First Citizens 2019 CRA Performance Evaluation

ATL 8/27/2019
PUBLIC DISCLOSURE
March 26, 2019
COMMUNITY REINVESTMENT ACT

PERFORMANCE EVALUATION
First -Citizens Bank & Trust Company

Certificate Number: 11063
239 Fayetteville Street

Raleigh, North Carolina 27601
Federal Deposit Insurance Corporation

Division of Depositor and Consumer Protection
Atlanta Regional Office
10 Tenth Street, Northeast, Suite 800

Atlanta, Georgia 30309
This document is an evaluation of this institution's record of meeting the credit needs of its entire
community, including low- and moderate -income neighborhoods, consistent with safe and sound
operation of the institution. This evaluation is not, nor should it be construed as, an assessment
of the financial condition of this institution. The rating assigned to this institution does not
represent an analysis, conclusion, or opinion of the federal financial supervisory agency
concerning the safety and soundness of this financial institution.
TABLE OF CONTENTS
Institution Rating
Overall Rating 1
Performance Test Ratings Table 1
Summary of Major Factors Supporting Rating 1
Institution
Scope of Evaluation 3
Description of Institution 6
Description of Assessment Area 8
Conclusions on Performance Criteria 9
Discriminatory or Other Illegal Credit Practices Review 20
North Carolina
Summary
State Rating 21
Description of Institution's Operations 21
North Carolina Non -Metropolitan State-wide Area (Full -Scope)

Raleigh, NC Metropolitan Area (Full -Scope)

Asheville, NC Metropolitan Area (Full -Scope)

Other North Carolina Assessment Areas (Limited -Scope)

Wilmington, NC Metropolitan Area (Limited -Scope)

Greensboro -High Point, NC Metropolitan Area (Limited -Scope)

Hickory -Lenoir -Morganton, NC Metropolitan Area (Limited -Scope)

Durham -Chapel Hill, NC Metropolitan Area (Limited -Scope)

Fayetteville, NC Metropolitan Area (Limited -Scope)

Goldsboro, NC Metropolitan Area (Limited -Scope)

Greenville, NC Metropolitan Area (Limited -Scope)

Jacksonville, NC Metropolitan Area (Limited -Scope)

New Bern, NC Metropolitan Area (Limited -Scope)

Rocky Mount, NC Metropolitan Area (Limited -Scope)

Virginia Beach -Norfolk -Newport News, VA -NC Metropolitan Area (Limited -Scope)
Winston-Salem, NC Metropolitan Area (Limited -Scope)

South Carolina
Summary
State Rating 64
Columbia, SC Metropolitan Area (Full -Scope)
Charleston -North Charleston, SC Metropolitan Area (Full -Scope)

Greenville -Anderson -Mauldin, SC Metropolitan Area (Full -Scope)

South Carolina Non -Metropolitan State-wide Area (Full -Scope)

Other South Carolina Assessment Areas (Limited -Scope)

Spartanburg, SC Metropolitan Area (Limited -Scope)

Florence, SC Metropolitan Area (Limited -Scope)

Hilton Head Island -Bluffton -Beaufort, SC Metropolitan Area (Limited -Scope)

Sumter, SC Metropolitan Area (Limited -Scope)

Virginia
Summary
State Rating 96
Roanoke, VA Metropolitan Area (Full -Scope)

Virginia Non -Metropolitan State-wide Area (Full -Scope)
Other Virginia Assessment Areas (Limited -Scope)

Lynchburg, VA Metropolitan Area (Limited -Scope)

Richmond, VA Metropolitan Area (Limited -Scope)

Blacksburg-Christiansburg-Radford, VA Metropolitan Area (Limited -Scope)

Charlottesville, VA Metropolitan Area (Limited -Scope)

Harrisonburg, VA Metropolitan Area (Limited -Scope)

Staunton -Waynesboro, VA Metropolitan Area (Limited -Scope)

Washington -Arlington -Alexandria, DC -VA -MD -WV Metropolitan Area (Limited -Scope)
Winchester, VA Metropolitan Area (Limited -Scope)

California
Summary
State Rating 125
San Diego -Carlsbad, CA Metropolitan Area (Full -Scope)
Los Angeles -Long Beach -Glendale, CA Metropolitan Division (Full -Scope)

Sacramento -Roseville -Arden -Arcade, CA Metropolitan Area (Full -Scope)

Other California Assessment Areas (Limited -Scope)

Anaheim -Santa Ana -Irvine Metropolitan Division (Limited -Scope)

Oakland -Haywood -Berkeley, CA Metropolitan Division (Limited -Scope)

Riverside -San Bernardino -Ontario, CA Metropolitan Area (Limited -Scope)

Georgia
Summary
State Rating 147
Atlanta -Sandy Spring -Roswell, GA Metropolitan Area (Full -Scope)

Other Georgia Assessment Areas (Limited -Scope)

Georgia Non -Metropolitan State-wide Area (Limited -Scope)

Athens -Clarke County, GA Metropolitan Area (Limited -Scope)
Savannah, GA Metropolitan Area (Limited -Scope)

Florida
Summary
State Rating 162
West Palm Beach -Boca Raton -Delray Beach, FL Metropolitan Division (Full -Scope)
Jacksonville, FL Metropolitan Area (Full -Scope)

Other Florida Assessment Areas (Limited -Scope)

Fort Lauderdale -Pompano Beach -Deerfield, FL Metropolitan Division (Limited -Scope)

Cape Coral -Fort Myers, FL Metropolitan Area (Limited -Scope)

Miami -Miami Beach -Kendall, FL Metropolitan Division (Limited -Scope)

Naples-Immokalee-Marco Island, FL Metropolitan Area (Limited -Scope)

Port St Lucie, FL Metropolitan Area (Limited -Scope)

North Port -Sarasota -Bradenton, FL Metropolitan Area (Limited -Scope)
Texas
Summary
State Rating 186
Austin -Round Rock, TX Metropolitan Area (Full -Scope)

Other Texas Assessment Areas (Limited -Scope)

Dallas -Plano -Irving, TX Metropolitan Division (Limited -Scope)

Houston -The Woodlands-Sugarland, TX Metropolitan Area (Limited -Scope)

Arizona
Summary
Arizona State Rating 197
Scope of Examination 197
Phoenix -Mesa -Scottsdale, AZ Metropolitan Area (Full -Scope)

Other Arizona Assessment Area (Limited -Scope)

Tucson, AZ Metropolitan Area (Limited -Scope)

Washington
Summary
State Rating 206
Seattle -Bellevue -Everett, WA Metropolitan Division (Full -Scope)

Other Washington Assessment Areas (Limited -Scope)

Tacoma -Lakewood, WA Metropolitan Division (Limited -Scope)

Olympia-Tumwater, WA Metropolitan Area (Limited -Scope)

Colorado
Summary
State Rating 218
Denver -Aurora -Lakewood, CO Metropolitan Area (Full -Scope)

Other Colorado Assessment Area (Limited -Scope)

Boulder, CO Metropolitan Area (Limited -Scope)

Tennessee
Summary
State Rating 227
Knoxville, TN Metropolitan Area (Full -Scope)
Chattanooga, TN -GA Metropolitan Area (Full -Scope)

Other Tennessee Assessment Areas (Limited -Scope)

Nashville -Davidson -Murfreesboro -Franklin, TN Metropolitan Area (Limited -Scope)

Johnson City, TN Metropolitan Area (Limited -Scope)

Maryland
Summary (Baltimore -Columbia -Townson, MD Metropolitan Area) (Full -Scope)
Maryland State Rating 243
New Mexico
Summary
State Rating 247
Albuquerque, NM Metropolitan Area (Full -Scope)

Other New Mexico Assessment Area (Limited -Scope)

Santa Fe, NM Metropolitan Area (Limited -Scope)

Oklahoma
Summary (Oklahoma City, OK Metropolitan Area) (Full -Scope)
Oklahoma State Rating 257
Oregon
Summary (Portland -Vancouver -Hillsboro, OR -WA Metropolitan Area) (Full -Scope)
Oregon State Rating 261
West Virginia
Summary (West Virginia Non -Metropolitan Area) (Full -Scope)
West Virginia State Rating 265
Wisconsin
Summary
Wisconsin State Rating 269
Milwaukee -Waukesha -West Allis, WI Metropolitan Area (Full -Scope)

Other Wisconsin Assessment Area (Limited -Scope)

Racine, WI Metropolitan Area (Limited -Scope)

Charlotte -Concord -Gastonia, NC -SC Multistate Metropolitan Area (Full -Scope)

Multistate Metropolitan Area Rating 279
Myrtle Beach -Conway -North Myrtle Beach, SC -NC Multistate Metropolitan Area (Full -Scope)
Augusta -Richmond County, GA -SC Multistate Metropolitan Area (Full -Scope)

Kansas City, KS -MO Multistate Metropolitan Area (Full -Scope)

Appendices
A
Assessment Area Breakdown of Loans, Deposits, and Branches 300
Description of Assessment Areas 305
Summary of State and Multistate Metropolitan Area Ratings 308

C
Glossary 309
Standard Core Tables 315

North Carolina 315
South Carolina 327
Virginia 339
California 351
Georgia 363
Florida 375
Texas 387
Arizona 399
Washington 411
Colorado 423
Tennessee 435
Maryland 447
New Mexico 459
Oklahoma. 471
Oregon 483
West Virginia 495
Wisconsin 507
Charlotte -Concord -Gastonia, NC -SC 519
Myrtle Beach -Conway -North Myrtle Beach, SC -NC 531
Augusta -Richmond County, GA -SC 543
Kansas City, KS -MO 555
INSTITUTION RATING
INSTITUTION'S CRA RATING: This institution is rated Satisfactory.
PERFORMANCE PERFORMANCE TESTS

LEVELS
Lending Test* Investment Test Service Test
Outstanding
High Satisfactory X X X
Low Satisfactory
Needs to Improve
Substantial
Noncompliance
* The Lending Test is weighted more heavily than the Investment and Service Tests when arriving at
an overall rating.
The Lending Test is rated High Satisfactory.
Lending levels reflect good responsiveness to assessment area credit needs.

A substantial majority of loans are originated in the institution's assessment areas.
The geographic distribution of loans reflects good penetration throughout the assessment
areas.
The distribution of loans reflects good penetration among retail customers of different
income levels and businesses and farms of different sizes.
The institution has made a relatively high level of community development loans.
The institution has used flexible lending practices to serve assessment area credit needs.
The Investment Test is rated High Satisfactory.
The bank has a significant level of qualified investments and donations.

The bank exhibits good responsiveness to credit and community economic development
needs through its investments and contributions.
The institution occasionally uses innovative and/or complex investments to support
community development initiatives.
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The Service Test is rated High Satisfactory.
Delivery systems are accessible to essentially all portions of the assessment area.
Changes to branches have not adversely affected accessibility to low- and moderate -
income geographies or individuals.
Services and business hours do not vary in a way that inconveniences low- or moderate -
income geographies or individuals.
The bank provided a relatively high level of community development services.
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SCOPE OF EVALUATION
General Information
This evaluation covers the period from the prior evaluation dated June 6, 2016, to the current
evaluation dated March 26, 2019. Examiners used the Interagency Large Institution
Examination Procedures to evaluate First -Citizens Bank & Trust Company's (First -Citizens
Bank) Community Reinvestment Act (CRA) performance. These procedures include three tests:
the lending, investment, and service tests.
The lending test considers an institution's performance with respect to its lending activity and
assessment area concentration; geographic distribution and borrower profile characteristics;
innovative and/or flexible lending practices; and community development lending. The
investment test considers the nature of an institution's qualified investments and donations. In
particular, the investment test considers the level, responsiveness, innovativeness, and
complexity of these activities. Lastly, the service test analyzes an institution's retail services in
relation to accessibility of delivery systems; branch locations, including the institution's record of
opening and closing branches, particularly branches located in low- or moderate -income
geographies, or primarily serving low- or moderate -income individuals; and reasonableness of
business hours and services. The service test also evaluates the level of community development
services.
First -Citizens Bank operates in 19 states as of the current evaluation date. During the evaluation
period, First -Citizens Bank operated in four additional states: Illinois, Minnesota, New Jersey,
and Pennsylvania. However, these four states are excluded from the scope of the current
evaluation, because the bank entered these markets through FDIC -assisted acquisitions, operated
in these markets for approximately a year or less, and ceased all banking activities as of
December 31, 2018. Examiners determined minimal lending and other banking activities in
these states during the evaluation period.
As noted in Appendix A, examiners excluded two assessment areas in Florida (Orlando and
Tampa MSAs) from the scope of the current evaluation, because the bank entered these markets
in the latter part of 2018; however, number of branches in these two MSAs is included in the
overall branch count and in the service test. Additionally, the bank now operates in Oregon and
Washington in the Portland -Vancouver -Hillsdale, OR -WA Multistate MSA. However, the bank
did not enter Washington until October 2018. Therefore, the multistate MSA is not rated
separately, and the Portland MSA assessment area is included in the analysis and rating for
Oregon. Furthermore, the bank's operations in some states were solely limited to the operations
in the multi -state metropolitan statistical areas (MSAs) that included those states; therefore, the
scope of this evaluation focused on the bank's operations in 21 rated areas: 17 states and 4 multi-
state MSA assessment areas.
Please refer to Appendix A for details regarding the states and multi -state MSA assessment
areas.
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Loan Products Reviewed
This evaluation includes a review of loans reported pursuant to the HMDA and CRA for 2016
and 2017. The tables in Appendix D present 2017 lending figures, as this is the most recent year
for which aggregate lending data is available for comparison purposes. However, examiners
reviewed lending performance for 2016 and discussed any observed anomalies under the
Geographic Distribution and Borrower Profile performance factors. Lastly, the Geographic
Distribution and Borrower Profile discussion focuses only on loans First -Citizens Bank
originated inside its assessment areas.
When weighing the loan products' impact on the conclusions, other than community
development lending, examiners evaluated home mortgage, small business, and small farm loans
on the volume of lending over the 2016 and 2017 review period. As shown in the following
table, First -Citizens Bank's reportable loans by number and dollar volume during the
aforementioned review period reflect an emphasis on small business loans. By comparison, the
bank has a nominal number and dollar amount of small farm loans. Therefore, as detailed below,
there were only five assessment areas covered in the small farm analysis.
Reviewed
Loan Category
# % S(000s) %
Home Mortgage 13,930 25.1 3,157,045 41.7
Small Business 39,539 71.3 4,212,004 55.6
Small Farm 1,987 3.6 201,682 2.7
Total 55,456 100.0 7,570,731 100.0
As reflected in the previous and following tables, commercial lending is the bank's primary product
by number and dollar volume within the overall bank structure. As such, the bank's lending
emphasis was commercial purpose loans in the majority of the assessment areas reviewed.
Therefore, examiners placed greater overall weight on the distribution of small business loans than
on the distribution of home mortgage loans and small farm loans. Additionally, examiners provided
appropriate comments in the assessment areas in which commercial loans were not the primary
product.
Home improvement loans were sufficient for an analysis in only the Asheville MSA; NC Non-MSA;
Raleigh MSA; Charlotte MSA; Columbia MSA; Greenville MSA; SC Non-MSA, and Milwaukee
MSA assessment areas. Additionally, small farm loans were sufficient for analysis in only the NC
Non-MSA; Raleigh MSA; Charlotte MSA; SC Non-MSA; and VA Non-MSA assessment areas.
Multi -family lending was not sufficient for analysis in any assessment area. However, examiners
considered multi -family loans that met the community development definition in the evaluation of
community development lending.
For the lending test, examiners reviewed the number and dollar volume of home mortgage, small
business, and small farm loans. While number and dollar volume of loans are presented,
examiners emphasized performance by number of loans under the geographic distribution and
borrower profile criteria, because the number of loans is a better indicator of the number of
businesses, farms, and individuals served.
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Federal banking agencies rely on U.S. Census data that is updated every five years for purposes
of CRA evaluations. This evaluation includes a review of bank performance that spans two sets
of Census data. Specifically, examiners compared 2016 loan data against 2010 Census data and
compared 2017 loan data to 2015 American Community Survey (ACS) Census data.
The following table presents gross loan activity from January 1, 2017, through December 31, 2017.
Loans Originated or Purchased (2017)

Loan Category $(000s) % #
Construction and Land Development 769,296 8.8 1,040 0.9
Secured by Farmland 38,915 0.4 128 0.1
1-4 Family Residential 1,806,728 20.7 13,127 11.4
Multi -Family (5 or more) Residential 58,537 0.7 69 0.1
Commercial Real Estate 2,492,909 28.5 3117 2.7
Commercial and Industrial 1,884,942 21.6 28,020 24.3
Agricultural 63,653 0.8 718 0.5
Consumer 954,187 10.9 64,894 56.3
Obligations of States/Political
285,793 3.2 76 0.1
Subdivisions
Lease Financing Receivables 298,408 3.4 3907 3.4
Other Loans 85,375 1.0 280 0.2
Total Loans 8,738,743 100.0 115,376 100.0
Source: Bank Records.
While reviewing lending in all assessment areas, examiners evaluated the bank's lending data,
deposit activity, and the number of branches to determine the rated areas that would receive the
most weight in assigning the overall rating. As shown in Appendix, North Carolina has the most
lending and deposit activity and the largest branching network. Consequently, examiners gave
the most weight to the bank's lending performance in North Carolina. Secondary weight was
assigned to South Carolina, Charlotte Multi -State NC -SC assessment area, Virginia, and
California in a descending order of impact.
This evaluation includes, or purchased during the evaluation period. In addition, the evaluation
includes all community development services performed during the evaluation period.
Community Development Activities
The evaluation period for community development loans, qualified investments, and community
development services was June 6, 2016, and March 26, 2019. However, the bank did not
provide any community development activities for 2019 as such had not been aggregated,
analyzed, and verified. Thus, the community development information only presents activities
through December 31, 2018. All qualified investments purchased prior to the last evaluation
date and still outstanding as of this evaluation date are also are included. Furthermore,
5
examiners evaluated community development activities quantitatively eased on tne financial
capacity of the bank, as well as qualitatively based upon the impact to the assessment areas.
DESCRIPTION OF INSTITUTION
Background
First -Citizens Bank is a $35.2 billion state -chartered financial institution that began its operations
in 1898 in Smithfield, North Carolina. First -Citizens Bank moved its headquarters from
Smithfield to Raleigh in May 1974. First -Citizens Bank is a subsidiary of First -Citizens
Bancshares, Inc., a one -bank holding company following the merger of First -Citizens Bank with
the South Carolina affiliate (First -Citizens Bank and Trust Company, Columbia, South Carolina).
Prior to the merger, the two banks were both in a chain affiliation through common ownership by
the Holding family. The Holding family controls the following affiliated holding companies and
banks: 1) Southern BancShares, Inc. / Southern Bank and Trust Company, Mount Olive, North
Carolina; and 2) Fidelity BancShares, Inc. / The Fidelity Bank, Fuquay-Varina, North Carolina.
As previously stated, First -Citizens Bank operated in 17 states and 4 multi -state MSAs as of the
evaluation date. The bank also operated in 4 additional states, as noted under the Scope of
Evaluation section. Examiners excluded the four states from the scope of the current evaluation
due to the timing of the bank's entry into and exit from those markets, as well as the minimal
lending and other banking activities during the evaluation period.
During the evaluation period, First -Citizens Bank acquired and/or merged with the following
financial institutions.
Acquisitions
Acquired Bank Acquisition Date Total Assets **
Bank of Virginia (Cordia Bancorp), VA. September 1, 2016 $353.8 million
Harvest Community Bank, NJ.* January 13, 2017 $126 million
Guaranty Bank, IL, MN, & W1.* May 5, 2017 $1 billion
HomeBanc, FL. May 1, 2018 $955 million
Securant Bank (Capital Commerce), WI. October 2, 2018 $226 million
Palmetto Heritage Bank, SC. November 1, 2018 $164 million
Source: Bank Records
*Acquired as part of government assisted transaction.
* *Reported on most recent Call Report prior to merger date.
First -Citizens Bank has 10 subsidiaries that include a registered broker dealer, a title insurance
company, a registered investment advisor, an insurance agency, and other non -bank financial
entities. First -Citizens Bank operates as a traditional commercial bank offering a wide range of
deposit and loan products to both consumer and commercial customers. Retail deposits
generated through the bank's branch operations have been utilized as the primary source of
funding for operation and growth.
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Operations
First -Citizens Bank operated 552 branch offices and 625 Automated Teller Machines (ATMs) in
the identified assessment areas during the evaluation period. Refer to Appendix A for a
summary of branches in each assessment area. The bank also offers a multi-lingual Tele-
Interpreter Service Line at all branches. The service offers interpreters fluent in more than 177
languages to help branch staff assist customers. Although the bank's business strategy is not
limited to any one business endeavor, banking relationships through commercial and residential
lending represent its primary business strategy.
As of December 31, 2018, Consolidated Report of Condition and Income, First -Citizens Bank
had total loans of $25.6 billion, or 72.4 percent of total assets. As shown in the following table,
commercial real estate and commercial and industrial loans represent the largest portion of the
loan portfolio at 54.2 percent, followed by one -to -four family residential properties at 28.0
percent.
Loan Portfolio Distribution as of 12/31/2018

Loan Category $(000s) cyo
Construction and Land Development 1,024,853 4.0

Secured by Farmland 177,855 0.7
1-4 Family Residential 7,160,258 28.0
Multi -family (5 or more) Residential 262,524 1.0
Commercial Real Estate 10,987,091 43.0
Total Real Estate Loans 19,612,581 76.7
Commercial and Industrial 2,867,481 11.2
Agricultural 185,564 0.7
Consumer 1,716,886 6.7
Obligations of States/Political Subdivisions 295,138 1.2
Lease Financing Receivables 594,757 2.3
Other 297,896 1.2
Total Loans 25,570,303 100.0
Source: Reports of Income and Condition
Ability and Capacity
There are no financial or legal impediments, other than legal lending limits, to prevent the bank
from meeting the credit needs of its assessment areas.
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DESCRIPTION OF ASSESSMENT AREAS
The CRA law requires each financial institution to define one or more assessment areas within
which its CRA performance will be evaluated. Operations in some states during the evaluation
period were limited to the operations in the multi -state MSAs. Therefore, for the purpose of this
evaluation, First -Citizens Bank operated in 77 assessment areas in 17 states and 4 multi -state
MSAs. As previously stated, Illinois, Minnesota, New Jersey, and Pennsylvania are excluded
from the scope of this evaluation due to the timing of the bank's entry into and exit from those
markets. First -Citizens Bank operated 1 assessment area in Illinois, 1 assessment area in
Minnesota, 1 assessment area in New Jersey, and 2 assessment areas in Pennsylvania. The
Orlando and Tampa MSA assessment areas were also excluded as the bank entered those
markets in October 2018.
Management selected the assessment areas based on the location of the bank's offices and the
expectation of attracting and retaining a customer base within the assessment areas. Examiners
rated the bank's performance in each state and multi -state MSA separately and combined the
counties that are not part of a MSA to form state-wide Non-MSA assessment areas for this CRA
evaluation.
Refer to Appendix A for a summary of the bank's assessment areas, including the number of
counties, census tracts, and branches within each assessment area.
Community Contact
During CRA evaluations, examiners contact community organizations or use recent interviews of
community contacts conducted within the assessment areas to gain insight regarding local
economic conditions and credit needs. During this evaluation, nine new community contacts
were interviewed from Wilson, North Carolina; Columbia, Lexington, and Summerville, South
Carolina; Jacksonville and St. Augustine, Florida; Sandy Springs, Georgia; and Knoxville,
Tennessee. Additionally several interviews from recent contacts were reviewed from Los
Angeles, San Diego, and Sacramento, California; Baltimore, Maryland; Oklahoma City,
Oklahoma; Roanoke, Virginia; Austin, Texas; Denver, Colorado; Portland, Oregon; Wilmington
and Mooresville, North Carolina; and Fort Mill, South Carolina.
The majority of the contacts' organizations represent economic development, with a few
representing housing and education. All contacts indicated that the economies in their areas are
stable and doing well, some with the lowest unemployment rates in several years. Although the
overall national economy is good, many of the contacts stated small businesses continue to
struggle with obtaining financing, and many start-up business owners lack the financial
education needed to obtain business loans and establish good credit records. Additionally, some
contacts stated, as housing prices rise in most areas, the supply of affordable housing for low -
and moderate -income individuals experienced a downward trend.
While economic improvement has been significant, the community contacts indicate there
continues to be economic development and affordable housing needs that financial organizations
are not meeting. In particular, there is a need for financial literacy education, particularly for
8
small businesses. In addition, micro -business loans and more flexible lending standards for start-
up businesses are significant needs that remain unmet. Further, affordable housing continues to
be a need for many assessment areas.
Credit and Community Development Needs and Opportunities
A review of demographic and economic data, as well as community contact information, indicate
the need for small business and home mortgage loans in most of the assessment areas. In
particular, community contacts noted the need for flexible small business loans, including micro-
business loans. Further, the community contacts mentioned the need for affordable housing
loans.
CONCLUSIONS ON PERFORMANCE CRITERIA

LENDING TEST
The Lending Test rating is High Satisfactory. Lending levels reflect good responsiveness to the
assessment areas' credit needs, and a substantial majority of loans are made in the assessment
areas. The geographic distribution of loans reflects good penetration throughout the assessment
areas, and the distribution of loans reflects good penetration among individuals of different
incomes and small businesses and farms of different sizes. The institution uses flexible lending
practices in order to serve the assessment areas' credit needs and originates a relatively high
level of community development loans.
Lending Activity
Lending levels reflect good responsiveness to the assessment areas' credit needs. As of the
December 31, 2018, Consolidated Report of Condition and Income, First -Citizens Bank had a
78.3 percent average loan -to -deposit ratio compared to a Uniform Bank Performance Report
(UBPR) peer group loan -to -deposit ratio of 88.2 percent. The bank's UBPR peer group includes
all 92 insured commercial banks having assets between $10 billion and $100 billion. The bank's
ratio ranged from a low of 74.9 percent in the first quarter of 2017 to a high of 82.6 percent in
the fourth quarter of 2018.
Assessment Area Concentration
A substantial majority of loans are made in the assessment areas. The following table provides
the bank's lending inside and outside of the assessment areas.
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Lending Inside and Outside of the Assessment Area
Number of Loans Dollars Amount of Loans $(000s)
Loan Category Inside Outside Total # Inside Outside Total $(000s)
# % # % $ % $ %
Home Mortgage
2016 7,012 94.9 379 5.1 7,391 1,566,592 95.0 82,120 5.0 1,648,712
2017 6,918 94.9 368 5.1 7,286 1,590,453 93.1 117,974 6.9 1,708,427
Subtotal 13,930 94.9 747 5.1 14,677 3,157,045 94.0 200,094 6.0 3,357,139
Small Business
2016 22,016 93.0 1,664 7.0 23,680 2,511,066 90.4 266,512 9.6 2,777,578
2017 17,523 94.1 1,101 5.9 18,624 1,700,938 92.9 130,829 7.1 1,831,767
Subtotal 39,539 93.5 2,765 6.5 42,304 4,212,004 91.4 397,341 8.6 4,609,345
Small Farm
2016 1,208 89.0 150 11.0 1,358 117,574 84.4 21,765 15.6 139,339
2017 779 88.4 102 11.6 881 84,108 83.9 16,189 16.1 100,297
Subtotal 1,987 88.7 252 11.3 2,239 201,682 84.2 37,954 15.8 239,636
Total 55,456 93.6 3,764 6.4 59,220 7,570,731 92.3 635,389 7.7 8,206,120
Source: 2016 and 2017 HMDA and CRA Reported Data
Geographic Distribution
The geographic distribution of loans reflects good penetration throughout the assessment areas.
Tables 2a through 7a in Appendix D detail the geographic distribution of loans for each
assessment area. Performance varied across assessment areas; however, overall, the percentage
of lending in low- and moderate -income census tracts was generally slightly below or consistent
with the demographic and aggregate lending data for home mortgage loans. However,
performance was generally above demographic data aggregate lending data for small business
and small farm loans. The Geographic Distribution for the WV Non-MSA assessment area was
not assessed as all census tracts are middle -and upper -income.
The geographic distribution of HMDA loans is detailed in Tables 2a through 5a in Appendix D

for each assessment area. Performance in low- and moderate -income census tracts for home
mortgage lending was generally comparable to aggregate lending and demographic data. For the
31 assessment areas that received full -scope reviews, only 13 had sufficient home mortgage
lending volume to provide a meaningful geographic distribution analyses. Of these 13
assessment areas, the geographic distribution was good in 5, adequate in 7, and poor in 1. In the
areas where the bank did not originate any loans in low-income census tracts, the owner -
occupied housing units were generally nominal.
The geographic distribution of small business loans is detailed in Table 6a in Appendix D for
each state assessment area. Performance in low- and moderate -income census tracts for small
business loans was generally comparable to the aggregate lending and demographic data. Of the
31 full -scope review assessment areas, the geographic distribution was excellent in 1, good in 15,
and adequate in 14.
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The geographic distribution of small farm loans is detailed in Table 7a in Appendix D for each
assessment area. Of the five assessment areas where small farms were reviewed, the geographic
distribution was excellent in the Raleigh MSA assessment area and good in the NC Non-MSA,
SC Non-MSA, VA Non-MSA, and Charlotte MSA assessment areas.
Additional detail is available in the analyses of each assessment area by state and multi -state
MSA.
Borrower Profile
The distribution of loans reflects good penetration throughout the assessment areas to borrowers
of different incomes and businesses and farm of different sizes. Tables 8a through 12a in
Appendix D detail the distribution of loans by income and revenue. Performance varied across
the assessment areas and by loan type. Performance was generally consistent with the
demographic and aggregate lending data for home mortgage loans. However, performance was
generally below demographics and well above or significantly above the aggregate lending data
for small business and small farm loans.
The distribution of HMDA loans by borrower income is detailed in Tables 8a through 10a in
Appendix D for each assessment area. Lending performance to low- and moderate -income
borrowers varied considerably among the assessment areas. For the 31 assessment areas that
received full -scope reviews, only 14 had sufficient home mortgage lending volume to provide a
meaningful analysis. Of the 14 assessment areas, the borrower distribution was good in 8 and
adequate in 6.
The distribution of loans to businesses of different sizes is detailed in Table 11 a in Appendix D

for each assessment area. In most of the assessment areas, performance was significantly above
aggregate data but below demographic data. For the 31 assessment areas that received full -scope
reviews, the performance was excellent in 3 assessment areas, good in 21 assessment areas,
adequate in 6 assessment areas, and poor in 1 assessment area.
The distribution of loans to farms of different sizes is detailed in Table 12a in Appendix D for
each assessment area. The distribution of loans was good in all five assessment areas that
received full -scope reviews for small farm lending.
Additional detail is available in the analyses of each assessment area by state and multi -state
MSA.
Innovative and/or Flexible Lending Practices
First -Citizens Bank uses flexible lending programs in order to serve assessment area credit
needs. During the current evaluation period, flexible lending programs total 3,298 loans totaling
$587.6 million. This performance represents a slight increase by number and dollar volume from
the previous evaluation. Four of the programs are limited to markets in North Carolina, South
Carolina, and Virginia, as they are provided through state housing agencies and the
Neighborhood Revitalization Program. In addition, one program is limited to the Cherokee
11
Indian Reservation in North Carolina. The remaining flexible loan programs are offered in all
assessment areas. A summary of the programs offered by First -Citizens Bank is detailed below.
Innovative and/or Flexible Lending Programs

2016* 2017 2018 Totals**
Type of Program
# $(000s) # $(000s) # $(000s) # $(000s)
SBA 78 33,019 134 56,932 88 4,662 300 94,613
FHA 205 31,424 275 43,407 243 37,251 723 112,082
VA 92 20,322 135 27,631 109 23,696 336 71,649
USDA 65 7,766 93 11,888 96 13,149 254 32,803
South Carolina Housing 4,676 3,448
9 845 45 29 83 8,969
Authority
North Carolina Housing 18,468 15,659 382 47,669
105 13,542 155 122
Finance Agency
Virginia Housing 220
2 220 0 0 0 0 2
Development Authority
Neighborhood Revitalization
11 1,105 12 1,221 7 632 30 2,958
Program
Community Opportunity 113 15,698 109 16,683 153 23,475 375 55,856
Home Ownership Mortgage 246 45,754 317 62,253 243 51,882 806 159,889
Express
Eastern Band of Cherokee 2 254 5 602 0 0 7 856
Indians
Totals 928 169,949 1,280 243,761 1,090 173,854 3,298 587,564
*June 6, 2016 - December 31, 2016
* *Bank did not provide data for 2019.
First -Citizens Bank offers several flexible small business loan programs for businesses who
would not otherwise qualify for standard commercial loans. First -Citizens Bank is a Preferred
Lender for the Small Business Administration (SBA) and offers the following loan programs:
SBA Express, SBA 7(a), and SBA 504. In addition, First -Citizens Bank refers commercial loans
to Business Development Corporation, a Community Development Financial Institution (CDFI)
that serves small businesses throughout Alabama, Florida, Georgia, North Carolina, South
Carolina, Tennessee, and Virginia. Since the previous evaluation, First -Citizens Bank has
referred two SBA 7(a) loans and four SBA 504 loans totaling $2.5 million to Business
Development Corporation.
First -Citizens Bank offers flexible housing loans through the following Federal government
agencies: Federal Housing Administration (FHA), Veterans Administration (VA), and the
United States Department of Agriculture (USDA). These programs provide affordable home
ownership opportunities to low- and moderate -income families. The programs also offer flexible
underwriting criteria, government guarantees, lower down -payment requirements, and closing
cost assistance. First -Citizens Bank also offers mortgages through three state housing agencies:
the North Carolina Housing Finance Agency, the South Carolina Housing Authority, and the
Virginia Housing Development Authority. The state housing agency programs target first-time
homebuyers as well as low- and moderate -income borrowers, and provide below market interest
rates and flexible terms. The Neighborhood Revitalization Program, which provides flexible
12
underwriting standards for specific communities targeted by the government for revitalization, is
offered through the North Carolina and South Carolina state housing agencies.
First -Citizens Bank further offers a proprietary affordable mortgage product, Community
Opportunity Mortgage, targeted toward low- and moderate -income individuals. Community
Opportunity Mortgage provides fixed-rate financing for home purchase loans for borrowers with
incomes below the median family income. Private mortgage insurance is not required and
underwriting requirements are more flexible than traditional standards. In addition, the bank
offers a proprietary affordable mortgage product, Home Ownership Mortgage Express, which
allows for first-time home buyer purchase transactions to have up to a 100 percent loan -to -value
ratio for applicants with credit scores of 660 or higher, and no mortgage insurance is required.
Finally, the bank offers flexible mortgage loans for the Cherokee Indian Reservation in North
Carolina. These loans provide financing for construction, refinance, and purchase of leasehold
property on the Cherokee Indian Reservation. This program provides Native Americans residing
on a reservation with access to long-term mortgage financing, and no mortgage insurance is
required.
Community Development Lending
First -Citizens Bank made a relatively high level of community development loans. First-
Citizens Bank made a relatively high level of community development loans. During the
evaluation period, the bank extended 375 community development loans for $713.4
million. This activity accounts for 2.8 percent of total loans and 2.0 percent of total assets as of
December 31, 2018. Since the last evaluation, the number and dollar volume of community
development loans increased by 43.7 and 47.5 percent, respectively. Although the bank has
increased its number and dollar volume of community development loans, 32.0 percent of the
qualified loans by number are renewals, which limit the overall level of responsiveness.
Of the 375 community development loans, 25 loans totaling $25.3 million were extended
outside of the assessment areas in a broader regional area. The loans are included in the
Community Development Lending analysis since the bank had served the needs of the
assessment areas.
First -Citizens Bank's community development loans support affordable housing to low- and
moderate -income individuals and small businesses in partnership with local and state
governmental agencies to promote economic development and revitalization or stabilization
efforts in low-, moderate-, and distressed non -metropolitan middle -income census tracts and
community development services within its assessment areas.
The following tables present community development lending by community development

purpose and year as well as in each rated area. A detailed discussion of community development
lending activities is provided within the assessment areas of each rated area
13
Community Development Lending by Activity Year
Affordable Community Economic Revitalize or
Totals**
Activity Year Housing Services Development Stabilize
# $(000s) # $(000s # $(000s) # $(000s) # $(000s)
2016* 24 30,993 30 16,321 4 6,778 15 143,939 73 198,031
2017 47 7,944 51 35,208 14 16,278 35 210,187 147 269,617
2018 33 61,773 75 34,524 19 47,798 28 101,698 155 245,793
Total 104 100,710 156 86,053 37 70,854 78 455,824 375 713,441
*6/6/2016-12/31/2016
* *Bank did not provide information for 2019.
Community Development Lending by Rated Area

