptions for PD, LGD and EAD. EAD is the estimated outstanding balance of the loan at the time of default. It is determined by the contractual payment schedule and expected payment profile of the loan, incorporating estimates for expected prepayments and future draws on revolving credit facilities. The Company discounts cash flows using the effective interest rate on the loan. The effective interest rate represents the contractual rate on the loan; adjusted for any purchase premiums, purchase discounts, and deferred fees and costs associated with the origination of the loan. The Company has made an accounting policy election to adjust the effective interest rate to take into consideration the effects of estimated prepayments. The ACL for loans is determined by measuring the amount by which a loan’s amortized cost exceeds its discounted cash flows.

The PD for commercial real estate loans is based largely on a model provided by a third party, using proxy loan information. The PDs generated by this model are reflective of current and expected changes in economic conditions and conditions in the commercial real estate market, and how they are expected to impact loan level and property level attributes, and ultimately the likelihood of a default event occurring. Significant loan and property level attributes include: loan to value ratios, debt service coverage, loan size, loan vintage and property types.

The PD for commercial loans is based on an internally developed PD rating scale that assigns PDs based on the Company’s internal risk grades for loans. This internally developed PD rating scale is based on a combination of the Company’s own historical data and observed historical data from the Company’s peers, which consist of banks that management believes align with our business profile. As credit risk grades change for loans in the commercial segment, the PD assigned to them also changes. As with commercial real estate loans, the PD for commercial loans is also impacted by current and expected economic conditions.

LGDs for commercial real estate loans are derived from a third party, using proxy loan information, and are based on loan and property level characteristics in the Company’s loan portfolio, such as: loan to values, estimated time to resolution, property size and current and estimated future market price changes for underlying collateral. The LGD is highly dependent upon loan to value ratios, and incorporates estimates for the expense associated with managing the loan through to resolution. LGDs also incorporate an estimate for the loss severity associated with loans where the borrower fails to meet their debt obligation at maturity, such as through a balloon payment or the refinancing of the loan through another lender. External factors that have an impact on LGDs include: changes in the CRE Price Index, GDP growth rate, unemployment rates and the Moody’s Baa rating corporate debt interest rate spread. LGDs are applied to each loan in the commercial real estate portfolio, and in conjunction with the PD, produce estimates for net cash flows not expected to be collected over the estimated term of the loan.

LGDs for commercial loans are also derived from a third party that has a considerable database of credit related information specific to the financial services industry and the type of loans within this segment, and is used to generate annual default information for commercial loans. These proxy LGDs are dependent upon data inputs such as: credit quality, borrower industry, region, borrower size and debt seniority. LGDs are then applied to each loan in the commercial portfolio, and in conjunction with the PD, produce estimates for net cash flows not expected to be collected over the estimated term of the loan.

U.S. GAAP requires the Company to develop reasonable and supportable forecasts of future conditions, and estimate how those forecasts are expected to impact a borrower’s ability to satisfy their obligation to the Bank and the ultimate collectability of future cash flows over the life of the loan. The Company uses economic scenarios from Moody’s Analytics in its estimation of a borrower’s ability to repay a loan in future periods. These scenarios are based on past events, current conditions and the likelihood of future events occurring. These scenarios typically are comprised of: (1) a base-case scenario, (2) an upside scenario, representing slightly better economic conditions than currently experienced and (3) a downside scenario, representing recessionary conditions. Management periodically evaluates economic scenarios and may decide that a particular economic scenario or a combination of probability-weighted economic scenarios should be used in the Company’s ACL model. The economic scenarios chosen for the model, the extent to which more than one scenario is used, and the weights that are assigned to them, are based on the Company’s estimate of the probability of each scenario occurring, which is based in part on analysis performed by an independent third-party. Economic scenarios chosen, as well as the assumptions within those scenarios, and whether to use a probability-weighted multiple scenario approach, can vary from one period to the next based on changes in current and expected economic conditions and due to the occurrence of specific events such as the COVID-19 pandemic. The Company recognizes the non-linearity of credit losses relative to economic performance and thus the Company believes consideration of and, if appropriate under the circumstances, use of multiple probability-weighted economic scenarios is appropriate in estimating credit losses over the forecast period. This approach is based on certain assumptions. The first assumption is that no single forecast of the economy, however detailed or complex, is completely accurate over a reasonable forecast time-frame, and is subject to revisions over time. By considering multiple scenario outcomes and assigning reasonable probability weightings to them, some of the uncertainty associated with a single scenario approach, the Company believes, is mitigated.

