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Loans
6 Months Ended
Jun. 30, 2024
Receivables [Abstract]  
Loans LOANS (In Thousands)
Loan Categories and Past Due Loans

The following two tables present loan balances outstanding as of June 30, 2024, December 31, 2023 and June 30, 2023 and an analysis of the recorded investment in loans that are past due at these dates. Generally, Arrow considers a loan past due 30 or more days when the borrower is two payments past due. Loans held-for-sale of $998, $165 and $312 as of June 30, 2024, December 31, 2023 and June 30, 2023, respectively, are included in the residential real estate balances for current loans.

Schedule of Past Due Loans by Loan Category
Commercial
CommercialReal EstateConsumerResidentialTotal
June 30, 2024
Loans Past Due 30-59 Days$466 $300 $11,735 $2,338 $14,839 
Loans Past Due 60-89 Days45 489 4,295 1,408 6,237 
Loans Past Due 90 or more Days79 15,148 1,207 3,359 19,793 
Total Loans Past Due590 15,937 17,237 7,105 40,869 
Current Loans163,242 741,541 1,121,576 1,248,295 3,274,654 
Total Loans$163,832 $757,478 $1,138,813 $1,255,400 $3,315,523 
December 31, 2023
Loans Past Due 30-59 Days$298 $— $13,511 $3,715 $17,524 
Loans Past Due 60-89 Days21 636 5,579 861 7,097 
Loans Past Due 90 or more Days30 15,308 1,801 3,140 20,279 
Total Loans Past Due349 15,944 20,891 7,716 44,900 
Current Loans155,875 729,543 1,090,776 1,191,814 3,168,008 
Total Loans$156,224 $745,487 $1,111,667 $1,199,530 $3,212,908 
June 30, 2023
Loans Past Due 30-59 Days$192 $— $10,275 $494 $10,961 
Loans Past Due 60-89 Days287 — 5,302 2,326 7,915 
Loans Past Due 90 or more Days59 — 1,776 2,828 4,663 
Total Loans Past Due538 — 17,353 5,648 23,539 
Current Loans146,980 723,948 1,070,412 1,105,018 3,046,358 
Total Loans$147,518 $723,948 $1,087,765 $1,110,666 $3,069,897 

Schedule of Non Accrual Loans by Category
Commercial
June 30, 2024CommercialReal EstateConsumerResidentialTotal
Loans 90 or More Days Past Due
  and Still Accruing Interest
$— $— $31 $884 $915 
Nonaccrual Loans79 15,148 1,260 3,631 20,118 
Nonaccrual With No Allowance for Credit Loss79 15,148 1,260 3,631 20,118 
Interest Income on Nonaccrual Loans— — — — — 
December 31, 2023
Loans 90 or More Days Past Due
  and Still Accruing Interest
$— $— $$446 $452 
Nonaccrual Loans30 15,308 1,877 3,430 20,645 
June 30, 2023
Loans 90 or More Days Past Due
  and Still Accruing Interest
$— $— $— $467 $467 
Nonaccrual Loans89 — 1,897 4,011 5,997 
Arrow disaggregates its loan portfolio into the following four categories:

Commercial - Arrow offers a variety of loan options to meet the specific needs of our commercial customers including term loans, time notes and lines of credit. Such loans are made available to businesses for working capital needs such as inventory and receivables, business expansion and equipment purchases. Generally, a collateral lien is placed on equipment or other assets owned by the borrower. Generally, these loans carry a higher risk than commercial real estate loans due to the nature of the underlying collateral, which can be business assets such as equipment and accounts receivable and generally have a lower liquidation value than real estate. In the event of default by the borrower, Arrow may be required to liquidate collateral at deeply discounted values. To reduce the risk, management usually obtains personal guarantees to support the borrowing, as permitted by applicable law.