Affordable Community Economic Revitalize
Totals
Rated Area Housing Services Development or Stabilize
# $(000s) # $(000s) # $(000s) # $(000s) # $(000s)
North Carolina 35 56,011 42 32,264 6 14,021 20 198,721 103 301,017
South Carolina 5 4,474 29 12,010 1 200 36 134,127 71 150,811
Charlotte -Concord -
Gastonia NC -SC Multi- 3 17,208 7 5,557 0 0 8 27,728 18 50,493
State MSA
Virginia 10 6,036 15 10,255 4 3,918 9 55,851 38 76,060
California 33 2,339 29 17,132 5 37,363 0 0 67 56,834
Georgia 1 8,000 4 377 2 6,050 3 38,161 10 52,588
Florida 5 3,885 3 75 0 0 0 0 8 3,960
Myrtle -Beach -Conway -
North Myrtle Beach
1 1,000 1 548 1 1,432 0 0 3 2,980
NC -SC Multi -State
MSA
Arizona 0 0 2 70 0 0 0 0 2 70
Washington 2 27 4 2,700 0 0 0 0 6 2,727
Texas 0 0 0 0 11 7,220 0 0 11 7,220
Augusta -Richmond
County GA -SC Multi- 0 0 2 600 0 0 0 0 2 600
State MSA
Tennessee 0 0 3 70 1 50 0 0 4 120
Colorado 0 0 2 75 2 100 0 0 4 175
New Mexico 0 0 6 1,847 3 300 0 0 9 2,147
Oklahoma 0 0 2 35 0 0 0 0 2 35
Maryland 0 0 0 0 1 200 0 0 1 200
Oregon 1 1,300 4 2,408 0 0 0 0 5 3,708
Kansas City KS -MO 3 185 0 0 0 0 0 0 3 185
Multi -State MSA
West Virginia 5 245 1 30 0 0 2 1,236 8 1,511
Wisconsin 0 0 0 0 0 0 0 0 0 0
Total 104 100,710 156 86,053 37 70,854 78 455,824 375 713,441
14
INVESTMENT TEST
The Investment Test rating is High Satisfactory. First -Citizens Bank maintains a significant
level of qualified investments and donations, occasionally in a leadership position, particularly
those that are not routinely provided by private investors. Considering available investment
opportunities, qualified investments demonstrate good responsiveness to the credit and
community development needs of the assessment areas. The level of new investments, as well as
performance relative to other comparable institutions, primarily supports this conclusion. The
bank makes occasional use of innovative and/or complex investments to support community
development initiatives.
The bank primarily fulfills its qualified investment objectives through the combination of SBA
Loan Pool Securities (SBA pools); Low -Income Housing Tax Credit (LIHTC) investments in
Community Affordable Housing Equity Corporation (CAHEC) projects RBC Tax Credit Equity
Funds; Ginnie Mae (GNMA) Securities backed by multifamily mortgages (MBS); and
certificates of deposits (CDs) in financial institutions. Additionally the bank made a large
amount of qualified grants, charitable donations, and in -kind donations.
Investment Activity
Investments and donations during the evaluation period total $338.5 million or 1.0 percent of
total assets, 10.2 percent of equity capital, and 19.9 percent of total investments as of December
31, 2018. The level of qualified investments compared favorably to similarly -situated banks
(selected by asset size). Current qualified investments represent a substantial increase from the
prior examination, when First -Citizens Bank maintained $170.7 million in qualified investments,
which represented 2.6 percent of total investments.
Qualified investments made during the evaluation period primarily include LIHTCs and MBSs,
which are designed to provide funding and liquidity to affordable housing markets. In addition,
economic development is strongly supported by SBA pools that provide funding to small
businesses. The following tables show qualified investment totals by rated area and activity
purpose and year. Of the $338.5 million, $279.5 million is new qualified investments, $56.2
million are prior period investments, and $2.8 million are grants and donations. Further details
regarding specific qualified investment, grant, and donation activity is provided later under each
state and assessment area.
Of the total qualified investments, $45.2 are regional investments that impact multiple rated
areas and assessment areas and are not designated to a specific assessment area in the analysis
and conclusions of the assessment areas and rated areas. The regional investments consist of
$30.0 million in CAHEC investments and $12.4 million in GNMA multi -housing investments.
The CAHEC and GNMA MBS investments provide support in various assessment areas for
affordable housing, which is an identified need in many areas. The regional activities also
include $142,000 in donations and $2.7 million in prior -period investments. The high volume of
regional investments further supports the overall rating.
15
Qualified Investments
Affordable Community Economic Revitalize or
Totals **
Activity Year Housing Services Development Stabilize
# $(000s) # $(000s) # $(000s) # $(000s) # $(000s)
Prior Period 8 56,181 0 0 0 0 0 0 8 56,181
2016* 2 18,000 0 0 0 0 0 0 2 18,000
2017 4 35,000 0 0 0 0 0 0 4 35,000
2018 7 133,530 0 0 10 92,956 0 0 17 226,486
YTD 2019 0 0 0 0 0 0 0 0 0 0
Subtotal 21 242,711 0 0 10 92,956 0 0 31 335,667
Qualified Grants
85 127 1,236 1,913 273 684 56 159 1,650 2,883
& Donations
Total 106 242,838 1,236 1,913 283 93,640 56 159 1,681 338,550
*June 6, 2016 - December 31, 2016
** Bank did not provide information for 2019.
Qualified Investments by Rated Area

Rated Area Affordable Community Economic Revitalize or Totals
Housing Services Development Stabilize
$(000s) $(000s) $(000s) $(000s) % $(000s)
Arizona 0 9 7,414 0 2.2 7,423
California 10,978 33 42,057 0 15.7 53,068
Colorado 11,219 5 0 0 3.3 11,224
Florida 19,887 33 5,006 1 7.4 24,927
Georgia 10,736 63 17,443 0 8.3 28,242
Maryland 1,510 2 0 0 0.4 1,512
New Mexico 2,469 10 0 0 0.7 2,479
North Carolina 34,965 859 530 72 10.8 36,426
Oklahoma 0 13 1 0 >0.1 14
Oregon 1,744 3 3,356 0 1.5 5,103
South Carolina 25,926 674 364 56 8.0 27,020
Tennessee 8,739 15 4 0 2.6 8,758
Texas 16,299 10 11,488 0 8.2 27,797
Virginia 15,855 84 1,063 2 5.0 17,004
Washington 18,009 7 3,906 0 6.5 21,922
West Virginia 0 1 1 5 >0.1 7
Wisconsin 0 10 0 0 >0.1 10
Augusta -Richmond County 448 37 2 0 0.1 487
GA -SC Multi -State MSA
Charlotte -Concord -Gastonia
7,813 13 94 18 2.3 7,938
NC -SC Multi -State MSA
Kansas City KS -MO Multi -
8,090 1 291 0 2.5 8,382
State MSA
Myrtle -Beach -Conway -North
Myrtle Beach NC -SC Multi- 3,064 16 4 0 0.9 3,084
State MSA
Regional Activities 45,087 15 116 5 13.4 45,223
Nationwide 0 0 500 0 0.1 500
Total 242,838 1,913 93,640 159 100.0 338,550
16
Responsiveness to Credit and Community Development Needs
First -Citizens Bank exhibits good responsiveness to credit and community economic
development needs. Since the last performance evaluation, bank management made a concerted
effort to ensure new investments and donations were concentrated in its assessment areas, which
further supports the bank's good responsiveness. The bank continues to be responsive in
providing affordable housing needs and expanding with the economic needs of small businesses
through investments into SBA pools collateralized by businesses within the assessment areas.
LIHTCs, MBS, SBA pools, and CDs make up the entirety of the new qualified investments.
First -Citizens Bank continues to invest in LIHTCs through two syndicators of tax credits for
affordable housing. One of the syndicators, CAHEC, is a large nonprofit syndicator of tax
credits for low-income rental housing. The mission of CAHEC is to raise and invest equity
capital in qualified LIHTC projects, to empower residents living in developments CAHEC helps
finance and to promote home ownership. CAHEC creates a new investment fund each year to
finance multi -family developments that utilize tax incentives provided through the LIHTC
program. Through its investments in CAHEC's equity funds, the bank participated in tax credit
programs throughout nine states. The other syndicator, Royal Bank of Canada -Tax Equity
Group (RBC-TEG) is a large national syndicator of tax credits for low-income rental housing.
RBC-TEG creates a new investment fund each year to finance multi -family developments that
utilize tax incentives provided through the LIHTC program. Through these investments, the
bank was able to invest in affordable housing projects specific to its assessment areas.
The bank has participated in four Ginnie Mae Multifamily REMIC Trust Pass -Through
Securities (Bonds). These issuances are composed of multifamily projects and construction
loans. The four investments that the bank made are supported by multifamily projects in nine
states.
SBA pools are securities that are made up of pooled loans from the U.S. Small Business
Administration. As a Federal agency, the SBA offers loan guarantees through its 7(a) loan
program, which allows small businesses that are unable to otherwise secure financing through
normal lending channels to obtain loans. The bank invested in six SBA Pools securitized by
small business loan guarantees in nine states.
Qualified investments also include deposits in minority- and women -owned financial institutions
(MDIs). During the performance evaluation period, the bank purchased four certificates of
deposits with four different MDIs. These MDIs were headquartered or had branch offices in five
states.
Qualifying grants and donations can be responsive to charitable or community -based

organizations serving local residents of their respective assessment area. Many organizations
rely on these contributions to continue their services. The bank made 1,650 qualifying
donations, including in -kind donations, and grants to qualified organizations during this
evaluation period totaling $2.9 million. The majority of the donations and grants went to
organizations that provide, in whole or part, community services, in addition to affordable
housing, economic development, and revitalization and stabilization.
17
Innovativeness or Complexity of Qualified Investments
The bank occasionally uses innovative and/or complex investments to support community
development initiatives. LIHTC, MBS, SBA pools and CDs make up the majority of new
investments since the prior examination. Although these investments help to sustain affordable
housing and economic development in the assessment areas, they were not innovative. However,
the majority of these investments were collateralized specifically to benefit the assessment areas
adding some complexity.
SERVICE TEST
The Service Test rating is High Satisfactory. First -Citizens Bank's delivery systems are
accessible to essentially all portions of the assessment areas, and the opening and closing of
branches throughout the assessment areas has not adversely affected the accessibility of its
delivery systems. Services and business hours do not vary in a way that inconveniences certain
portions of the assessment areas, particularly low- and moderate -income geographies, or
individuals and alternative delivery systems enhance the availability of financial services. In
addition, First -Citizens Bank provided a relatively high level of community development
services within most of its assessment areas.
Accessibility of Delivery Systems
The bank has an extensive branch network, and in most assessment areas, the distribution of
branches is similar to the population demographics of the assessment area. Refer to Tables 15 in
the appendix for details on the branch distribution by geography for each full -scope assessment
area.
Changes in Branch Locations
To the extent changes have been made, the institution's record of opening and closing branches
has not adversely affected the accessibility of its delivery systems, particularly in low- and
moderate -income geographies and/or to low- and moderate income individuals. During the
evaluation period, the bank opened and/or acquired 60 branches and closed 62 branches
primarily through mergers and acquisitions. Of the 60 branches opened or acquired, 15 or 25.0
percent were located in low- and moderate -income census tracts. Of the 62 branch closings, 19
or 30.6 were located in low- and moderate -income census tracts. No further decision is provided
for those areas where no branches were opened or closed.
Reasonableness of Business Hours and Services
Services and business hours do not vary in a way that inconveniences certain portions of the
assessment areas, particularly low- and moderate -income geographies, or individuals. First -
Citizens Bank offers a full range of consumer and commercial loan and deposit products through
its branch network designed to meet the banking needs of local communities. Each branch offers
the same products and services. Business hours are generally 9:00 a.m. to 5:00 p.m. on Monday
through Thursday and 9:00 a.m. to 6:00 p.m. on Friday, with some locations open on Saturday.
18
Performance in this criterion is generally consistent throughout each rated state or multi -state
MSA and related assessment areas. Therefore, the Service Test conclusions for each rated area
or full -scope review assessment area omit further discussion of this performance.
First -Citizens Bank offers several different delivery systems for its customers. In addition to the
extensive branch network, the bank provides an ATM network of 625 machines, online banking
and bill pay, mobile banking (text messaging, mobile web, and mobile app), and a toll -free
telephone banking call center. The online services are offered 24 -hours a day, allowing
customers to check account balances, transfer money between accounts and to other customers
via Popmoney, make loan payments, and pay bills, all at no cost. In addition, the bank offers
consumers the ability to apply for mortgage loans and check line reserve products through the
bank's website and by telephone. These additional loan application portals extend the reach of
the bank's services to all customers who have access to the interne or a telephone. Further, the
bank offers Apple Pay, Android Pay, and Samsung Pay, whereby customers may use their
iPhone or Android devices in place of debit or credit cards at retail locations. Overall, these
alternative delivery systems enhance the accessibility of the bank's financial services.
Performance in this criterion is generally consistent throughout in each rated state or multi -state
and related assessment areas. Therefore, the Service Test conclusions for each rated area or full -
scope review assessment area omit further discussion of this performance.
Services via telephone include standard services, such as checking account balances, transferring
funds, and making loan payments. In addition, the bank offers the ability to open accounts over
the telephone. The telephone contact center is staffed with some bi-lingual (English/Spanish)
personnel and various branch offices employ bi-lingual staff. This extends the reach of the
bank's services to all customers who have access to a telephone. Opening accounts and applying
for a loan via telephone are available from 8:00 a.m. to 8:00 p.m. on the weekdays and 8:00 a.m.
to 6:00 p.m. on the weekends.
The bank has recognized that it operates in diverse markets where a multitude of languages are
spoken, which can create communication barriers with current and prospective customers. In an
effort to better serve its customer base and minimize communication barriers, the bank's 625
ATMs have been upgraded throughout its assessment areas to include English, Spanish, and
Audio. The bank also offers a multi-lingual Tele-Interpreter Service Line at all branches. The
service offers interpreters fluent in more than 177 languages to help branch staff assist
customers.
The bank introduced a new checking deposit account product, Sure Advantage, in 2018 that is
targeted to customers who do not qualify for other bank checking accounts due to negative
checking account banking history. This product allows the bank to reach the underbanked and
those who are unable to use the banking system due to previous poor account management. The
account does not allow the customer to opt -in to overdraft protection services in order to protect
the customer from accumulating high fees and to discourage overspending. The monthly fee for
this account is $5 with electronic banking statements. If the customer maintains the account in
good standing for 12 months, the account is eligible to convert to another bank checking account.
The bank has opened 5,714 Sure Advantage accounts as of December 31, 2018.
19
Community Development Services
First -Citizens Bank proVided a relatively high level of community development services within
its assessment areas during this evaluation period. Examiners noted that the bank provided 1,311
community development services during the evaluation period. Given the time period covered
by this evaluation, the total services equate to approximately 0.9 community development
services per branch per year. Bank personnel have been most active in North Carolina, South
Carolina, and Virginia. Bank management and employees provide financial advice and
assistance to organizations with missions consistent with the definition of community
development. These organizations provide an array of community development services to low -
and moderate -income individuals and small businesses. Most of the community development
services involved financial literacy sessions targeted to small business owners or low- and
moderate -income individuals, and memberships on the Boards of community development
organizations. In addition, the bank participates in the Interest on Lawyer's Trust Account
(IOLTA) programs, which provide free or reduced fee legal services for low -and moderate -
income individuals, for every state in its footprint. The bank remitted monies on approximately
3,000 deposit accounts in each of the years 2016, 2017, and 2018. Refer to the discussions of
Community Development Services within each assessment area analysis for additional details
and examples.
DISCRIMINATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW
Examiners did not identify any evidence of discriminatory or other illegal credit practices;
therefore, this consideration did not affect the institution's CRA rating.
20
NORTH CAROLINA
CRA RATING FOR NORTH CAROLINA: Satisfactory
The Lending Test is rated: High Satisfactory

The Investment Test is rated: High Satisfactory
The Service Test is rated: High Satisfactory
SCOPE OF EVALUATION
The evaluation of the North Carolina performance considered the operations of First -Citizens Bank
in 15 assessment areas, which are detailed in Appendix A Examiners conducted full -scope reviews
of the bank's performance in the Asheville MSA, Raleigh MSA and NC Non-MSA assessment
areas. A majority of the bank's loans (55.1 percent), deposits (60.1 percent), and branches (56.6
percent) within North Carolina are concentrated in these assessment areas. Small business loans
constitute the primary loan type in all assessment areas. Home mortgage loans were limited in
some assessment areas; however, they were reviewed in all assessment areas. Small farm loans
were reviewed in the Raleigh MSA and NC Non-MSA assessment areas. Examiners based
performance evaluation and conclusions primarily upon the small business lending.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN NORTH CAROLINA
The bank operates 196 or 35.4 percent of branch offices in North Carolina. North Carolina
accounts for 43.5 percent of the bank -wide deposits and 39.5 percent of loans. Overall, First -
Citizens Bank ranks 3rd in the state in deposit market share at 9.5 percent. Competitor
institutions in the assessment areas include Branch Banking and Trust Company (BB&T) and
Wells Fargo Bank, NA; together, the two institutions account for 46.6 percent of the deposit
market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN NORTH CAROLINA
LENDING TEST
The Lending Test rating for North Carolina is High Satisfactory. Lending levels reflect good
responsiveness to the North Carolina assessment areas' credit needs. The geographic distribution
reflects good penetration, and the borrower profile reflects good distribution to borrowers of
different incomes and businesses and farm of different sizes. In addition, the bank used flexible
lending practices and originated a relatively high level of community development loans. The
performance in assessment areas that received limited -scope reviews was generally consistent the
full -scope review areas.
Lending Activity
Lending levels reflect good responsiveness to the North Carolina assessment areas' credit needs.
The tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017
for each North Carolina assessment area. Small business loans constitute the primary loan type in
21
all assessment areas. Home mortgage loans were limited in some assessment areas; however, they
were reviewed in all three full -scope assessment areas, as well as in 12 limited -scope areas. Small
farm loans were reviewed in the Raleigh MSA and NC Non-MSA assessment areas. Examiners
based performance evaluation and conclusions primarily upon the small business lending. The
performance in assessment areas that received limited -scope reviews was generally below the full -
scope review areas.
The geographic distribution of HMDA, small business, and small farm loans is good.
The geographic distribution of HMDA loans reflects adequate penetration throughout the
assessment areas. Adequate performance in the Non-MSA and Asheville MSA assessment areas
and a good performance in the Raleigh MSA assessment area primarily support this conclusion.
The geographic distribution of small business loans reflects good penetration throughout the
assessment areas. Good performance in the Raleigh MSA and Asheville MSA assessment areas
and an adequate performance in the Non-MSA assessment area primarily support this
conclusion.
The geographic distribution of small farm loans reflects good penetration. Good performance in
the Non-MSA assessment area and excellent performance in the Raleigh MSA assessment area
primarily support this conclusion.
Borrower Profile
The distribution of HMDA, small business, and small farm loans to borrowers of different
incomes and businesses and farm of different sizes is good.
The distribution of HMDA loans is adequate among borrowers of different income levels.
Adequate performance in all three full -scope assessment areas supports this conclusion.
The distribution of small business loans is good among businesses of different sizes. Good
performance in the Raleigh MSA and Asheville MSA assessment areas and excellent
performance in the Non-MSA assessment area primarily support this conclusion.
The distribution of small farm loans is good among farms of different sizes. Good performance
in the full -scope NC Non-MSA and Raleigh MSA assessment areas supports this conclusion.
First -Citizens Bank originated a relatively high level of community development loans in North
Carolina. During this evaluation period, the bank originated 103 community development loans
totaling $301.0 million. This represents 27.5 percent by number and 42.2 percent by dollar
volume of total bank -wide community development loans. The percent of community
development loans by dollar volume in the state is slightly above state lending levels at 39.5
22
percent. However, by number, lending levels are below the bank -wide lending levels. Three
loans totaling $7.1 million were originated outside the assessment areas but within the broader
state-wide area. Since the bank has been responsive to community development needs and
opportunities within its assessment areas, the loans were included. The analysis for each full -
scope North Carolina assessment area includes a detailed discussion of community development
loans.
INVESTMENT TEST
The Investment Test performance is rated High Satisfactory in North Carolina. The bank has a
significant level of qualified investments, donations, and grants of $36.4 million in North Carolina.
This represents 10.8 percent of total bank -wide qualified investments. Investments since the last
examination include two GNMA-multifamily securities totaling $9.4 million, one certificate of
deposit of $250,000 held at an MDI, and 655 donations or grants totaling $1.2 million. Prior period
investments total $25.5 million for affordable housing projects. The performance in assessment
areas that received limited -scope reviews was generally below the full -scope review areas.
SERVICE TEST
The Service Test rating for North Carolina is High Satisfactory. The bank operates 196 branches in
North Carolina, which represents 35.4 percent of total branches. Delivery systems are accessible to
essentially all portions of the assessment areas, and changes in branches have not adversely affected
low- or moderate -income areas or individuals. The bank provided an adequate level of community
development services in North Carolina. The bank provided 432 community development services
in North Carolina, which equates to 0.8 community development services per branch per year. In
addition, the bank provides mortgage servicing for 304 affordable home mortgages totaling
approximately $80 million for a CDFI located in and serving North Carolina. The servicing of these
loans provides a valuable service for the CDFI to maintain lower operating costs; thus, providing
additional funds for loans. The performance in assessment areas that received limited -scope reviews
was generally consistent the full -scope review areas.
23
NONMETROPOLITAN STATE-WIDE AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NORTH CAROLINA

NON-MSA ASSESSMENT AREA
The NC Non-MSA assessment area consists of 35 counties, which are summarized in Appendix
A. The bank operates 57 or 29.1 percent of its North Carolina branch offices in the NC Non-
MSA assessment area. As shown in Appendix A, the assessment area represents 23.0 percent of
the rated area loans and 25.7 percent of the rated area deposits.
The 2015 ACS Census shows the majority of the owner -occupied housing units, businesses, and
farms are located in middle -income census tracts. The FFIEC has designated certain non -
metropolitan middle -income census tracts as distressed based on high unemployment rates, high
poverty rates, and population losses, or rural underserved based on population size, density, and
dispersion. In the NC Non-MSA assessment area, the FFIEC designated 169 or 76.5 percent of
the 221 middle -income census tracts in 24 of the 35 counties as distressed and/or underserved.
The following table presents demographic information from the 2015 ACS Census and 2017
D&B data.
Demographic Information for the

NC Non-MSA Assessment Area
Low Moderate Middle Upper NA*
Demographic Characteristics
.
#
% of # 'Yo of # % of # % of # % of #
Geographies (Census Tracts) 384 1.8 16.1 57.6 23.4 1.0
Population by Geography 1,579,377 1.0 16.5 61.5 20.9 0.0
Housing Units by Geography 798,851 1.0 15.2 60.4 23.4 0.0
Owner -Occupied Units by Geography 425,709 0.3 14.2 62.8 22.7 0.0
Occupied Rental Units by Geography 189,689 2.5 21.2 58.0 18.4 0.0
Vacant Units by Geography 183,453 1.0 11.6 57.3 30.1 0.0
Businesses by Geography 83,695 1.0 16.4 58.6 24.1 0.0
Farms by Geography 5,481 0.1 15.0 66.0 18.8 0.0
Family Distribution by Income Level 411,094 20.8 17.7 19.4 42.1 0.0
Household Distribution by Income Level 615,398 24.5 15.5 17.2 42.9 0.0
Median Family Income Non-MSAs (2015) $47,794 Median Housing Value $143,358
Median Gross Rent $696
Families Below Poverty Level 15.2%
Source: 2015 ACS Census and 2017 D&B data
Due to rounding, totals nzay not equal 100.0 percent
(*) The NA category consists of geographies that have not been assigned an income classification.
The bank operates in a moderately competitive market. As of June 30, 2018, 46 FDIC -insured
institutions operated 422 branches in the assessment area. Of these institutions, the bank ranked
2nd in total deposits with a market share of 15.4 percent. The top five financial institutions
account for 65.7 percent of the deposit market share.
24
Employment Conditions
According to the Bureau of Labor Statistics, unemployment rates have consistently decreased in
all of the counties. The following table reflects the average annual unemployment rates and
trends for the counties, state, and nation.
Unemp oyment Rates

2016 2017 2018
Area
%
Allegany County 5.5 5.2 4.5
Ashe County 4.8 4.2 3.6
Avery County 5.0 4.4 3.6
Beaufort County 5.7 5.1 4.6
Bladen County 6.9 6.0 5.3
Carteret County 5.2 4.5 4.3
Cherokee County 5.7 5.1 4.4
Clay County 5.5 5.0 4.3
Columbus County 6.4 5.6 5.0
Duplin County 5.3 4.9 4.3
Graham County 8.8 6.8 5.9
Greene County 5.3 4.5 3.9
Halifax County 7.9 7.4 6.1
Harnett County 5.8 5.1 4.6
Jackson County 5.4 4.8 4.1
Lee County 5.9 5.2 4.3
Lenoir County 5.9 4.6 4.0
McDowell County 4.8 4.2 3.4
Macon County 5.4 4.7 3.9
Martin County 6.8 5.8 5.0
Moore County 5.0 4.5 3.8
Pasquotank County 6.3 5.6 4.8
Polk County 4.6 4.2 3.7
Rutherford County 6.7 6.2 5.1
Sampson County 5.5 4.8 4.0
Stanly County 4.6 4.2 3.6
Surry County 4.8 4.3 3.5
Swain County 6.1 5.1 4.3
Transylvania County 4.9 4.4 3.8
Vance County 7.2 6.3 5.7
Warren County 7.3 6.9 5.9
Watauga County 4.5 4.1 3.5
Wilkes County 4.8 . 4.3 3.7
Wilson County 8.1 7.3 6.1
Yancey County 5.2 4.6 3.6
North Carolina 5.1 4.6 4.1
National Average 4.9 4.4 3.9
Source: Bureau of Labor Statistics
In 2017, according to D&B data, the top industries were services, retail trade, and construction.
The top employers could not be determined due to the limited amount of information that is
available for the counties.
25
Considering demographic and economic data, examiners determined that small business loans
represent a primary credit need for the assessment area. The significant percentage of businesses
with gross annual revenues of $1 million or less at 82.3 percent and the large number of
businesses with four or fewer employees at 67.9 percent support this conclusion.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NC NON-MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Non-MSA assessment area reflects good
responsiveness to assessment area credit needs. The geographic distribution reflects adequate
penetration throughout the assessment area, and the borrower profile reflects good distribution to
borrowers of different incomes and businesses and farm of different sizes. In addition, the bank
uses flexible lending practices and is a leader in originating community development loans.
Lending Activity
Lending levels reflect good responsiveness to the assessment area's credit needs. The core tables
in Appendix D detail the number and dollar volume of HMDA and CRA loans in this assessment
area.
The geographic distribution of HMDA, small business, and small farm loans is adequate.
assessment area. The bank did not originate any home purchase, home improvement, or home
refinance loans in low-income census tracts; however, only 0.34 percent of owner -occupied
housing units are in the low-income tracts, and aggregate lending was nominal. In moderate -
income census tracts, all three loan products were below the demographic data but consistent
with the aggregate lending data.
The geographic distribution of small business loans reflects adequate penetration throughout the
assessment area. Small business lending in low-income census tracts was consistent with the
demographic and aggregate lending data. Lending in moderate -income census tracts was below
the demographic data but consistent with the aggregate lending data.
The geographic distribution of small farm loans reflects good penetration throughout the
assessment area. The bank did not originate any small farm loans in low-income census tracts;
however, less than 0.2 percent of small farms were located in low-income census tracts, and
aggregate lenders did not extend any small farm loans in the tracts. Lending in the moderate -
income census tracts was above the demographic data and slightly above the aggregate lending
data.
26
Borrower Profile
The borrower distribution of HMDA, small business, and small farm loans is good.
The distribution of HMDA loans reflects adequate penetration among borrowers of different
income levels. For home purchase loans, performance to low-income borrowers was
significantly below the demographic data but consistent with the aggregate lending data.
Lending to moderate -income borrowers was well below demographic data and below aggregate
lending data. For home improvement and home refinance loans, the bank's performance to low-
income borrowers was well below the demographic and aggregate lending data. Lending to
moderate -income borrowers for both loan types was below the demographic data but consistent
with the aggregate lending data.
The distribution of small business loans reflects excellent penetration among businesses of
different sizes. Performance was significantly above the aggregate lending data but below the
percentage of small businesses. In addition, loans amounts of $100,000 or less, regardless of
business size, were 84.6 percent reflects excellent access to credit for very small businesses.
The distribution of small farm loans reflects good penetration among farms of different sizes.
Lending to farms with gross annual revenues of $1 million or less was significantly above the
aggregate lending data but well below the percentage of small farms. Loans to small farms in
amounts of $100,000 or less, regardless of farm size, were 75.5 percent, which indicates the bank
is meeting the credit needs of small farms.
First -Citizens Bank is a leader in originating community development loans in the NC Non-MSA
assessment area. The bank originated 35 community development loans totaling $156.6
million. This amount represents 35.0 percent by number and 53.3 percent by dollar volume of
community development loans originated within the North Carolina assessment areas
only. Regarding the community development purpose, 7 loans support affordable housing, 11
loans support community services, and 17 loans support revitalization or stabilization. Examples
of community development loans include a $90.0 million loan, through a multi -bank
participation, to a tribal casino enterprise located in a distressed middle -income census tract to
provide funding for the expansion of business operations. As a result, jobs were created for low -
and moderate -income individuals; a $9.0 million loan to a non-profit regional health care
provider for the expansion of a medical center located in a distressed middle -income census
tract; and 2 loans, a loan renewal, and 4 renewal lines of credit totaling $442,000 to a community
development corporation to provide funding for the development of affordable housing
communities throughout the assessment area.
INVESTMENT TEST
The bank has a significant level of qualified investments in the NC Non-MSA assessment area
relative to the bank's operations, exhibiting good responsiveness to credit and community
development needs. Qualified investments total $9.2 million or 25.3 percent of total North
27
Carolina qualified investments. This total consists of $9.1 million in prior period equity
investments supporting affordable housing and 125 donations or grants totaling $104,000. Of
the donations or grants, $5,000 benefited affordable housing, $74,000 benefited community
services, $20,000 benefited economic development, and $5,000 benefited revitalization or
stabilization.
SERVICE TEST
Delivery systems in the Non-MSA assessment area are accessible to essentially all portions of
the assessment area, and the opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank provided an adequate level of community
development services.
The bank operates 57 branches in the assessment area, representing 29.1 percent of branches in
North Carolina. The bank operates 1 branch (1.8 percent) in a low-income tracts and 11
branches (19.3 percent) in moderate -income tracts. Overall, the branching distribution is similar
to the percentage of the population in the respective geographies.
To the extent changes have been made, the opening and closing of branches has not adversely
affected the accessibility of delivery systems, particularly in low- and moderate -income
geographies or to low- and moderate -income individuals. Since the last evaluation, the bank has
not opened any branches. The bank closed three branches with two in middle -income
geographies and one in an upper -income geography.
The institution provided limited level of community development services in this assessment
area. Employees participated in approximately 74 community development services. This
performance represents 17.1 percent of all community development services in the state, which
is below the assessment area's share of branches at 29.1 percent. The community development
services equate to 0.5 services per branch per year. The following are examples of community
development services provided.
An employee provided a financial literacy session on the importance of saving to clients

of a department of social services.
An employee serves on the Board and family selection committee for the Habitat for
Humanity.
An employee partnered with an organization providing services to low- and moderate -
income individuals to provide a financial literacy workshop.
28
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE RALEIGH MSA

ASSESSMENT AREA
The Raleigh MSA assessment area consists of the entire Raleigh, NC MSA, which comprises
Franklin, Johnston, and Wake Counties. The bank operates 33 or 16.8 percent of its North
Carolina branch offices in the Raleigh MSA assessment area. As shown in Appendix A, the
assessment area represents 20.6 percent of the rated area loans and 22.9 percent of the rated area
deposits.
The 2015 ACS Census shows the owner -occupied housing units, businesses, and farms are fairly
evenly distributed between in moderate-, middle-, and upper -income census tracts, with
significantly less opportunities in the low-income tracts. The following table presents
demographic information from the 2015 Census and 2017 D&B data.

Raleigh MSA Assessment Area
Demo g raphic Characteristics

#
% of # % of # % of # % of # % of #
Median Family Income MSA (2015) $78,057 Median Housing Value $226,048
Due to rounding, totals may not equal 100.0 percent.
The bank operates in a highly competitive market. Thirty five FDIC -insured institutions
operated 300 branches within this area as of June 30, 2018. Of these institutions, the bank
ranked 4th in total deposits with a market share of 10.9 percent. The top five financial
institutions account for 74.4 percent of the deposit market share.
29
vmployment tonaitions
According to the Bureau of Labor Statistics, unemployment rates have declined. The following
table reflects the average annual unemployment rates and trends for the counties, state, and
nation. Johnston and Wake Counties have unemployment rates consistently below both state and
national average rates. The unemployment rates in Franklin County were comparable to state
averages but were slightly above national averages for all years under review.
Unemp oyment Rates

2016 2017 2018
Area
Franklin County 5.2 4.6 4.0

Johnston County 4.7 4.1 3.6
Wake County 4.3 3.9 3.4

In 2017, the top industries were professional and business services, government, and education
and health services. The top employers were IBM Corp., WakeMed Health & Hospitals, North
Carolina State University, Rex Healthcare, and SAS Institute Inc.
Considering demographic and economic data, examiners determined small business loans
businesses with four or fewer employees at 70.7 percent support this conclusion. Additionally,
affordable housing represents a need as 39.7 percent of the families are low- and moderate -
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE RALEIGH MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Raleigh MSA assessment area reflects
good responsiveness to assessment area credit needs. The geographic distribution reflects good
uses flexible lending practices and originated a relatively high level of community development
loans.
30
Lending Activity
area.
The geographic distribution of HMDA loans reflects good penetration throughout the assessment
area. For home purchase and refinance loans, performance in low- income census tracts was
consistent with the demographic and aggregate lending data. Home purchase lending in
moderate -income census tracts was slightly below the demographic data but slightly above the
aggregate lending data. Home refinance lending in moderate -income census tracts was
consistent with the demographic data and above the aggregate lending data. For home
improvement loans, performance in low-income census tracts was above the demographic and
aggregate lending data. However, in 2016, the bank did not extend any of its 27 home
improvement loans in low-income census tracts. Home improvement lending in moderate -
income census tracts was below the demographic data but consistent with the aggregate lending
data.
assessment area. Small business loans in low-income census tracts were consistent with the
demographic and aggregate lending data. Performance in moderate -income census tracts was
above the demographic and aggregate lending data.
The geographic distribution of small farm loans reflects excellent penetration throughout the
assessment area. Small farm loans in low-income census tracts were above the demographic
data and consistent with the aggregate lending data. The bank's performance in moderate -
income census tracts substantially exceeded the demographic and aggregate lending data.
Borrower Profile
incomes. For home purchase and home refinance loans, performance to low-income borrowers
was below demographics but above the aggregate lending data. Performance for home purchase
loans to moderate -income borrowers was consistent with the demographic data but slightly
below the aggregate lending data. Home refinance lending to moderate -income borrowers was
below the demographics and well below aggregate lending data. For home improvement loans,
performance was poor, as lending to low- and moderate -income borrowers was significantly
below the demographic and aggregate lending data. Further, in 2016, the bank did not originate
any of its 27 home improvement loans to low- or moderate -income borrowers.
31
The distribution of small business loans reflects good penetration among businesses of different
sizes. Performance was well below the demographic data but above aggregate lending data.
Further, loans in amounts of $100,000 or less, regardless of size of the business, were 78.7
percent, which reflects good access to credit for very small businesses.
The borrower distribution of small farm loans reflects good penetration among farms of different
sizes. Performance was significantly below the demographic data but well above aggregate
lending data.
First -Citizens Bank originated a relatively high level of community development loans in the
Raleigh MSA assessment area. The bank originated 20 community development loans totaling
$35.2 million. This amount represents 20.0 percent by number and 12.0 percent by dollar
volume of total community development loans within North Carolina assessment areas
loans support community services, 1 loan supports economic development, and 1 loan supports
revitalization or stabilization. Examples of community development loans include an $8.0
million renewal line of credit to a CDFI to provide liquidity for the financing of affordable
housing loans in the assessment area; an $8.5 million loan for the construction of a 96 -unit
LIHTC affordable housing development; and 2 renewal lines of credit totaling $1.4 million to a
non-profit affordable housing development organization that develops and manages affordable
housing and offers homeownership education courses.
INVESTMENT TEST
The bank has a significant level of qualified investments in the Raleigh MSA assessment area
development needs. Qualified investments total $5.7 million, or 15.7 percent of total North
Carolina qualified investments. This total includes prior period equity investments of
approximately $5.2 million and 117 donations or grants totaling $533,000. Of the donations or
grants, $18,000 benefited affordable housing, $325,000 benefited community services, $147,000
benefited economic development, and $43,000 benefited revitalization or stabilization.
SERVICE TEST
Delivery systems in the Raleigh MSA assessment area are accessible to essentially all portions of
the assessment area, and the opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank provided a relatively high level of community
North Carolina. Three branches (9.1 percent) are located in low-income tracts with 10 branches
32
(30.3 percent) in moderate -income tracts. Overall, the branching distribution is similar to the
percentage of the population in the respective geographies.
affected the accessibility of its delivery systems, particularly in low- and moderate -income
not opened any branches, but it closed one branch in an upper -income geography.
The institution provided an adequate level of community development services in this

assessment area. Employees participated in 66 community development services. This
is similar to the assessment area's share of branches at 16.8 percent. The community
development services equate to 0.7 services per branch per year. The following are examples of
community development services provided in this assessment area.
An employee serves on the Board of a foundation that provides college grants and
scholarships for students from low-income families.
An employee serves on the Board of an affordable multi -family housing lending
consortium.
An employee provided a financial literacy session on the basics of business banking and
getting your small business started to the participants of a community college small
business center.
An employee provided a financial literacy session on how to build and re -build credit and
general banking knowledge to clients of a non-profit consumer education services
organization.
33
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ASHEVILLE MSA

ASSESSMENT AREA
The Asheville MSA assessment area comprises the entire Asheville, NC MSA, which consists of
Buncombe, Haywood, Henderson, and Madison Counties. The bank operates 21 or 10.7 percent
of its North Carolina branch offices in the Asheville MSA assessment area. As shown in
Appendix A, the assessment area represents 11.5 percent of the rated area loans and 11.5 percent
of the rated area deposits.
farms are in middle -income census tracts. The following table presents demographic
information from the 2015 ACS Census and 2017 D&B data.