As of January 1, 2020, upon the adoption of ASC 326, the Company’s ACL model used three probability-weighted scenarios representing a base-case scenario, an upside scenario and a downside scenario. The weightings assigned to each scenario were as follows: the base-case scenario, or most likely scenario, was assigned a weighting of 40%, while the upside and downside scenarios were each assigned weightings of 30%. As of June 30, 2020, the Company’s ACL model used the same three probability weighted scenarios, updated for current expected economic conditions, including the current and estimated future impact associated with the on-going COVID-19 pandemic. The Company evaluated the weightings of each economic scenario in the current period with the assistance of an independent third party, and determined the current weightings of 40% for the base-case scenario, and 30% for each of the upside and downside scenarios appropriately reflect the likelihood of outcomes for each scenario given the current economic environment. For the three months ended March 31, 2020, the Company’s ACL model used three probability-weighted scenarios, however the composition and weightings of those scenarios differed from those used in the model as of June 30, 2020 due to the rapid emergence of the of the COVID-19 pandemic in the first quarter of 2020. These scenarios included (i) a base-case scenario with a weighting of 37.5%, (ii) a critical pandemic scenario with a weighting of 30%, and (iii) a more severe down-side scenario with a weighting of 32.5%. The composition of these scenarios and their assigned weightings were determined with the assistance of an independent third party, and were reflective of the rapidly changing economic conditions, economic uncertainty and volatility in financial markets brought on by the COVID-19 pandemic and the estimated likelihood of each scenario occurring as of March 31, 2020.

The Company currently forecasts economic conditions over a two-year period, which we believe is a reasonable and supportable period. Beyond the point which the Company can provide for a reasonable and supportable forecast, economic variables revert to their long-term averages. The Company has reflected this reversion over a period of three years in each of its economic scenarios used to generate the overall probability-weighted forecast. Changes in economic forecasts impact the PD, LGD and EAD for each loan, and therefore influence the amount of future cash flows for each loan the Company does not expect to collect.

The Company derives the economic forecasts it uses in its ACL model from an independent third party that has a large team of economists, data-base managers and operational engineers with a history of producing monthly economic forecasts for over 25 years. The forecasts produced by this third party have been widely used by banks, credit unions, government agencies and real estate developers. These economic forecasts cover all states and metropolitan areas in the Unites States, and reflect changes in economic variables such as: GDP growth, interest rates, employment rates, changes in wages, retail sales, industrial production, metrics associated with the single-family and multifamily housing markets, vacancy rates, changes in equity market prices and energy markets.

It is important to note that the Company’s ACL model relies on multiple economic variables, which are used under several economic scenarios. Although no one economic variable can fully demonstrate the sensitivity of the ACL calculation to changes in the economic variables used in the model, the Company has identified certain economic variables that have significant influence in the Company’s model for determining the ACL. As of June 30, 2020, the Company’s ACL model incorporated the following assumptions for key economic variables in the base-case and downside scenarios:

The Company recognizes that historical information used as the basis for determining future expected credit losses may not always, by themselves, provide a sufficient basis for determining future expected credit losses. The Company, therefore, periodically considers the need for qualitative adjustments to the ACL. Qualitative adjustments may be related to and include, but not be limited to, factors such as: (i) management’s assessment of economic forecasts used in the model and how those forecasts align with management’s overall evaluation of current and expected economic conditions, (ii) organization specific risks such as credit concentrations, collateral specific risks, regulatory risks and external factors that may ultimately impact credit quality, (iii) potential model limitations such as limitations identified through back-testing, and other limitations associated with factors such as underwriting changes, acquisition of new portfolios and changes in portfolio segmentation and (iv) management’s overall assessment of the adequacy of the ACL, including an assessment of model data inputs used to determine the ACL. As of June 30, 2020, qualitative adjustments included in the ACL totaled $15.0 million. These adjustments relate to potential limitations in the model. Management determined through additional review that certain key model drivers are potentially underestimating the impact of the on-going COVID-19 pandemic may have on small and medium sized businesses, and may not be fully reflecting the potential for a more turbulent economic recovery. Management reviews the need for and appropriate level of qualitative adjustments on a quarterly basis, and as such, the amount and allocation of qualitative adjustments may change in future periods.


	Three Months Ended June 30, 2020

	Beginning ACL Balance ⁽¹⁾		Initial ACL Recorded for PCD Loans		Charge-offs		Recoveries		Provision for Credit Losses		Ending ACL Balance
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner occupied	$	15,896	$	3,025	$	—	$	—	$	44,086	$	63,007
Multifamily	14,722		8,710		—		—		40,079		63,511
Construction and land	9,222		2,051		—		—		7,531		18,804
SBA secured by real estate	935		—		(554)		—		1,629		2,010
Business loans secured by real estate
CRE owner-occupied	26,793		3,766		—		11		17,643		48,213
Franchise real estate secured	7,503		—		—		—		5,557		13,060
SBA secured by real estate	4,044		235		—		3		86		4,368
Commercial loans
Commercial and industrial	15,742		2,325		(2,286)		21		26,165		41,967
Franchise non-real estate secured	16,616		—		(1,227)		—		6,287		21,676
SBA non-real estate secured	516		924		(556)		(2)		(282)		600

Retail loans
Single family residential	1,137		—		(62)		1		403		1,479
Consumer loans	2,296		206		—		1		1,073		3,576
Totals	$	115,422	$	21,242	$	(4,685)	$	35	$	150,257	$	282,271


	Six Months Ended June 30, 2020

	Beginning ACL Balance ⁽¹⁾		Adoption of ASC 326		Initial ACL Recorded for PCD Loans		Charge-offs		Recoveries		Provision for Credit Losses		Ending ACL Balance
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner occupied	$	1,899	$	8,423	$	3,025	$	(387)	$	—	$	50,047	$	63,007
Multifamily	729		9,174		8,710		—		—		44,898		63,511
Construction and land	4,484		(124)		2,051		—		—		12,393		18,804
SBA secured by real estate	1,915		(1,401)		—		(554)		—		2,050		2,010
Business loans secured by real estate
CRE owner-occupied	2,781		20,166		3,766		—		23		21,477		48,213
Franchise real estate secured	592		5,199		—		—		—		7,269		13,060
SBA secured by real estate	2,119		2,207		235		(315)		74		48		4,368
Commercial loans
Commercial and industrial	13,857		87		2,325		(2,776)		26		28,448		41,967
Franchise non-real estate secured	5,816		9,214		—		(1,227)		—		7,873		21,676
SBA non-real estate secured	445		218		924		(792)		2		(197)		600

Retail loans
Single family residential	655		541		206		(62)		1		138		1,479
Consumer loans	406		1,982		—		(8)		1		1,195		3,576
Totals	$	35,698	$	55,686	$	21,242	$	(6,121)	$	127	$	175,639	$	282,271


	For the Three Months Ended June 30, 2019
	Beginning ALLL Balance		Charge-offs		Recoveries		Provision for Credit Losses		Ending ALLL Balance
	(Dollars in thousands)