Commercial Real Estate - Arrow offers commercial real estate loans to finance real estate purchases, refinancings, expansions and improvements to commercial properties. Commercial real estate loans are made to finance the purchases of real property which generally consists of real estate with completed structures. These commercial real estate loans are typically secured by first liens on the real estate, which may include apartments, commercial structures, housing businesses, healthcare facilities, and both owner- and non-owner-occupied facilities. These loans are typically less risky than commercial loans, since they are secured by real estate and buildings, and are generally originated in amounts of no more than 80% of the appraised value of the property. However, Arrow also offers commercial construction and land development loans to finance projects. Many projects will ultimately be used by the borrowers' businesses, while others are developed for resale. These real estate loans are also typically secured by first liens on the real estate, which may include apartments, commercial structures, housing businesses, healthcare facilities and both owner-occupied and non-owner-occupied facilities. There is enhanced risk during the construction period, since the loan is secured by an incomplete project. Arrow’s Commercial Real Estate loans are primarily located within the footprint of the Company’s branch network, with some loans extending into the greater upstate New York area. Arrow does not provide Commercial Real Estate loans in major metropolitan areas such as New York City, Boston, etc.

Consumer Loans - This category is primarily comprised of automobile loans. Arrow primarily finances the purchases of automobiles indirectly through dealer relationships located throughout upstate New York and Vermont. Most automobile loans carry a fixed rate of interest with principal repayment terms typically ranging from three to seven years. Automobile loans are underwritten on a secured basis using the underlying collateral being financed. Arrow also offers a variety of consumer installment loans to finance personal expenditures. Most of these loans carry a fixed rate of interest with principal repayment terms typically ranging from one to five years, based upon the nature of the collateral and the size of the loan. In addition to installment loans, Arrow also offers personal lines of credit and overdraft protection. Several of these consumer loans are unsecured, which carry a higher risk of loss.

Residential - Residential real estate loans consist primarily of loans secured by first or second mortgages on primary residences. Arrow originates fixed-rate and adjustable-rate one-to-four-family residential real estate loans for the construction, purchase of real estate or refinancing of an existing mortgage. These loans are collateralized primarily by owner-occupied properties generally located in Arrow's market area. Loans on one-to-four-family residential real estate are generally originated in amounts of no more than 80% of the purchase price or appraised value (whichever is lower), or have private mortgage insurance. Arrow’s underwriting analysis for residential mortgage loans typically includes credit verification, independent appraisals, and a review of the borrower’s financial condition. Mortgage title insurance and hazard insurance are normally required. It is Arrow's general practice to underwrite residential real estate loans to secondary market standards. Construction loans have a unique risk, because they are secured by an incomplete dwelling. This risk is reduced through periodic site inspections, including one at each loan draw period. In addition, Arrow offers fixed home equity loans, as well as home equity lines of credit to consumers to finance home improvements, debt consolidation, education and other uses.  Arrow's policy allows for a maximum loan to value ratio of 80%, although periodically higher advances are allowed.  Arrow originates home equity lines of credit and second mortgage loans (loans secured by a second junior lien position on one-to-four-family residential real estate).  Risk is generally reduced through underwriting criteria, which include credit verification, appraisals, a review of the borrower's financial condition, and personal cash flows.  A security interest, with title insurance when necessary, is taken in the underlying real estate.

Allowance for Credit Losses

Loan segments were selected by class code and application code to ensure each segment is comprised of loans with homogenous loan characteristics and similar risk profiles. The resulting loan segments are commercial, commercial real estate, consumer and residential real estate loans. The consumer segment is mainly comprised of automobile loans, and since they are relatively short-term in nature, with similar dollar amounts and collateral, the vintage analysis method was selected to determine the credit loss reserve. The vintage method utilizes Arrow loan data exclusively as the method calculates a loss rate based on the total origination balance of the loans by year and the charge-off and recovery rate of the same origination year. Arrow maintains, over the life of the loan, the loss curve by vintage year. The discounted cash flow method (DCF) is used to calculate the reserve for credit losses for the commercial, commercial real estate and residential real estate segments.
The June 30, 2024 allowance for credit losses calculation incorporated a reasonable and supportable forecast period to account for economic conditions utilized in the measurement. The quantitative model utilized a six-quarter economic forecast sourced from reputable third-parties that reflects no change in the forecasted national unemployment rate, forecasted gross domestic product projected to improve by approximately 0.17%, and the home price index (HPI) forecast to increase by approximately 2.62% from the previous quarter economic forecast. The overall change in the allowance from March 31, 2024 was primarily driven by the following factors: net loan growth contributed $0.5 million, changes in macro economic conditions reduced the allowance by $0.8 million, qualitative factors increased the allowance by $0.4 million, and net charge-offs of $0.6 million. The second quarter provision for credit losses was $775 thousand. In addition, Arrow recorded a credit for estimated credit losses on off-balance sheet credit exposures in
other liabilities of $153 thousand in the second quarter of 2024. Management's evaluation considers the allowance for credit losses for loans to be appropriate as of June 30, 2024.