Asheville MSA Assessment Area
Demographic Characteristics #
% of # % of # % of # % of # % of #
Population by Geography 437,252 1.6 14.0 63.9 20.5 0.0
Due to rounding, totals may not equal 100.0 percent
institutions operated 114 branches within this area. Of these institutions, the bank ranked 2nd in
total deposits with a market share of 19.1 percent. The top five financial institution accounts for
64.6 percent of the deposit market share.
table reflects the average annual unemployment rates and trends for the counties, state, and
34
nation. The average unemployment rates were below state and national averages for the counties
in the assessment area for all years under review, except in 2016 when Madison County was
consistent with the national average rate.
Unemp oyment Rates

2016 2017 2018
Area % % %
Buncombe County 3.9 3.4 3.0
Haywood County 4.5 4.0 3.4
Henderson County 4.3 3.8 3.2
Madison County 4.9 4.2 3.6

In 2017, the top industries were education and health services, leisure and hospitality services,
and retail trade. The top employers were Mission Health System and Hospital, Ingles Markets
Inc., VA Medical Center, The Biltmore Co., and The Omni Grove Park Inn.
affordable housing represents a need as 38.8 percent of the families.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ASHEVILLE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Asheville MSA assessment area reflects
borrowers of different incomes and businesses of different sizes. In addition, the bank used
flexible lending practices and is a leader in originating community development loans.
Lending Activity
area.
35
The geographic distribution of HMDA and small business loans is good.
assessment area. For home purchase loans, performance in low-income census tracts was
consistent with the demographic and aggregate lending data. Performance in moderate -income
census tracts was below the demographic and aggregate lending data. The bank did not originate
any home improvement loans in low-income census tracts; however, only 1.3 percent of owner -
occupied housing is in the low-income tracts, and aggregate data stood at 2.3 percent. Home
improvement lending in moderate -income census tracts was slightly below the demographic and
aggregate lending data. For home refinance loans, performance in low-income census tracts was
above the demographic and aggregate lending data. Lending performance in moderate -income
census tracts was slightly below the demographic data but consistent with the aggregate lending
data.
assessment area. Small business loans in both low- and moderate -income census tracts were
consistent with the demographic and aggregate lending data.
Borrower Profile
The distribution of HMDA and small business loans to borrowers of different incomes and
businesses of different sizes is good.
incomes. For home purchase and home refinance loans, performance to low-income borrowers
was significantly below demographics but consistent with the aggregate lending data.
Performance for home purchase and home refinance loans to moderate -income borrowers was
well below the demographic and aggregate lending data. For home improvement loans, lending
to low-income borrowers was significantly below the demographic and below the aggregate
lending data. For moderate -income borrowers, performance was below aggregate and
demographic data. However, in 2016, approximately 50.0 percent of home improvement loans
originated to low- or moderate -income borrowers.
sizes. Performance was well below demographic data but well above the aggregate lending data.
Further, loans in amounts of $100,000 or less, regardless of the business size, were 82.0 percent,
which reflects good access to credit for very small businesses.
First -Citizens Bank is a leader in originating community development loans in the Asheville
MSA assessment area. The bank originated 11 community development loans totaling $60.8
community development loans in North Carolina. Regarding the community development
36
purpose, 1 loan supports affordable housing, 5 loans support community services, 3 loans
support economic development, and 2 loans support revitalization or stabilization. Examples of
community development loans include a $43.0 million loan to a non-profit health care system for
the construction of a hospital, a $975,000 loan to a community development corporation that
develops and repairs affordable housing, and a $150,000 loan to a CDFI that provides capital to
small businesses and non-profit organizations to support job creation and economic
development.
INVESTMENT TEST
The bank has poor level of qualified investments in the Asheville MSA assessment area relative
to the bank's operations, exhibiting adequate responsiveness to credit and community
development needs. Qualified investments consisted of 106 donations or grants totaling
$193,000 or 0.5 percent of total North Carolina qualified investments. Of these donations/grants,
$5,000 benefits affordable housing, $152,000 benefit community services, $26,000 benefits
economic development, and $10,000 benefits revitalization or stabilization.
SERVICE TEST
Delivery systems are accessible to essentially all portions of the assessment area, and the
opening and closing of branches has not adversely affected the accessibility of delivery systems.
North Carolina. None of the branches are in low-income tracts; however, the population in low-
income tracts is low at 1.6 percent. Three branches (14.3 percent) are in moderate -income tracts.
Overall, the branching distribution is similar to the percentage of the population in the respective
geographies.
geographies or to low- and moderate -income individuals. During the last evaluation period, the
bank did not open any branches, but it closed a branch in a middle -income geography.
The institution provided a relatively high level of community development services in this
assessment area. Employees participated in approximately 48 community development services.
This performance represents 11.1 percent of all community development services in the state,
which is similar to the assessment area's share of branches at 10.7 percent. The community
community development services provided.
37
An employee serves as a loan committee member for a non-profit organization that
provides lending directed at creating jobs in the Appalachian region.
An employee provided a financial literacy session for clients of an affordable housing
organization, focusing on how to improve credit scores; and budget and save for
mortgage loan down payments.
An employee serves on a committee of an affordable housing advisory council.
38
OTHER NORTH CAROLINA ASSESSMENT AREAS
(Limited -Scope Review)
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LIMITED SCOPE REVIEW

NORTH CAROLINA ASSESSMENT AREAS
The following table summarizes the conclusions for the 12 North Carolina assessment areas
reviewed using limited -scope examination procedures. Examiners drew conclusions regarding
the institution's CRA performance from reviewing available facts and data, including
performance figures, aggregate lending data comparisons, and demographic information. The
conclusions did not alter the overall performance rating.
Assessment Area Lending Test Investment Test Service Test

Wilmington MSA Consistent Below Consistent
Greensboro MSA Consistent Below Above
Hickory MSA Consistent Consistent Below
Durham MSA Consistent Above Below
Fayetteville MSA Consistent Below Consistent
Goldsboro MSA Consistent Consistent Consistent
Greenville MSA Consistent Above Above
Jacksonville MSA Below Below Below
New Bern MSA Below Below Above
Rocky Mount MSA Below Below Consistent
Virginia Beach MSA Below Below Consistent
Winston-Salem MSA Consistent Below Consistent
A summary of First -Citizens Bank's operations and activities for each limited -scope assessment
area follows with additional information in the core tables in Appendix D. Please note that the
HMDA, small business and small farm lending figures in the activity table in the "Conclusions
on Performance Criteria" section for each limited -scope review area below are based on the
combined 2016 and 2017 lending data, while the figures for the community development loans,
investments, and services are from June 6, 2016, to March 26, 2019.
39
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE WILMINGTON MSA

ASSESSMENT AREA
The Wilmington MSA assessment area is a contiguous area consisting of New Hanover and
Pender Counties. These two counties fully compose the Wilmington, NC MSA assessment area.
Demographic data for the assessment area follows.

Wilmington MSA Assessment Area
% of # % of # % of #
% of # % of #
Farms by Geography 571 7.2 25.9 37.5 29.2 0.2
Median Family Income MSA $64,357 Median Housing Value $222,834
The assessment area is moderately competitive in the financial services market. According to
the FDIC Deposit Market Share data as of June 30, 2018, 20 financial institutions operated 72
full -service branches within the assessment area. Of these institutions, First -Citizens Bank
ranked 4th with 9.7 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE WILMINGTON MSA

ASSESSMENT AREA
First -Citizens Bank operates 10 branches in this assessment area. The bank originated and
engaged in the following activities in the assessment area during the review period.
40
Activity # $
Small Business Loans 1,183 $123.9 million
HMDA Loans 335 $103.2 million
Small Farm Loans 21 $3.1 million
Community Development Loans 7 $2.4 million
Investments (New) -- --
Investments (Prior Period) -- --
Donations 41 $59,000
CD Services 38 --
41
METROPOLITAN AREAS
(Limited -Scope)
L*
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE GREENSBORO MSA
ASSESSMENT AREA
The Greensboro MSA assessment area is a contiguous area consisting of Guilford, Randolph,
and Rockingham Counties. These three counties fully compose the Greensboro -High Point, NC
MSA assessment area. Demographic data for the assessment area follows.

Greensboro MSA Assessment Area
ow Mo Berate Middle Upper
% of # % of # of #
(1/0 of # ° A of # %NA

Population by Geography - 741,433 5.7 23.3 42.8 28.1 0.0
Median Family Income MSA- (2015) $55,218 Median Housing Value $145,143
Due to rounding. totals may not equal 100.0 percent
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE GREENSBORO MSA

ASSESSMENT AREA
42
Activity # $
Small Business Loans 935 $107.3 million
Small Farm Loans 13 $480,000
Community Development Loans 1 $50,000
Investments (Prior Period) -- $448,000
CD Services 42 --
43
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE HICKORY MSA

ASSESSMENT AREA
The Hickory MSA assessment area is a contiguous area consisting of Alexander, Burke,
Caldwell, and Catawba Counties. These four counties fully compose the Hickory -Lenoir -
Morganton, NC MSA assessment area. Demographic data for the assessment area follows.

Hickory MSA Assessment Area
% of # % of # % of # (1/0 of # % of #
ranked 3rd with 14.9 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE HICKORY MSA

ASSESSMENT AREA
44
Activity # $
Small Business Loans 1,204 $103.0 million
Investments (Prior Period) -- $1.4 million
CD Services 9 --
45
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE DURHAM MSA

ASSESSMENT AREA
The Durham MSA assessment area is a contiguous area consisting of Chatham, Durham, and
Orange Counties. The Durham -Chapel Hill, NC MSA has four counties within in its boundaries;
however, the bank has only delineated three counties as its assessment area. Demographic data
for the assessment area follows.

Durham MSA Assessment Area
% of # % of # % of # % of # % of #



CONCLUSIONS ON PERFORMANCE CRITERIA IN THE DURHAM MSA

ASSESSMENT AREA
First -Citizens Bank operates eight branches in this assessment area. The bank originated and
46
Activity # .$
Investments (New) -- $2.9 million
CD Services 15 --
47
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE FAYETTEVILLE MSA

ASSESSMENT AREA
The Fayetteville MSA assessment area consists of Cumberland County. The Fayetteville, NC
MSA has two counties; however, the bank has only delineated the one county as its assessment
area. Demographic data for the assessment area follows.

Fayetteville MSA Assessment Area
% of #
% of # °A) of # % of # (1/0 of #


Farms by Geography 439 . 0.2 9.8 62.6 27.3 0.0
Due to rounding. totals nzay not equal 100.0 percent
ranked 2" with 17.5 percent deposit market share. The top five financial institution accounts for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE FAYETTEVILLE MSA

ASSESSMENT AREA
First -Citizens Bank operates nine branches in this assessment area. The bank originated and
48
Activity # S
CD Services 20 --
49
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE GOLDSBORO MSA

ASSESSMENT AREA
The Goldsboro MSA assessment area consists of Wayne County, which composes the
Goldsboro, NC MSA. Demographic data for the assessment area follows.

Goldsboro MSA Assessment Area
°A of # % of # % of # % of # % of #
Median Family Income MSA -(2015) $50,552 Median Housing Value $110,634
Source: 2015 ACS Census and 20/7 D&B data
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE GOLDSBORO MSA

ASSESSMENT AREA
First -Citizens Bank operates three branches in this assessment area. The bank originated and
50
Activity # $
Small Fann Loans 48 $4.2 million
CD Services 9 --
51
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE GREENVILLE MSA

ASSESSMENT AREA
The Greenville MSA assessment area consists of Pitt County, which composes the Greenville,
NC MSA. Demographic data for the assessment area follows.

Greenville MSA Assessment Area
'% of # % of # % of # °A of # % of #
Median Family Income MSA - (2015) $56,239 Median Housing Value $128,235
ranked 3rd with 13.8 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE GREENVILLE MSA

ASSESSMENT AREA
First -Citizens Bank operates six branches in this assessment area. The bank originated and
52
Activity # $
LIMDA Loans 151 $30.1 million
CD Services 46 --
53
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE JACKSONVILLE MSA

ASSESSMENT AREA
The Jacksonville MSA assessment area consists of Onslow County, which composes the
Jacksonville, NC MSA. Demographic data for the assessment area follows.

Jacksonville MSA Assessment Area
% of #
% of # ')/0 of # 4)/0 of # % of #
Farms by Geography 292 0.0 - 6.2 78.8 15.1 0.0
ranked 1st with 37.1 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE JACKSONVILLE MSA

ASSESSMENT AREA
First -Citizens Bank operates seven branches in this assessment area. The bank originated and
54
Activity # $
HIMDA Loans 64 $10.5 million
Small Fann Loans 15 $741,000
CD Services 10 --
55
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NEW BERN MSA

ASSESSMENT AREA
The New Bern MSA assessment area is a contiguous area consisting of Craven, Jones, and
Pamlico Counties. These three counties fully compose the New Bern, NC MSA. Demographic
data for the assessment area follows.

New Bern MSA Assessment Area
% of # % of # % of # % of # % of #
Median Family Income (2015) $55,158 Median Housing Value $145,650
ranked 2'd with 25.4 percent deposit market share. The top five financial institution accounts for
94.4 percent of the total deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NEW BERN MSA

ASSESSMENT AREA
56
Activity # $
Community Development Loans -- --
CD Services 29 --
57
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ROCKY MOUNT MSA

ASSESSMENT AREA
The Rocky Mount MSA assessment area consists of Nash County. The Rocky Mount, NC MSA
has two counties; however, the bank has only delineated the one county as its assessment area.

Rocky Mount MSA Assessment Area
Demo graphic Characteristics #
% of # % of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ROCKY MOUNT MSA

ASSESSMENT AREA
First -Citizens Bank operates one branch in this assessment area. The bank originated and
58
Activity # $
Donations 1 $1,000
CD Services 3 --
59
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE VIRGINIA BEACH MSA

ASSESSMENT AREA
The Virginia Beach MSA assessment area consists of Gates County. The Virginia Beach -
Norfolk -Newport News, VA -NC MSA has seven counties and nine independent cities; however,
the bank has only delineated the one county as its assessment area. Demographic data for the
assessment area follows.

Virginia Beach MSA Assessment Area
°A of # % of # % of # % of # % of #
Occupied Rental Units by Geography 898 0.0 34.3 65.7 0.0 0.0
Vacant Units by Geography 823 0.0 49.9 50.1 0.0 0.0
Businesses by Geography 366 0.0 39.9 60.1 0.0 0.0
the FDIC Deposit Market Share data as of June 30, 2018, 2 financial institutions operated 2 full -
service branches within the assessment area. Of these institutions, First -Citizens Bank ranked
2" with 45.6 percent deposit market share. The top financial institution accounts for 54.4
percent of the deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE VIRGINIA BEACH MSA

ASSESSMENT AREA
60
Activity # $
Small Business Loans 16 $459,000
HMDA Loans 2 $109,000
Donations -- --
CD Services 3 --
61
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE WINSTON-SALEM MSA
L*
ASSESSMENT AREA
The Winston-Salem MSA assessment area is a contiguous area consisting of Forsyth, Stokes,
and Yadkin Counties. The Winston-Salem, NC MSA has five counties; however, the bank has
only delineated the three counties as its assessment area. Demographic data for the assessment
area follows.

Winston-Salem MSA Assessment Area
ow Moderate Middle Upper
(1/0 of # % of # % of # % of # of
%NA #


The assessment area is highly competitive in the financial services market. According to the
FDIC Deposit Market Share data as of June 30, 2018, 18 financial institutions operated 111 full -
service branches within the assessment area. Of these institutions, First -Citizens Bank ranked 5th
with 1.8 percent deposit market share. The top five financial institutions account for 93.2
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE WINSTON-SALEM MSA

ASSESSMENT AREA
62
Activity # $
CD Services 20 --
63
SOUTH CAROLINA
CRA RATING FOR SOUTH CAROLINA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the South Carolina performance considered the operations of First -Citizens
Bank in eight assessment areas, which are detailed in Appendix A. Examiners conducted full -
scope reviews of performance in the Columbia MSA, Charleston MSA, Greenville MSA, and SC
Non-MSA assessment areas. A significant portion of the bank's loans (84.1 percent), deposits
(81.0 percent), and branches (80.9 percent) in South Carolina are concentrated in these
assessment areas. Small business and home mortgage loans were reviewed in all assessment
areas, while small farm loans were only reviewed in the full -scope SC Non-MSA assessment
area. Small business loans constitute the primary loan type by number in South Carolina.
Therefore, examiners based performance evaluation and conclusions primarily upon the small
business lending, except within the Charleston MSA assessment area where home mortgage
lending constitute the primary product.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN SOUTH CAROLINA
The bank operates 115 or 20.8 percent of branch offices in South Carolina. South Carolina
accounts for 20.5 percent of the bank -wide deposits and 20.5 percent of loans. Overall, First -
Citizens Bank ranks 4th in the state in deposit share at 8.7 percent. Competitor institutions in the
assessment areas include Wells Fargo Bank, NA; Bank of America, NA; and BB&T. Together,
the three competitor institutions account for 46.0 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN SOUTH CAROLINA
LENDING TEST
The Lending Test rating for South Carolina is High Satisfactory. Lending levels reflect good
responsiveness to the South Carolina assessment areas' credit needs. The geographic distribution
reflects good penetration, and the borrower profile reflects a good distribution. In addition, the bank
uses flexible lending practices and originated a relatively high level of community development loans.
The performance in the limited -scope Florence MSA and Hilton Head MSA assessment areas was
consistent with the full -scope review areas. However, performance in the limited -scope
Spartanburg MSA and Sumter MSA assessment areas was below the performance in the full -scope
review areas.
64
Lending Activity
Lending levels reflect good responsiveness to the South Carolina assessment areas' credit needs. The
tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for each
South Carolina assessment area.
The geographic distribution of home mortgage loans reflects adequate penetration throughout the
assessment areas. Adequate performance in all the full -scope assessment areas primarily
supports this conclusion.
assessment areas. Good performance in the Charleston MSA, Columbia MSA, and SC Non-
MSA assessment areas and adequate performance in the Greenville MSA assessment area
primarily supports this conclusion.
assessment area. Good performance in the SC Non-MSA assessment area supports this
conclusion.
Borrower Profile
The distribution of HMDA, small business loans, and small farms to borrowers of different
The distribution of home mortgage loans is good among borrowers of different income levels.
Good performance in all four full -scope assessment areas supports this conclusion.
The distribution of loans is good among businesses of different sizes. Excellent performance in
the Columbia MSA assessment area and good performance in the Charleston, Greensville MSA,
and SC Non-MSA assessment areas primarily supports this conclusion.
The distribution of loans is good among farms of different sizes. Good performance in the SC
Non-MSA assessment area supports this conclusion.
First -Citizens Bank originated a relatively high level of community development loans in South
Carolina. During this evaluation period, the bank originated 71 community development loans
totaling approximately $150.8 million. This represents 18.9 percent by number and 21.1 percent
by dollar volume of bank -wide community development loans. The percent of community
development loans by number and dollar volume in the state is commensurate with the bank -
wide lending levels at 20.5 percent. One loan totaling $850,000 was originated outside the
65
assessment areas but within the broader state-wide area. Since the bank has been responsive to
community development needs and opportunities within its assessment areas, the loans were
included. The analysis for each full -scope assessment area includes a discussion of community
development loans.
INVESTMENT TEST
The Investment Test performance is rated High Satisfactory in South Carolina. The bank has a
significant level of qualified investments and donations of $27.0 million in South Carolina
relative to the operations in the state. This assessment is primarily supported by the significant
investments in the SC Non-MSA assessment area where over 99.0 percent of the middle -income
census tracts are either distressed or underserved. The total qualified investments in South
Carolina represent 8.0 percent of bank -wide qualified investments. Investments include four
GNMA-multifamily securities totaling $19.0 million, one certificate of deposit in the amount of
$250,000 at an MDI, and 432 donations or grants totaling $914,000. Further, prior period
investments total $6.8 million for affordable housing projects. GNMA- multifamily securities
supporting affordable housing represented the highest percentage of total investments at 70.4
percent. The performance in the limited -scope Sumter MSA and Hilton Head MSA assessment
areas was below the full -scope review areas. However, performance in the limited -scope
Spartanburg MSA assessment was above and Florence MSA assessment area was consistent with
the full -scope review areas.
SERVICE TEST
The Service Test rating for South Carolina is High Satisfactory. The bank operates 115 branches
in South Carolina which represents 20.8 percent of all branches. Delivery systems are accessible
to essentially all portions of the assessment areas. The bank closed a total 15 branches with 5
branches in low- and moderate -income geographies since the last evaluation. The closures have
generally not adversely affected low- or moderate -income areas or individuals, because the
percent of branches in low- and moderate -income geographies is still similar to the percent of
population in those geographies. In addition, the bank provided a relatively high level of
community development services in South Carolina. The bank provided 277 community
development services in South Carolina, which equates to 0.9 community development services
per branch per year. Further, the bank provides mortgage servicing for two non-profit
organizations that provide affordable housing in South Carolina. The servicing of these 512
loans totaling approximately $18.0 million provides a valuable service for the entities to maintain
lower operating costs; thus, providing additional funds for loans. The performance in the
limited -scope assessment areas was consistent or above the full -scope review areas.
66
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE COLUMBIA

ASSESSMENT AREA
The Columbia MSA assessment area consists of Fairfield, Kershaw, Lexington, Richland, and
Saluda. The Columbia, SC MSA has six counties; however, the bank did not delineate Calhoun
County as part of its assessment area. The bank operates 25 or 21.7 percent of its South Carolina
branch offices in this assessment area. As shown in Appendix A, the assessment area represents
23.0 percent of the rated area loans and 28.2 percent of the rated area deposits.
The 2015 ACS Census shows that owner -occupied housing units, businesses, and farms are
relatively equally distributed among moderate-, middle-, and upper -income census tracts. The
following table presents demographic information from the 2015 ACS Census and 2017 D&B
data.

Columbia MSA Assessment Area
Demo graphic Characteristics Low Moderate Middle Upper NA*

#
% of # % of # % of # % of # % of #
institutions operated 177 branches within the area. Of these institutions, the bank ranked 4th in
total deposits with a market share of 9.1 percent. The top five financial institutions account for
67
table reflects the average unemployment rates and trends for the assessment area, state, and
nation. Most counties have unemployment rates consistently below both state and national
average rates. However, Fairfield County's annual unemployment rates were consistently
higher.
Unemployment Rates
2016 2017 2018
Area
Fairfield County 7.2 7.4 6.4

Kershaw County 5.2 4.5 3.7
Lexington County 4.1 3.6 3.0
Richland County 4.8 4.3 3.6
Saluda County 4.5 3.9 3.2
South Carolina 5.0 4.3 3.8
In 2017, the top industries were government, education and health services, and professional and
business services. The top employers were Palmetto Health, Blue Cross & Blue Shield of South
Carolina, University of South Carolina, Lexington Medical Center, and Wal-Mart Services Inc.
affordable housing represents a need as 39.7 percent of the families are categorized as low- or
moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE COLUMBIA MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Columbia MSA assessment area reflects
penetration throughout the assessment area, and the borrower profile reflects an excellent
distribution to borrowers of different incomes and businesses of different sizes. In addition, the
bank uses flexible lending practices and originated a relatively high level of community
development loans.
68
Lending Activity
area.
assessment area. For home purchase loans, performance in low-income census tracts was
consistent with the demographic data and above aggregate lending data. Lending in moderate -
income census tracts was well below the demographic data but consistent with aggregate
lending. For home improvement loans, performance in low-income census tracts was consistent
with the demographic and above aggregate lending. However, lending in moderate -income
census tracts was below the demographic and aggregate lending data. For home refinance loans,
performance in low-income census tracts was above the demographic and aggregate lending
data. Lending in moderate -income census tracts was below the demographic data but above the
aggregate lending data.
assessment area. In 2017, small business lending in low- and moderate -income census tracts was
consistent with the demographic and aggregate lending data. Additionally, 2016 performance in
both low- and moderate -income census tracts was consistent with the demographic data and
exceeded the aggregate lending data.
Borrower Profile
businesses of different sizes is excellent, which is primarily supported by the excellent small
business lending.
The borrower distribution of HMDA loans reflects good penetration among borrowers of
different incomes. For home purchase loans, performance to low-income borrowers was well
below demographics and was slightly above the aggregate lending data. Lending to moderate -
income borrowers was above the demographic data but was slightly below the aggregate lending
data. For home improvement loans, performance to low-income borrowers was below but was
more than double aggregate lending. Lending to moderate -income borrowers was consistent
with the demographic and aggregate lending data. For home refinance loans, performance to
low-income borrowers was well below the demographics and was slightly above aggregate
lending data. Lending to moderate -income borrowers exceeded the demographic and aggregate
lending data.
The distribution of small business loans reflects excellent penetration among businesses of
different sizes. Performance was slightly below the demographic data but substantially above
69
the aggregate lending data. Further, loans in amounts of $100,000 or less, regardless of business
size, were 85.1 percent, which reflects excellent access to credit for very small businesses.
Columbia MSA assessment area. The bank originated 18 community development loans totaling
$23.7 million. This amount represents 25.7 percent by number and 15.8 percent by dollar
volume of community development loans within the South Carolina assessment areas
loans support community services, and 6 loans support revitalization or stabilization. Examples
of community development loans include a $2.9 million line of credit to a non-profit housing
authority that provides affordable housing, a $3.4 million loan to a non-profit organization that
provides comprehensive healthcare services for low- and moderate -income individuals, and a
$9.5 million loan to fund infrastructure improvements for a school district with a majority of
students receiving free or reduced -cost lunch.
INVESTMENT TEST
The bank has a poor level of qualified investments and donations of $736,000 in the Columbia
MSA assessment area, which exhibits poor responsiveness to credit and community development
needs. This total represents 2.7 percent of total South Carolina qualified investments.
Investments include one $250,000 certificate of deposit maintained at an MDI, and 151 donation
and/or grant contributions totaling $486,000. Of these donations and grants, $47,000 benefits
affordable housing, $382,000 benefit community services, $46,000 benefit economic
development, and $11,000 benefit revitalization or stabilization.
SERVICE TEST
opening and closing of branches has not adversely affected the accessibility of its delivery
systems. The bank provided a relatively high level of community development services.
South Carolina. Two branches (8.0 percent) are in low-income tracts with 9 branches (16.7
percent) in moderate -income tracts. Overall, the branching distribution in low- and moderate -
income census tracts is similar to the percentage of the population in low-income geographies
and slightly higher in moderate -income geographies.
70
not opened any branches in this assessment area. The bank closed four branches with two in
moderate -income tracts, and one each in a middle -income and an upper -income geography.
is similar to the assessment area's share of branches at 21.7 percent. Community development
An employee serves on the Board for an organization that assists small businesses by
providing loans to businesses that are unable to get traditional bank financing.
An employee serves on the Board of an organization that provides affordable housing.
An employee provided a financial literacy session on how poor credit impacts
homeownership in collaboration with a community development office whose mission is
to improve the quality of life by providing economic, housing, and social opportunities.
71
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE CHARLESTON MSA

ASSESSMENT AREA
The Charleston MSA assessment area consists of the entire Charleston -North Charleston, SC
MSA, which comprises Berkeley, Charleston, and Dorchester Counties. The bank operates 18 or
15.7 percent of South Carolina branch offices in the assessment area. As shown in Appendix A,
the assessment area contains 26.3 percent of the rated area loans and 14.5 percent of the rated
area deposits when compared to the bank's total performance in South Carolina.
The 2015 ACS Census showed the highest volume of the owner -occupied housing units,
businesses, and farms are in middle- and upper -income census tracts. The following table
presents demographic information from the 2015 ACS Census and 2017 D&B data.

Charleston MSA Assessment Area
% of # % of # (1/0 of # % of # % of #
Median Gross Rent $1,021
The bank operates in a highly competitive market. As of June 30, 2018, 32 FDIC -insured
institutions operated 189 branches within this area. Of these institutions, the bank ranked 5th in
total deposits with a market share of 6.5 percent. The top four financial institutions account for
72
nation. All assessment area counties have unemployment rates consistently below state and
national average rates.
Unemployment Rates
2016 2017 2018
Area
%
Berkeley County 4.6 3.8 3.2
Charleston County 4.1 3.5 2.9
Dorchester County 4.6 3.8 3.2
In 2017, the top industries were government, professional and business services, and leisure and
hospitality services. The top employers were Joint Base Charleston, Medical University of
South Carolina, Boeing Co., Roper of St. Francis, and SPAWAR-Atlantic.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CHARLESTON MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Charleston MSA assessment area reflects
adequate responsiveness to assessment area credit needs. The geographic distribution reflects
adequate penetration throughout the assessment area, and the borrower profile reflects good
development loans.
Lending Activity
Lending levels reflect adequate responsiveness to the assessment area's credit needs. The core
tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in this
assessment area.
The geographic distribution of HMDA and small business loans is adequate.
73
assessment area. In 2017, home purchase lending in low-income census tracts was consistent
with the demographic data but exceeded aggregate lending. Lending in moderate -income census
tracts was below the demographic data but above aggregate lending data. In 2016, home
purchase lending in moderate -income census tracts was below demographic and aggregate data.
Home refinance lending in low-income census tracts was above the demographic data and well
above aggregate lending data. Lending in moderate -income census tracts was below the
demographic data but slightly above aggregate lending data. In 2016, home refinance lending in
moderate -income census tracts was below the demographic data and the aggregate lending data.
demographic and aggregate lending data. Lending in moderate -income census tracts was above
the demographic and aggregate lending data.
Borrower Profile
The distribution of HMDA and small business loans is good to borrowers of different incomes
and businesses of different sizes.
The distribution of HMDA loans reflects good penetration among borrowers of different
incomes. For home purchase and refinance loans, performance to low-income borrowers was
well below the demographics but above aggregate lending data. Lending to moderate -income
borrowers for both loan types was above the demographic and aggregate lending data.
sizes. Lending to small businesses was well above the demographics. Further, loans in amounts
of $100,000 or less, regardless of size of the business, were 76.8 percent, which reflects good
access to credit for very small businesses.
Charleston MSA assessment area. The bank originated five community development loans
totaling $27.5 million, which were responsive to the assessment area needs. This amount
represents 7.1 percent by number and 18.3 percent by dollar volume of community development
lending within the South Carolina assessment areas. Regarding the community development
purpose, two loans support community services and three loans support revitalization or
stabilization. Examples of community development loans include financing totaling $13.7
million and $5.5 million for two businesses to construct industrial buildings in moderate -income
census tracts, which border an Opportunity Zone; and an $8.0 million line of credit to renovate
one of the newly constructed industrial buildings, which created 100 jobs.
74
INVESTMENT TEST
The bank has a poor level of qualified investments and donations of $550,000 in the Charleston
MSA assessment area, which exhibits poor responsiveness to credit and community development
needs. This total represents 2.0 percent of total South Carolina qualified investments and
consisted of one prior period equity investment of $447,000 that supports affordable housing and
45 donations totaling $103,000. Of these donations, $6,000 benefits affordable housing; $67,000
benefit community services; and $30,000 benefits economic development.
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the assessment area and
the opening and closing of branches generally not adversely affected the accessibility of its
delivery systems in low-income geographies. The bank provided a relatively high level of
community development services.
The bank operates 18 branches in the assessment area, representing 15.7 percent of the bank's
branches in South Carolina. The population percentage in low-income geographies is low at 6.7
percent, and the bank does not have any branches in the low-income geographies. The
percentage of branches in moderate -income geographies is 33.3 which compares favorably to the
population percentage in moderate -income geographies of 21.4.
To the extent changes have been made, the opening and closing of branches generally not
adversely affected the accessibility of its delivery systems in low-income geographies. Since the
last evaluation, the bank opened one branch in upper -income geography. The bank has closed
two branches with one in a low-income geography and one in a middle -income geography.
is slightly higher than the assessment area's share of branches and deposits. Community
An employee serves on the Board of a housing authority that assists low-income families
by helping them attain safe, decent, and affordable housing.
An employee partnered with an organization that provides homebuyer resources and
knowledge to low- and moderate -income families to hold a financial literacy session on
the home buying process.
75
An employee serves on the loan committee of a CDC that provides financing to small
businesses through the SBA 504 loan program.
An employee serves on the Board of a redevelopment corporation whose mission is to
facilitate affordable housing and neighborhood revitalization.
76
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE GREENVILLE MSA

ASSESSMENT AREA
The Greenville MSA assessment area consists of the entire Greenville -Anderson -Mauldin, SC
MSA, which includes Anderson, Greenville, Laurens, and Pickens Counties. The bank operates
18 or 15.7 percent of its South Carolina branch offices in this assessment area. As shown in
Appendix A, the assessment area contains 18.4 percent of the rated area loans and 14.3 percent
of the rated area deposits.
The 2015 ACS Census showed that the largest percentage of owner -occupied housing units,
businesses, and farms are located in middle -income census tracts. The following table presents
demographic information from the 2015 ACS Census and 2017 D&B data.

