our subsidiary banks may make to directors and other insiders, and specified approval procedures must be followed
in making loans that exceed certain amounts.  In addition, all loans our subsidiary banks make to directors and other
insiders must satisfy the following requirements:
•  The loans must be made on substantially the same terms, including interest rates and collateral, as
prevailing at the time for comparable transactions with persons not affiliated with us or the subsidiary
banks;
• The subsidiary banks must follow credit underwriting procedures at least as stringent as those applicable to
comparable transactions with persons who are not affiliated with us or the subsidiary banks; and
• The loans must not involve a greater than normal risk of repayment or other unfavorable features.