The following table details activity in the allowance for credit losses on loans for the three and six months ended June 30, 2024 and June 30, 2023:

Allowance for Credit Losses
CommercialCommercial Real EstateConsumerResidentialTotal
March 31, 2024$2,842 $14,168 $2,756 $11,795 $31,561 
Charge-offs$— $— $(1,850)$— $(1,850)
Recoveries$— $— $523 $— $523 
Provision$(811)$(57)$1,556 $87 $775 
June 30, 2024$2,031 $14,111 $2,985 $11,882 $31,009 
December 31, 2023$1,958 $15,521 $2,566 $11,220 $31,265 
Charge-offs$(9)$— $(3,124)$— $(3,133)
Recoveries$— $— $1,485 $— $1,485 
Provision$82 $(1,410)$2,058 $662 $1,392 
June 30, 2024$2,031 $14,111 $2,985 $11,882 $31,009 
March 31, 2023$1,737 $15,502 $2,863 $10,682 $30,784 
Charge-offs$— $— $(1,274)$(6)$(1,280)
Recoveries$— $— $718 $— $718 
Provision$235 $195 $339 $179 $948 
June 30, 2023$1,972 $15,697 $2,646 $10,855 $31,170 
December 31, 2022$1,961 $15,213 $2,585 $10,193 $29,952 
Charge-offs$— $— $(2,602)$(6)$(2,608)
Recoveries$— $— $1,324 $— $1,324 
Provision$11 $484 $1,339 $668 $2,502 
June 30, 2023$1,972 $15,697 $2,646 $10,855 $31,170 


Estimated Credit Losses on Off-Balance Sheet Credit Exposures Recognized as Other Liabilities

Financial instrument credit losses apply to off-balance sheet credit exposures such as unfunded loan commitments and standby letters of credit. A liability for expected credit losses for off-balance sheet exposures is recognized if the entity has a present contractual obligation to extend the credit and the obligation is not unconditionally cancellable by the entity. Changes in this allowance are reflected in other operating expenses within the non-interest expense category. As of June 30, 2024, the total unfunded commitment off-balance sheet credit exposure was $986 thousand.

Individually Evaluated Loans

All loans that exceed $250,000, which are on nonaccrual status, are evaluated on an individual basis. Arrow has a policy applicable to collateral dependent financial assets when the borrower is experiencing financial difficulty and the repayment is expected through the sale of the collateral. This policy allows Arrow to use fair value of the collateral at the reporting date adjusted for estimated cost to sell when recording the net carrying amount of the asset and determining the allowance for credit losses for a financial asset. In the event where the repayment of a collateral dependent financial asset is expected to be provided substantially through the operation of the collateral, Arrow will use fair value of the collateral at the reporting date when recording the net carrying amount of the asset and determining the allowance for credit losses. As of June 30, 2024, there were five total relationships identified to be evaluated for loss on an individual basis which had an amortized cost basis of $17.1 million and none had an allowance for credit loss.
The following tables present the amortized cost basis of collateral-dependent loans by class of loans as of June 30, 2024, December 31, 2023 and June 30, 2023:
June 30, 2024Collateral Type -Residential Real EstateCollateral Type - Commercial Real EstateTotal Loans
Commercial$— $— $— 
Commercial Real Estate— 15,179 15,179 
Consumer— — — 
Residential1,886 — 1,886 
Total$1,886 $15,179 $17,065 

December 31, 2023Collateral Type -Residential Real EstateCollateral Type - Commercial Real EstateTotal Loans
Commercial$— $— $— 
Commercial Real Estate— 15,308 15,308 
Consumer— — — 
Residential1,446 — 1,446 
Total$1,446 $15,308 $16,754 

June 30, 2023Collateral Type -Residential Real EstateCollateral Type - Commercial Real EstateTotal Loans
Commercial$— $— $— 
Commercial Real Estate— — — 
Consumer— — — 
Residential1,963 — 1,963 
Total$1,963 $— $1,963 