Greenville MSA Assessment Area
% of # % of # % of # °/0 of # % of #
Fanns by Geography 1,220 2.4 21.2 48.9 27.5 0.0
77
nation. Most assessment area counties have unemployment rates consistently at or below both
state and national average rates. In 2016, however, the Laurens County's average unemployment
rate was slightly higher than state and national averages.
Unemployment Rates
2016 2017 2018
Area
%
Anderson County 4.6 3.9 3.4
Greenville County 4.2 3.7 3.1
Laurens County 5.2 4.4 3.8

Pickens County 5.0 4.1 3.5
In 2017, the top industries were professional and business services, government, and
manufacturing. The top employers were Greenville Health System, Michelin North American
Inc., BI -LO Supermarkets, Bon Secours St. Francis Health System, and AnMed Health.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE GREENVILLE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Greenville MSA assessment area reflects
adequate penetration throughout the assessment area, and the borrower profile reflects a good
distribution to borrowers of different incomes and businesses and farm of different sizes. In
addition, the bank uses flexible lending practices and originated an adequate level of community
development loans.
Lending Activity
assessment area.
78
assessment area. For home purchase loans, performance in low-income census tracts was above
the demographic and aggregate data. Lending in moderate -income census tracts was well below
the demographic data but consistent with aggregate lending data. For home improvement loans,
the bank did not originate any loans in low-income census tracts; however, the tracts contain
only 3.1 percent of owner -occupied housing, and aggregate lending was low at 3.6 percent.
Lending in moderate -income census tracts was below the demographic data but consistent with
the aggregate lending data. For home refinance loans, performance in low-income census tracts
was consistent with the demographic and aggregate lending data. Performance in moderate -
income census tracts was well below the demographic data and lower than aggregate lending
data.
assessment area. Small business loans in both low- and moderate -income census tracts were
below the demographic and aggregate lending data.
Borrower Profile
incomes. For home purchase loans, performance to low-income borrowers was well below
demographics but than double the aggregate lending data. Lending to moderate -income
borrowers was above the demographic data and consistent with aggregate lending data. For
home improvement loans, the bank did not make any loans to low-income borrowers. For
moderate -income lending, performance was significantly below demographic and aggregate
lending data. However, performance was strong in 2016, particularly to low-income borrowers,
to whom loan originations significantly exceeded the demographic and was more than double the
aggregate lending data. For home refinance loans, performance to low-income borrowers was
well below demographics but exceeded aggregate lending data. Performance to moderate -
income borrowers was consistent with the demographic and aggregate lending data.
The borrower distribution of small business loans reflects good penetration among businesses of
different sizes. Lending was below demographics but significantly above the aggregate data.
Further, loans in amounts of $100,000 or less, regardless of business size, were 80.7 percent,
which reflects good access to credit for very small businesses.
First -Citizens Bank originated an adequate level of community development loans in the
Greenville MSA assessment area. The bank originated 10 community development loans
79
totaling $5.6 million. This amount represents 14.3 percent by number and 3.8 percent by dollar
volume of total community development loans within the South Carolina assessment
areas. Regarding the community development purpose, 9 loans support community services, and
lloan supports revitalization or stabilization. Examples of community development loans
include bonds totaling $2.8 million and $1.6 million to fund infrastructure improvements for a
school district with a majority of students receiving free or reduced -cost lunch and a $300,000
loan to a CDFI that extends small business loans, finances affordable housing developments, and
provides financial literacy courses.
INVESTMENT TEST
The bank has an poor level of qualified investments in the Greensville MSA assessment area
relative to the bank's operations. Qualified investments total $79,000, which is 0.3 percent of
total South Carolina qualified investments. There was no prior period or new qualified equity or
debt investment, as the new investments during the current evaluation period consist solely of
donations. The donations were responsive to the assessment area needs because qualifying
donations can be particularly responsive to cash -strapped charitable or community based
organizations serving local residents of the respective assessment areas. Of the donations made
in the Greenville MSA assessment area, $1,000 benefitted affordable housing, $64,000
benefitted community service, $13,000 benefitted economic development, and $1,000 benefitted
stabilization or revitalization.
SERVICE TEST
opening and closing of branches has generally not adversely affected the accessibility of its
delivery systems. The bank provided a relatively high level of community development services.
branches in South Carolina. Two branches (11.1 percent) are in low-income tracts and 3
branches (16.7 percent) in moderate -income tracts. The branching distribution in low-income
geographies is well above the percentage of the population in the respective geographies, and
branching distribution in moderate -income geographies is lower than the percentage of the
population.
To the extent changes have been made, the opening and closing of branches has generally not
adversely affected the accessibility of its delivery systems, particularly in low- and moderate -
income geographies or to low- and moderate -income individuals. Since the last evaluation, the
bank has not opened any branches in this assessment area; however, the bank closed one branch
in a moderate -income geography.
80
is slightly above the assessment area's share of branches and deposits. Community development
An employee serves on the Board of a literacy organization that provides low-cost,

affordable adult educational services.
Employees taught eleven financial literacy courses to low- and moderate -income students
in collaboration with a non-profit organization whose mission is to provide youth with
successful financial management habits.
An employee conducted a first-time homebuyer class in collaboration with a non-profit
organization whose mission is to build a brighter future for underserved families through
financial education, lending, and investing.
An employee partnered with an affordable housing organization to provide a financial
literacy session that discussed credit reports and how to become ready to apply for a
mortgage loan.
81
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SC NON-MSA

ASSESSMENT AREA
The SC Non-MSA assessment area consists of 15 counties, which are summarized in Appendix
A. The bank operates 32 or 27.8 percent of the South Carolina branch offices in the SC Non-
MSA assessment area. As shown in Appendix A, the assessment area contains 16.4 percent of
farms are located in middle -income census tracts. The FFIEC has designated certain non -
poverty rates, and significant population losses. In addition, the FFIEC has designated certain
middle -income census tracts as underserved, because those communities have difficulty meeting
essential community needs. In the SC Non-MSA assessment area, the FFIEC designated 85 of
the 86 middle -income census tracts as distressed and/or underserved. The following table
presents demographic information from the 2015 ACS Census and 2017 D&B data.

SC Non-MSA Assessment Area
°A of # % of # % of # °A of # % of #
institutions operated 162 branches within this area. Of these institutions, the bank ranked 1 st in
total deposits with a market share of 18.9 percent.
82
According to the Bureau of Labor Statistics, unemployment rates have consistently decreased in
all of the counties. However, most of the counties have higher unemployment rates than both
state and national averages. The following table reflects average unemployment rates and trends
from 2016 to 2018 for the counties within the assessment area, state and nation.
Unemp oyment Rates

2016 2017 2018
Area % % 0/0
Abbeville County 5.5 4.6 3.8

Barnwell County 7.3 6.0 4.7
Chesterfield County 5.0 4.4 3.3
Clarendon County 6.6 6.0 4.4
Dillon County 6.7 5.7 4.7
Georgetown County 6.8 5.5 4.6
Greenwood County 5.2 4.5 3.5
Lee County 7.0 6.0 4.2
McCormick County 5.5 4.6 3.5
Marion County 8.7 7.4 5.6
Marlboro County 8.4 6.6 4.8
Newberry County 4.4 4.2 2.9
Oconee County 5.1 4.4 3.0
Orangeburg County 8.8 7.1 5.4
Williamsburg County 7.7 6.3 5.3
In 2017, according to D&B data, the top industries were services, retail trade, and non -
classifiable establishments. The top employers could not be determined due to the limited
amount of information that is available for the counties.
83
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SC NON-MSA
ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the SC Non-MSA assessment area reflects
Lending Activity
area.
assessment area. The bank did not originate any home purchase, home refinance, or home
improvement loans in low-income census tracts in 2016 or 2017. However, demographics
reflect 0.4 percent of owner -occupied housing in the low-income tracts, and aggregate lending
was less than 0.1 percent for all three lending types. For home purchase loans, performance in
moderate -income census tracts was significantly below the demographic data but consistent with
to aggregate lending data. For home improvement loans, 2017 performance in moderate -income
census tracts was consistent with the demographic and aggregate lending data. For home
refinance loans, performance in moderate -income census tracts was consistent with demographic
data, and exceeded aggregate lending data.
demographic and aggregate lending data. Performance in moderate -income census tracts was
above the demographic and aggregate lending data.
assessment area. The bank did not originate any small farm loans in low-income census tracts in
2016 or 2017; however, this performance is reasonable as less than 0.1 percent of small farms are
located in low-income geographies. The bank's 2017 performance in moderate -income census
tracts was above the demographic data and well above aggregate lending data.
84
Borrower Profile
incomes. In 2017, for home purchase, performance to low-income borrowers was significantly
below demographics but consistent with the aggregate lending data. Home improvement loans
were also significantly below demographics and well below aggregate data. However, in 2016,
home improvement lending to low-income borrowers significantly aggregate lending data. For
home purchase loans, performance to moderate -income borrowers was consistent with the
demographic and aggregate lending data. For home improvement loans, performance to
moderate -income borrowers was well below the demographic and aggregate lending data. For
home refinance loans to low-income borrowers, performance was significantly below
demographic data and was higher than the aggregate lending data. Home refinance lending to
moderate -income borrowers was well below demographic and lower than aggregate lending data.
sizes. Lending to small businesses was below the demographic data but well above aggregate
lending data. Further, loans in amounts of $100,000 or less, regardless of business size, were
85.5 percent, which reflects excellent access to credit for very small businesses.
The borrower distribution of small farm loans reflects good penetration among farms of different
sizes. Performance was well below demographics but well above aggregate lending data. The
2016 performance was lower. Loans in amounts of $100,000 or less, regardless of farm size,
were 71.0 percent, which indicates the bank is meeting the credit needs of small farms.
First -Citizens Bank is a leader in originating community development loans in the SC Non-MSA
assessment area. The bank originated 21 community development loans totaling $44.2
community development loans within the South Carolina assessment areas only. Regarding the
community development purpose, 5 loans support community services, 1 loan supports
economic development, and 15 loans support revitalization or stabilization. Examples of
community development loans include a $20.0 million loan to provide a non-profit telephone
cooperative working capital for expanding affordable broadband, landline telephone, and
wireless services throughout distressed and underserved middle -income census tracts and a
$300,000 loan to a non-profit organization that serves as a homeless shelter and provides
financial and social services to low- and moderate -income individuals.
INVESTMENT TEST
The bank has a significant level of qualified investments in the SC Non-MSA assessment area
development needs. Qualified investments total $14.7 million or 54.3 percent of total South
85
Carolina qualified investments. Investments include GNMA-multifamily securities totaling $9.8
million, which supports affordable housing activities, and 93 donation/grant contributions
totaling $138,000. Of these contributions, $2,000 benefitted affordable housing, $69,000
benefitted community services, $23,000 benefitted economic development, and $44,000
benefitted revitalization or stabilization. Additionally, a prior period equity investment of $4.7
million continues to support affordable housing.
SERVICE TEST
systems. The bank provided a relatively high level of community development services.
branches in South Carolina. None of the branches are in low-income tracts; however, only 0.8
percent of the population is in those tracts. Six branches (18.8 percent) are in moderate -income
tracts. Overall, the branching distribution in moderate -income geographies is similar to the
percentage of the population.
geographies or to low- and moderate -income individuals. Since the last evaluation, the bank
opened two branches in upper -income geographies and closed five branches in middle -income
geographies.

performance represents 22.0 percent of community development services in the state, which is
slightly below the assessment area's share of branches. The community development services
equate to 0.7 services per branch per year. The following are examples of community
development services provided in this assessment area.
An employee serves as the commissioner of a regional housing authority. In this

capacity, the employee provides financial advice on the available housing programs for
low- and moderate -income families.
An employee provided a financial literacy session to a group of small business farmers.
The employee partnered with a local chapter of a state organization whose mission is to
secure the future of small farms by providing aid and educational programs.
An employee serves on the Board of an economic alliance organization that provides
leadership and financial support to small businesses relocating to the area.
86
OTHER SOUTH CAROLINA ASSESSMENT AREAS
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LIMTED-SCOPE REVIEW

SOUTH CAROLINA ASSESSMENT AREAS
The following table summarizes the conclusions for the four South Carolina assessment areas

Spartanburg MSA Consistent Above Consistent
Florence MSA Consistent Consistent Consistent
Hilton Head MSA Consistent Below Above
Sumter MSA Below Below Above
area follows with additional information in the core tables in Appendix D. Please note the
qualified investments, and community development services are from June 6, 2016, to March 26,
2019.
87
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SPARTANBURG MSA

ASSESSMENT AREA
The Spartanburg MSA assessment area consists of Spartanburg County. The Spartanburg, SC
MSA has two counties; however, the bank not delineated Union County as part of its assessment

Spartanburg MSA Assessment Area
°Ai of # % of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SPARTANBURG MSA

ASSESSMENT AREA
88
Activity # $
Small Fann Loans 6 $130,000
CD Services 23 --
89
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE FLORENCE MSA

ASSESSMENT AREA
The Florence MSA assessment area consists of Darlington and Florence Counties. These two
counties fully compose the Florence, SC MSA. Demographic data for the assessment area
follows.

Florence MSA Assessment Area
% of # % of # % of #
°A of # % of #

(*) The NA category consists of geographies that have not been assigned an income classification..
ranked 2nd with 14.5 percent deposit market share. The top five financial institutions accounts
for 67.0 percent of the deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE FLORENCE MSA

ASSESSMENT AREA
90
Activity # $
CD Services 13 --
91
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE HILTON HEAD MSA

ASSESSMENT AREA
The Hilton Head MSA assessment area consists of Beaufort County. The Hilton Head Island -
Bluffton -Beaufort, SC MSA has two counties within its boundaries; however, the bank not
delineated Jasper County as part of its assessment area. Demographic data for the assessment
area follows.

Hilton Head MSA Assessment Area
% of # % of # % oft?
°/0 of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE HILTON HEAD MSA

ASSESSMENT AREA
92
Activity # $
Small Farm Loans 0 --
Donations 5 $16,000
CD Services 15 --
93
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SUMTER, SC MSA

ASSESSMENT AREA
The Sumter MSA assessment area consists of Sumter County, which composes the Sumter MSA.

Sumter MSA Assessment Area
% of # % of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SUMTER MSA

ASSESSMENT AREA
94
Activity # $
Donations 8 $9,000
CD Services 11 --
95
VIRGINIA
CRA RATING FOR VIRGINIA: Satisfactory

The Investment Test is rated: Low Satisfactory
SCOPE OF EVALUATION
The evaluation of the Virginia performance considered the operations of First -Citizens Bank in
10 assessment areas, which are detailed in Appendix A. Examiners conducted full -scope
reviews of the bank's performance in the Roanoke MSA and VA Non-MSA assessment areas. A
significant portion of the loans (48.2 percent), deposits (63.0 percent), and branches (48.9
percent) in Virginia are concentrated in these assessment areas. Small business loans constitute
the primary loan type in all assessment areas. Home mortgage loans were limited in some
assessment areas; however, they were reviewed in both full -scope assessment areas, as well as in
four limited -scope areas. Farm loans were reviewed in the VA Non-MSA assessment area.
Examiners based performance evaluation and conclusions primarily upon the small business
lending.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN VIRGINIA
The bank operates 47 or 8.5 percent of branch offices in Virginia. Virginia accounts for 5.7
percent of the bank -wide deposits and 6.9 percent of loans. First -Citizens Bank ranks 18th in the
state in deposit market share at 0.5 percent. Competitor institutions in the assessment areas
include Capital One Bank (USA), NA; E*TRADE Bank; and Wells Fargo Bank, NA. Together,
the three competitor institutions account for 46.1 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN VIRGINIA
LENDING TEST
The Lending Test rating for Virginia is High Satisfactory. Lending levels reflect good
responsiveness to the Virginia assessment areas' credit needs. The geographic distribution reflects
good penetration throughout the assessment area, and the borrower profile reflects good distribution
to borrowers of different incomes and businesses and farm of different sizes. In addition, the
development loans. The performance in assessment areas that received limited -scope reviews
was generally consistent with the full -scope review areas.
Lending Activity
Lending levels reflect good responsiveness to the Virginia assessment areas' credit needs. The
tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for
each Virginia assessment area.
96
The geographic distribution of HMDA loans reflects good penetration throughout Virginia.
Good performance in the full -scope assessment areas primarily supports this conclusion.
assessment areas. Good performance in the full -scope assessment areas primarily supports this
conclusion.
The geographic distribution of small farm loans throughout the Virginia Non-MSA assessment
area reflects good penetration.
Borrower Profile
The distribution of HMDA, small business, and small farm loans is good.
The distribution of HMDA loans is good among borrowers of different income levels. Good
performance in the full -scope assessment areas primarily supports this conclusion.
The distribution of small business loans is good among businesses of different sizes. Good
performance in the full -scope assessment areas primarily supports this conclusion.
The distribution of small farm loans is good among farms of different sizes in the full -scope
Virginia Non-MSA assessment area.
First -Citizens Bank originated a relatively high level of community development loans in
Virginia. During this evaluation period, the bank originated 38 community development loans
totaling $76.0 million. This represents 10.1 percent by number and 10.7 percent by dollar
volume of bank -wide community development loans. The percent of community development
loans by number and dollar volume in the state is well above the bank -wide lending levels in the
state at 6.9 percent. Three of the loans totaling $1.4 million were originated outside the
assessment areas but within the broader state-wide area. Since the bank has been responsive to
community development needs and opportunities within its assessment areas, the loans were
included. The analysis for each full -scope Virginia assessment area includes a detailed
discussion of community development loans.
INVESTMENT TEST
The Investment Test performance is rated Low Satisfactory in Virginia. The bank has an
adequate level of qualified investments in Virginia relative to operations in this state. Qualified
investments total $17.0 million or 5.0 percent of bank -wide qualified investments. Investments
include five LIHTC investments for affordable housing projects totaling $13.7 million, one
97
GNMA-multifamily security totaling $700,000, $1.0 million in SBA pools that supported two
small businesses, 146 donations or grants totaling $125,000, and one prior investment totaling
$1.5 million, which supported affordable housing. The performance in assessment areas that
received limited -scope reviews was consistent with or above the full -scope review areas.
SERVICE TEST
The Service Test rating for Virginia is High Satisfactory. The bank operates 47 branches in
Virginia which represents 8.5 percent of all branches. Overall, delivery systems are accessible to
essentially all portions of the assessment areas. The opening and closing of branches has not
adversely affected the accessibility of its delivery systems. During the evaluation period, 7
branches were opened, 3 branches were closed. All were within middle- and upper -income
tracts. The bank provided a relatively high level of community development services in
Virginia. Specifically, the bank provided 195 community development services, which equates
to 1.5 community development services per branch per year. The performance in assessment
areas that received limited -scope reviews was generally consistent with the full -scope review
areas.
98
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ROANOKE MSA

ASSESSMENT AREA
The Roanoke MSA assessment area consists of Botetourt and Roanoke Counties and the
independent cities of Roanoke and Salem. The Roanoke, VA MSA contains two additional
counties; however, the bank did not include these counties in the assessment area. The bank
operates seven or 14.9 percent of its Virginia branch offices in the Roanoke MSA assessment
area. As shown in Appendix A, the assessment area represents 31.1 percent of the rated area
loans and 16.6 percent of the rated area deposits.
The 2015 ACS Census shows that a majority of the owner -occupied housing units, businesses,
and farms are in middle- and upper -income census tracts. The following table presents

Roanoke MSA Assessment Area

#
% of # % of # % of # % of # % of #
Source:2015 ACS Census and 2017 D&B data
99
table reflects the average annual unemployment rates and trends for the assessment area, state,
and nation during the evaluation period. The counties have unemployment rates generally below
both state and national average rates.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Botetourt County 3.7 3.6 2.7
Roanoke County 3.6 3.4 2.8
Roanoke City 4.3 4.2 3.3
Salem City 4.0 3.8 3.0
Virginia 4.1 3.7 3.0
In 2017, the top industries were education and health services, government; and professional and
business services. The top employers were Roanoke Memorial Community Hospital, Kroger,
Wells Fargo Bank NA, HCA Virginia Health System, and Wal-Mart Stores Inc.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ROANOKE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Roanoke MSA assessment area reflects
good responsiveness to assessment area's credit needs. The geographic distribution reflects good
borrowers of different incomes and businesses of different sizes. In addition, the bank uses
flexible lending practices and originated a relatively high level of community development loans.
Lending Activity
Lending levels reflect good responsiveness to the assessment area's credit needs. The core tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in this assessment area.
Small business loans constitute the primary loan type in the assessment area.
100
area. The bank did not originate any home purchase loans in low-income census tracts; however,
demographics reflect limited owner -occupied housing at 1.8 percent, and aggregate lending was
low at 1.2 percent. Home purchase lending in moderate -income census tracts was above the
demographic and aggregate lending data. For home refinance loans, performance in both low -
and moderate -income census tracts was consistent with the demographic and aggregate lending
data.
assessment area. Small business lending in both low- and moderate -income census tracts was
consistent with demographic and aggregate lending data.
Borrower Profile
incomes. For home purchase loans, performance to low-income borrowers was below
demographics but above aggregate lending data. Lending to moderate -income borrowers was
above the demographic data but below the aggregate lending data. For home refinance loans,
performance to low-income borrowers was substantially below demographics and well below
aggregate lending data. However, lending to moderate -income borrowers was well above
demographic data and exceeded aggregate lending data.
sizes. Small business lending to businesses with annual gross revenues of $1 million or less was
significantly below demographics but above aggregate lending. Further, loans in amounts of
$100,000 or less, regardless of business size, were 63.1 percent, which reflects good access to
credit for very small businesses.
Roanoke MSA assessment area. The bank originated 12 community development loans totaling
$2.6 million. This amount represents 34.3 percent by number and 3.4 percent by dollar volume
of community development lending within the Virginia assessment areas only. Regarding the
community development purpose, 6 loans support affordable housing, and 6 loans support
community services. Examples of community development loans include a $1.1 million loan to
a CDFI that provides financing for affordable housing, housing rehabilitation, and community
development loans to municipalities for wastewater infrastructure and 7 lines of credit totaling
$1.0 million to a non-profit community action agency. These credits supported operations and
101
funded a line of credit for rehabilitating and constructing several affordable housing units in
partnership with HUD and the city's Department of Housing and Community Development.
INVESTMENT TEST
The bank has a poor level of qualified investments in the Roanoke MSA assessment area relative
to the bank's operations. Qualified investments consist of 41 donation or grant contributions
totaling $33,000 or 0.2 percent of total Virginia development investments. Of these
contributions, $29,000 benefitted community services, $3,000 benefitted economic development,
and $1,000 benefitted stabilization or revitalization.
SERVICE TEST
systems. The bank provided an excellent level of community development services.
The bank operates seven branches in the assessment area representing 14.9 percent of branches
in Virginia. One branch (14.3 percent) is in a moderate -income tracts, which is similar to the
population. The bank does not have any branches in low-income geographies where the
population is 4.2 percent.
The institution is a leader in providing community development services in the assessment area.
Employees participated in 61 community development services. This performance represents
31.3 percent of all community development services in the state, which is double the percentage
of the branches in this assessment area. In addition, this level of services equates to 3.2 services
per branch per year. The following are examples of community development services provided.
An employee serves as Board Chairman for an economic development authority that

administers enterprise zone grants.
An employee serves on the property committee for a non-profit organization that helps
individuals and families achieve economic and personal independence through education,
employment, affordable housing, and safe and healthy environments. In this role, the
employee oversees the affordable housing units including handling the financials of the
properties and determining housing fund assistance.
Employees taught a numerous sessions of a class on how to use a checking account
responsibly for clients of a rescue mission that provides a safe haven to families and
individuals in crisis. The mission provides a comprehensive array of services to help
people who are homeless, struggling with addictions, or victims of abuse.
102
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE VA NON-MSA

ASSESSMENT AREA
The VA Non-MSA assessment area consists of the seven counties and four independent cities as
summarized in Appendix A. The bank operates 16 or 34.0 percent of its Virginia branch offices
in the VA Non-MSA assessment area. As shown in Appendix A, the assessment area represents
The FFIEC has designated certain non -metropolitan middle -income census tracts as distressed
based on high unemployment rates, high poverty rates, and significant population losses. In
addition, the FFIEC has designated certain middle -income census tracts in rural areas as
underserved because those communities have difficulty meeting essential community needs. A
census tract can be designated as distressed or underserved. In the VA Non-MSA assessment
area, the FFIEC designated 17 (32.1 percent) of the 53 middle -income census tracts as distressed
and/or underserved. The majority of the owner -occupied housing units, businesses, and farms
are in middle- income census tracts. The following table presents demographic information from
the 2015 ACS Census and 2017 D&B data.

VA Non-MSA Assessment Area

#
% of # % of # % of # % of # % of #
total deposits with a market share of 15.7 percent. The top financial institution accounts for 18.0
103
table reflects the average annual unemployment rates and trends of the assessment area counties,
state and nation during the evaluation period. The areas have unemployment rates that are at or
above both state and/or national averages.
Unemployment Rates
2016 2017 2018
Area
% % %
Alleghany County 5.1 4.9 4.0
Brunswick County 6.0 5.5 5.0
Carroll County 5.2 4.7 3.7
Covington City 5.9 6.3 4.8
Danville City 6.1 6.0 5.4
Emporia City 6.5 5.5 4.9
Galax City 5.0 4.5 3.7
Greensville County 5.1 4.6 3.8
Mecklenburg County 5.7 5.3 4.4
Nottoway County 4.0 4.0 3.2
Pittsylvania County 4.8 4.5 3.8
Virginia 4.1 3.7 3.0
In 2017, the top industries were services, retail trade; and finance, insurance, and real estate.
Considering the demographic and economic data, examiners determined that small business
loans represent a primary credit need for the assessment area. The significant percentage of
businesses with gross annual revenues of $1 million or less at 80.2 percent and the large number
of businesses with four or fewer employees at 69.3 percent support this conclusion.
Additionally, affordable housing represents a need as 41.9 percent of the families are low- and
moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE VA NON-MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Virginia Non-MSA reflects good
responsiveness to the assessment area's credit needs. The geographic distribution reflects good
104
Lending Activity
area.
area. For home purchase and refinance loans, performance in low-income census tracts was
consistent with the demographic and aggregate lending data. Performance for both loan types in
moderate -income census tracts was consistent with the demographic data and above the
assessment area. The bank did not originate any small business loans in low-income census
tracts; however, only 0.7 percent of businesses are in the low-income tracts, aggregate data stood
at 0.7 percent also. Performance in moderate -income census tracts was above the demographic
and aggregate lending data.
assessment area. The bank did not originate any small farm loans in low-income census tracts;
however, small farms in the low-income tracts are nominal, and aggregate lenders did not extend
small farms loans in the tracts as well. Small farm performance in moderate -income census
tracts was well above the demographic and aggregate lending data.
Borrower Profile
The borrower distribution of HMDA, small business, and small farm loans is good.
incomes. The bank did not originate any home purchase loans to low-income borrowers. This
performance is poor when compared with aggregate lending data and demographics. However,
performance for home purchase loans to moderate -income borrowers significantly exceeded the
demographic data and was well above aggregate lending data. For home refinance loans,
performance to low-income borrowers was significantly below demographics and consistent with
aggregate lending data. Lending to moderate -income borrowers was above demographic and
sizes. Lending to businesses with annual gross revenues of $1 million or less was well below
demographics but significantly exceeded aggregate lending data. Further, loans in amounts of
$100,000 or less, regardless of business size, were 84.4 percent, which reflects excellent access
to credit for very small businesses.
105
Lending to farms with annual gross revenues of $1 million or less was substantially below
demographics but exceeded aggregate lending. Further, loans in amounts of $100,000 or less,
regardless of farm size, were 50.0 percent, which reflects adequate access to credit for very small
businesses.
First -Citizens Bank is a leader in originating community development loans in the VA Non-
community development lending within the Virginia assessment areas only. The percent of
community development loans by number and dollar volume in the assessment area significantly
exceeded the bank -wide lending levels in the assessment area. Regarding the community
development purpose, 1 loan supports affordable housing, 4 loans support community services, 1
loan supports economic development, and 8 loans support revitalization or stabilization.
Examples of community development loans include 4 loans totaling $30.0 million to a rural
electric cooperative to improve the electrical system infrastructure and reliability in distressed
and underserved middle -income census tracts, a $5.0 million loan to construct two LIHTC
affordable housing developments, and a $10.0 million loan to a newly -constructed hospital
located in an Opportunity Zone that serves distressed and underserved middle -income census
tracts.
INVESTMENT TEST
The bank has a poor level of qualified investments in the VA Non-MSA assessment area relative
to the bank's operations. Qualified investments consisted of 43 donations or grants totaling
$24,000 or 0.1 percent of total Virginia qualified investments. Of these contributions, $22,000
benefit community services, $1,000 benefits economic development, and $1,000 benefits
stabilization or revitalization.
SERVICE TEST
Delivery systems are readily accessible to all portions of the assessment area, and the opening
and closing of branches has not adversely affected the accessibility of its delivery systems. The
bank provided a relatively high level of community development services.
Virginia. In moderate -income geographies, the percentage of bank branches is 37.5 which is
almost double the population in moderate -income geographies at 19.5 percent. The bank does
not have any branches in low-income geographies; however, the population percentage is
nominal at 1.5 percent.
106
is consistent with the assessment area's share of branches and deposits. Community
An employee serves as Chair of the Resource Development Committee for a non-profit

organization that provides services to low- and moderate -income youth focusing on
academic success, healthy lifestyle, and character development. In this role, the employee
assesses the financial needs of the organization and helps with budgeting and fundraising.
An employee serves as the Treasurer for an organization that provides job training and
technical training for the unemployed.
An employee serves as Chairman for an economic development organization that serves a
primarily low- and moderate -income and underserved county.
107
OTHER VIRGINIA ASSESSMENT AREAS
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LIMITED -SCOPE REVIEW

VIRGINIA ASSESSMENT AREAS
The following table summarizes the conclusions for the eight Virginia assessment areas reviewed
using limited -scope examination procedures. Examiners drew conclusions regarding the
institution's CRA performance from reviewing available facts and data, including performance
figures, aggregate lending data comparisons, and demographic information. The conclusion did
not alter the overall performance rating for lending or services tests. However, the investment
test was impacted by the significant level of investments in the Richmond MSA, Washington
MSA, and Winchester MSA assessment areas. In all three assessment areas, the level of
investments is significantly above the bank's operations.

Lynchburg MSA Below Consistent Consistent
Richmond MSA Consistent Above Below
Blacksburg MSA Below Consistent Below
Charlottesville MSA Below Consistent Consistent
Harrisonburg MSA Consistent Consistent Above
Staunton -Waynesboro MSA Below Consistent Consistent
Washington MSA Consistent Above Consistent
Winchester MSA Below Above Consistent
A summary of First -Citizens Bank's operations and activities for the limited -scope assessment
areas follows with additional information in the Appendices. Please note the HMDA, small
business and small farm lending figures in the activity table in the "Conclusions on Performance
Criteria" section for each limited -scope review area below are based on the combined 2016 and
2017 lending data, while the figures for the community development loans, investments, and
services are from June 6, 2016, to March 26, 2019.
108
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE LYNCHBURG MSA

ASSESSMENT AREA
The Lynchburg MSA assessment area consists of Bedford and Campbell Counties and the
independent city of Lynchburg. The Lynchburg, VA MSA includes four counties and one
independent city; however, the bank only included the two counties and the independent city in
the assessment area. Demographic data for the assessment area follows.

Lynchburg MSA Assessment Area
% of # % of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LYNCHBURG MSA

ASSESSMENT AREA
First -Citizens Bank operates two branches in this assessment area. The bank originated and
109
Activity # $
1-11MDA Loans 24 $5.6 million
Community Development Loans 0 --
Donations 3 $2,000
CD Services 8 --
110
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE RICHMOND MSA

ASSESSMENT AREA
The Richmond assessment area consists of Chesterfield and Henrico Counties as well as the
independent city of Richmond. The Richmond, VA MSA includes 13 counties and 4
independent cities; however, the bank only included the 2 counties and 1 independent city in the
assessment area. Demographic data for the assessment area follows.

Richmond MSA Assessment Area
Demographic Characteristics Low Moderate Middle Upper NA*

ti
')/0 of # % of # % of # % of # °A of #
13th with 0.3 percent deposit market share. The top five financial institutions account for 94.4
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE RICHMOND MSA

ASSESSMENT AREA
111
Activity # $
Donations 3 $7,000
CD Services 9 --
112
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE BLACKSBURG MSA

ASSESSMENT AREA
The Blacksburg MSA assessment area consists of Montgomery County. The Blacksburg-
Christiansburg-Radford, VA MSA has five counties and an independent city. However, the bank
delineated the one county as its assessment area. Demographic data for the assessment area
follows.

Blacksburg MSA Assessment Area
Demo g raphic Characteristics #
°A of # (Y0 o f # 4)/0 of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE BLACKSBURG MSA

ASSESSMENT AREA
113
Activity # $
Donations 3 $2,000
CD Services 8 --
114
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE CHARLOTTESVILLE

MSA ASSESSMENT AREA
The Charlottesville MSA assessment area consists of Albemarle County and the independent city
of Charlottesville. The Charlottesville, VA MSA has five counties and one independent city;
however, the bank delineated the one county and the independent city as its assessment area.

Charlottesville MSA Assessment Area
% of # % of # °A of # °A of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CHARLOTTESVILLE MSA

ASSESSMENT AREA
115
Activity # $
I-FMDA Loans 44 $13.2 million
Investments (New) -- $419,000
CD Services 18 --
116
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE HARRISONBURG MSA

ASSESSMENT AREA
The Harrisonburg MSA assessment area consists of Rockingham County and the independent
city of Harrisonburg City. The one county and independent city compose the Harrisonburg, VA
MSA. Demographic data for the assessment area follows.

Harrisonburg MSA Assessment Area

#
% of # % of # % of # % of # % of #
70.6 percent of the total deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE HARRRISONBURG MSA

ASSESSMENT AREA
117
Activity # $
Donations 1 $1,000
CD Services 9 --
118
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE STAUNTON MSA

ASSESSMENT AREA
The Staunton MSA assessment area consists of Augusta County and the independent cities of
Staunton and Waynesboro. The one county and the two cities compose the Staunton -
Waynesboro, VA MSA. Demographic data for the assessment area follows.

Staunton MSA Assessment Area
Demo g raphic Characteristics Low Moderate Middle Upper NA*

#
°A of # °A of # °A of # (1/0 of # % of #
Source: 2015 AC'S Census and 2017 D&B data
(*) The NA category consists ofgeographies that have not been assigned an income classification.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE STAUNTON MSA

ASSESSMENT AREA
119
Activity # $
Donations 6 $6,000
CD Services 5 --
120
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE WASHINGTON MSA

ASSESSMENT AREA
The Washington MSA assessment area consists of Arlington, Fairfax, Loudoun, Spotsylvania
and Warren Counties, in addition to the independent cities of Fairfax and Fredericksburg. The
Washington MSA includes 11 counties and 6 independent cities; however, the bank only
included the 5 counties and 2 independent cities in the assessment area. Demographic data for
the assessment area follows.

Washington MSA Assessment Area
% of 14 % of # % of # % of # °/0 of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE WASHINGTON MSA

ASSESSMENT AREA
First -Citizens Bank operates five branches in this assessment area. The bank originated and
121
Activity # $
I-IIMDA Loans 31 $7.9 million
CD Services 15 --
122
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE WINCHESTER MSA

ASSESSMENT AREA
The Winchester MSA assessment area consists of Frederick County and the independent city of
Winchester. The one county and the one independent city compose the Winchester, VA MSA.

Winchester MSA Assessment Area

% of # % of # % of # % of # % of #
(*) The NA category consists of geographies that have not been assigned art income classification.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE WINCHESTER MSA

ASSESSMENT AREA
123
Activity # S
Donations 3 $3,000
CD Services 6 --
124
CALIFORNIA
CRA RATING FOR CALIFORNIA: Satisfactory

The Investment Test is rated: Outstanding
SCOPE OF EVALUATION
The evaluation of the California performance considered the operations of First -Citizens Bank in
six assessment areas, which are detailed in Appendix A. Examiners conducted full -scope
reviews of performance in the San Diego MSA, Los Angeles MD, and Sacramento MSA
assessment areas. A significant portion of the loans (77.1 percent), deposits (67.8 percent), and
branches (66.7 percent) in California are concentrated in these assessment areas. Small business
loans constitute the primary loan type in all assessment areas. Home mortgage loans were
limited, and no farm loans were reviewed in any assessment areas. Therefore, the conclusions
were primarily based upon the small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN CALIFORNIA
The bank operates 21 or 3.7 percent of branch offices in California. California accounts for 4.5
include Bank of America, NA; Wells Fargo Bank, NA; and JPMorgan Chase, NA. Together, the
three competitor institutions account for 50.7 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN CALIFORNIA
LENDING TEST
The Lending Test rating for California is High Satisfactory. Lending levels reflect good
responsiveness to the California assessment areas' credit needs. The geographic distribution
reflects good penetration throughout the assessment areas, and the borrower profile reflects good
bank uses flexible lending practices and is a leader in originating community development loans.
The performance in assessment areas that received limited -scope reviews was generally below
Lending Activity
Lending levels reflect good responsiveness to the California assessment areas' credit needs. The
each California assessment area.
125
assessment areas. Within the three full -scope areas, the bank exhibited excellent performance in
the Los Angeles MD assessment area, good performance in the San Diego MSA assessment area,
and adequate performance in the Sacramento MSA assessment area.
Borrower Profile
The distribution of loans reflects good distribution to borrowers of different incomes and
businesses of different sizes. Good performance in the San Diego MSA and Los Angeles MD
assessment areas and adequate performance in the Sacramento MSA assessment area primarily
support this conclusion.
First -Citizens Bank is a leader in originating community development loans in California.

