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Commitments and Contingent Liabilities
9 Months Ended
Sep. 30, 2023
Commitments and Contingent Liabilities  
Commitments and Contingent Liabilities

Note 14 — Commitments and Contingent Liabilities

In the normal course of business, we make various commitments and incur certain contingent liabilities, which are not reflected in the accompanying financial statements. The commitments and contingent liabilities include guarantees, commitments to extend credit, and standby letters of credit. At September 30, 2023, commitments to extend credit and standby letters of credit totaled $10.6 billion. As of September 30, 2023, the liability recorded for expected credit losses on unfunded commitments, excluding unconditionally cancellable exposures and letters of credit, was $62.3 million and recorded on the Balance Sheet. See Note 2 — Summary of Significant Accounting Policies for discussion of liability recorded for expected credit losses on unfunded commitments.

We have been named as defendant in various legal actions, arising from its normal business activities, in which damages in various amounts are claimed. We are also exposed to litigation risk related to the prior business activities of banks acquired through whole bank acquisitions. Although the amount of any ultimate liability with respect to such matters cannot be determined, in the opinion of management, as of September 30, 2023, any such liability is not expected to have a material effect on our consolidated financial statements.

In May 2023, the Federal Deposit Insurance Corporation (“FDIC”) approved a notice of proposed rulemaking to implement a special assessment, in connection with the systemic risk determination announced in March 2023, to recover the cost associated with protecting uninsured depositors following the recent bank failures. The FDIC is proposing to collect the special assessment at the base annual rate of approximately 12.5 basis points of the Company’s uninsured deposits reported as of December 31, 2022, adjusted to exclude the first $5 billion, over eight quarterly assessment periods, beginning after the first quarter 2024. We expect the FDIC will enact a special deposit insurance assessment in the second half of 2023 that will significantly increase our FDIC deposit insurance costs. The total cost and timing is subject to change prior to any final rule depending on any adjustments to the loss estimate, mergers or failures, or amendments to reported estimates of uninsured deposits.