Allowance for Credit Losses - Collectively and Individually Evaluated
CommercialCommercial Real EstateConsumerResidentialTotal
June 30, 2024
Ending Loan Balance - Collectively Evaluated$163,832 $742,330 $1,138,813 $1,253,512 $3,298,487 
Allowance for Credit Losses - Loans Collectively Evaluated2,031 14,111 2,985 11,882 31,009 
Ending Loan Balance - Individually Evaluated— 15,148 — 1,888 17,036 
Allowance for Credit Losses - Loans Individually Evaluated— — — — — 
December 31, 2023
Ending Loan Balance - Collectively Evaluated$156,224 $730,179 $1,111,667 $1,198,084 $3,196,154 
Allowance for Credit Losses - Loans Collectively Evaluated1,958 15,521 2,566 11,220 31,265 
Ending Loan Balance - Individually Evaluated— 15,308 — 1,446 16,754 
Allowance for Credit Losses - Loans Individually Evaluated— — — — — 
June 30, 2023
Ending Loan Balance - Collectively Evaluated$147,518 $723,948 $1,087,765 $1,108,703 $3,067,934 
Allowance for Credit Losses - Loans Collectively Evaluated1,972 15,697 2,646 10,855 31,170 
Ending Loan Balance - Individually Evaluated— — — 1,963 1,963 
Allowance for Credit Losses - Loans Individually Evaluated— — — — — 

Through the provision for credit losses, an allowance for credit losses is maintained that reflects the best estimate of the calculated expected credit losses in Arrow's loan portfolio as of the balance sheet date. Additions are made to the allowance for credit losses through a periodic provision for credit losses. Actual credit losses are charged against the allowance for credit losses when loans are deemed uncollectible and recoveries of amounts previously charged off are recorded as credits to the allowance for credit losses.
Arrow's loan officers and risk managers meet at least quarterly to discuss and review the conditions and risks associated with certain criticized and classified commercial-related relationships. In addition, the independent internal loan review department performs periodic reviews of the credit quality indicators on individual loans in the commercial loan portfolio.
Arrow considers the need to qualitatively adjust expected credit loss estimates for information not already captured in the loss estimation process. These qualitative factor adjustments may increase or decrease management’s estimate of expected credit losses. Adjustments are not made for information that has already been considered and included in the loss estimation process.
Arrow considers the qualitative factors that are relevant as of the reporting date, which may include, but are not limited to the following factors:
The nature and volume of Arrow's financial assets;
The existence, growth, and effect of any concentrations of credit;
The volume and severity of past due loans, the volume of nonaccrual loans, and the volume and severity of adversely classified or graded loans;
The value of the underlying collateral for loans that are not collateral-dependent;
Arrow's lending policies and procedures, including changes in underwriting standards and practices for collections, write-offs, and recoveries;
The quality of Arrow's loan review function;
The experience, ability, and depth of Arrow's lending, investment, collection, and other relevant management/staff;
The effect of other external factors such as the regulatory, legal and technological environments; competition; and events such as natural disasters;
Actual and expected changes in international, national, regional, and local economic and business conditions and developments in which the institution operates that affect the collectability of financial assets; and
Other qualitative factors not reflected in quantitative loss rate calculations.