During this evaluation period, the bank originated 67 community development loans totaling
$56.8 million. This represents 17.9 percent by number and 8.0 percent by dollar volume of
bank -wide community development loans. The percent of community development loans by
number and dollar volume is well above the bank -wide lending levels in the state. Fourteen of
the loans totaling $1.7 million were originated outside the assessment areas but within the
broader state-wide area. Since the bank has been responsive to community development needs
and opportunities within its assessment areas, the loans were included. The analysis for each
full -scope California assessment area includes a detailed discussion of community development
loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in California. The bank has an excellent
level of qualified investments in California relative to operations in this state. Qualified
investments in California total $53.0 million or 15.7 percent of bank -wide qualified investments.
Investments include a LIHTC for an affordable housing project totaling $1.0 million; a GNMA-
Multifamily security totaling $1.3 million; $42.0 million in SBA pools that support 36 small
businesses; and 46 donations or grants totaling $38,000. Additionally, prior period equity
investments total $8.7 million for affordable housing projects. SBA pool investments for
economic development represented the highest percentage of investments at 79.3 percent. The
performance in assessment areas that received limited -scope reviews was generally below the
full -scope review areas.
SERVICE TEST
The Service Test rating for California is High Satisfactory. The bank operates 21 branches in
California which represents 3.8 percent of all branches. The branches are considered accessible
to essentially all portions of the assessment areas given the population demographics and the
number of branches per assessment area. Changes in branches did not adversely affect low- or
126
moderate -income areas or individuals. The bank opened only one branch in a middle -income
geography since the last evaluation with no branches closed. The bank has a relatively high level
of community development services in the California assessment areas. Specifically, the bank
provided 59 community development services in California, which equates to 1.0 community
development service per branch per year. The performance in assessment areas that received
limited -scope reviews was generally consistent with the full -scope review areas.
127
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SAN DIEGO MSA

ASSESSMENT AREA
The San Diego MSA assessment area comprises San Diego County, which represents the entire
MSA. The bank operates seven or 33.3 percent of its California branch offices in this assessment
loans and 25.5 percent of deposits.
The 2015 ACS Census shows the majority of owner -occupied housing units, businesses, and
farms are located within middle- and upper -income census tracts. The following table presents
demographics information from the 2015 ACS Census and 2017 D&B data.

San Diego MSA Assessment Area
% of #
% of # % of # % of # % of #

Housing Units by Geography 1,180,806 7.7 21.7 34.2 36.5 0.0
Household Distribution by Income Level 1,094,157 24.8 15.7 17.1 42.4 0.0
institutions operated 590 branches within this assessment area. Of these institutions, the bank
ranked 23rd in total deposits with a market share of 0.4 percent. The top five financial
and nation during the evaluation period. San Diego County has unemployment rates consistently
128
below both state and national average rates.
Unemp oyment Rates

2016 2017 2018
Area
San Diego County 4.7 4.0 3.2

California 5.5 4.8 4.2
In 2017, the top industries were government, professional and business services, and education
and health services. The top employers were Marine Corps Base Camp Pendleton, University of
California -San Diego, Naval Base San Diego, Sharp HealthCare, and Scripps Health.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SAN DIEGO MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the San Diego MSA assessment area reflects
good responsiveness to the assessment area's credit needs. The geographic distribution reflects
good penetration throughout the assessment area, and the borrower profile reflects good distribution
to borrowers of different incomes and businesses of different sizes. In addition, the bank uses
flexible lending practices and is a leader in originating community development loans.
Lending Activity
in Appendix D detail the number and dollar volume of HMDA and CRA loans.
First -Citizens Bank did not originate a sufficient number of HMDA loans to derive meaningful
conclusions. The bank originated one home purchase loan in a moderate -income census tract in
2017.
129
assessment area. Small business lending in low-income census tracts was consistent with
demographic and aggregate lending data, while lending in moderate -income census tracts was
well above the demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated one home purchase loan to a borrower with no stated income.
different sizes. Small business loans to businesses with annual gross revenues of $1 million or
less was substantially below the demographics but exceeded the aggregate lending. Further,
loans in amounts of $100,000 or less, regardless of business size, were 73.5 percent, which
reflects good access to credit for very small businesses.
First -Citizens Bank is a leader in originating community development loans in the San Diego
community development lending within the California assessment areas only. This performance
was well above the bank's lending levels in the assessment area. Regarding the community
development purpose, 4 loans support affordable housing, and 16 loans support community
services. Examples of community development loans include a $4.7 million loan to a non-profit
health center that provides medical services to low- and moderate -income individuals; a $1.2
million loan and a renewal of a $500,000 line of credit to a non-profit organization that provides
housing, food, and employment services to low- and moderate -income individuals; and 4 loans
totaling $63,000 to a non-profit, state-wide lending consortium that provides financing for
affordable multi -family housing.
INVESTMENT TEST
The bank has a significant level of qualified investments in the San Diego MSA assessment area
relative to operations and exhibited good responsiveness to credit and community development
needs. Qualified investments total $7.7 million or 14.5 percent of total California qualified
investments. Investments include one GNMA-multifamily security for affordable housing
totaling $1.3 million, $2.9 million in affordable housing prior period investments, 19 donation or
grant contributions totaling $12,000 benefitting community services, and $3.4 million in SBA
pools that support three small businesses.
130
SERVICE TEST
Delivery systems are accessible to essentially all portions of the assessment area. The bank
provided a relatively high level of community development services.
The bank operates seven branches in the assessment area representing 33.3 percent of branches
in California. The percentage of branches in low-income geographies is 28.6, which
significantly exceeds the low-income population percentage at 8.9. There are no branches in
moderate -income geographies where the population percentage is 23.6.
The institution provided a relatively high level of community development services. Employees
participated in 27 community development services. This performance represents 45.8 percent
of all community development services in the state, which is above the assessment area's share
of branches. Community development services equate to 1.4 services per branch per year. The
following are examples of community development services.
An employee serves on a committee of a non-profit organization that addresses

homelessness issues by providing individuals with a wide range of emergency,
transitional, and permanent housing.
An employee provided a financial literacy event focused on business loan options for the
clients of a CDC that provides capital to small businesses to expand, grow, and create
jobs.
131
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE LOS ANGELES MD

ASSESSMENT AREA
The Los Angeles MD assessment area consists of Los Angeles County, which represents the
entire Los Angeles -Long Beach -Glendale, CA MD. The bank operates four or 19.0 percent of
California branch offices in this assessment area. As shown in Appendix A, the assessment area
represents 25.5 percent of the rated area loans and 15.5 percent of the rated area deposits.
The 2015 ACS Census shows that the majority of the owner -occupied housing units, businesses,
and farms are located in upper -income census tracts. The following table presents demographics

Los Angeles MD Assessment Area
% of # % of #
% of # % of # % of #
Geographies (Census Tracts) 2,346 9.4 28.7 24.9 34.8 2.2
Owner -Occupied Units by Geography 1,499,879 2.4 17.2 26.6 53.7 0.1
Occupied Rental Units by Geography 1,763,190 12.2 34.2 23.6 29.2 0.9
Family Distribution by Income Level 2,186,485 24.5 16.3 16.7 42.4 0.0
Due to rounding. totals may not equal 100.0 percent.
institutions operated 1,747 branches within this area. Of these institutions, the bank ranked 67th
in total deposits with a market share of 0.1 percent. The top five financial institutions account
table reflects the average annual unemployment rates and trends within the assessment area,
state, and nation. Except in 2016, the unemployment rate in Los Angeles County has generally
132
hovered at or above state or national average rates.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Los Angeles County 5.3 4.8 4.6
In 2017, the top industries were education and health services, professional and business
services, and government. The top employers were University of California in Los Angeles,
Kaiser Permanente, University of Southern California, Northrop Grumman Corp, and Providence
Health Systems.
with gross annual revenues of $1 million or less at 87.2 percent, and the large number of
businesses with four or fewer employees at 71.1 percent support this conclusion. Additionally, a
high demand for multifamily rental properties is needed as supported by the high number of
individuals renting.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LOS ANGELES MD

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Los Angeles MD assessment area reflects
excellent responsiveness to the assessment area's credit needs. The geographic distribution reflects
excellent penetration throughout the assessment area, and the borrower profile reflects good
bank uses flexible lending practices and is a leader in originating community development loans.
The rating was primarily supported by First -Citizens Bank's leadership in originating community
development loans.
Lending Activity
Lending levels reflect excellent responsiveness to the assessment area's credit needs. The core
assessment area.
133
The geographic distribution of HMDA and small business loans is excellent.
conclusions. The bank originated three home purchase loans, one of which was originated in a
moderate -income census tract. In addition, the bank originated one home refinance loan in an
upper -income census tract.
The geographic distribution of small business loans reflects excellent penetration throughout the
assessment area. Small business lending in low-income census tracts was consistent with
demographic and aggregate lending data. However, lending in moderate -income census tracts
was significantly above demographic and aggregate lending data.
Borrower Profile
The distribution of HMDA and small business loans is good.
conclusions. The bank originated three home purchase loans and one home refinance loan, none
of which were originated to low- or moderate -income borrowers.
less was substantially below demographics but exceeded aggregate lending. Further, loans in
amounts of $100,000 or less, regardless of business size, were 78.8 percent which reflects good
First -Citizens Bank is a leader in originating community development loans in the Los Angeles
MD assessment area compared to operations in the assessment area. The bank originated 16
community development loans totaling $22.3 million. This amount represents 30.2 percent by
number and 40.4 percent by dollar volume of community development lending within the
California assessment areas only. Regarding the community development purpose, 11 loans
support affordable housing, 2 support community services, and 3 support economic
developments. Examples of community development loans include a $5.6 million SBA loan and
a subsequent $6.7 million loan modification to finance the construction of a business' new
facility in a moderate -income census tract designated as a HUD Empowerment Zone; a $4.0
million loan to a non-profit organization that provides behavioral, mental health, and foster care
services to low- and moderate -income families; and the bank participated in 11 loans totaling
$144,000 to a non-profit state-wide lending consortium that provides financing for affordable
multi -family housing.
134
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Los Angeles MD assessment area
relative to operations. Qualified investments total $29.7 million or 55.9 percent of California
qualified investments. Investments include $3.5 million in affordable housing prior period
equity investments, 7 donation or grant contributions totaling $7,000 benefitting community
services, and $26.1 million in SBA pools that supported 22 small businesses. Investments
exhibit excellent responsiveness to credit and community development needs.
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the assessment area.
The bank operates four branches in the assessment area representing 19.0 percent of branches in
California. There are no branches in low-income geographies where the population percentage is
8.6. The bank has one branch in a moderate -income geography which equates to 25.0 percent of
branches and is similar to the population percentage of 25.3 in moderate income geographies.
assessment area. Two employees participated in nine community development services equating
to 0.8 services per branch per year. This performance represents 15.3 percent of all community
development services in the state, which is similar to the assessment area's share of deposits and
branches. Community development services equate to 0.8 services per branch per year. The
following are examples of community development services provided.
An employee serves as a Board member for a foundation that battles poverty by

empowering youth and families in Los Angeles with the skills, resources, and
relationships necessary to thrive.
An employee provided a financial literacy session to small business owners in
collaboration with a non-profit organization that provides and administers SBA lending.
135
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SACRAMENTO MSA

ASSESSMENT AREA
The Sacramento MSA assessment area consists of Placer and Sacramento Counties. The
Sacramento -Roseville -Arden -Arcade, CA MSA has four counties; however, the bank has only
delineated the two counties as its assessment area. The bank operates three or 14.3 percent of
California branches in the assessment area. As shown in Appendix A, the assessment area
represents 17.0 percent of the rated area loans and 26.8 percent of the rated area deposits.
The 2015 ACS Census showed that the majority of the owner -occupied housing units,
businesses, and farms are located within middle- and upper -income census tracts. The following
table presents demographics information from the 2015 ACS Census and 2017 D&B data.
Demographic Information for

Sacramento MSA Assessment Area
% of # % of # % of # % of # % of #

136
and nation. Overall, the unemployment rates in the assessment area were consistently at or
below state averages and were above national rates for 2016 and 2017 in Sacramento County.
Unemp oyment Rates

2016 2017 2018
Area
Placer County, CA 4.5 3.8 3.1
Sacramento County, CA 5.4 4.6 3.7

business services. The top employers were University of California (Davis and UC Davis
Health), Kaiser Permanente, Sutter Health, and Intel Corp.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SACRAMENTO MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Sacramento MSA assessment area reflects
adequate responsiveness to the assessment area's credit needs. The geographic distribution reflects
adequate penetration throughout the assessment area, and the borrower profile reflects adequate
development loans.
Lending Activity
assessment area.
137
conclusions. The bank originated one home purchase loan and one home refinance loan, neither
of which was originated in a low- or moderate -income census tract.
assessment area. Small business lending in low- and moderate -income census tracts was below
demographic and aggregate lending data.
Borrower Profile
The distribution of HMDA and small business loans is adequate.
The bank did not originate a sufficient number of HMDA loans to derive meaningful
conclusions. The bank originated one home purchase loan to a borrower with no stated income.
In addition, the bank originated one home refinance loan to a moderate -income borrower.
The distribution of small business loans reflects adequate penetration among businesses of
less was substantially below the demographics and slightly below aggregate lending. Further,
loans in amounts of $100,000 or less, regardless of business size, were 69.7 percent which
reflects good access to credit for very small businesses.
Sacramento MSA assessment area. The bank originated 11 community development loans
totaling $2.4 million. This amount represents 20.8 percent by number and 4.3 percent by dollar
volume of community development lending within the California assessment areas only.
Regarding the community development purpose, 2 loans support affordable housing, and 9 loans
support community services. Examples of community development loans include a $49,000 line
of credit to a non-profit organization that provides free mental health services to low- and
moderate -income individuals and a $175,000 renewal line of credit to a non-profit developer of
affordable housing communities for low-income families.
INVESTMENT TEST
The bank has a significant level of qualified investments in the Sacramento MSA assessment
area relative to operations, exhibiting good responsiveness to credit and community development
needs. Qualified investments total $6.5 million or 12.3 percent of California qualified
investments. Investments include $882,000 in affordable housing prior period equity
investments; seven donation or grant contributions totaling $10,000, which benefitted affordable
138
housing and community services; and $5.6 million in SBA pools that support three small
businesses in the assessment area.
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the assessment area.
The bank provided an adequate level of community development services.
The bank operates three branches in the assessment area representing 14.3 percent of branches in
California. There is one branch each in a low-income tract which is significantly above the
population levels in those tracts. None of the branches are in moderate -income tracts with a
population level of 25.0 percent.

assessment area. Employees participated in five community development services. This
below the assessment area's share of branches and deposits. Community development services
equate to 0.6 services per branch per year. An example of a community development service is
noted below.
A bank employee provided a financial literacy event in collaboration with a small

business development corporation. The small business development corporation provides
existing and start-up small businesses with technical assistance designed to improve their
competitive standing in the marketplace. Topics discussed included real estate lending,
cash flow management, debt service coverage, and contract negotiations.
139
OTHER CALIFORNIA ASSESSMENT AREAS
(Limited -Scope Reviews)
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE LIMITED -SCOPE

CALIFORNIA ASSESSMENT AREAS REVIEWED
The following table summarizes the conclusions for the three California assessment areas

Anaheim MD Above Consistent Consistent
Oakland MD Below Below Below
Riverside MSA Below Below Consistent
area follows with additional information in the Appendices. Please note that the HMDA, small
business, and small farm lending figures in the activity table in the "Conclusions on Performance
services are from June 6, 2016 to March 26, 2019.
140
METROPOLITAN AREA
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ANAHEIM MD

ASSESSMENT AREA
The Anaheim MD assessment area consists of Orange County, which composes the Anaheim -
Santa Ana -Irvine, CA MD. Demographic data for the assessment area follows.

Anaheim MD Assessment Area

#
% of # % of # %of# %of# % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ANAHEIM MD

ASSESSMENT AREA
141
Activity # $
1-11MDA Loans 3 $900,000
Donations 1 $1,000
CD Services 8 --
142
METROPOLITAN AREA
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE OAKLAND MD

ASSESSMENT AREA
The Oakland MD assessment area consists of Contra Costa County. The Oakland -Haywood -
Berkeley, CA MD has two counties; however, the bank has only delineated the one county as its

Oakland MD Assessment Area

11
'Yo of # % of # % of # % of # % of #

last with zero percent deposit market share. The top five financial institutions account for 79.1
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE OAKLAND MD

ASSESSMENT AREA
143
Activity # $
Small Business Loans 6 $L6 million
HMDA Loans 0 --
Donations 0 --
CD Services 0 --
144
METROPOLITAN AREA
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE RIVERSIDE MSA

ASSESSMENT AREA
The Riverside MSA assessment area consists of Riverside County. The Riverside -San
Bernardino -Ontario, CA MSA has two counties; however, the bank has only delineated the one
county as its assessment area. Demographic data for the assessment area follows.

Riverside MSA Assessment Area
Demo g raphic Characteristics #
% of # % of # % of # % of # % of #
21st with 0.6 percent deposit market share. The top five financial institutions account for 68.7
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE RIVERSIDE MSA

ASSESSMENT AREA
145
Activity # $
Donations 12 $8,000
CD Services 10 --
146
GEORGIA
CRA RATING FOR GEORGIA: Satisfactory

The Service Test is rated: Low Satisfactory
SCOPE OF EVALUATION
The evaluation of the Georgia performance considered the operations of First -Citizens Bank in
four assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope
review of performance in the Atlanta, GA MSA assessment area. A significant portion of the
loans (78.7 percent), deposits (69.0 percent), and branches (60.9 percent) in Georgia are
concentrated in the assessment area. Small business loans constitute the primary loan type in all
assessment areas, comprising 80.5 percent of the loans. Therefore, the conclusions were
primarily based upon small business lending performance. Home mortgage loans were reviewed
in the full -scope assessment area, and small farm loans were not included in the analysis.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN GEORGIA
The bank operates 23 or 4.2 percent of branch offices in Georgia. Georgia accounts for 3.6
include SunTrust Bank; Wells Fargo Bank, NA; and Bank of America, NA. Together, the three
competitor institutions account for 51.1 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN GEORGIA
LENDING TEST
The Lending Test rating for Georgia is High Satisfactory. Lending levels reflect good
responsiveness to the Georgia assessment areas' credit needs. The geographic distribution reflects
development loans. The performance in the limited -scope GA Non-MSA assessment area was
above the full -scope area performance while performance in the other two limited -scope areas
was below the full -scope review.
Lending Activity
Lending levels reflect good responsiveness to the Georgia assessment areas' credit needs. The tables
in Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for each
Georgia assessment area.
147
The geographic distribution of HMDA loans reflects poor penetration throughout the assessment
areas. Poor performance in the Atlanta MSA assessment area supports this conclusion.
assessment areas. Adequate performance in the Atlanta MSA assessment area supports this
conclusion.
Borrower Profile
The distribution of HMDA loans is adequate among borrowers of different income levels.
Adequate performance in the Atlanta MSA assessment area supports this conclusion.
The distribution of loans is good among businesses of different sizes. Good performance in the
Atlanta MSA assessment area assessment area supports this conclusion.
First -Citizens Bank originated a relatively high level of community development loans in
Georgia. During this evaluation period, the bank originated 10 community development loans
totaling $52.6 million. This represents 2.7 percent by number and 7.4 percent by dollar volume
of bank -wide community development loans. The percent of community development loans by
number is below the bank -wide lending levels in the state at 3.6 percent. However, the percent
by dollar exceeded the bank -wide lending levels in the state. Two of the loans totaling $13.0
million were originated outside the assessment areas but within the broader state-wide
area. Since the bank has been responsive to community development needs and opportunities
within its assessment areas, the loans were included. The analysis for the full -scope Georgia
assessment area includes a detailed discussion of community development loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Georgia. The bank has an excellent
level of qualified investments in Georgia relative to the operations. Qualified investments total
$28.2 million or 8.3 percent of bank -wide qualified investments. Investments include one
LIHTC for an affordable housing project totaling $8.0 million; $17.4 million in SBA pools that
support 18 small businesses; 57 donations or grants totaling $67,000; and $2.7 million in a prior
period investment. SBA pool investments supporting economic development represent the
highest percentage of investments at 61.8 percent. The performance in the limited -scope Athens
MSA assessment area was above the full -scope area performance while performance in the other
two limited -scope areas was below the full -scope review.
148
SERVICE TEST
The Service Test rating for Georgia is Low Satisfactory. The bank operates 23 branches in
Georgia which represents 4.2 percent of bank -wide branches. The branches are considered
reasonably accessible to essentially all portion of the assessment areas. Changes to branches
occurred only in middle -income geographies and, thus, did not adversely affect low- or
moderate -income assessment areas or individuals. The bank had an adequate level of
community development services. The bank provided 49 community development services in
Georgia which equates to 0.8 community development services per branch per year. The
performance in the limited -scope GA Non-MSA assessment area was below the full -scope area
performance while performance in the other two limited -scope areas was above the full -scope
review.
149
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ATLANTA MSA

ASSESSMENT AREA
The Atlanta MSA assessment area comprises Cherokee, Cobb, DeKalb, Forsyth, Fulton, and
Gwinnett Counties. The Atlanta -Sandy Springs -Roswell, GA MSA includes 29 counties;
however, the bank delineated only 6 of the counties as the assessment area. The bank operates
14 or 60.9 percent of Georgia branch offices in this assessment area. As shown in Appendix A,
the assessment area represents 78.7 percent of the rated area loans and 69.0 percent of the rated
area deposits.
primarily within upper -income census tracts. The following table presents demographic

Atlanta MSA Assessment Area
% of # % of # % of # % of # % of #

Source: 20/5 ACS Census and 2017 D&B data
150
and nation during the evaluation period. The counties have unemployment rates generally below
both state and national average rates. However, Fulton and DeKalb Counties remain consistent
with state and national average rates for 2018.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Cherokee County 4.2 3.7 3.0
Cobb County 4.6 4.1 3.3
DeKalb County 5.4 4.8 3.9
Forsyth County 4.2 3.8 3.1
Fulton County 5.4 4.8 3.9

Gwinnett County 4.7 4.2 3.4
Georgia 5.4 4.7 3.9
In 2017, the top industries were professional and business services, education and health
services, and government. The top employers were Delta Air Lines Inc., Wal-Mart Stores Inc.,
The Home Depot Inc., Emory University, and WellStar Health System Inc.
Considering demographic and economic data, examiners determined small business loans for
new business owners represent a primary credit need for the assessment area. The significant
percentage of businesses with gross annual revenues of $1 million or less at 87.5 percent and the
large number of businesses with four or fewer employees at 73.4 percent support this conclusion.
Financial education courses on topics such as financing business ventures and obtaining capital
are also needed in this area, as a large number of small businesses are located here.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ATLANTA MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Atlanta MSA assessment area reflects
good responsiveness to assessment area credit needs. The geographic distribution reflects
development loans.
151
Lending Activity
area.
First -Citizens Bank's geographic distribution of HMDA loans reflects poor penetration
throughout the assessment area. The bank did not originate any home purchase or home
refinance loans in low-income census tracts; however, only 3.8 percent of owner -occupied
housing is in the low-income tracts, and aggregate lending was low. For home purchase loans,
performance in moderate -income census tracts was consistent with demographic and aggregate
lending data. For home refinance loans, performance in and moderate -income census tracts was
significantly below aggregate and demographic data.
assessment area. Small business lending in low- income census tracts was consistent with
demographic and aggregate lending data. Small business lending in moderate -income census
tracts was below demographic and aggregate lending data.
Borrower Profile
The distribution of HMDA and small business to borrowers of different incomes and businesses
of different sizes loans is good.
incomes. For home purchase loans, performance to low-income borrowers was significantly
below demographics but was above aggregate lending. Performance for home purchase loans to
moderate -income borrowers was above demographic data and aggregate lending data. The bank
did not originate any home refinance loans to low-income borrowers. Lending to moderate -
income borrowers was below demographic and aggregate lending data.
sizes. Loans to businesses with annual gross revenues of $1 million or less was significantly
below demographics but well above aggregate lending. Further, loans in amounts of $100,000 or
less, regardless of business size, were 74.8 percent, which reflects good access to credit for very
small businesses.
Atlanta MSA assessment area. The bank originated seven community development loans
totaling $37.6 million. This amount represents 87.5 percent by number and 95.0 percent by
152
dollar volume of community development lending within the Georgia assessment areas only.
Regarding the community development purpose, four loans support community services, one
loan supports economic development, and two loans support revitalization or stabilization.
Examples of community development loans include a $1.1 million loan to a business located in a
low-income census tract with funding to expand operations and create ten jobs; and a $25,000
line of credit to a community development corporation that provides services including
workforce development, affordable housing construction and renovation, and financial literacy
classes.
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Atlanta MSA assessment area
relative to operations, which exhibits excellent responsiveness to credit and community
development needs in the assessment area. Qualified investments total $19.1 million or 67.8
percent of Georgia qualified investments. Investments consist of $16.4 million in SBA pools
that support 17 small businesses; a prior period investment of $2.7 million, which supported
affordable housing; and 25 donation or grant contributions totaling $46,000. Of these
contributions, $1,000 benefitted affordable housing, $43,000 benefitted community services, and
$2,000 benefitted economic development.
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the assessment area, and
the opening and closing of branches has not adversely affected the accessibility of its delivery
systems. The bank provided an adequate level of community development services.
Georgia. The branching distribution in low-income geographies is similar to the percentage of
the population. There are no branches in moderate -income geographies, and the population is
21.8 percent in moderate -income geographies.
not closed any branches but opened a branch in a middle -income geography.
The institution provided an adequate level of community development services. Employees

participated in 30 community development services resulting in 0.8 services per branch per year.
This performance represents 61.2 percent of all community development services in the state,
153
which is similar to the assessment area's share of branches and deposits. The following are
examples of community development services provided in this assessment area.
An employee held a financial literacy event for residents of an addiction recovery center
for homeless individuals. Topics presented included budgeting and credit score
knowledge.
An employee provided a financial literacy session focused on SBA lending in
collaboration with a small business development center.
An employee serves on the Board of a non-profit affordable housing organization.
An employee partnered with an economic development organization to host a financial
literacy event for female, small business owners to discuss equipment leasing, merchant
services, and the loan process. The organization specializes in providing micro and small
business loans to promote successful small business startups in specific targeted areas
identified as economically oppressed due to limited resources, poverty levels, and high
unemployment.
154
OTHER GEORGIA ASSESSMENT AREAS

GEORGIA ASSESSMENT AREAS
The following table summarizes the conclusions for the three Georgia assessment areas reviewed
figures, aggregate lending data comparisons, and demographic information. The conclusions did
not alter the overall performance rating.

GA Non-MSA Above Below Below
Athens MSA Below Above Above
Savannah MSA Below Below Above
area follows with additional information in the Appendices. Please note that the HMDA, small
services are from June 6, 2016 to March 26, 2019.
155
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE GA NON-MSA

ASSESSMENT AREA
The GA Non-MSA assessment area consists of Franklin, Hart, and Stephens Counties.

GA Non-MSA Assessment Area
%of# %of# %of# °A o f # %of#
Median Family Income (2015) $45,816 Median Housing Value $108,357
The bank operates in a moderately competitive market. According to the FDIC Deposit Market
Share data as of June 30, 2018, eight financial institutions operated 24 full -service branches
within the assessment area. Of these institutions, First -Citizens Bank ranked 3rd with 18.9
percent deposit market share. The top five financial institutions account for 84.5 percent of the
deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE GA NON-MSA

ASSESSMENT AREA
First -Citizens Bank operates five branches in this assessment area. The bank originated and
156
Activity # $
Donations 19 $5,000
CD Services 3 --
157
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ATHENS MSA

ASSESSMENT AREA
The Athens MSA assessment area consists of Madison County. The Athens -Clarke County, GA
MSA consists of four counties; however, the bank has only delineated the one county as its

Athens MSA Assessment Area
% of # °A o f # °A o f # %of# %of#
There is limited competition by financial institutions in this market. According to the FDIC
Deposit Market Share data as of June 30, 2018, only three financial institutions operated six full -
1st with 45.2 percent deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ATHENS MSA

ASSESSMENT AREA
158
Activity # $
Donations 5 $1,000
CD Services 8 --
159
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SAVANNAH

MSA ASSESSMENT AREA
The Savannah MSA assessment area consists of Chatham County. The Savannah, GA MSA
consists of three counties; however, the bank has only delineated the one county as its

Savannah MSA Assessment Area
% of # % of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SAVANNAH

MSA ASSESSMENT AREA
First -Citizens Bank operates one branch in this AA. The bank originated and engaged in the
following activities in the assessment area during the review period.
160
Activity # $
Donations 8 $15,000
CD Services 8 --
161
FLORIDA
CRA RATING FOR FLORIDA: Satisfactory
The Lending Test is rated: Low Satisfactory

SCOPE OF EVALUATION
The evaluation of the Florida performance considered the operations of First -Citizens Bank in
eight assessment areas, which are detailed in Appendix A. Examiners conducted full -scope
reviews of performance in the Jacksonville MSA and West Palm Beach MSA assessment areas.
A large portion of the loans (45.1 percent), deposits (51.1 percent), and branches (43.8 percent)
in Florida are concentrated in these assessment areas. The bank also operates in the Tampa -St.
Pete, FL MSA and the Orlando, FL MSA. However, the assessment areas are excluded given the
time of entry into the markets and are not included in neither the deposit and branch
concentrations nor the assessment of the community development services comparisons for
branch levels. Small business loans constitute the primary loan type in all assessment areas. Home
mortgage loans were limited, and no farm loans were reviewed in any assessment areas. Therefore,
the conclusions were primarily based upon the small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN FLORIDA
The bank operates 26 or 4.7 percent of branch offices in Florida. Florida accounts for 3.9
include Bank of America, NA; Wells Fargo Bank, NA; and JPMorgan Chase Bank, NA.
Together, the three competitor institutions account for 41.8 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN FLORIDA
LENDING TEST
The Lending Test rating for Florida is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Florida assessment areas' credit needs. The geographic distribution reflects
adequate penetration throughout the assessment area, and the borrower distribution reflects good
penetration to borrowers of different incomes and businesses of different sizes. In addition, the
bank uses flexible lending practices and originated a low level of community development loans.
The performance in assessment areas that received limited -scope reviews was generally
consistent with the full -scope review areas.
162
Lending Activity
Lending levels reflect adequate responsiveness to the Florida assessment areas' credit needs. The
Florida assessment area.
The geographic distribution of HMDA and small business loans reflects adequate penetration
throughout the assessment areas and is primarily supported by small business lending
performance. Adequate performance in the West Palm Beach MSA assessment area and good
performance in the Jacksonville MSA assessment area primarily support this conclusion.
Borrower Profile
The distribution of HMDA and small business loans reflects good distribution to borrowers of
different incomes and businesses of different sizes and is primarily supported by good lending
performance to businesses of different sizes. Good performance in the West Palm Beach MSA
and the Jacksonville MSA assessment areas primarily supports this conclusion.
First -Citizens Bank originated a low level of community development loans in Florida. During
this evaluation period, the bank originated 8 community development loans totaling $4.0 million.
This performance represents a significant decline from the last evaluation's performance of 10
community development loans totaling $14.0 million. The current performance represents 2.1
percent by number and 0.6 percent by dollar volume of bank -wide community development
loans. The percent of community development loans by number is slightly below the bank -wide
lending levels in the state at 2.8 percent. The percent by dollar volume is significantly below the
bank -wide lending levels in the state. The analysis for the full -scope Florida assessment areas
includes a detailed discussion of community development loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Florida. The bank has an excellent
level of qualified investments in Florida relative to operations in this state. Qualified
include one $1.0 GNMA-multifamily security supporting affordable housing, five LIHTC
totaling $18.1 million supporting affordable housing projects, $5.0 million in SBA pools that
support 12 small businesses, a $778,000 prior period investment supporting affordable housing,
and 44 donations or grants totaling $48,000. LIHTC investments supporting affordable housing
represented the highest percentage of investments at 72.6 percent. The performance in the
limited -scope assessment areas was mixed with two below, one consistent, and three above
performance in the full -scope review areas.
163
SERVICE TEST
The Service Test rating for Florida is High Satisfactory. The bank operates 26 branches in
Florida, which represents 4.7 percent of all branches. However, 10 of the branches are in the
Tampa MSA and Orlando MSA assessment areas. The branches are reasonably accessible to
essentially all portions of the assessment area except in the Jacksonville MSA assessment where
all four branches are located in upper -income tracts. Changes in branches did not adversely
affect low- or moderate -income areas or individuals. Since the last evaluation, the bank opened
two branches in moderate -income tracts. Regarding branches closings, the bank closed three
branches with one each in a moderate -income tract middle -income census tract, and upper -
income tract. The bank provided a relatively high level of community development services in
Florida by providing 50 community development services, which equates to 1.1 community
development services per branch per year when the Tampa MSA and Orlando MSA assessment
area branches are excluded. The performance in the limited -scope assessment areas was mixed
with two below, two consistent, and two above performance in the full -scope review areas.
164
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE WEST PALM BEACH

MSA ASSESSMENT AREA
The West Palm Beach MSA assessment area consists of Palm Beach County, which represents
the entire West Palm Beach -Boca Raton -Delray Beach, FL MSA. The bank operates three or
18.8 percent of its Florida branch offices in the assessment area. As shown in Appendix A, the
assessment area represents 26.1 percent of the rated area loans. Additionally, the assessment
area accounts for 22.3 percent of the rated area deposits as reflected in Appendix D.
primarily located in middle- and upper -income tracts with good levels in moderate -income areas.
The following table presents demographics information from the 2015 ACS Census and 2017
D&B data.