Investor loans secured by real estate
CRE non-owner-occupied	$	1,668	$	(488)	$	—	$	585	$	1,765
Multifamily	669		—		—		36		705
Construction and land	5,960		—		—		(552)		5,408
SBA secured by real estate	2,704		(721)		—		(661)		1,322
Business loans secured by real estate
CRE owner-occupied	1,969		—		15		315		2,299
Franchise real estate secured	2,173		(1,376)		—		(218)		579
SBA secured by real estate	1,966		(254)		—		(101)		1,611
Commercial loans
Commercial and industrial	13,587		(393)		47		555		13,796
Franchise non-real estate secured	5,698		(160)		—		648		6,186
SBA non-real estate secured	503		(244)		1		170		430
Retail loans
Single family residential	758		—		1		(55)		704
Consumer loans	201		—		—		20		221
Totals	$	37,856	$	(3,636)	$	64	$	742	$	35,026


	For the Six Months Ended June 30, 2019
	Beginning ALLL Balance		Charge-offs		Recoveries		Provision for Credit Losses		Ending ALLL Balance
	(Dollars in thousands)

Investor loans secured by real estate
CRE non-owner-occupied	$	1,624	$	(488)	$	—	$	629	$	1,765
Multifamily	740		—		—		(35)		705
Construction and land	5,964		—		—		(556)		5,408
SBA secured by real estate	1,827		(721)		—		216		1,322
Business loans secured by real estate
CRE owner-occupied	1,908		—		23		368		2,299
Franchise real estate secured	743		(1,376)		—		1,212		579
SBA secured by real estate	1,824		(254)		—		41		1,611
Commercial loans
Commercial and industrial	13,695		(695)		114		682		13,796
Franchise non-real estate secured	6,066		(160)		—		280		6,186
SBA non-real estate secured	654		(244)		4		16		430
Retail loans
Single family residential	808		—		1		(105)		704
Consumer loans	219		(5)		1		6		221
Totals	$	36,072	$	(3,943)	$	143	$	2,754	$	35,026

The change in the ACL during the three months ended June 30, 2020 of $166.8 million is reflective of a $150.3 million in provision for credit losses, $4.7 million in net charge-offs, and the establishment of $21.2 million in net ACL for PCD loans acquired in the Opus acquisition. The change in the ACL for the six months ended June 30, 2020 of $246.6 million is reflective of a $55.7 million adjustment associated with the Company’s adoption of ASC 326 on January 1, 2020, which was recorded through a cumulative effect adjustment to retained earnings, as well as a $175.6 million provision for credit losses on loans, net charge-offs of $6.0 million, and the establishment of $21.2 million in net ACL for PCD loans previously mentioned. The provision for credit losses during the three and six months ended June 30, 2020 includes approximately $75.9 million related to the initial ACL required for the acquisition of non-PCD loans in the Opus acquisition. Under ASC 326, the Company is required to record an ACL for estimates of life-time credit losses on loans at the time of acquisition. For non-PCD loans, the initial ACL is established through a charge to provision for credit losses at the time of acquisition. However, the ACL for PCD loans is established through an adjustment to the loan’s purchase price (or initial fair value). In addition, the provision for credit losses for the three and six months ended June 30, 2020 is also reflective of unfavorable changes in economic forecasts used in the Company’s ACL model driven by the COVID-19 pandemic.

The Company maintains an allowance for credit losses on off-balance sheet commitments related to unfunded loans and lines of credit, which is included in other liabilities of the consolidated balance sheets. The allowance for off-balance sheet commitments was $22.0 million at June 30, 2020 and $3.3 million at December 31, 2019. The change in the allowance for off-balance sheet commitments can be attributed to several factors, including: (i) an $8.3 million increase in the first quarter of 2020 attributed to the Company’s adoption of ASC 326, (ii) a $8.6 million provision for credit losses in the second quarter of 2020 related to the assumption of off-balance sheet loan commitments in the acquisition of Opus and the initial ACL the Company was required to establish at the time of acquisition, and (iii) a $1.9 million in provision for credit losses for the first six months of 2020 related primarily to the deterioration in economic forecasts, primarily in the second quarter of 2020, used in the Company’s CECL model. The total provision for credit losses for off-balance sheet commitments totaled $10.4 million and $10.5 million for the three and six months ended June 30, 2020, respectively.