Loan Credit Quality Indicators and Modification
In 2023 and the first half of 2024, no loans met the criteria for disclosure as part of ASU 2022-02. Any modifications of loans were either immaterial in natural or were made for competitive purposes, i.e., the borrowers were not experiencing financial hardship.
The following tables present credit quality indicators by total loans amortized cost basis by origination year as of June 30, 2024, December 31, 2023 and June 30, 2023:
Term Loans Amortized Cost Basis by Origination YearRevolving Loans Amortized Cost BasisRevolving Loan Converted to TermTotal
June 30, 202420242023202220212020Prior
Commercial:
Risk rating
Satisfactory$19,007 $46,303 $29,211 $20,914 $7,857 $21,277 $13,079 $— $157,648 
Special mention— — — — 95 — — — 95 
Substandard— — — — — 3,096 2,993 — 6,089 
Doubtful— — — — — — — — — 
Total Commercial Loans$19,007 $46,303 $29,211 $20,914 $7,952 $24,373 $16,072 $— $163,832 
Current-period gross charge-offs$— $— $— $— $$— $— $— $
Commercial Real Estate:
Risk rating
Satisfactory$35,839 $89,553 $130,911 $110,649 $118,694 $201,890 $3,093 $— $690,629 
Special mention— — 10,892 — — 8,005 — — 18,897 
Substandard— 148 9,082 2,011 2,272 34,317 122 — 47,952 
Doubtful— — — — — — — — — 
Total Commercial Real Estate Loans$35,839 $89,701 $150,885 $112,660 $120,966 $244,212 $3,215 $— $757,478 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Consumer:
Risk rating
Performing$221,472 $353,205 $299,384 $157,987 $69,260 $35,735 $479 $— $1,137,522 
Nonperforming22 197 353 449 173 97 — — 1,291 
Total Consumer Loans$221,494 $353,402 $299,737 $158,436 $69,433 $35,832 $479 $— $1,138,813 
Current-period gross charge-offs$834 $441 $888 $597 $214 $150 $— $— $3,124 
Residential:
Risk rating
Performing$64,802 $177,575 $233,558 $188,007 $111,407 $354,568 $120,968 $— $1,250,885 
Nonperforming— 201 442 631 441 2,454 346 — 4,515 
Total Residential Loans$64,802 $177,776 $234,000 $188,638 $111,848 $357,022 $121,314 $— $1,255,400 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Total Loans$341,142 $667,182 $713,833 $480,648 $310,199 $661,439 $141,080 $— $3,315,523 
Term Loans Amortized Cost Basis by Origination YearRevolving Loans Amortized Cost BasisRevolving Loan Converted to TermTotal
December 31, 202320232022202120202019Prior
Commercial:
Risk rating
Satisfactory$54,584 $34,047 $23,470 $9,655 $4,107 $13,360 $8,586 $— $147,809 
Special mention— — — 117 — — — — 117 
Substandard— — — — — 3,199 5,099 — 8,298 
Doubtful— — — — — — — — — 
Total Commercial Loans$54,584 $34,047 $23,470 $9,772 $4,107 $16,559 $13,685 $— $156,224 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Commercial Real Estate:
Risk rating
Satisfactory$81,582 $151,818 $105,365 $120,845 $41,406 $174,516 $1,667 $— $677,199 
Special mention— 10,439 — — — 4,084 — — 14,523 
Substandard150 9,169 1,670 2,533 791 38,955 497 — 53,765 
Doubtful— — — — — — — — — 
Total Commercial Real Estate Loans$81,732 $171,426 $107,035 $123,378 $42,197 $217,555 $2,164 $— $745,487 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Consumer:
Risk rating
Performing$405,099 $355,217 $195,799 $93,708 $44,206 $15,252 $— $— $1,109,281 
Nonperforming208 783 551 210 81 85 468 — 2,386 
Total Consumer Loans$405,307 $356,000 $196,350 $93,918 $44,287 $15,337 $468 $— $1,111,667 
Current-period gross charge-offs$366 $1,368 $2,122 $604 $397 $266 $— $— $5,123 
Residential:
Risk rating
Performing$161,878 $231,365 $192,588 $116,451 $73,875 $296,935 $122,573 $— $1,195,665 
Nonperforming— — 444 666 127 2,268 360 — 3,865 
Total Residential Loans$161,878 $231,365 $193,032 $117,117 $74,002 $299,203 $122,933 $— $1,199,530 
Current-period gross charge-offs$— $— $— $21 $— $33 $— $— $54 
Total Loans$703,501 $792,838 $519,887 $344,185 $164,593 $548,654 $139,250 $— $3,212,908 
Term Loans Amortized Cost Basis by Origination YearRevolving Loans Amortized Cost BasisRevolving Loan Converted to TermTotal
June 30, 202320232022202120202019Prior
Commercial:
Risk rating
Satisfactory$15,063 $38,012 $25,715 $11,653 $5,763 $35,571 $9,487 $— $141,264 
Special mention— — — 139 — — — — 139 
Substandard— — — — 60 3,290 2,765 — 6,115 
Doubtful— — — — — — — — — 
Total Commercial Loans$15,063 $38,012 $25,715 $11,792 $5,823 $38,861 $12,252 $— $147,518 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Commercial Real Estate:
Risk rating
Satisfactory$32,681 $162,581 $105,800 $123,336 $42,397 $191,641 $2,971 $— $661,407 
Special mention— — — — — 4,987 — — 4,987 
Substandard— 9,427 1,685 2,394 802 43,221 25 — 57,554 
Doubtful— — — — — — — — — 
Total Commercial Real Estate Loans$32,681 $172,008 $107,485 $125,730 $43,199 $239,849 $2,996 $— $723,948 
Current-period gross charge-offs$— $— $— $— $— $— $— $— $— 
Consumer:
Risk rating
Performing$217,691 $414,437 $238,016 $122,156 $64,295 $28,740 $— $— $1,085,335 
Nonperforming30 666 766 229 146 120 473 — 2,430 
Total Consumer Loans$217,721 $415,103 $238,782 $122,385 $64,441 $28,860 $473 $— $1,087,765 
Current-period gross charge-offs$95 $705 $1,034 $324 $246 $198 $— $— $2,602 
Residential:
Risk rating
Performing$62,554 $231,714 $195,831 $120,506 $78,455 $316,683 $99,788 $— $1,105,531 
Nonperforming— 115 417 939 949 2,289 426 — 5,135 
Total Residential Loans$62,554 $231,829 $196,248 $121,445 $79,404 $318,972 $100,214 $— $1,110,666 
Current-period gross charge-offs$— $— $— $— $— $$— $— $
Total Loans$328,019 $856,952 $568,230 $381,352 $192,867 $626,542 $115,935 $— $3,069,897 