West Palm Beach MSA Assessment Area
Demo graphic Characteristics

#
% of # °A of # % of # °A of # % of #
165
and nation. The county unemployment rate was consistent with or below both state and national
average rates.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Palm Beach County 4.7 4.2 3.6

Florida 4.8 4.2 3.7

services, and leisure and hospitality services. The top employers were Publix Super Markets
Inc., Tenet Healthcare Corp., and Hospital Corp. of America.
with gross annual revenues of $1 million or less at 91.0 percent and the ldrge number of
affordable housing represents a need as over 40.1 percent of families are low- and moderate -
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE WEST PALM BEACH MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the West Palm Beach MSA assessment area
reflects adequate responsiveness to assessment area credit needs. The geographic distribution
reflects adequate penetration throughout the assessment area, and the borrower profile reflects
good distribution to borrowers of different incomes and businesses of different sizes. In
addition, the bank uses flexible lending practices and originated a low level of community
development loans. The performance in the limited -scope assessment areas was consistent with
or above the full -scope review areas.
Lending Activity
assessment area.
166
conclusions. The bank originated seven home purchase loans and two home refinance loans but
none originated in low- or moderate -income census tracts.
assessment area. Small business lending in low-income census tracts was slightly above
was well below demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated seven home purchase loans in 2017, and two of them
originated to moderate -income borrowers. The bank originated only two home refinance loans,
but none originated to a low- or moderate -income borrower.
The distribution of small business loans reflects good distribution among businesses of different
sizes. Loans to businesses with annual gross revenues of $1 million or less were substantially
below the demographics but were well above the aggregate lending. Further, loans in amounts of
$100,000 or less, regardless of business size, were 76.1 percent, which reflects good access to
credit for very small businesses.
First -Citizens Bank originated few, if any, community development loans in the West Palm
Beach MSA assessment area. The bank originated five community development loans totaling
$125,000. This amount represents 62.5 percent by number and 3.2 percent by dollar volume of
community development loans within Florida. Two loans support affordable housing, and three
loans support community services. Examples of community development loans include a
$25,000 line of credit to a non-profit organization that provides affordable housing through the
acquisition and rehabilitation of residential properties and one loan and two renewed lines of
credit totaling $75,000 to an organization that provides social services including job training, re-
entry services, and food and clothing for low-income individuals.
INVESTMENT TEST
The bank has a poor level of qualified investments in the West Palm Beach MSA assessment
area relative to operations, which exhibit poor responsiveness to credit and community
development needs. Qualified investments total $193,000 or 0.8 percent of Florida qualified
167
investments. Investments include an SBA pool totaling $187,000 that supports a small business
and seven donation or grant contributions totaling $6,000. Of these contributions, $4,000
benefitted community services, $1,000 benefitted economic development, and $1,000 benefitted
revitalization and stabilization. The performance in the limited -scope Cape Cora MSA, Miami
MSA, and North Port -Sarasota MSA assessment areas was above the full -scope review areas.
However, performance in the limited -scope Fort Lauderdale MSA, Naples MSA, and Port St.
Lucie MSA assessment areas was below the performance in the full -scope review areas.
SERVICE TEST
opening and closing of branches has improved the accessibility of its delivery systems. The bank
Florida. The bank operates a branch in a moderate -income geography, which is comparable to
the population in moderate -income tracts. The bank does not have a branch in low-income
geographies where the population percentage is 7.3.
To the extent changes have been made, the opening and closing of branches has improved the
accessibility of its delivery systems, particularly in moderate -income geographies. Since the last
evaluation, the bank opened one branch in a moderate -income geography and closed a branch in
a middle- and upper -income geography.
participated in 12 community development services. This performance represents 24.0 percent
of all community development services in the state, which is above the assessment area's share
of branches. Community development services equate to 1.5 per branch per year. The following
are examples of community development services provided in this assessment area.
An employee held a financial literacy event in partnership with a housing authority. The
employee presented at the family self-sufficiency class and discussed budgeting, the
difference between debit and credit cards, and home and car loans.
An employee provided a financial literacy session at a high school where the student
population is primarily low- or moderate -income.
168
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE JACKSONVILLE MSA

ASSESSMENT AREA
The Jacksonville MSA assessment area consists of Duval and St. Johns Counties. The
Jacksonville, FL MSA has five counties; however, the bank only delineated two counties as its
assessment area. The bank operates four or 25.0 percent of its Florida branch offices in the
assessment area. As shown in Appendix A, the assessment area represents 19.0 percent of the
rated area loans. Additionally, as shown in Appendix D, the assessment area represents 19.3
percent of the rated area deposits.
The 2015 ACS Census shows most of the owner -occupied housing units, businesses and farms
are in middle- and upper -income census tracts. The following table presents demographics

Jacksonville MSA Assessment Area

#
% of # % of # % of # % of # % of #
institutions operated 241 branches within this area. Of these institutions, the bank ranked 21st in
169
and nation. Duval County was consistent with and St. Johns County was below state and
national average rates.
Unemp oyment Rates

2016 2017 2018
Area % %
%
Duval County 4.9 4.1 4.0
St. Johns County 3.8 3.3 3.4
Florida 4.8 4.2 3.7
services, and leisure and hospitality services. The top employers were Naval Air Station
Jacksonville, Baptist Health, Mayport Naval Station, Bank of America Merrill Lynch, and
Florida Blue.
affordable housing represents a need as 39.7 percent of families are low- and moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE JACKSONVILLE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Jacksonville MSA assessment area
reflects good penetration throughout the assessment area, and the borrower profile reflects good
bank uses flexible lending practices. The bank did not originate any community development
loans.
Lending Activity
assessment area.
170
conclusions. Of the seven home purchase loans the bank originated, none originated in a low-
income census tract, but one originated in a moderate -income census tract. Of the four home
refinance loans the bank originated, none originated in low- or moderate -income census tracts.
assessment area. Small business loans in low-income tracts was below demographic and
aggregate data while lending in moderate -income census tracts was slightly above demographic
and aggregate lending data.
Borrower Profile
conclusions. The bank originated seven home purchase loans in 2017, one of which was
originated to a moderate -income borrower. Additionally, the bank originated four home
refinance loans, one of which was originated to moderate -income borrowers.
The distribution of small business loans reflects good distribution among businesses of different
sizes. Small business loans to businesses with annual gross revenues of $1 million or less was
significantly below demographics but significantly above aggregate lending. Further, loans in
amounts of $100,000 or less, regardless of business size, were 81.7 percent, which reflects good
First -Citizens Bank did not originate any community development loans in the Jacksonville
MSA assessment area during the evaluation period.
INVESTMENT TEST
The bank has a significant level of qualified investments in the Jacksonville MSA assessment
area relative to operations, and exhibited a good responsiveness to credit and community
development needs. Qualified investments total $3.3 million or 13.2 percent of Florida qualified
investments. Investments include LIHTC investments $3.1 million that support affordable
housing projects, $127,000 in SBA pools that contributed to economic development by
supporting small businesses, and six donation or grant contributions totaling $14,000. Of these
contributions, $5,000 benefitted community services and $9,000 benefitted economic
development.
171
SERVICE TEST
Delivery systems are accessible to limited portions of the assessment area. The bank provided a
relatively high level of community development services.
The bank operates four branches in the assessment area representing 25.0 percent of branches in
Florida. All four branches are located in upper -income geographies. However, the bank's
alternative delivery systems help provide access throughout the entire assessment area despite no
branches in low- or moderate -income areas.
participated in 11 community development services or 1.0 service per branch per year. This
similar to the assessment area's share of branches. The following are examples of community
development services provided in this assessment area.
Two employees presented at an SBA conference and answered financing questions from
small business owners.
An employee provided a financial literacy session on credit counseling and tips for
saving money in conjunction with a United Way RealSense event. RealSense is a
nationally recognized financial stability program designed to save families money and
promote fiscal responsibility. RealSense provides free financial education, counseling,
and tax preparation services to help people save money and build assets.
172
OTHER FLORIDA ASSESSMENT AREAS

FLORIDA ASSESSMENT AREAS
The following table summarizes the conclusions for the six Florida assessment areas reviewed
test was impacted by the significant level of investments in the Cape Coral MSA, Miami MSA,
and North Port -Sarasota MSA assessment areas. The level of investments in these assessment
areas were significantly above the bank's operations.

Fort Lauderdale MSA Consistent Consistent Below
Cape Coral MSA Consistent Above Consistent
Miami MSA Above Above Above
Naples MSA Consistent Below Consistent
Port St. Lucie MSA Consistent Below Above
North Port -Sarasota MSA Consistent Above Below
area follows with additional information in the core tables in Appendix D. Please note that the
HMDA, small business, and small farm lending figures in the activity table in the "Conclusions
investments, and services are from June 6, 2016 to March 26, 2019.
173
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE FORT LAUDERDALE

MSA ASSESSMENT AREA
The Fort Lauderdale MSA assessment area consists of Broward County, which composes the
Fort Lauderdale -Pompano Beach -Deerfield, FL MSA. Demographic data for the assessment
area follows.

Fort Lauderdale MSA Assessment Area
% of # % of # % of # % of # % of #
33rd with 0.1 percent deposit market share. The top five financial institutions account for 64.5
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE FORT LAUDERDALE MSA

ASSESSMENT AREA
174
Activity # $
Donations 7 $5,000
CD Services 3 --
175
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE CAPE CORAL MSA

ASSESSMENT AREA
The Cape Coral MSA assessment area consists of Lee County, which composes the Cape Coral -
Fort Myers, FL MSA. Demographic data for the assessment area follows.

Cape Coral MSA Assessment Area
% of # % of # % of # °A of # % of #

24th with 0.6 percent of the deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CAPE CORAL MSA

ASSESSMENT AREA
176
Activity # $
FMDA Loans 5 $1.1 million
CD Services 8 --
177
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE MIAMI MSA

ASSESSMENT AREA
The Miami MSA assessment area consists of Miami -Dade County, which composes the Miami -
Miami Beach -Kendall, FL MSA. Demographic data for the assessment area follows.

Miami MSA Assessment Area
%of# %of# °A o f # % of # % of #

57th with less than 0.1 percent deposit market share. The top five financial institutions account
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE MIAMI MSA

ASSESSMENT AREA
178
Activity # $
Donations 3 $1,000
CD Services 6 --
179
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NAPLES MSA

ASSESSMENT AREA
The Naples MSA assessment area consists of Collier County, which composes the Naples-
Immokalee-Marco Island, FL MSA. Demographic data for the assessment area follows.
Naples MSA Assessment Area
% of # % of # % of 4 °A of # % of 4

CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NAPLES MSA

ASSESSMENT AREA
180
Activity # $
Donations 4 $4,000
CD Services 3 --
181
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE PORT ST. LUCIE MSA

ASSESSMENT AREA
The Port St. Lucie MSA assessment area consists of Martin County. The Port St. Lucie, FL
MSA has two counties; however, the bank has only delineated the one county as its assessment

Port St. Lucie MSA Assessment Area
%of# ')/0 o f # % of # % of # % of #
full -service service branches within the assessment area. Of these institutions, First -Citizens
Bank ranked 14th with 0.5 percent deposit market share. The top five financial institutions
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE PORT ST. LUCIE MSA

ASSESSMENT AREA
182
Activity # $
Donations 4 $3,000
CD Services 6 --
183
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NORTH PORT -

SARASOTA MSA ASSESSMENT AREA
The North Port -Sarasota MSA assessment area consists of Manatee and Sarasota Counties.
These two counties fully compose the North Port -Sarasota, FL MSA. Demographic data for the
assessment area follows.

North Port -Sarasota MSA Assessment Area
% of # % of # °A of # % of # °A of #

Due to rounding, totals may not equal 100.0
ranked 31st with 0.2 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NORTH PORT -SARASOTA

MSA ASSESSMENT AREA
184
Activity # $
Donations 1 $1,000
CD Services 1 --
185
TEXAS
CRA RATING FOR TEXAS: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Texas performance considered the operations of First -Citizens Bank in
three assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope
review of the performance in the Austin MSA assessment area. A significant portion of the
loans (67.7 percent), deposits (65.3 percent), and branches (42.9 percent) in Texas are
concentrated in this assessment area. Small business loans constitute the primary loan type in all
assessment areas. Home mortgage loans were limited, and no farm loans were originated in any
assessment areas. Therefore, the conclusions in this state were primarily based upon the bank's
small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN TEXAS
The bank operates seven or 1.3 percent of branch offices in Texas. Texas accounts for 0.8
percent of the bank -wide deposits and 1.4 percent of loans. First -Citizens Bank ranks 234th in
the state in deposit market share at less than 0.1 percent. Competitor institutions in the
assessment areas include JPMorgan Chase Bank, NA; Bank of America, NA; and USAA Federal
Saving Bank. Together, the three competitor institutions account for 44.6 percent of the market
share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN TEXAS
LENDING TEST
The Lending Test rating for Texas is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Texas assessment areas' credit needs. The geographic distribution reflects
adequate penetration throughout the assessment areas, and borrower profile reflects adequate
distribution of loans to borrowers of different incomes and businesses of different sizes. In
addition, the bank uses flexible lending practices and originated a relatively high level of
community development loans. The performance in the limited -scope assessment areas was
consistent with or above the performance in the full -scope review area.
Lending Activity
Lending levels reflect adequate responsiveness to the Texas assessment areas' credit needs. The
each Texas assessment area.
186
performance in all three assessment areas.
Borrower Profile
businesses of different sizes reflects is adequate and is primarily supported by lending
performance to businesses of different sizes in all three assessment areas.
First -Citizens Bank originated a relatively high level of community development loans in Texas.
During the evaluation period, the bank originated 11 community development loans totaling $7.2
million. This performance represents 2.9 percent by number and 1.0 percent by dollar volume of
number is above the bank -wide lending levels in the state at 1.4 percent. The analysis for the
full -scope Texas assessment area includes a detailed discussion of community development
loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Texas. The bank has an excellent level
of qualified investments in Texas relative to the bank's operations in this state. The bank's
qualified investments total $27.8 million or 8.2 percent of bank -wide qualified investments.
Investments include one prior period equity investment of $1.2 million that supported affordable
housing; five LIHTC investments totaling $15.1 that supported affordable housing projects;
$11.5 million in SBA pools that supported 11 small businesses in the assessment area; and 15
donations/grants totaling $16,000. The LIHTC investments that supported affordable housing
projects represented the highest percentage of investments at 54.2 percent
SERVICE TEST
The Service Test rating for Texas is Low Satisfactory. The bank operates seven branches in
Texas, which represents 1.3 percent of all branches. The branches are considered accessible to
limited portions of the assessment areas given all seven branches are located in upper -income
geographies. However, the alternative delivery systems provide additional access throughout the
assessment areas. The bank provided a relatively high level of community development services
in Texas. Specifically, the bank provided 21 community development services, which equates to
1.1 community development services per branch per year.
187
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE AUSTIN MSA

ASSESSMENT AREA
The Austin MSA assessment area consists of Travis and Williamson Counties. The Austin -
Round Rock, TX MSA has five counties; however, the bank only delineated the two counties as
its assessment area. The bank operates three or 42.9 percent of its Texas branch offices in the
Austin MSA assessment area. As shown in Appendix A, the assessment area represents 67.7
percent of the rated area loans and 65.3 percent of the rated area deposits.
farms are located in middle- and upper -income census tracts. Therefore, most lending
opportunities will be in these census tracts. The following table presents demographic

Austin MSA Assessment Area
% of # % of # % of # % of # % of #


188
and nation. Both counties have rates below state and national average rates.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Travis County 3.2 3.0 2.8
Williamson County 3.4 3.2 3.0
Texas 4.6 4.3 3.9
In 2017, the top industries were professional and business services, government, and leisure and
hospitality services. The top employers were University of Texas at Austin, Dell, Inc., Seton
HealthCare Network, Wal-Mart Stores, Inc., and St. David's Healthcare.
represent a primary credit need for the assessment area. The significant percent of businesses
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE AUSTIN MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Austin MSA assessment area reflects
addition, the bank uses flexible lending practices and originated a relatively high level of
community development loans.
Lending Activity
Lending levels reflect adequate responsiveness to assessment area credit needs. The core tables
area.
189
conclusions. The bank originated six home purchase loans and two refinance loans in 2017, and
none were originated in low- or moderate -income census tracts.
assessment area. The small business lending in both low- and moderate -income census tracts
was slightly below the demographic and aggregate lending data.
Borrower Profile
conclusions. None of the home purchase and refinance loans in 2017 were originated to a low -
or moderate -income borrowers.
The distribution of small business loans reflects adequate penetration among businesses of
different sizes. Lending to small businesses was significantly below demographic data but
consistent with aggregate lending. Further, loans in amounts of $100,000 or less, regardless of
business size, were 77.5 percent, which reflects good access to credit for very small businesses.
Austin MSA assessment area. The bank originated four community development loans totaling
$6.9 million. This amount represents 36.4 percent by number and 95.8 percent by dollar volume
of community development lending in Texas. Regarding the community development purpose,
all four loans support economic development. Examples of community development loans
include two loans totaling $350,000 to provide funding for a CDFI's micro -enterprise lending
program and two SBA 504 loans totaling $6.6 million to provide financing for a business to
relocate its main office to a larger building in a moderate -income census tract, which also created
new jobs.
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Austin MSA assessment area,
relative to the bank's operations. This performance exhibited excellent responsiveness to the
credit and community development needs. Qualified investments total $7.0 million or 25.2
percent of qualified investments in Texas. Investments include two LIHTC investments for
affordable housing projects totaling $3.7 million; $2.1 million in SBA pools that support three
small businesses in the assessment area; and five donation or grant contributions totaling $8,000.
Of these contributions, $1,000 benefitted affordable housing, $6,000 benefitted community
190
services, and $1,000 benefited economic development. Lastly, a prior period equity investment
total $1.2 million, which supported affordable housing activities, is also included.
SERVICE TEST
Delivery systems, including alternative delivery systems, are accessible to limited portion
portions of the assessment area. The opening and closing of branches has not adversely affected
the accessibility of its delivery systems. The bank provided a relatively high level of community
Texas. All branches are located in upper -income geographies. However, alternative systems are
reasonably accessible to essentially all portions of the assessment area.
similar to the assessment area's share of branches. Community development services equate to
1.2 services per branch per year. The following are examples of community development
services.
Two employees taught a financial literacy course at a small business incubator non-profit
organization.
An employee participated in the Greater Austin Money Smart Week, which is a week-
long financial education and awareness initiative in partnership with the Alliance for
Economic Inclusion.
An employee serves on the finance committee of a non-profit organization that provides
food, clothing, educational development, and dental care for low-income people.
191
OTHER TEXAS ASSESSMENT AREAS

TEXAS ASSESSMENT AREAS
The following table summarizes the conclusions for the two Texas assessment areas reviewed
institution's performance from reviewing available facts and data, including performance figures,
aggregate lending data comparisons, and demographic information. The conclusions did not
alter the overall performance rating.

Dallas MSA Above Consistent Consistent
Houston MSA Consistent Consistent Consistent
areas follows with additional information in the Appendices. Please note the HMDA, small
services are from June 6, 2016, to March 26, 2019.
192
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE DALLAS MSA

ASSESSMENT AREA
The Dallas MSA assessment area consists of Dallas and Collin Counties. The Dallas -Plano -
Irving, TX MSA has seven counties; however, the bank has only delineated the two counties as
its assessment area.
FDIC Deposit Market Share data as of June 30, 2018, 124 financial institutions operated 869 full
95th with less than 0.1 percent of the deposit market share. The top five financial institutions

Dallas MSA Assessment Area
(Dallas County only)**

#
% of # % of # % of # % of # % of #
(* *) FCB has designated Dallas and Collin Counties as its assessment area within the Dallas MSA. However, the evaluation focused analyses
only on Dallas County because of the timing of the bank's entry into Collin County.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE DALLAS MSA

ASSESSMENT AREA
193
Activity # $
1-IMDA Loans 1 $200,000
Donations 5 $2,000
CD Services 7 --
194
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE HOUSTON MSA

ASSESSMENT AREA
The Houston MSA assessment area consists of Fort Bend and Harris Counties. The Houston -
The Woodlands-Sugarland MSA has nine counties; however, the bank has only delineated the
two counties as its assessment area. Demographic data for the assessment area follows.

Houston MSA Assessment Area
Demo g raphic Characteristics Low Moderate Middle Upper NA*

#
''/o of # % of # % of # % of # % of #
Family Distribution by Income Level 1,195,439 25.7 16.4 16.9 41.1 0.0
Median Family Income - MSA (2015) $69,373 Median Housing Value $175,476
FDIC Deposit Market Share data as of June 30, 2018, 81 financial institutions operated 1,076
ranked 68th with less than 0.1 percent of the deposit market share. The top five financial
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE HOUSTON MSA

ASSESSMENT AREA
195
Activity # S
ENDA Loans 2 $200,000
Donations 5 $6,000
CD Services 4 --
196
ARIZONA
CRA RATING FOR ARIZONA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Arizona performance considered the operations of First -Citizens Bank in
two assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope
review of the bank's performance in the Phoenix MSA assessment area. A substantial portion of
the loans (92.5 percent), deposits (97.8 percent), and branches (66.7 percent) in Arizona are
concentrated in this assessment area. Small business loans constitute the primary loan type in both
assessment areas. Home mortgage loans were limited, and no farm loans were originated in either
assessment area. Therefore, the conclusions were primarily based on the small business lending
performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN ARIZONA
The bank operates three or 0.5 percent of branch offices in Arizona. Arizona accounts for 0.6
percent of the bank -wide deposits and 1.8 percent of loans. First -Citizens Bank ranks 32" in the
include JPMorgan Chase, NA; Wells Fargo Bank, NA; and Bank of America, NA; together, the
CONCLUSIONS ON PERFORMANCE CRITERIA IN ARIZONA
LENDING TEST
The Lending Test rating for Arizona is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Arizona assessment areas' credit needs. The geographic distribution reflects
development loans. The performance in the limited -scope assessment area was consistent with
the full -scope assessment area.
Lending Activity
Lending levels reflect adequate responsiveness to the Arizona assessment areas' credit needs. The
Arizona assessment area.
197
throughout the assessment areas. This conclusion is supported by adequate performance in both
assessment areas.
Borrower Profile
businesses of different sizes is adequate. This performance is primarily supported by an
adequate distribution to businesses of different sizes in both assessment areas.
First -Citizens Bank originated a low level of community development loans in Arizona. During
the evaluation period, the bank originated two community development loans totaling
$70,000. This represents 0.5 percent by number and 0.0 percent by dollar volume of bank -wide
community development loans. The percent of community development loans by number and
dollar volume is below the bank -wide lending levels in the state at 1.8 percent. The analysis for
the full -scope Arizona assessment area includes a detailed discussion of community development
loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Arizona. The bank has an excellent
level of qualified investments in Arizona relative to the bank's operations. Qualified investments
in Arizona total $7.4 million or 2.2 percent of bank -wide qualified investments. Investments
consist of $7.4 million in SBA pools that supported nine small business loans in Arizona
assessment areas and five donations or grants totaling $9,000. SBA pools supporting economic
development represented the highest percentage of investments at 99.9 percent. The
performance in the limited- scope assessment area was below the performance in the full -scope
assessment area.
SERVICE TEST
The Service Test rating for Arizona is High Satisfactory. The state rating was predicated on the
bank's activity in the Phoenix assessment area. Specifically, 97.8 percent of deposits in the state
are generated from the two branches in the Phoenix MSA assessment area. Branches are
accessible to limited portions of the assessment areas. None of the three branches in Arizona are
located in a low- or moderate -income census tracts. However, the bank offers several alternative
delivery systems for its customers, including low- and moderate -income customers. The bank is
a leader in providing community development services. The bank provided 15 community
development services in Arizona, which equates to approximately 1.8 community development
services per branch per year. The performance in the limited- scope assessment area was below
the performance in the full -scope assessment area.
198
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE PHOENIX MSA

ASSESSMENT AREA
The Phoenix MSA assessment area consists of Maricopa County. The Phoenix -Mesa -Scottsdale,
AZ MSA has two counties; however, the bank has only delineated the one county as its
assessment area. The bank operates two or 66.7 percent of its Arizona branch offices in the
Phoenix MSA assessment area. As shown in Appendix A, the assessment area represents 92.5
percent of loans and 97.8 percent of deposits in Arizona.
The 2015 ACS Census shows the owner -occupied housing units, businesses, and farms are
primarily located within middle- and upper -income census tracts. However, good levels are also
found in the moderate -income areas. Most lending opportunities will be in these census tracts.
D&B data.

Phoenix MSA Assessment Area
Demo graphic Characteristics

#
% of # % of # % of # % of # % of #
199
According to the Bureau of Labor Statistics, unemployment rates have fluctuated. Maricopa
County's average annual unemployment rate decreased in 2017 but slightly increased in 2018.
The unemployment rates for Maricopa County remained below state and national average for
2016 and 2017. The following table reflects the unemployment rates and trends for the
assessment area, state, and national averages.
Unemp oyment Rates

2016 2017 2018
Area
Maricopa County 4.6 4.2 4.4

Arizona 5.4 4.9 4.7
services, and retail trade. The top employers were Banner Health System, Wal-Mart Stores, Inc.,
Wells Fargo, NA, Arizona State University, and HonorHealth.
affordable housing represents a need as low- and moderate -income families total 38.7 percent.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE PHOENIX MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Phoenix MSA assessment area reflects
development loans.
Lending Activity
area.
200
conclusions. The bank originated nine home purchase loans and four refinance loans in 2017,
but none were originated in low- or moderate -income census tracts.
demographic and aggregate lending data. Lending in moderate -income census tracts was below
Borrower Profile
businesses of different sizes is adequate.
conclusions. The bank originated nine home purchase loans and four refinance loans in 2017,
but none were originated to low- or moderate -income borrowers.
The borrower distribution of small business loans reflects adequate penetration among
businesses of different sizes. Small business loans to businesses with annual gross revenues of
$1 million or less is significantly below demographics but above aggregate lending. Also, loans
in amounts of $100,000 or less, regardless of business size, were 65.8 percent, which reflects
First -Citizens Bank originated a low level of community development loans in the Phoenix MSA
assessment area. The bank originated two community development loans totaling $70,000. This
amount represents 100.0 percent of community development lending in Arizona. The
community development loans supported community services through financing a non-profit
organization's operations that provide social services to low- and moderate -income individuals.
For example, the organization provides a food and clothing bank, crisis housing, and medical and
dental services.
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Phoenix MSA assessment area,
relative to the bank's operations. This performance exhibited good responsiveness to credit and
community development needs. Qualified investments total $7.4 million or almost 99.9 percent
of Arizona qualified investments. Investments consist of $7.4 million in SBA pools that
supported economic development and donation or grant contributions of $6,000 that benefitted
community services.
201
SERVICE TEST
Delivery systems, including alternative delivery systems, are accessible to limited portions of the
assessment area. The opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank is a leader in providing community development
services.
The bank operates two branches in the assessment area, representing 66.7 percent of branches in
Arizona. Branches are accessible to limited portions of the assessment areas. All branches are
located in upper -income geographies. However, alternative systems are reasonably accessible to
essentially all portions of the assessment area.
The bank is a leader in providing community development services in this assessment area.
Employees participated in 15 community development services. This performance represents
100.0 percent of all community development services in the state, which is above the assessment
area's share of branches at 66.7 percent. Community development services equate to 2.7
services per branch per year. The following are examples of community development services.
An employee provided a homebuyer education financial literacy session for the

candidates of affordable housing through a city neighborhood revitalization department.
Three employees provide financial literacy sessions several times a year to low- and
moderate -income individuals attending educational and job skills training courses.
Topics presented by the bankers include basic banking knowledge, understanding and
improving credit, and home buying information.
An employee serves as a Board member of the Habitat for Humanity.
202
OTHER ARIZONA ASSESSMENT AREAS

ARIZONA ASSESSMENT AREA REVIEWED
The following table summarizes the conclusions for the Arizona assessment area reviewed using
limited -scope examination procedures. Examiners drew conclusions regarding the institution's
CRA performance from reviewing available facts and data, including performance figures,
aggregate lending data comparisons, and demographic information. The conclusions did not
alter the overall performance rating.

Tucson MSA Consistent Below Below
area follows with additional information in the Appendices. Please note the HMDA, small
2017 lending data, while the figures for the community development loans, qualified
investments, and community development services are from June 6, 2016, to March 26, 2019.
203
METROPOLITAN AREA
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE TUCSON MSA

ASSESSMENT AREA
The Tucson MSA assessment area consists of Pima County, which comprises the Tucson, AZ

Tucson MSA Assessment Area
% of # 'Yo of # % of # % of # '% of #

service branches within the assessment area. Of these institutions, First -Citizens ranked 18th
with less than 0.1 percent deposit market share. The top five financial institutions account for
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE TUCSON MSA

ASSESSMENT AREA
204
Activity # $
Donations 1 $3,000
CD Service 0 --
205
WASHINGTON
CRA RATING FOR WASHINGTON: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Washington performance considered the operations of First -Citizens Bank
in three assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope
review of the Seattle MSA assessment area. A large portion of the loans (71.7 percent), deposits
(33.6 percent), and branches (50.0 percent) in Washington are concentrated in these assessment
areas. Home mortgage loans were limited, and no farm loans were originated in the assessment
areas. Therefore, the conclusions were primarily based on the small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN WASHINGTON
The bank operates six or 1.1 percent of branch offices in Washington. Washington accounts for
1.1 percent of the bank -wide deposits and 1.5 percent of loans. Overall, First -Citizens Bank
ranks 23rd in the state in deposit market share at 0.3 percent. Competitor institutions in the
assessment areas include Bank of America, NA; Wells Fargo Bank, NA; and JPMorgan Chase,
NA. Together, the three competitor institutions account for 51.9 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN WASHINGTON
LENDING TEST
The Lending Test rating for Washington is High Satisfactory. Lending levels reflect good
responsiveness to the Washington assessment areas' credit needs. The geographic distribution
reflects good penetration throughout the assessment areas, and borrower profile reflects good
development loans. The performance in the limited -scope Tacoma MSA assessment area was
below the full -scope assessment area. However, performance in the limited -scope Olympia
MSA assessment area was consistent with the performance in the full -scope assessment area.
Lending Activity
Lending levels reflect good responsiveness to the Washington assessment areas' credit needs. The
Washington assessment area.
206
The geographic distribution of HMDA and small business loans reflects good penetration
performance in the Seattle MSA assessment area.
Borrower Profile
businesses and farm of different sizes reflects good distribution and is primarily supported by
lending performance to businesses of different sizes in the Seattle MSA assessment area.
First -Citizens Bank originated an adequate level of community development loans in

Washington. During this evaluation period, the bank originated six community development
loans totaling $2.7 million. This represents 1.6 percent by number and 0.4 percent by dollar
volume of bank -wide community development loans. The percent of community development
loans by number and dollar volume is below the bank -wide lending levels in the state at 1.5
percent. One loan totaling $15,000 was originated outside the assessment areas but within the
broader state-wide area. Since the bank has been responsive to community development needs
and opportunities within its assessment areas, the loan was included. The analysis for the full -
scope Washington assessment area includes a detailed discussion of community development
loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Washington. The bank has an
excellent level of qualified investments in Washington, relative to operations in this state. The
qualified investments total $21.9 million or 6.5 percent of bank -wide qualified investments.
Investments include one prior period investment totaling $2.9 million that supported affordable
housing, LIHTC investments totaling $15.1 million that also supported affordable housing
projects, SBA pools for $3.9 million that supported economic development, and 22 donations or
grants totaling $15,000. The LIHTC investments represented the highest percentage of
investments in the state at 69.0 percent. The performance in the limited -scope assessment areas
was below the full -scope assessment area.
SERVICE TEST
The Service Test rating for Washington is Low Satisfactory. The bank operates six branches in
Washington, which represents 1.1 percent of all branches. Overall, branches are essentially
accessible to essentially all portions of the bank's assessment areas. One of the six branches in
the state is located in a low-income census tract, and another branch is located in moderate -
income census tract. The bank provided an adequate level of community development services
in Washington. Specifically, the bank provided 16 community development services, which
equate to approximately one community development service per branch per year. The
207
performance in the limited -scope Tacoma MSA assessment area was consistent with the full -
scope assessment area. However, performance in the limited -scope Olympia MSA assessment
area was above the performance in the full -scope assessment area.
208
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SEATTLE MSA

ASSESSMENT AREA
The Seattle MSA assessment area consists of King County. The Seattle -Bellevue -Everett, WA
MSA has two counties; however, the bank only delineated one county within the assessment
area. The bank operates three or 50.0 percent of its Washington branches in this assessment
area. As shown in Appendix A, the assessment area represents 71.7 percent of the and 33.6
percent of deposits in the state.
The 2015 ACS Census shows that most of the owner -occupied housing units, businesses, and
opportunities will be in these census tracts. However, there is a fair volume in the moderate -
income areas. The following table presents demographics information from the 2015 ACS
Census and 2017 D&B data.

Seattle MSA Assessment Area

#
% of # % of # % of # % of # % of #
209
and nation. King County's unemployment rates were consistently below state and national
average rates.
Unemp oyment Rates

2016 2017 2018
Area % % %
King County 3.9 3.7 3.3
Washington 5.3 4.8 4.6

services, and government. The top employers were Boeing Co., Amazon, Microsoft Corp.,
University of Washington, and Providence Health & Services.
affordable housing represents a need as low- and moderate -income families exceed 38.4 percent.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SEATTLE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Seattle MSA assessment area reflects
penetration throughout the assessment area, and the borrower profile reflects a good distribution
to borrowers of different incomes and businesses of different sizes. In addition, the bank uses
flexible lending practices and originated an adequate level of community development loans.
Lending Activity
Lending levels reflect good responsiveness to assessment area credit needs. The core tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in this assessment
area.
210
conclusions. In 2017, the bank originated only one home purchase loan, and it was originated in
an upper -income census tract. However, one of the three home refinance loans in 2017 was
originated in a moderate -income census tract.
assessment area. Small business lending in low- income census tracts was slightly below
demographic and aggregate data while lending in moderate -income tracts was above both data
sets.
Borrower Profile
conclusions. The bank originated one home purchase loan and three home refinance loans in
2017, but none were originated to low- or moderate -income borrowers.
less were significantly below demographics but exceeded aggregate data. Further, loans in
amounts of $100,000 or less, regardless of business size, were 74.3 percent, which reflects good
First -Citizens Bank originated an adequate level of community development loans in the Seattle
MSA assessment area. The bank originated three community development loans totaling $2.6
community development lending within the Washington assessment areas only. Regarding the
purpose, one loan supports affordable housing and two loans support community services.
Examples of community development loans include a $2.6 million loan to a tribal addiction
treatment center located in a moderate -income census tract that provides free outpatient services
for Native Americans and a $12,000 loan to a CDFI through a multi -bank participation. The
participation funds were used for a 112 -unit affordable housing development located in a
moderate -income census tract, which is rent -restricted to 50.0 percent of the county's median
income.
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Seattle MSA assessment area,
relative to operations. This performance exhibited excellent responsiveness to credit and
211
community development needs. Qualified investments total $16.8 million or 76.7 percent of
Washington qualified investments. Investments consist of LIHTC investments for affordable
housing projects totaling $15.1 million, SBA pools for $1.6 million that supported small
businesses in the assessment area, and four donation or grant contributions totaling $3,000. Of
these contributions, $1,000 benefitted community services and $2,000 benefitted economic
development.
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the assessment area, and
the opening and closing of branches has improved the accessibility of its delivery systems. The
bank provided a limited level of community development services.
The bank operates three branches in the assessment area representing 50.0 percent of the bank's
branches in Washington. One branch (33.3 percent) is in a low-income census tract, and the
other two are located in upper -income census tracts. The branch distribution in the low-income
tract at 33.3 percent significantly exceeds the percentage of the population in that tract at 5.1
percent.
To the extent changes have been made, the opening and closing of branches has improved the
accessibility of its delivery systems, particularly in low- and moderate -income census tracts or to
low- and moderate -income individuals. Since the last evaluation, the bank opened one branch in
this assessment area in a low-income census tract.
The institution provided a limited level of community development services in this assessment
area. Employees participated in four community development services. This performance
represents 25.0 percent of all community development services in the state, which is below the
assessment area's share of branches at 50.0 percent. Community development services equate to
0.5 community development services per branch per year. One example is an employee led a
financial literacy presentation to a group of small business owners who have annual revenues
less than $1 million. The employee discussed common types of account fraud, protection against
account fraud, and how to obtain small business financing.
212
OTHER WASHINGTON ASSESSMENT AREAS

WASHINGTON ASSESSMENT AREAS
The following table summarizes the conclusions for the two Washington assessment areas
conclusions did not alter the performance rating.

Tacoma MSA Below Consistent Consistent
Olympia MSA Consistent Consistent Above
area follows with additional information in the core tables in Appendix D. Please note the
qualified investments, and community development services are from June 6, 2016, to March 26,
2019.
213
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE TACOMA MSA

ASSESSMENT AREA
The Tacoma MSA assessment area consists of Pierce County, which composes the Tacoma -
Lakewood, WA MSA. Demographic data for the assessment area follows.

Tacoma MSA Assessment Area
Lo w Moderate Middle Upper NA*
% of # % of # % of # % of # % of #

CONCLUSIONS ON PERFORMANCE CRITERIA IN THE TACOMA MSA

ASSESSMENT AREA
214
Activity # $
Donations 6 $7,000
CD Services 7 --
215
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE OLYMPIA MSA

ASSESSMENT AREA
The Olympia MSA assessment area consists of Thurston County, which composes the Olympia-
Tumwater, WA MSA. Demographic data for the assessment area follows.

