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Community Reinvestment Act of 1977
The Community Reinvestment Act of 1977, or CRA subjects a bank to regulatory assessment to determine if
the institution meets the credit needs of its entire community, including low- and moderate-income neighborhoods
served by the bank, and to take that determination into account in its evaluation of any application made by such
bank for, among other things, approval of the acquisition or establishment of a branch or other deposit facility, an
office relocation, a merger, or the acquisition of shares of capital stock of another financial institution. The
regulatory authority prepares a written evaluation of an institution’s record of meeting the credit needs of its entire
community and assigns a rating. We believe our subsidiary banks have taken significant actions to comply with the
CRA, and each has received at least a “satisfactory” commendation in its most recent review by federal regulators
with respect to its compliance with the CRA.
Monitoring and Reporting Suspicious Activity
Under the Bank Secrecy Act, IRS rules and other regulations, we are required to monitor and report unusual or
suspicious account activity as well as transactions involving the transfer or withdrawal of amounts in excess of
prescribed limits.  In the wake of the tragic events of September 11th, on October 26, 2001, the President signed the
Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism,
or USA PATRIOT Act, of 2001. Under the USA PATRIOT Act, financial institutions are subject to prohibitions
against specified financial transactions and account relationships as well as enhanced due diligence and “know your
customer” standards in their dealings with foreign financial institutions and foreign customers. For example, the
enhanced due diligence policies, procedures, and controls generally require financial institutions to take reasonable
steps to:
• to conduct enhanced scrutiny of account relationships to guard against money laundering and report any
suspicious transaction;
• to ascertain the identity of the nominal and beneficial owners of, and the source of funds deposited into,
each account as needed to guard against money laundering and report any suspicious transactions;
• to ascertain for any foreign bank, the shares of which are not publicly traded, the identity of the owners of
the foreign bank, and the nature and extent of the ownership interest of each such owner; and
• to ascertain whether any foreign bank provides correspondent accounts to other foreign banks and, if so, the
identity of those foreign banks and related due diligence information.
Under the USA PATRIOT Act, financial institutions are also required to establish anti-money laundering
programs. The USA PATRIOT Act sets forth minimum standards for these programs, including:
• the development of internal policies, procedures, and controls;
• the designation of a compliance officer;
• an ongoing employee training program; and
• an independent audit function to test the programs.
In addition, the USA PATRIOT Act also requires the Secretary of the Treasury to adopt rules addressing a
number of related issues, including increasing the cooperation and information sharing between financial
institutions, regulators, and law enforcement authorities regarding individuals, entities and organizations engaged in,
or reasonably suspected based on credible evidence of engaging in, terrorist acts or money laundering activities. Any
financial institution complying with these rules will not be deemed to violate the privacy provisions of the Gramm-
Leach-Bliley Act that are discussed below.  Finally, under the regulations of the Office of Foreign Asset Control, we
are required to monitor and block transactions with certain “specially designated nationals” who OFAC has
determined pose a risk to U.S. national security.