For the purposes of the table above, nonperforming consumer and residential loans were those loans on nonaccrual status or were 90 days or more past due and still accruing interest.
As of June 30, 2024, the amortized cost of consumer mortgage loans secured by residential real estate properties for which formal foreclosure proceedings are in process is $2.4 million.
For the allowance calculation, an internally developed system of five credit quality indicators is used to rate the credit worthiness of each commercial loan defined as follows:
1) Satisfactory - "Satisfactory" borrowers have acceptable financial condition with satisfactory record of earnings and sufficient historical and projected cash flow to service the debt.  Borrowers have satisfactory repayment histories and primary and secondary sources of repayment can be clearly identified;
2) Special Mention - Loans in this category have potential weaknesses that deserve management’s close attention.  If left uncorrected, these potential weaknesses may result in deterioration of the repayment prospects for the asset or in the institution’s credit position at some future date.  "Special mention" assets are not adversely classified and do not expose an institution to sufficient risk to
warrant adverse classification.  Loans which might be assigned this credit quality indicator include loans to borrowers with deteriorating financial strength and/or earnings record and loans with potential for problems due to weakening economic or market conditions;
3) Substandard - Loans classified as “substandard” are inadequately protected by the current sound net worth or paying capacity of the borrower or the collateral pledged, if any.  Loans in this category have well defined weaknesses that jeopardize the repayment. They are characterized by the distinct possibility that Arrow will sustain some loss if the deficiencies are not corrected. “Substandard” loans may include loans which are likely to require liquidation of collateral to effect repayment, and other loans where character or ability to repay has become suspect. Loss potential, while existing in the aggregate amount of substandard assets, does not have to exist in individual assets classified substandard;
4) Doubtful - Loans classified as “doubtful” have all of the weaknesses inherent in those classified as “substandard” with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of current existing facts, conditions, and values, highly questionable and improbable.  Although possibility of loss is extremely high, classification of these loans as “loss” has been deferred due to specific pending factors or events which may strengthen the value (e.g. possibility of additional collateral, injection of capital, collateral liquidation, debt restructure, economic recovery, etc).  Loans classified as “doubtful” need to be placed on non-accrual; and
5) Loss - Loans classified as “loss” are considered uncollectible with collateral of such little value that their continuance as bankable assets is not warranted.  As of the date of the balance sheet, all loans in this category have been charged-off to the allowance for loan losses.  
Commercial loans are generally evaluated on an annual basis depending on the size and complexity of the loan relationship, unless the credit related quality indicator falls to a level of "special mention" or below, when the loan is evaluated quarterly.  The credit quality indicator is one of the factors used in assessing the level of incurred risk of loss in our commercial related loan portfolios.