Olympia MSA Assessment Area
% of #
% of # % of # % of # % of #
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE OLYMPIA MSA

ASSESSMENT AREA
216
Activity # $
Donations 12 $5,000
CD Service 5 --
217
COLORADO
CRA RATING FOR COLORADO: Satisfactory

The Service Test is rated: Needs to Improve
SCOPE OF EVALUATION
The evaluation of the Colorado performance considered the operations of First -Citizens Bank in
two assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope
review of the performance in the Denver MSA assessment area. A significant portion of the
loans (82.0 percent), deposits (90.3 percent), and branches (80.0 percent) in Colorado are
concentrated in this assessment area. Small business loans constitute the primary loan type in all
assessment areas. Home mortgage loans were limited, and one farm loan was originated in the
assessment areas. Therefore, the conclusions in this state were primarily based on small business
lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN COLORADO
The bank operates five or 0.9 percent of branch offices in Colorado. Colorado accounts for 0.6
percent of the bank -wide deposits and 0.9 percent of loans. First -Citizens Bank ranks 63rd in the
include Wells Fargo Bank, NA; U.S. Bank, N.A.; and FirstBank; together, the three competitor
institutions account for 46.0 percent of the market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN COLORADO
LENDING TEST
The Lending Test rating for Colorado is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Colorado assessment areas' credit needs. The geographic distribution reflects
adequate penetration throughout the assessment areas, and the borrower distribution reflects good
distribution to borrowers of different incomes and businesses different sizes. In addition, the bank
use flexible lending practices and originated a low level of community development loans. The
performance in the limited -scope assessment area was consistent with the full -scope review area.
Lending Activity
Lending levels reflect adequate responsiveness to the Colorado assessment areas' credit needs. The
each Colorado assessment areas.
218
performance in the Denver MSA assessment area.
Borrower Profile
The distribution of HMDA and small business loans reflects good distribution to borrowers of
different incomes and businesses and farm of different sizes and is primarily supported by
lending performance to businesses of different sizes in the Denver MSA assessment area.
First -Citizens Bank originated a low level of community development loans in Colorado. During
the evaluation period, the bank originated four community development loans totaling $175,000.
This represents 1.1 percent by number and 0.0 percent by dollar volume of bank -wide
community development loans. The percent of community development loans by number
slightly exceeds the bank -wide lending levels in the state at 0.9 percent. However, the percent
by dollar volume is below the bank -wide lending levels. The analysis for the full -scope
Colorado assessment area includes a detailed discussion of community development loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Colorado. The bank has an excellent
level of qualified investments in Colorado relative to the bank's operations in this state.
Qualified investments total $11.2 million or 3.3 percent of bank -wide qualified investments.
Investments include prior period equity investments of $905,000, which support affordable
housing; LIHTC investments totaling $7.4 million that supported affordable housing projects;
GNMA multifamily securities for $2.9 million that support affordable housing; and five
donations or grants totaling $5,000 that benefitted community services. The LIHTC investments
represented the highest percentage of investments at 66.2 percent. Nearly all investments are in
the Denver MSA assessment area. The performance in the limited -scope assessment area was
below the full -scope review area.
SERVICE TEST
The Service Test for Colorado is rated Needs to Improve. First -Citizens Bank delivery systems,
including alternative delivery systems, are accessible to limited portions of the assessment areas.
None of the five branches the bank operates in Colorado are located in a low- or moderate -
income census tract. However, the service delivery systems, particularly alternative systems, are
reasonably accessible to essentially all portions of the assessment area. The bank provided a
limited level of community development services in Colorado during the evaluation period.
Specifically, the bank provided seven community development services, which equates to
approximately 0.5 community development services per branch per year. The performance in
the limited -scope assessment area was above the full -scope review area.
219
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE DENVER MSA

ASSESSMENT AREA
The Denver MSA assessment area comprises Adams, Arapahoe, Denver, and Douglas Counties,
which represent a portion of the Denver -Aurora -Lakewood MSA. The bank operates four or
80.0 percent of its Colorado branch offices in this assessment area. As shown in Appendix A,
the assessment area represents 82.0 percent of loans and 90.3 percent deposits in Colorado.
The 2015 ACS Census shows that owner -occupied housing units are evenly presented across the
moderate-, middle-, and upper -income tracts. The largest level of businesses and farms is in
upper -income census tracts with good levels also present in the moderate- and middle -income
tracts. The following table presents demographics information from the 2015 ACS Census and
2017 D&B data.

Denver MSA Assessment Area
% of # % of # % of # % of # % of #
220
According to the Bureau of Labor Statistics, unemployment rates have remained consistent. The
following table reflects the average annual unemployment rates and trends for the assessment
area, state, and nation. The assessment area counties have unemployment rates consistently
below national average rates. However, the unemployment rate in Adams County was higher
than state and other county averages in 2016 and 2017.
Unemp oyment Rates

2016 2017 2018
Area
% % %
Adams County 3.6 3.1 3.3
Arapahoe County 3.1 2.8 2.8
Denver County 3.1 2.8 3.0
Douglas County 2.7 2.4 2.7
Colorado 3.2 2.7 3.3
and health services. The top employers were HealthONE, University of Colorado Hospital,
Lockheed Martin Corp., Centura Health, and United Airlines, Inc.
affordable housing represents a need 40.6 percent of the families are low- and moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE DENVER MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Denver MSA assessment area reflects
adequate penetration throughout the assessment area, and the borrower profile reflects a good
bank used flexible lending practices and originated a low level of community development loans.
221
Lending Activity
area.
conclusions. The bank originated nine home purchase loans and one refinance loan in 2017,
three of which were originated in low- or moderate -income census tracts.
assessment area. The small business lending in low- and moderate -income census tracts was
below the demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated one home purchase and one home refinance to borrowers with
no stated income. Thus, only eight purchases were available for analysis. Of those eight, none
were originated to low- or moderate -income borrowers.
sizes. Lending to businesses with annual gross revenues of $1 million or less was significantly
below the demographics but exceeded the aggregate lending. Further, loans in amounts of
$100,000 or less, regardless of business size, were 86.4 percent, which reflects excellent access
First -Citizens Bank originated a low level of community development loans in the Denver MSA
assessment area. The bank originated four community development loans totaling $175,000.
This amount represents 100.0 percent of community development lending in Colorado.
Regarding the community development purpose, two loans support community services, and two
loans support economic development. Examples of community development loans include a
$50,000 origination and refinancing of a loan to a CDFI that provides capital to small businesses
and start-ups.
222
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Denver MSA assessment area
relative to the bank's operations. This performance exhibited excellent responsiveness to credit
and community development needs. Qualified investments total $11.2 million or almost 100.0
percent of Colorado qualified investments. Investments include prior period investments totaling
$905,000 that support affordable housing, a LIHTC investment for an affordable housing project
totaling $7.4 million, GNMA multifamily securities for $2.9 million that support affordable
housing, and three donation or grant contributions totaling $4,000 that benefitted community
services.
SERVICE TEST
First -Citizens Bank's delivery systems are accessible to limited portions of the Denver MSA
assessment area, and the opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank provided a limited level of community
The bank operates four branches in the Denver MSA assessment area. Three branches are in
middle -income census tracts, and one is in an upper -income census tract. However, First-
Citizens Bank's service delivery systems, particularly alternative systems, are reasonably
accessible to essentially all portions of the assessment area.
area. Employees participated in five community development services. This performance
represents 71.4 percent of community development services in the state, which is below the
assessment area's share of branches and deposits. Community development services equate to
0.4 services per branch per year. The following are examples of community development
services provided.
An employee serves on the loan committee of a CDC specializing in SBA 504 loans.
An employee provided a financial literacy session to start-up businesses in collaboration
with a small business development center.
223
OTHER COLORADO ASSESSMENT AREA

COLORADO ASSESSMENT AREA
The following table summarizes the conclusions for the Colorado assessment area reviewed

Boulder MSA Consistent Below Above
224
METROPOLITAN AREA
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE BOULDER MSA

ASSESSMENT AREA
The Boulder MSA assessment consists of Boulder County, which comprises the Boulder, CO
MSA. Demographic data for the assessment area follows. The assessment area is highly
competitive in the financial services market. According to the FDIC Deposit Market Share data
as of June 30, 2018, 30 financial institutions operated 103 full -service branches within the
assessment area. Of these institutions, First -Citizens Bank ranked 27th with 0.2 percent deposit
market share. The top five financial institutions account for 65.1 percent of the deposit market
share.

Boulder MSA Assessment Area
Demographic Characteristics L ow Moderate Middle Upper

ft
°A) of # % of # °A of # % of # of #
%NA*
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE BOULDER MSA

ASSESSMENT AREA
225
Activity # $
Donations 2 $1,000
CD Services 2 --
226
TENNESSEE
CRA RATING FOR TENNESSEE: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Tennessee performance considered the operations of First -Citizens Bank in
four assessment areas, which are detailed in Appendix A. Examiners conducted full -scope reviews
of performance in the Knoxville MSA and Chattanooga MSA assessment areas. A significant
portion of the loans (76.3 percent), deposits (66.0 percent), and branches (50.0 percent) in
Tennessee are concentrated in these assessment areas. Small business loans constitute the primary
loan type in all assessment areas. Home mortgage loans were limited, and no farm loans were
originated in any assessment areas. Therefore, the conclusions were primarily based on small
business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN TENNESSEE
The bank operates six or 1.2 percent of branch offices in Tennessee. Tennessee accounts for 0.3
include SunTrust Bank, NA; Pinnacle Bank; and Regions Bank. Together, the three competitor
CONCLUSIONS ON PERFORMANCE CRITERIA IN TENNESSEE
LENDING TEST
The Lending Test rating for Tennessee is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Tennessee assessment areas' credit needs. The geographic distribution
reflects adequate penetration throughout the assessment areas, and borrower profile reflects
adequate distribution of loans to borrowers of different incomes and businesses of different sizes.
In addition, the bank uses flexible lending practices. The bank made a low level of community
development loans. The performance in the limited -scope assessment areas was consistent with
Lending Activity
Lending levels reflect adequate responsiveness to the Tennessee assessment areas' credit needs. The
Tennessee assessment area.
227
performance in the Knoxville MSA and Chattanooga MSA assessment areas.
Borrower Profile
The distribution of HMDA and small business loans reflects adequate distribution to borrowers
of different incomes and businesses of different sizes and is primarily supported by lending to
businesses of different sizes in the Knoxville MSA and Chattanooga MSA assessment areas.
The performance in Knoxville MSA assessment was adequate, while performance was good in
the Chattanooga MSA assessment area.
First -Citizens Bank originated a low level of community development loans in

Tennessee. During this evaluation period, the bank originated four community development
loans totaling $120,000. This represents 1.1 percent by number and 0.0 percent by dollar volume
of bank -wide community development loans. The percent of community development loans by
number slightly exceeds the bank -wide lending levels in the state at 1.1 percent. However, the
percent by dollar volume is below the bank -wide lending levels. The analysis for each full -scope
Tennessee assessment area includes a detailed discussion of community development loans.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Tennessee. The bank has an excellent
level of qualified investments in Tennessee, relative to the bank's operations in this state. This
performance exhibited good responsiveness to credit and community development needs.
Investments include LIHTC investments totaling $5.7 million that support affordable housing
projects; GNMA multifamily securities totaling $3.0 million that support affordable housing; and
11 donations or grants totaling $19,000, which benefitted community services and economic
development. The LIHTC investments supporting affordable housing projects represented the
highest percentage of investments at 65.5 percent. The performance in the limited -scope
Nashville MSA assessment area above the full -scope review areas. However, performance in the
limited -scope Johnson City MSA assessment area was below the performance in the full -scope
review areas.
SERVICE TEST
The Service Test rating for Tennessee is Low Satisfactory. The bank operates six branches in
Tennessee which represents 1.2 percent of all branches. One branch is located in a low-income
tract with one in a middle -income tract and four in upper -income tracts. The branches are
reasonably accessible to essentially all portions of the assessment areas. The bank provided an
adequate level of community development services in Tennessee. Specifically, the bank
228
provided 15 community development services, which equate to almost one community
development service per branch per year. The performance in the limited -scope Nashville MSA
assessment area was above the full -scope assessment area. However, performance in the
limited -scope Johnson City MSA assessment area was below with the performance in the full -
scope assessment area.
229
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE KNOXVILLE MSA

ASSESSMENT AREA
The Knoxville MSA assessment area consists of Knox County. The Knoxville, TN MSA has
nine counties; however, the bank delineated the one county as its assessment area. The bank
operates two or 33.3 percent of its Tennessee branch offices in the Knoxville MSA assessment
loans and 45.4 percent of the rated area deposits.
farms are primarily located within middle- and upper -income census tracts. Therefore, most
lending opportunities will be in these census tracts. The following table presents demographic

Knoxville MSA Assessment Area
% of ft % of # % of # % of # % of #

230
table reflects the average annual unemployment rates and trends for Knox County, Tennessee,
and nation during the evaluation period. Knox County's unemployment rates were consistently
below state and national average rates.
Unemp oyment Rates

2016 2017 2018
Area % %
Knox County 4.0 3.2 2.5

Tennessee 4.7 3.7 3.5
and health services. The top employers were Covenant Health, University of Tennessee, Wal-
Mart Stores, Inc., University Health System, and Oak Ridge National Laboratory.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE KNOXVILLE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Knoxville MSA assessment area reflects
development loans.
Lending Activity
assessment area.
231
conclusions. The bank originated three home purchase loans, and none were originated in low -
or moderate -income census tracts.
tracts, but this performance is mitigated by the low demographic and aggregate lending data in
these census tracts. Lending in moderate -income census tracts was consistent with the
demographic data and slightly above the aggregate lending data.
Borrower Profile
conclusions. The bank originated three home purchase loans, and none were originated to low -
The distribution of small business loans reflects adequate distribution among businesses of
different sizes. Small business lending to businesses with annual gross revenues of $1 million or
less was significantly below demographic data but exceeded aggregate lending. Further, loans in
amounts of $100,000 or less, regardless of business size, were 58.9 percent, which reflects
adequate access to credit for very small businesses.
First -Citizens Bank originated a low level of community development loans in the Knoxville
MSA assessment area. The bank originated one community development loan totaling
community development lending in Tennessee. The community development loan provided
financing to a non-profit organization that extends various services to low- and moderate -income
individuals and small businesses. These services include homeownership and financial literacy
courses, workforce development, and small business lending.
INVESTMENT TEST
The bank has an excellent level of qualified investments in the Knoxville MSA assessment area
relative to the bank's operations. This performance exhibits good responsiveness to credit and
community development needs. Qualified investments total $5.3 million or 60.6 percent of
Tennessee qualified investments. Investments consist of GNMA-multifamily securities for
affordable housing totaling $3.0 million, LIHTC investments for an affordable housing project
232
totaling $2.3 million, and four donation or grant contributions totaling $9,000. Of these
contributions, $7,000 benefitted community services, and $2,000 benefitted economic
development.
SERVICE TEST
First -Citizens Bank's delivery systems are accessible to limited portions of the Knoxville MSA
assessment area, and the opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank provided a limited level of community
The bank operates two of the six Tennessee branches in the Knoxville MSA assessment area.
The branches are located in upper -income census tracts. However, First -Citizens Bank's service
delivery systems, particularly alternative systems, are reasonably accessible to essentially all
portions of the assessment area.
area. Employees participated in three community development services. This performance
represents 20.0 percent of all community development services in the state. Community
development services equate to 0.5 services per branch per year. The community development
services in this assessment area consisted of three financial literacy sessions, two of which were
small business -related, and one was targeted to low- and moderate -income women.
233
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE CHATTANOOGA MSA

ASSESSMENT AREA
The Chattanooga MSA assessment area consists of Hamilton County. The Chattanooga, TN
MSA has three counties; however, the bank delineated only Hamilton County as its assessment
area. The bank operates one or 16.7 percent of its Tennessee branch offices in the Chattanooga
MSA assessment area. As shown in Appendix A, the assessment area contains 33.8 percent of
The 2015 ACS Census shows the owner -occupied housing units, businesses, and farms are
primarily located within middle- and upper -income census tracts. Therefore, most lending

Chattanooga MSA Assessment Area
% of # °A of # % of # °A of # °A) of #

234
table reflects the average annual unemployment rates and trends for Hamilton County, state,
nation during the evaluation period. Hamilton County has had unemployment rates comparable
to national averages and consistently above state averages. However, it was below the national
average in 2018.
Unemp oyment Rates

2016 2017 2018
Area % % %
Hamilton County 4.9 3.9 3.6
Tennessee 4.7 3.7 3.5
In 2017, the top industries were government, education and health services, and manufacturing.
The top employers were BlueCross BlueShield of Tennessee, Erlanger Health System,
Tennessee Valley Authority, Volkswagen Chattanooga, and McKee Foods Corp.
affordable housing represents a need as low- and moderate -income families total 37.2 percent.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CHATTANOOGA MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Chattanooga MSA assessment area
reflects adequate penetration throughout the assessment area, and the borrower profile reflects a
good distribution. In addition, the bank used flexible lending practices and originated a low level
of community development loans.
Lending Activity
assessment area.
235
conclusions. The bank made seven home purchase loans, with one originated in a moderate -
income census tract. The sole home refinance loan originated in an upper -income census tract.
assessment area. Small business lending in low-income census tracts was below the
demographic and aggregate lending data. However, the bank's performance in moderate -income
census tracts was consistent with the demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated seven home purchase and one home refinance loan, and none
below demographics but significantly higher than aggregate lending. In 2016, the lending to
small businesses was even higher. Further, loans in amounts of $100,000 or less, regardless of
business size, were 69.6 percent, which reflects good access to credit for very small businesses.
First -Citizens Bank originated a low level of community development loans in the Chattanooga
MSA assessment area. The bank originated one community development loan totaling
community development lending in Tennessee. The community development loan supported
economic development by providing funds to a CDFI that supports the capital needs of small and
start-up businesses.
INVESTMENT TEST
The bank has few, if any, qualified investments in the Chattanooga MSA assessment area. This
performance exhibited poor responsiveness to credit and community development needs.
Qualified investments total $1,000 or less than 0.1 percent of Tennessee qualified investments.
The only investment made in this area was a donation of $1,000 that benefitted community
services.
236
SERVICE TEST
Delivery systems are reasonably accessible to essentially all portions of the institution's
assessment area. The opening and closing of branches has not adversely affected the
accessibility of its delivery systems. The bank provided a relatively high level of community
The bank operates one of the six Tennessee branches in this assessment area, which is located in
a middle -income census tract. However, First -Citizens Bank's service delivery systems,
particularly alternative systems, are reasonably accessible to essentially all portions of the
assessment area.
assessment area. Employees participated in four community development services. This
performance represents 26.7 percent of all community development services in the state.
Community development services equate to 1.5 services per branch per year. The community
development services consisted of four financial literacy sessions to four different organizations,
three of which were small business -related.
237
OTHER TENNESSEE ASSESSMENT AREAS

TENNESSEE ASSESSMENT AREAS
The following table summarizes the conclusions for the two Tennessee assessment areas
conclusions did not alter the overall performance rating for lending and services tests. However,
the excellent level of qualified investments in the Nashville MSA relative to bank operations
impacted the rating favorably.

Nashville MSA Consistent Consistent Above
Johnson City MSA Consistent Below Below
238
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NASHVILLE MSA

ASSESSMENT AREA
The Nashville MSA assessment area consists of Davidson and Williamson Counties. The
Nashville -Davidson -Murfreesboro, TN MSA has nine counties; however, the bank has only
delineated the two counties as its assessment area. Demographic data for the assessment area
follows.

Nashville MSA Assessment Area

#
% of # % of # (1/0 of # % of # °A of #
FDIC Deposit Market Share data as of June, 2018, 41 financial institutions operated 304 full -
percent of the total deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NASHVILLE MSA

ASSESSMENT AREA
239
Activity # $
Donations 3 $5,000
CD Services 7 --
240
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE JOHNSON CITY MSA

ASSESSMENT AREA
The Johnson City MSA assessment area consists of Washington County. The Johnson City, TN
MSA has three counties; however, the bank has only delineated Washington County as its

Johnson City MSA Assessment Area
% of # % of # % of # % of # °A of #
the FDIC Deposit Market Share data as of June, 2018, 19 financial institutions operated 43 full -
percent of the total deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE JOHNSON CITY MSA

ASSESSMENT AREA
241
Activity # $
Donations 3 $4,000
CD Services 1 --
242
MARYLAND
CRA RATING FOR MARYLAND: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Maryland performance considered the operations of First -Citizens Bank in
one assessment area, which is detailed in Appendix A. Examiners conducted a full -scope review of
the bank's performance in the Baltimore MSA assessment area. The bank originated no home
mortgage or small farm loans in the Baltimore MSA assessment area during the evaluation. As such,
examiners based conclusions on small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN MARYLAND
The Baltimore -Columbia -Townson, MD MSA has seven counties. The bank delineated only
Anne Arundel and Howard Counties CRA assessment area. However, this evaluation focused on
performance in Anne Arundel County, because the bank started operations in the Howard
County in the latter half of 2018. The bank operates one or 0.2 percent of branch offices within
Anne Arundel County. This county also accounts for 0.4 percent of bank -wide rated loans and
0.2 percent of bank -wide deposits.
farms are in middle- and upper -income census tracts. Therefore, most lending opportunities will
be in these census tracts. The following table presents demographic information from the 2015
ACS Census and 2017 D&B data.
243
Baltimore MSA Assessment Area
(Anne Arundel County Only)**
% of # % of # % of # % of # % of #
(**) FCB has designated the Anne Arundel and Howard Counties as its CRA assessment within the Baltimore MSA. However, the evaluation
focused analyses only on the Anne Arundel County because of the timing of the bank's entry into the Howard County.
The assessment area is very competitive in the financial services market. According to the FDIC
Deposit Market Share data as of June 30, 2018, 31 financial institutions operated 224 full -service
branches within the assessment area. Of these institutions, First -Citizens Bank ranks 22nd in
deposit market share at 0.2 percent. Competitor institutions in the assessment area include Bank
of America, NA; Manufacturers and Traders Trust Company; and BB&T, which account for 46.2
table reflects the average annual unemployment rates and trends for the Anne Arundel County,
Maryland, and nation. Anne Arundel unemployment rates were consistently below state and
below or at the level of national averages during the evaluation.
Unemp oyment Rates

2016 2017 2018
Area % %
Anne Arundel County 3.8 3.6 3.9
Maryland 4.4 4.1 4.2

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services, and government. The top employers were Fort George G. Meade, Johns Hopkins
University, Aberdeen Proving Ground, University of Maryland Medical System, and John
Hopkins Health System.
CONCLUSIONS ON PERFORMANCE CRITERIA IN MARYLAND
LENDING TEST
The Lending Test rating for Maryland is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Baltimore MSA assessment area credit needs. The geographic distribution
adequate distribution of loans to businesses of different sizes. In addition, the bank uses flexible
lending practices and originated a low level of community development loans.
Lending Activity
Lending levels reflect adequate responsiveness to the assessment area's credit needs. The tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for the Baltimore
MSA assessment area.
assessment area. There are no low-income census tracts in the assessment area. In 2017, small
business lending in moderate -income census tracts was below demographic and aggregate
lending data. However, in 2016, small business lending in moderate -income census tracts was
below demographic data but above aggregate lending data. .
Borrower Profile
The distribution of loans reflects an adequate distribution to businesses of different sizes.

Lending to businesses with annual gross revenues of $1 million or less was substantially below
the demographics and just below the aggregate lending. Performance in 2016 was higher and
was comparable to aggregate data. The loans in amounts of $100,000 or less, regardless of
business size, were 45.5 percent, which reflects adequate access to credit for very small
businesses.
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First -Citizens Bank originated a low level of community development loans in the Baltimore
MSA assessment area. During this evaluation period, the bank originated one community
development loan totaling $200,000. This represents 0.3 percent by number and 0.0 percent by
dollar volume of bank -wide community development loans. This performance is consistent by
number and below by dollar volume of the lending levels in the state. The community
development loan supported economic development by providing funds to an economic
development corporation. This corporation provides capital to county businesses and supports
workforce development needs.
INVESTMENT TEST
The Investment Test performance is rated Low Satisfactory in Maryland. The bank has an
adequate level of qualified investments relative to the bank -wide operations. Qualified
consist of LIHTC investments that support affordable housing projects totaling $1.5 million and
seven donation or grant contributions totaling $6,000. Of these contributions, $4,000 benefit
affordable housing, and $2,000 benefit community services.
SERVICE TEST
The Service Test rating for Maryland is Low Satisfactory. The bank operates two branches in
Maryland, with one in Howard County and one in Anne Arundel County. Both branches are in
upper -income tracts. The current evaluation focused on the bank's performance in Anne
Arundel County because of the timing of the bank's entry into Howard County. The bank
opened one branch in Howard County in an upper -income area. The opening and closing of
branches has not adversely affected the accessibility of its delivery systems. The bank provided
an adequate level of community development services. The bank completed three community
development services, which equates to 0.5 community development services per branch per
year.
246
NEW MEXICO
CRA RATING FOR NEW MEXICO: Satisfactory

SCOPE OF EVALUATION
The evaluation of the New Mexico performance considered the operations of First -Citizens Bank in
two assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope review
of performance in the Albuquerque MSA assessment area. A significant portion of the loans (84.6
percent), deposits (62.8 percent), and branches (50.0 percent) in New Mexico are concentrated in
this assessment. Small business loans constitute the primary loan type in both assessment areas.
Home mortgage loans were limited, and no farm loans were originated in either assessment area.
Therefore, the conclusions in this state were primarily based on small business lending
performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN NEW MEXICO
The bank operates two or 0.4 percent of branch offices in New Mexico. New Mexico accounts
for 0.3 percent of the bank -wide deposits and 0.6 percent of loans. First -Citizens Bank ranks
43rd in the state in deposit market share at 0.3 percent. Competitor institutions in the assessment
areas include Wells Fargo Bank, NA; Bank of America, NA; and BOKF, NA. Together, the
CONCLUSIONS ON PERFORMANCE CRITERIA IN NEW MEXICO
LENDING TEST
The Lending Test rating for New Mexico is Low Satisfactory. Lending levels reflect adequate
responsiveness to the New Mexico assessment areas' credit needs. The geographic distribution
In addition, the bank uses flexible lending practices and originated an adequate level of community
development loans. The performance in the limited -scope assessment area was above the full -
scope assessment area.
Lending Activity
Lending levels reflect adequate responsiveness to the New Mexico assessment areas' credit needs.
The tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for
each New Mexico assessment area.
247
throughout the assessment areas and is primarily supported by adequate performance in the
Albuquerque MSA assessment area.
Borrower Profile
The distribution of HMDA and small business loans reflects adequate distribution to businesses
of different sizes and is primarily supported by adequate performance in the Albuquerque MSA
assessment area.
First -Citizens Bank originated an adequate level of community development loans in New
Mexico. During this evaluation period, the bank originated nine community development loans
totaling $2.1 million. This represents 2.4 percent by number and 0.3 percent by dollar volume of
number is well above the bank -wide lending levels in the state at 0.6 percent. However, the
percent by dollar volume is below the bank -wide lending levels in the state. The analysis for the
full -scope New Mexico assessment area includes a discussion of the community development
loans.
INVESTMENT TEST
The Investment Test performance is rated High Satisfactory in New Mexico. The bank has an
adequate level of qualified investments in New Mexico relative to operations in this state. This
performance exhibited adequate responsiveness to credit and community development needs.
Investments include prior period equity investments of $469,000 that support affordable housing;
GNMA-multifamily securities totaling $2.0 million supporting affordable housing; and seven
donations or grants totaling $10,000 benefitting community services. The GNMA-multifamily
securities that support affordable housing projects represent the highest percentage of
investments at 80.7 percent. The performance in the limited -scope assessment area was
significantly above the full -scope assessment area.
SERVICE TEST
The Service Test rating for New Mexico is High Satisfactory. Delivery systems are accessible to
essentially all portions of assessment areas. The bank operates two branches in New Mexico.
Most of the deposits in this state are generated from the Albuquerque branch, which is located in
a moderate -income census tract. The bank is a leader in providing community development
services in New Mexico. Specifically, the bank provided 13 community development services.
This performance is higher than the bank -wide assessment area's share of branches of 0.4
percent and equates to approximately 2.4 community development services per branch per year.
248
The majority of the services occurred in the Santa Fe MSA assessment area. The performance in
the limited -scope assessment area was above the full -scope assessment area.
249
METROPOLITAN AREA
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE ALBUQUERQUE MSA

ASSESSMENT AREA
The Albuquerque MSA assessment area comprises Bernalillo County in its entirety. The
Albuquerque, NM MSA has four counties; however, the bank delineated the one county as its
assessment area. The bank operates one or 50.0 percent of its New Mexico branch offices in the
Albuquerque MSA assessment area. As shown in Appendix A, the assessment area represents
primarily fairly evening dispersed within moderate-, middle-, and upper -income census tracts.
D&B data.

Albuquerque MSA Assessment Area
% of # % of # °A of # % of # % of #
institutions operated 119 branches within the area. Of these institutions, the bank ranked 13th in
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and nation. Bernalillo County's unemployment rates during the evaluation period were generally
above national and below state average rates.
Unemp oyment Rates

2016 2017 2018
Area % % %
Bernalillo County 5.8 5.5 4.4
New Mexico 6.6 5.9 4.9
Source: Bureau of Labor Stausucs
business services. The top employers were University of New Mexico, Kirtland Air Force Base,
Sandia National Laboratories, Presbyterian Healthcare Services, and UNM Hospital.
Considering demographic and economic data, examiners determined small business loans for
new business owners represent a primary credit need for the assessment area. The significant
percentage of businesses with gross annual revenues of $1 million or less at 83.8 percent and the
large number of businesses with four or fewer employees at 70.9 percent support this conclusion.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE ALBUQUERQUE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Albuquerque MSA assessment area
Also, the bank uses flexible lending practices and originated an adequate level of community
development loans.
Lending Activity
assessment area.
251
conclusions. The bank originated two home purchase loans in 2017, neither of which were
originated in low- or moderate -income census tracts.
assessment area. Small business lending in low-income census tracts was well above the
was well below the demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated two home purchase loans in 2017, neither of which were
The borrower distribution of small business loans reflects adequate penetration among
businesses of different sizes. Lending to businesses with annual gross revenues of $1 million or
less significantly below demographic data but exceeded aggregate lending data. Further, loans to
in amounts of $100,000, regardless of business size, were 69.3 percent, which reflects good
First -Citizens Bank made an adequate level of community development loans in the
Albuquerque MSA assessment area. The bank originated 3 community development loans
totaling $300,000. This amount represents 33.3 percent by number and 14.0 percent by dollar
volume of community development lending in New Mexico. All three loans were renewals,
which support economic development by providing funds to a CDFI that extends loans to small
businesses and non-profit organizations.
INVESTMENT TEST
The bank has an adequate level of qualified investments in the Albuquerque MSA assessment
area relative to operations. This performance exhibited adequate responsiveness to credit and
community development needs. Qualified investments total $470,000 or 19.0 percent of New
Mexico qualified investments. Investments consist of two donations totaling $1,000 that
benefitted community services and prior period equity investments totaling $469,000 that
benefitted affordable housing.
SERVICE TEST
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The bank operates one of the two New Mexico's branches in the Albuquerque MSA assessment
area, which is located in a moderate -income census tract.
assessment area. Employees participated in four community development services. This
is below the assessment area's share of branches at 62.8 percent. Community development
An employee serves as treasurer for a non-profit legal aid agency that serves the legal
needs of New Mexico's children for safe and stable homes, education, and healthcare.
An employee conducted two financial literacy sessions in collaboration with a CDC that
administers the SBA 504 program and provides technical and other financial assistance to
small businesses.
253
OTHER NEW MEXICO ASSESSMENT AREA

NEW MEXICO ASSESSMENT AREA
The following table summarizes the conclusions for the New Mexico assessment area reviewed
test was impacted by the significant level of investments in the assessment area.

Santa Fe MSA Above Above Above
254
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE SANTA FE MSA

ASSESSMENT AREA
The Santa Fe MSA assessment area consists of Santa Fe County, which composes the Santa Fe,
NM MSA. Demographic data for the assessment area follows.

Santa Fe MSA Assessment Area

Demographic Characteristics /4
% of # % of # % of # % of # % of #
Source: 2015 ACS Census and 2017 D&B Data
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE SANTA FE MSA

ASSESSMENT AREA
255
Activity # $
HMDA Loans 0 --
Investments (New) $2 million
Investments (Prior Period) --
Donations 5 $9,000
CD Services 9 --
256
OKLAHOMA
CRA RATING FOR OKLAHOMA: Needs to Improve

The Investment Test is rated: Needs to Improve
SCOPE OF EVALUATION
The evaluation of the Oklahoma performance considered the operations of First -Citizens Bank in
the Oklahoma City MSA assessment area, which received a full -scope review. Small business
loans constitute the primary loan type in the assessment area. Home mortgage loans were limited,
and no farm loans were originated. Therefore, conclusions in this state were primarily based on
small business lending.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN OKLAHOMA
The Oklahoma City MSA assessment area consists of Oklahoma County. The MSA has seven
counties; however, the bank delineated the one county as its assessment area. The bank operates
two or 0.4 percent of branches in the assessment area. The assessment area accounts for 0.5
percent of the bank -wide rated loans and 0.4 percent of deposits.
The 2015 ACS Census shows that most of the owner -occupied housing units and businesses are
fairly evenly dispersed among in moderate-, middle-, and upper -income census tracts. The
following table presents demographic information from the 2015 ACS Census and 2017 D&B
data.
257
Oklahoma City MSA Assessment Area
% of # % of # % of # % of # % of #
service branches within the assessment area. Of these institutions, First -Citizens Bank ranks 33rd
in the state in deposit market share at 0.5 percent. Competitor institutions in the assessment area
include MidFirst Bank; JPMorgan Chase Bank, NA; and BOKF, NA and account for 36.7
percent of deposit market share.
table reflects the average annual unemployment rates and trends for the Oklahoma County, state
and nation. The unemployment rates during the evaluation period were below state and national
average rates.
Unemp oyment Rates

2016 2017 2018
Area
Oklahoma County 4.3 4.2 3.6

Oklahoma 4.8 4.3 3.8

business services. The top employers were Tinker Air Force Base, University of Oklahoma -
258
Norman, FAA Mike Monroney Aeronautical Center, Integris Health, and Hobby Lobby Stores
Inc.
income, respectively.
CONCLUSIONS ON PERFORMANCE CRITERIA IN OKLAHOMA
LENDING TEST
The Lending Test rating is Low Satisfactory in Oklahoma. Lending levels reflect adequate
responsiveness to the Oklahoma City MSA assessment area credit needs. The geographic
distribution reflects adequate penetration throughout the assessment areas, and borrower profile
reflects good distribution of loans to borrowers of different incomes and businesses of different
sizes. In addition, the bank uses flexible lending practices and originated a low level of community
development loans.
Lending Activity
Lending levels reflect adequate responsiveness to the assessment area's credit needs. The tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for the Oklahoma
City MSA assessment area.
conclusions. The bank originated seven home purchase loans in 2017, and two of the loans were
originated in moderate -income census tracts.
tracts. Lending in moderate -income census tracts was consistent with demographic and
259
Borrower Profile
conclusions. The bank originated seven home purchase loans in 2017, and none were originated
to low- or moderate -income borrowers.
below demographic data but above aggregate lending data. Further, loans in amounts of
$100,000 or less, regardless of business size, were 76.3 percent, which reflects very good access
First -Citizens Bank originated a low level of community development loans in the Oklahoma
City MSA assessment area. During the evaluation period, the bank originated two community
development loans totaling $35,000. This represents 0.5 percent by number and 0.0 percent by
dollar volume of bank -wide community development loans. The community development loans
supported community services by providing funds to a non-profit community food bank.
INVESTMENT TEST
The Investment Test performance is rated Needs to Improve in Oklahoma. The bank has a poor
level of qualified investments in the Oklahoma City MSA assessment area relative to operations.
Qualified investments total $14,000, which is less than 0.1 percent of bank -wide qualified
investments. Investments include nine donation or grant contributions totaling $14,000. Of
these contributions, $13,000 benefitted community services, and $1,000 benefitted economic
development. Performance reflects a significant decline from the last evaluation's $1.1 million
investments.
SERVICE TEST
The Service Test rating for Oklahoma is Low Satisfactory. The bank operates two branches in
Oklahoma, with one in a moderate -income census tract and one in upper -income census tract.
The branches are considered accessible to essentially all portions of the bank's assessment area.
The bank provided an adequate level of community development services. Specifically, the bank
provided three community development services, which equates to 0.6 community development
services per branch per year.
260
OREGON
CRA RATING FOR OREGON: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Oregon performance considered the operations of First -Citizens Bank in
the Portland MSA assessment area, which received a full -scope review. The bank operations in
Oregon and Washington within the Portland -Vancouver -Hillsdale, OR -WA Multistate MSA.
However, the multistate MSA was not reviewed and rated separately as the bank entered
Washington in October 2018. Therefore, only the Oregon portion of the multistate MSA was
reviewed. Refer to Appendix A for further assessment area details. Small business loans
constitute the primary loan type in the assessment area. Home mortgage loans were limited, and
no farm loans were reviewed. Therefore, conclusions were primarily based upon the bank's
small business lending.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN OREGON
The Portland MSA assessment area consists of Clackamas and Multnomah Counties. The
Portland -Vancouver -Hillsdale, OR -WA Multistate MSA has seven counties; however, the bank
delineated the two counties as its assessment area. The bank operates two branches or 0.4
percent of bank -wide branch offices in its Portland MSA assessment area. The assessment area
accounts for 0.4 percent of the bank -wide loans and 0.3 percent of deposits.
farms are distributed between middle- and upper -income census tracts with a good level in
moderate -income tracts. The following table presents demographic data from the 2015 ACS
Census and 2017 D&B data.
261
Portland MSA Assessment Area
% of #
'% of # % of # %of# %of#

21th with 0.2 percent deposit market share. Competitor institutions in the assessment area
include U.S. Bank of NA, Bank of America, NA, and Wells Fargo Bank, NA. Together these
According to the Bureau of Labor Statistics, as depicted in the table below, the average annual
unemployment rates for the assessment area declined during the evaluation period and remained
below state and national averages.
Unemp oyment Rates