	December 31, 2019
	Loans Evaluated Individually for Impairment		ALLL Attributed to Individually Evaluated Loans		Loans Evaluated Collectively for Impairment		ALLL Attributed to Collectively Evaluated Loans
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied	$	1,088	$	—	$	2,069,053	$	1,899
Multifamily	—		—		1,575,726		729
Construction and land	—		—		438,786		4,484
SBA secured by real estate	390		—		68,041		1,915
Business loans secured by real estate
CRE owner-occupied	—		—		1,846,554		2,781
Franchise real estate secured	—		—		353,240		592
SBA secured by real estate	1,517		—		86,864		2,119
Commercial loans
Commercial and industrial	7,529		—		1,385,741		13,857
Franchise non-real estate secured	10,834		—		553,523		5,816
SBA non-real estate secured	1,118		—		16,308		445
Retail loans
Single family residential	366		—		254,658		655
Consumer loans	—		—		50,975		406
Totals	$	22,842	$	—	$	8,699,469	$	35,698


	Commercial Real Estate Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
June 30, 2020	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied
0% - 5.00%	$	153,133	$	561,104	$	474,139	$	258,886	$	279,780	$	793,398	$	10,924	$	—	$	2,531,364
>5.00% - 10.00%	—		2,897		8,428		86,660		37,621		39,947		—		—		175,553
Greater than 10%	2,296		3,988		322		14,155		2,585		52,870		559		—		76,775
Multifamily
0% - 5.00%	520,782		1,723,731		991,561		746,855		460,328		678,741		1,031		—		5,123,029
>5.00% - 10.00%	1,599		17,431		8,692		2,176		4,098		8,906		—		—		42,902
Greater than 10%	—		12,607		9,794		12,545		10,409		14,271		—		—		59,626
Construction and Land
0% - 5.00%	13,838		32,921		4,296		20,357		—		6,919		66		—		78,397
>5.00% - 10.00%	—		40,785		21,154		3,275		—		—		395		—		65,609
Greater than 10%	—		67,142		129,990		14,739		—		1,549		—		—		213,420
SBA secured by real estate
0% - 5.00%	495		10,704		12,115		16,181		7,135		11,352		—		—		57,982
>5.00% - 10.00%	—		—		512		—		—		—		—		—		512
Greater than 10%	—		—		594		—		394		—		—		—		988
Total investor loans secured by real estate	$	692,143	$	2,473,310	$	1,661,597	$	1,175,829	$	802,350	$	1,607,953	$	12,975	$	—	$	8,426,157
Business loans secured by real estate
CRE owner-occupied
0% - 5.00%	$	211,860	$	402,474	$	309,907	$	304,611	$	234,139	$	488,345	$	3,124	$	—	$	1,954,460
>5.00% - 10.00%	186		33,118		35,922		22,510		26,918		42,552		1,504		—		162,710
Greater than 10%	5,979		16,066		7,086		3,386		6,797		13,173		497		—		52,984
Franchise real estate secured
0% - 5.00%	18,724		86,263		74,832		95,221		28,550		42,831		—		—		346,421
>5.00% - 10.00%	754		—		632		8,627		3,028		101		—		—		13,142
Greater than 10%	928		2,545		728		—		—		883		—		—		5,084
SBA secured by real estate
0% - 5.00%	1,905		7,693		13,476		16,611		8,547		24,605		365		—		73,202
>5.00% - 10.00%	—		—		683		1,699		2,306		3,416		—		—		8,104
Greater than 10%	—		—		—		914		148		3,174		—		—		4,236
Total business loans secured by real estate	$	240,336	$	548,159	$	443,266	$	453,579	$	310,433	$	619,080	$	5,490	$	—	$	2,620,343


	Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
June 30, 2020	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied
55% and below	$	73,769	$	241,867	$	191,322	$	156,622	$	189,946	$	618,498	$	10,924	—		$	1,482,948
>55-65%	54,874		214,909		119,539		177,366		104,448		231,545		559		—		903,240
>65-75%	22,526		108,464		169,089		23,368		25,379		31,566		—		—		380,392
Greater than 75%	4,260		2,749		2,939		2,345		213		4,606		—		—		17,112
Multifamily
55% and below	123,726		387,468		341,633		223,446		95,645		290,333		599		—		1,462,850
>55-65%	164,019		734,321		386,341		266,322		167,271		283,527		432		—		2,002,233
>65-75%	234,636		609,946		270,888		269,910		211,919		122,199		—		—		1,719,498
Greater than 75%	—		22,034		11,185		1,898		—		5,859		—		—		40,976
Construction and land
55% and below	13,838		136,216		107,812		30,148		—		8,468		461		—		296,943
>55-65%	—		4,632		42,778		8,223		—		—		—		—		55,633
>65-75%	—		—		3,697		—		—		—		—		—		3,697
Greater than 75%	—		—		1,153		—		—		—		—		—		1,153
SBA secured by real estate
55% and below	—		1,148		655		841		332		436		—		—		3,412
>55-65%	—		3,187		1,647		3,860		623		4,791		—		—		14,108
>65-75%	495		3,724		7,802		5,364		4,358		2,829		—		—		24,572
Greater than 75%	—		2,645		3,117		6,116		2,216		3,296		—		—		17,390
Total investor loans secured by real estate	$	692,143	$	2,473,310	$	1,661,597	$	1,175,829	$	802,350	$	1,607,953	$	12,975	$	—	$	8,426,157
Business loan secured by real estate
CRE owner-occupied
55% and below	$	55,579	$	153,995	$	171,876	$	196,583	$	150,233	$	377,115	$	5,125	—		$	1,110,506
>55-65%	63,067		100,226		89,960		64,803		73,724		81,403		—		—		473,183
>65-75%	56,327		175,639		63,734		54,957		39,714		58,581		—		—		448,952
Greater than 75%	43,052		21,798		27,345		14,164		4,183		26,971		—		—		137,513
Franchise real estate secured
55% and below	7,461		18,360		14,615		16,057		11,567		20,926		—		—		88,986
>55-65%	928		8,900		13,096		29,110		7,823		5,919		—		—		65,776
>65-75%	2,911		49,851		25,927		9,859		11,062		14,848		—		—		114,458
Greater than 75%	9,106		11,697		22,554		48,822		1,126		2,122		—		—		95,427
SBA secured by real estate
55% and below	736		1,735		6,537		4,784		2,348		10,568		365		—		27,073
>55-65%	104		514		2,337		2,643		2,252		4,121		—		—		11,971
>65-75%	264		2,687		754		4,602		3,167		5,871		—		—		17,345
Greater than 75%	801		2,757		4,531		7,195		3,234		10,635		—		—		29,153

Total business loans secured by real estate	$	240,336	$	548,159	$	443,266	$	453,579	$	310,433	$	619,080	$	5,490	$	—	$	2,620,343


	Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
June 30, 2020	(Dollars in thousands)
Retail Loans
Single family residential
Greater than 740	$	4,863	$	8,236	$	13,274	$	9,719	$	31,203	$	96,475	$	27,050	—		$	190,820
>680 - 740	—		1,190		2,268		4,794		2,660		18,190		9,095		—		38,197
>580 - 680	—		—		—		466		3,178		9,030		959		—		13,633
Less than 580	—		—		11		12		1,333		21,128		36		—		22,520
Consumer loans
Greater than 740	72		95		863		51		20		2,661		1,993		—		5,755
>680 - 740	—		59		7		37,988		—		488		1,737		—		40,279
>580 - 680	—		20		—		—		3		150		51		—		224
Less than 580	—		—		—		—		—		20		31		—		51
Total retail loans	$	4,935	$	9,600	$	16,423	$	53,030	$	38,397	$	148,142	$	40,952	$	—	$	311,479