2016 2017 2018
Area
% %
Clackamas 4.3 3.7 3.7
Multnomah 4.2 3.6 3.5
Oregon 4.8 4.1 4.0
services, and government. The top employers were Intel Corp., Providence Health Systems,
Oregon Health and Science University, Legacy Health System, and Nike, Inc.
262
with gross annual revenues of $1 million or less at 87.7 percent, and the large number of
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN OREGON
LENDING TEST
The Lending Test rating is High Satisfactory in Oregon. Lending levels reflect good responsiveness
to the Portland MSA assessment area credit needs. The geographic distribution reflects good
flexible lending practices and originated a relatively high level of community development loans.
Lending Activity
Lending levels reflect good responsiveness to the assessment area's credit needs. The tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for the
Portland MSA assessment area.
conclusions. The bank originated two home purchase loans in 2017, and one originated in a
moderate -income census tract.
assessment area. Small business lending in low- and moderate -income census tracts was
consistent with the demographic and aggregate lending data.
Borrower Profile
conclusions. The bank originated two home purchase loans in 2017, and none originated to low -
263
The distribution of loans is good among businesses of different sizes. Loans to businesses with
annual gross revenues of $1 million or less was substantially below demographics but well above
the aggregate lending. Further, loans in amounts of $100,000 or less, regardless of business size,
were 81.6 percent, which reflects very good access to credit for very small businesses.
Portland MSA assessment area. During this evaluation period, the bank originated five
community development loans totaling $3.7 million. This represents 1.3 percent by number and
0.5 percent by dollar volume of bank -wide community development loans, which is above the
bank -wide lending levels in the assessment area by number and consistent with bank -wide
lending levels by dollar volume. Regarding the community development purpose, one loan
supports affordable housing, and four loans support community services. Examples of
community development loans include a $1.3 million loan to a non-profit organization that
provides affordable housing to low-income families and a $250,000 line of credit that provided
funding for a non-profit organization's residential, workforce training, and job placement
services for low- and moderate -income individuals with developmental disabilities.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in Oregon. The bank has an excellent
level of qualified investments in the Portland MSA assessment area relative to the bank's
operations. Qualified investments total $5.1 million or 1.5 percent of bank -wide qualified
investments. Investments consist of LIHTC that support an affordable housing project totaling
$1.7 million; $3.4 million in SBA pools that support four small businesses; and eight donations
totaling $6,000. Of the donations, $3,000 benefitted community services, and $3,000 benefited
economic development.
SERVICE TEST
The Service Test rating is High Satisfactory in Oregon. Delivery systems are accessible to
essentially all portions of the assessment area, and the opening and closing of branches has not
adversely affected the accessibility of its delivery systems. One of the two branches is located in
an upper -income geography, and the other branch is located in a geography that has no income
designation. In addition, the bank provided a relatively high level of community development
services. Specifically, the bank provided five community development services which equates to
0.9 community development service per branch per year.
264
WEST VIRGINIA
CRA RATING FOR WEST VIRGINIA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the West Virginia performance considered the operations of First -Citizens Bank
in the WV Non-MSA assessment area, which received a full -scope review. Refer to Appendix A
for further assessment area details. Small business loans constitute the primary loan type in the
assessment area. Home mortgage loans were second in volume, and no farm loans were reviewed
in the assessment area. Therefore, the conclusions are primarily based upon the small business
lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN WEST VIRGINIA
The WV Non-MSA assessment area consists of Greenbrier and Pocahontas Counties. The bank
operates five or 0.9 percent of branch offices in West Virginia. West Virginia accounts for 0.4
percent of the bank -wide deposits and 0.2 percent of loans.
The 2015 ACS Census shows the vast majority of the owner -occupied housing units, businesses,
and farms are located in middle -income census tracts. The FFIEC has designated certain non -
poverty rates, and significant population losses. In addition, the FFIEC has designated certain
middle -income census tracts in rural areas as underserved because those communities have
difficulty meeting essential community needs. A census tract can be designated as distressed
and/or underserved. In the WV Non-MSA assessment area, the FFIEC designated 9 or 81.8
percent of the 11 middle -income census tracts as distressed and/or underserved in 2016. In 2017,
none were designated. The following table presents demographic information from the 2015
ACS Census and 2017 D&B data.
265
WV Non-MSA Assessment Area
% of # % of # % of # % of #
% of #
Median Family Income Non-MSAs - (2015) $48,507 Median Housing Value $108,252
Due to rounding, totals may not equal /00.0 percent.
the FDIC Deposit Market Share data as of June 30, 2018, 8 financial institutions operated 24fu11-
service branches within the assessment area. Of these institutions, First -Citizens Bank ranked 3rd
with 15.5 percent deposit market share. Competitor institutions in the assessment area include
City National Bank of West Virginia and Premier Bank, Inc. Together, the two competitor
table reflects the average annual unemployment rates and trends for the Greenbrier and
Pocahontas Counties, state, and nation. Greenbrier County had an unemployment rate below the
state but above the national average in all three years. In 2016 and 2017, the unemployment
rates in Pocahontas County were above both the state and national average rates; however, the
unemployment rate in Pocahontas County was below the state and above national average rates
in 2018.
Unemp oyment Rates

2016 2017 2018
Area % %
%
Greenbrier County 5.4 4.8 5.0
Pocahontas County 6.6 6.0 4.9

West Virginia 6.1 5.2 5.3

266
In 2017, according to D&B data, the top industries were services, retail trade, and construction.
The top employers were Greenbrier Hotel Corporation and Snowshoe Mountain, Inc. The top
employers could not be determined due to a limited amount of information available for the
counties.
affordable housing represents a need as 35.7 percent of families are low- and moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN WEST VIRGINIA
LENDING TEST
The Lending Test rating is High Satisfactory in West Virginia. Lending levels reflect good
responsiveness to the WV Non-MSA assessment area credit needs. A geographic distribution was
not conducted as the assessment area does not include any low- or moderate -income census
tracts. However, the borrower distribution reflects good penetration to borrowers of different
incomes and businesses of different sizes. In addition, the bank uses flexible lending practices and
originated a relatively high level of community development loans.
Lending Activity
Lending levels reflect good responsiveness to the assessment area's credit needs. The tables in
Appendix D detail the number and dollar volume of HMDA and CRA loans in 2017 for the WV Non-
Borrower Profile
The distribution of HMDA loans is good among borrowers of different income levels. First -
Citizens Bank did not originate a sufficient number of home purchase loans to derive meaningful
conclusions. The bank originated eight home purchase loans in 2017 with one originated to a
low-income borrower. However, for home refinance loans, the bank demonstrated outstanding
performance to moderate -income borrowers when compared the demographic and aggregate
lending data. No home refinance loans originated to low-income borrowers. Further, in 2016,
home purchase and refinance lending significantly exceeded the demographic and aggregate
lending data.
The distribution of small business loans is excellent among businesses of different sizes.
Lending to businesses with annual gross revenues of $1 million or less was comparable to
267
demographics and substantially above aggregate lending. Further, loans in amounts of $100,000
or less were 80.0 percent, which reflects excellent access to credit for very small businesses.
WV Non-MSA assessment area. During this evaluation period, the bank originated eight
0.2 percent by dollar volume of bank -wide community development loans. This level is above
by number and consistent by dollar volume when compared to bank -wide lending levels.
Regarding the community development purpose, five loans support affordable housing, one loan
supports community services, and two loans support revitalization or stabilization. One loan
totaling $1.2 million was originated outside the assessment area but within the broader state-wide
area. Since the bank has been responsive to community development needs and opportunities
within its assessment area, the loan was included. Examples of community development loans
include three renewals of a $49,000 line of credit to a non-profit corporation that develops
affordable rental housing, assists low-income families with purchasing and repairing homes, and
provides homebuyer education courses and two renewals of a $49,000 line of credit to a
governmental housing authority, which administers the Section 8 Housing Choice Voucher
program.
INVESTMENT TEST
The Investment Test performance is rated Needs to Improve in West Virginia. The bank has a
poor level of qualified investments in the assessment area relative to bank -wide operations.
Qualified investments total $7,000 or less than 0.1 percent of bank -wide development
investments. This performance represents a significant decline from the last performance
evaluation's qualified investment of $2.1 million. Qualified investments of $7,000 are
comprised solely of six donations. Of these donations, $1,000 benefitted community services,
$1,000 benefitted economic development, and $5,000 benefitted revitalization or stabilization.
SERVICE TEST
The Service Test rating is Low Satisfactory in West Virginia. Delivery systems are accessible to
essentially all portions of the assessment area, and the opening and closing of branches has not
adversely affected the accessibility of its delivery systems. The bank operates five branches in
West Virginia with four in middle -income geographies and one in an upper -income geography.
There are no low- and moderate -income geographies in the assessment area. The bank provided
an adequate level of community development services. Specifically, the bank provided a nine
community development services during the evaluation, which equates to approximately 0.7
community development service per branch per year.
268
WISCONSIN
CRA RATING FOR WISCONSIN: Needs to Improve

SCOPE OF EVALUATION
The evaluation of the Wisconsin performance considered the operations of First -Citizens Bank in
two assessment areas, which are detailed in Appendix A. Examiners conducted a full -scope review
of the performance in the Milwaukee MSA assessment area. Home mortgage loans constitute the
primary loan type during the evaluation period. Therefore, the conclusions are primarily based on the
home mortgage lending performance. In 2017, First -Citizens Bank originated 3 HMDA loans and 3
small business loans, and all originations occurred in the Milwaukee MSA assessment. In 2016, First -
Citizens Bank originated 36 HMDA loans, and they were all home improvement loans. Specifically,
92.3 percent of the home mortgage loans were for home improvement purposes.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN WISCONSIN
The bank operates 14 or 2.5 percent of branch offices in Wisconsin. Wisconsin accounts for 1.5
percent of the bank -wide deposits and less than 0.1 percent of loans. Currently, the bank
operates 14 branches in Wisconsin. First -Citizens Bank began operations with two branches in
Wisconsin in March 2016 through the FDIC -assisted acquisition of North Milwaukee State
Bank, which operated only in Milwaukee County within the Milwaukee -Waukesha -West Allis,
WI MSA. One branch remains. In May 2017, First -Citizens Bank acquired Guaranty Bank,
adding 10 branches in Wisconsin. Washington and Waukesha Counties in the Milwaukee-
WauKesha-West Allis, MSA were added to the assessment area. A new assessment area was
established with Racine County in the Racine, WI MSA. Guaranty Bank was primarily a high -
cost checking account provider to low- and very low-income customers, with no lending
infrastructure. As such, First -Citizens Bank devoted significant time to implement full banking
systems, including recruitment and training, in order to deliver a full slate of banking products
and services in the two assessment areas. Nine branches remain. In October 2018, First -Citizens
Bank acquired Securant Bank with 4 branches. The acquisition did not change the assessment
areas' configuration, since all four branches were located in the Milwaukee MSA assessment
area.
First -Citizens Bank ranks 18th in the state in deposit market share at 0.7 percent. Competitor
institutions in the assessment areas include U.S. Bank NA; BMO Harris Bank, NA; and JP
Morgan Chase Bank, NA. Together, the three competitor institutions account for 60.1 percent of
the market share.
269
CONCLUSIONS ON PERFORMANCE CRITERIA IN WISCONSIN
LENDING TEST
The Lending Test rating for Wisconsin is Low Satisfactory. Lending levels reflect adequate
responsiveness to the Wisconsin assessment areas' credit needs. The geographic distribution
reflects good penetration in the assessment areas, and the borrower profile reflects poor
penetration in the assessment areas. Also, the bank uses flexible lending practices. The bank did
not originate any community development loans in Wisconsin. The performance in the limited -
scope assessment area was below the full -scope assessment area.
Lending Activity
Lending levels reflect adequate responsiveness to the Wisconsin assessment areas' credit needs. The
Wisconsin assessment area
The geographic distribution of HMDA and small business loans in Wisconsin is good and is
supported by performance in the Milwaukee MSA assessment area.
Borrower Profile
The distribution of HMDA and small business loans in Wisconsin is poor.
None of the HMDA loans in 2017 or 2016 were originated to low- or moderate -income
borrowers. None of the three small business loans in 2017 were originated to businesses with
revenues of $1 million or less. The percentage of businesses with gross annual revenues of $1
million or less is 78.4 percent.
First -Citizens Bank did not originate any community development loans in Wisconsin during the
evaluation period.
INVESTMENT TEST
The Investment Test performance is rated Needs to Improve in Wisconsin. The bank has a poor
level of qualified investments in Wisconsin relative to the bank's operations in this state. The
bank's qualified investments total $10,000, which is less than 0.1 percent of bank -wide qualified
investments. Investments include 11 donations totaling $10,000, which benefitted the
Milwaukee MSA assessment area. The performance in the limited -scope assessment area was
below the full -scope assessment area.
270
SERVICE TEST
The Service Test rating for Wisconsin is Low Satisfactory. The bank operates 14 branches in
Wisconsin, which represents 2.5 percent of all branches. Two branches are in low-income
census tracts, and two branches are located in a moderate -income census tracts. The branches
are accessible to essentially all portions of the assessment areas. The bank provided a limited
level of community development services in Wisconsin. In particular, the bank provided 13
community development services during the evaluation period, which equates to approximately
0.3 per branch per year. The performance in the limited -scope assessment area was consistent
with the full -scope assessment area.
271
METROPOLITAN AREAS
(Full -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE MILWAUKEE MSA

ASSESSMENT AREA
The Milwaukee MSA assessment area consists of Milwaukee, Washington, and Waukesha
Counties. The Milwaukee MSA has four counties; however, the bank did not delineate Ozaukee
County as part of its assessment area. The bank operates 13 or 92.9 percent of its Wisconsin
branch offices in the assessment area. As shown in Appendix A, the assessment area represents
Demographic Information the

Milwaukee MSA Assessment Area
% of # % of # % of # % of # % of #
272
table reflects the average annual unemployment rates and trends for the counties within the
assessment area, state, and nation. Washington and Waukesha Counties' unemployment rates
have remained consistently below state and national average. Conversely, in 2016, Milwaukee
County's unemployment rate surpassed state and national average and exceeded the states'
unemployment rate for 2017 and 2018.
Unemp oyment Rates

2016 2017 2018
Area
% %
Milwaukee County 5.0 4.0 3.0
Washington County 3.3 2.8 2.2
Waukesha County 3.4 2.9 2.3
Wisconsin 4.0 3.3 2.9
services, and manufacturing. The top employers were Aurora Health Care, Inc., Quad Graphics,
Inc., Froedtert Health, The Kroger Co., and Ascension Wisconsin.
affordable housing represents a need as 41.7 percent of the families low- or moderate -income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE MILWAUKEE MSA

ASSESSMENT AREA
LENDING TEST
First -Citizens Bank's Lending Test performance in the Milwaukee MSA assessment area reflects
adequate responsiveness to the Wisconsin assessment area's credit needs. The geographic
distribution reflects good penetration throughout the assessment area, and borrower profile reflects
poor distribution of loans to borrowers of different incomes and businesses of different sizes.
The bank uses flexible lending practices but did not originate any community development loans in
the assessment area during the evaluation period.
273
1,enoing Activity
assessment area.
In 2017, First -Citizens Bank did not originate a sufficient number of HMDA loans to derive
meaningful conclusions. The bank originated two home purchase loans and one home refinance
loans, and none originated in low- or moderate -income census tracts. However, in 2016, the
bank originated 36 home improvement loans, and the lending performance in low- and moderate -
income census tracts significantly exceeded the demographic and aggregate data.
First -Citizens Bank did not originate a sufficient number of small business loans to derive
meaningful conclusions. Of the three small business loans originated in 2017, one was
originated in a low-income census tract, and one was originated in a moderate -income census
tract. The bank did not originate any small business loans in 2016.
Borrower Profile
businesses of different sizes is poor.
In 2017, First -Citizens Bank did not originate a sufficient number of HMDA loans to derive
meaningful conclusions. None of the three HMDA loans in 2017 were originated to low- or
moderate -income borrowers. Also, none of the 36 home improvement loans in 2016 were
First -Citizens Bank did not originate a sufficient number of small business loans to derive
meaningful conclusions. In 2017, all three small business loans were originated to businesses
with annual gross revenues of greater than $1 million. The bank did not originate any small
business loans in 2016.
First -Citizens Bank did not originate any community development loans in the Milwaukee MSA
assessment area during the evaluation period.
INVESTMENT TEST
The bank has a poor level of qualified investments in the Milwaukee MSA assessment area,
relative to operations. This performance exhibited poor responsiveness to credit and community
development needs. Qualified investments total $10,000, or less than 0.1 percent of Wisconsin
274
qualified investments. Investments include 11 donations totaling $10,000, which benefitted
community services.
SERVICE TEST
provided a limited level of community development services.
The bank operates 13 branches in this assessment area, which represents 92.9 percent of all
branches in Wisconsin. Two branches are in low-income census tracts (15.4 percent), and one
branch (7.7 percent) is in a moderate -income census tract.
area. Employees participated in 11 community development services. This performance
represents 94.3 percent of all community development services in the state, which is just above
the level of branches. However, community development services equate to 0.3 services per
branch per year.
275
OTHER WISCONSIN ASSESSMENT AREAS

WISCONSIN ASSESSMENT AREA REVIEWED
The following table summarizes the conclusions for the Wisconsin assessment area reviewed
figures, aggregate lending data comparisons, and demographic information. The conclusions did

Racine MSA Below Below Consistent
investments, and community development services are from date of acquisition in May 2017 to
March 26, 2019.
276
METROPOLITAN AREAS
(Limited -Scope)
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE RACINE MSA

ASSESSMENT AREA
The Racine MSA assessment area consists of Racine County, which composes the Racine, WI

Racine MSA Assessment Area
% of # % of # % of # % of # % of #
Median Family Income MSA - 39540 Rac'ne, WI $68,728 Median Housing Value $161,164
MSA
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE RACINE MSA

ASSESSMENT AREA
First -Citizens Bank operates one branch in this assessment area. The bank engaged in the
following activities in the assessment area during the review period.
277
Activity # $
Small Business Loans 0 --
IIMDA Loans 0 --
Donations 0 --
CD Services 2 --
278
MULTISTATE METROPOLITAN AREA
CRA RATING FOR CHARLOTTE-CONCORD-GASTONIA, NC -SC MULTISTATE

MSA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Charlotte -Concord -Gastonia, NC -SC Multistate MSA performance
considered a full -scope review of the bank's operations in five counties in North Carolina and
three counties in South Carolina, which represent a portion of this multi -state MSA. Additional
assessment area information is detailed in Appendix A. Home mortgage, small business, and
small farm loans were reviewed. Small business loans constitute the primary loan type by
number and received the most weight.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN CHARLOTTE MSA

ASSESSMENT AREA
The Charlotte- Concord -Gastonia, NC -SC Multistate MSA has ten counties. However, the bank
delineated the eight counties, as noted above, as its assessment area. The two counties the bank
excluded from are Gaston and Rowan Counties in North Carolina. The bank operates 45 or 8.2
percent of branch offices in the Charlotte MSA assessment area. The assessment area accounts
for 8.8 percent of the bank -wide rated loans and 8.6 percent of deposits.
The 2015 Census shows the majority of the owner -occupied housing units, businesses, and farms
are located within middle- and upper -income census tracts. The following table presents
279
Charlotte MSA Assessment Area
L ow Moderate Middle Upper NA*
% of # % of # %of# %of# % of #

with 1.2 percent deposit market share. The top five financial institutions account for 83.0
table reflects the average annual unemployment rates and trends for the assessment area, states,
and nation. All counties, except Chester and Lancaster Counties, have unemployment rates
generally below or consistent with both state and national average rates. Chester and Lancaster
Counties were above or equal to both state and national average rates for all three years.
280
Unemp oyment Rates
2016 2017 2018
Area
% % ')/0
Cabarrus County, NC 4.6 4.1 3.6

Iredell County, NC 4.8 4.2 3.6
Lincoln County, NC 4.7 4.0 3.4
Mecklenburg County, NC 4.7 4.3 3.7
Union County, NC 4.4 4.0 3.4
Chester County, SC 7.2 6.1 4.8
Lancaster County, SC 5.3 4.7 3.8
York County, SC 4.6 4.0 3.3

In 2017, the top industries were government, leisure and hospitality services, and retail trade.
The top employers were Atrium Health, Wells Fargo, Wal-Mart Stores Inc., Bank of America
Corp., and American Airlines.
affordable housing represents a need as 38.1 percent of the families are low- or moderate -
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CHARLOTTE MSA

ASSESSMENT AREA
LENDING TEST
The Lending Test rating for the Charlotte MSA assessment area is High Satisfactory. Lending
levels reflect good responsiveness to the assessment area's credit needs. The geographic
distribution reflects good penetration, and the borrower profile reflects good distribution to
use flexible lending practices and originated a relatively high level of community development
loans.
Lending Activity
in Appendix D detail the number and dollar volume of HMDA and CRA loans in the Charlotte
281
area. For home purchase loans, performance in low-income census tracts was consistent with
demographic and aggregate lending data, whereas lending in moderate -income census tracts was
well above demographic and aggregate lending data. For home improvement loans, performance
in low-income census tracts was significantly higher than demographic and aggregate lending
data. Home improvement lending in moderate -income census tracts was lower than aggregate
and demographic data. For home refinance loans, performance in low-income census tracts was
consistent with demographic and aggregate lending data, whereas lending in moderate -income
census tracts was above the demographic and well above aggregate lending data.
demographic and aggregate lending data. Lending in moderate -income census tracts was above
demographic data and aggregate lending data.
assessment area. Small farm lending in low-income census tracts was consistent with
demographic data and higher than aggregate lending data. Lending in moderate -income census
tracts was above the demographic data and slightly above the aggregate lending data.
Borrower Profile
demographics and significantly above aggregate lending data. Performance for home purchase
loans to moderate -income borrowers was well above demographic and above aggregate lending
data. For home improvement loans, performance to low-income borrowers was significantly
below demographics and was slightly above aggregate lending data. Lending to moderate -
income borrowers was well below demographic and aggregate lending data. For home refinance
loans, performance to low-income borrowers was well below demographics and above aggregate
lending data. Lending to moderate -income borrowers was above the demographic data and was
consistent with the aggregate lending data.
sizes. Lending to businesses with gross annual revenues of $1 million or less was well below
demographics but significantly above the aggregate data. Further, loans in amounts of $100,000
or less were 78.5 percent, regardless of business size, which reflects good access to credit for
very small businesses.
282
Lending to farms with annual gross revenues of $1 million or less was significantly below
demographics but exceeded the aggregate lending. Further, loans in amounts of $100,000 or less
were 68.0 percent, regardless of farm size, which reflects good access to credit for very small
businesses.
Charlotte MSA assessment area. During this evaluation period, the bank originated 18
community development loans totaling $50.5 million. This represents 5.1 percent by number
and 7.3 percent by dollar volume of bank -wide community development loans. Regarding the
community development purpose, 3 loans supported affordable housing, 7 loans supported
community services, and 8 loans supported revitalization or stabilization. Examples of
community development loans include a $3.7 million loan to a CDFI for purchasing affordable
housing loans from the Community Investment Corporation of the Carolinas; a $6.9 million loan
for the construction of a 96 -unit LIHTC affordable housing development in partnership with a
governmental housing authority; a $6.6 million loan for the construction of an 85 -unit LIHTC
affordable housing development; and a $2.3 million loan to a non-profit organization for the
construction of a 16 -bed crisis center for families with children who have substance abuse
disorders or developmental disabilities, and over 70 percent of organization's revenue is derived
from Medicaid services.
INVESTMENT TEST
The Investment Test performance is rated Low Satisfactory in the Charlotte MSA assessment
area. The bank has an adequate level of qualified investments relative to the bank -wide
operations. Qualified investments total $7.9 million or 2.3 percent of bank -wide qualified
investments. Investments include GNMA-multifamily securities totaling $6.2 million that
benefitted affordable housing and 88 donation totaling $125,000. Of these donations, $13,000
benefitted community services, $94,000 benefitted economic development, and $18,000
benefitted revitalization or stabilization. Additionally, qualified investments include prior period
equity investment of $1.7 million that benefitted affordable housing.
SERVICE TEST
The Service Test rating is Low Satisfactory in the Charlotte MSA assessment area. Delivery
systems are reasonably accessible to essentially all portions of the assessment area, and the
opening and closing of branches has not generally adversely affected the accessibility of its
delivery systems. The bank operates 3 branches (6.7 percent) in low- and 10 branches (22.2
percent) in moderate -income census tracts. Even though the bank closed two branches in low-
income geographies and a branch in a moderate -income geography, the closings have generally
not adversely affected the accessibility of its delivery systems. The branch distribution
percentages remain similar to the population demographics for each geography type. There were
no branch openings since the last evaluation. The bank provided an adequate of community
development services. Specifically, the bank provided 77 community development services,
283
which equates to 0.6 community development services per branch per year and is slightly below
the share of bank -wide branches. The following are examples of community development
services provided in this assessment area.
An employee provided a financial literacy session to clients of a CDC. Topics covered

included how to prepare to buy a first home, getting credit in order, and down -payment
assistance.
Three employees provided credit education and technical assistance to farmers at a small
farming agricultural event.
An employee serves on the Board for an organization that serves to inspire young girls
through athletics. The organization provides their services free or charge to young ladies
that can't afford the dues.
An employee conducted a financial literacy event for small businesses entitled "Basics
of Business Financing and Financing Options." The event was conducted in
collaboration with a community development loan fund organization.
284
CRA RATING FOR MYRTLE BEACH-CONWAY-NORTH MYRTLE BEACH, SC -NC
MULTISTATE MSA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Myrtle Beach -Conway -North Myrtle Beach, SC -NC Multistate MSA
performance considered the bank's operations in the Myrtle Beach MSA assessment rea
consisting of Brunswick County in North Carolina and Horry County in South Carolina, which
represent the entire Myrtle multi -state MSA. Additional Myrtle MSA assessment area
information is summarized in Appendix A. Home mortgage and small business loans were
reviewed. Based on number and dollar, both of these loan types were weighted equally.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE MYRTLE BEACH MSA

ASSESSMENT
The bank operates 10 or 1.8 percent of its branch offices in the Myrtle Beach MSA assessment
area. Four branches are located in the Brunswick County in North Carolina and six branches are
located in the Horry County in South Carolina. The Myrtle Beach MSA assessment area
accounts for 2.2 percent of the bank -wide rated loans and 1.4 percent of deposits.
The 2015 ACS Census shows that the majority of the owner -occupied housing units, businesses,
and farms are located within middle -income census tracts. The following table presents
285
Myrtle Beach MSA Assessment Area
% of #
% of # % of # 'Yo of # % of #
with 4.8 percent deposit market share. Competitor institutions in the assessment area include
BB&T, The Conway National Bank, Bank of America, NA, and Wells Fargo, NA. Together, the
four competitor institutions account for 50.2 percent of the market share.
table reflects the average annual unemployment rates and trends for the counties, states, and
nation. Both counties have unemployment rates above both state and national average rates.
Unemp oyment Rates

2016 2017 2018
Area %
%
Brunswick County, NC 6.4 5.6 5.2
Horry County, SC 5.9 5.0 4.2


286
In 2017, the top industries were leisure and hospitality services, retail trade, and government.
The top employers were Wal-Mart Stores Inc., Coastal Carolina University, Conway Medical
Center, Grand Strand Regional Medical Center, and Progress Energy Company.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE MYRTLE BEACH MSA

ASSESSMENT AREA
LENDING TEST
The Lending Test rating for the Myrtle Beach MSA assessment area is Low Satisfactory.
Lending levels reflect adequate responsiveness to the assessment area's credit needs. The
geographic distribution reflects adequate penetration throughout the assessment area, and the
borrower profile reflects adequate distribution to borrowers of different incomes and businesses
of different sizes. In addition, the bank uses flexible lending practices and originated an
adequate level of community development loans.
Lending Activity
tables in Appendix D detail the number and dollar volume of HMDA and CRA loans in the
Myrtle Beach MSA assessment area.
assessment area. First -Citizens Bank did not originate any home purchase loans in low-income
census tracts. However, only 0.4 percent of owner -occupied housing units were located in low-
income census tracts, and aggregate lending performance was 0.6 percent. Lending in moderate-
income census tracts was consistent with demographic data and above aggregate lending data.
For home refinance loans, lending in low-income census tracts was above demographics and
aggregate data while lending in moderate -income was below demographic and aggregate lending
data.
assessment area. Small business lending in low- and moderate -income census tracts was below
287
Borrower Profile
incomes. For home purchase loans, performance to low-income borrowers was significantly
below demographics but was nearly double aggregate lending data. Lending to moderate -
income borrowers was below demographic data and aggregate lending data. Home refinance
lending to low-income borrowers was substantially below demographics and below aggregate
lending. Lending to moderate -income borrowers was well below demographics and below
sizes. Lending to businesses with annual gross revenues of $1 million or less was well below
demographics but well above aggregate lending. Further, loans in amounts of $100,000 or less,
regardless of business size, were 82.6 percent, which reflects very good access to credit for very
small businesses.
First -Citizens Bank originated an adequate level of community development loans in the Myrtle
Beach MSA assessment area. During this evaluation period, the bank originated three
0.4 percent by dollar volume of bank -wide community development loans, which is below the
bank -wide lending levels in the Myrtle Beach MSA assessment area. Regarding the community
development purpose, one loan supports affordable housing, one loan supports community
services, and one loan supports economic development. Examples of community development
loans include a $1.0 million loan to a governmental housing authority for the construction of an
8 -unit affordable housing complex located in a low-income census tract and a $1.4 million loan
to construct a new retail store in a moderate -income census tract, which led to the creation of 10
new jobs for low- and moderate -income individuals.
INVESTMENT TEST
The Investment Test performance is rated Low Satisfactory in the Myrtle Beach MSA
assessment area. The bank has an adequate level of qualified investments in this assessment area
relative to the bank's operations. Qualified investments in the Myrtle Beach MSA assessment
area total $3.1 million or 0.9 percent of bank -wide qualified investments. Investments include
LIHTC investments for an affordable housing project totaling $3.1 million and 27 donations
totaling $23,000. Of the donations, $3,000 benefitted affordable housing, $16,000 benefitted
community services, and $4,000 benefitted economic development.
288
SERVICE TEST
The Service Test rating is High Satisfactory in the Myrtle Beach MSA assessment area.
operates 10 branches in this assessment area which represents 1.8 percent of all branches. One
branch (10.0 percent) is in a low-income geography, and two branches (20.0 percent) are in
moderate -income geographies. The bank provided an adequate level of community development
services. Specifically, the bank provided 20 community development services which equates to
0.7 community development services per branch per year. The following are examples of
community development services provided.
An employee serves as a Board member for a housing authority.

An employee serves on the Board for a foundation that provides funds for low-income
families medical expenses.
289
CRA RATING FOR AUGUSTA -RICHMOND COUNTY, GA -SC MULTISTATE MSA:

Satisfactory

SCOPE OF EVALUATION
The evaluation of the Augusta -Richmond County, GA -SC Multistate MSA performance
considered the bank's operations in the Augusta MSA assessment area which consists of three
counties in Georgia and two counties in South Carolina. The assessment area represents a portion of
the Augusta -Richmond County, GA -SC Multi -state MSA. Additional Augusta MSA assessment
area information is detailed in Appendix A. Home mortgage and small business loans were
reviewed. By number and dollar, small business loans constituted the primary loan type and
therefore received the most weight.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN AUGUSTA MSA

ASSESSMENT AREA
The Augusta MSA assessment area consists of Columbia, McDuffie, and Richmond Counties in
Georgia and Aiken and Edgefield Counties in South Carolina. The Augusta -Richmond County,
GA -SC Multi -state MSA has seven counties; however, the bank did not delineate Burke and
Lincoln Counties as part of its assessment area. The bank operates 12 or 2.1 percent of branch
offices in the assessment area. The assessment area accounts for 1.3 percent of the bank -wide
rated loans and 1.7 percent of deposits.
farms are disbursed among middle- and upper -income census tracts. There is also a good level
in the moderate -income areas. The following table presents demographic information from the
2015 ACS Census and 2017 D&B data.
290
Augusta MSA Assessment Area

#
% of # % of # % of # % of # % of #
ranked 7th with a 6.4 percent deposit market share. Competitor institutions included Wells Fargo
Bank, NA, South State Bank, and Bank of America, NA. Together, the three competitor
table reflects the average annual unemployment rates and trends of the assessment area, states,
and nation. The unemployment rates in McDuffie and Richmond Counties are well above state
and national rates, while the other counties have rates comparable to state and national rates.
291
Unemp oyment Rates
2016 2017 2018
Area
Columbia County, GA 4.6 4.1 3.5

McDuffie County, GA 7.3 6.2 5.6
Richmond County, GA 6.7 5.9 5.1
Aiken County, SC 5.0 4.1 3.3
Edgefield County, SC 5.7 4.6 3.5
Georgia 5.4 4.8 4.0
In 2017, the top industries were government, professional and business services, and education
and health services. The top employers were U.S. Army Signal Center & Fort Gordon,
Washington Savannah River Company, Georgia Regents University, Augusta University, and
University Hospital.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN AUGUSTA MSA ASSESSMENT

AREA
LENDING TEST
The Lending Test rating for the Augusta MSA assessment area is High Satisfactory. Lending
distribution reflects good penetration, and the borrower profile reflects a good distribution to
flexible lending practices and originated a low level of community development loans.
Lending Activity
in Appendix D detail the number and dollar volume of HMDA and CRA loans in the August
292
area. The bank did not originate any home purchase loans in low-income census tracts; however,
aggregate lending was also limited at 1.5 percent. Home purchase lending in moderate -income
census tracts was consistent with the demographic data and almost double aggregate lending
data. For home refinance loans, lending in low-income census tracts was consistent with the
demographic and aggregate lending data. Home refinance lending in moderate -income census
tracts was above demographic data and significantly exceeded aggregate lending data.
assessment area. Small business lending in low-income census tracts was below demographic
data and aggregate lending data. However, lending in moderate -income census tracts was above
the demographic data and significantly exceeded the aggregate lending data.
Borrower Profile
demographics but above aggregate lending data. Performance for home purchase loans to
moderate -income borrowers was lower than the demographic and half aggregate lending data.
For home -refinance loans, performance to low-income borrowers was substantially below
demographics and below aggregate lending data. Lending to moderate -income borrowers was
also lower than demographic and aggregate lending data. Conversely, in 2016, home purchase
loans to low-income borrowers and for home purchase and refinance loans to moderate -income
borrowers exceeded demographics and aggregate lending data. In addition, home refinance
loans, to low-income borrowers was above aggregate lending data.
The distribution of small business loans reflects good penetration among businesses. Lending to
businesses with annual gross revenues of $1 million or less was significantly below
demographics but significantly above aggregate data. Further, loans in amounts of $100,000 or
less, regardless of business size, were 78.6 percent, which reflects good access to credit for very
small businesses.
First -Citizens Bank originated a low level of community development loans in the Augusta MSA
assessment area. During the evaluation period, the bank originated two community development
loans totaling $600,000. This represents 0.6 percent by number and 0.1 percent by dollar volume
of bank -wide community development loans, which is below the bank -wide lending levels in the
Augusta MSA assessment area. Both community development loans supported community
293
services by providing financing to a non-profit organization located in a moderate -income census
tract that provides services for individuals with physical or intellectual disabilities, including
workforce development, support services, and residential services.
INVESTMENT TEST
The Investment Test performance is rated Needs to Improve in the Augusta MSA assessment
area. The bank has a poor level of qualified investments relative to the bank -wide operations in
this assessment area. Qualified investments in the Augusta MSA assessment area total $487,000
or 0.1 percent of bank -wide qualified investments. The investments consisted of 19 donations
totaling $40,000. Of the donations, $1,000 benefitted affordable housing, $37,000 benefitted
community services, and $2,000 benefitted economic development. A prior period equity
investment of $447,000 that benefitted affordable housing is included among the qualified
investments for this assessment area. Investments consisted of 19 donations totaling $40,000.
Of the donations, $1,000 benefitted affordable housing, $37,000 benefitted community services,
and $2,000 benefitted economic development.
SERVICE TEST
The Service Test rating is Low Satisfactory in the Augusta MSA assessment area. Delivery
systems are reasonably accessible to essentially all portions of the assessment area, and the
systems. The bank operates 12 branches in this assessment area, which represents 2.1 percent of
bank -wide branches. There are no branches in low-income geographies, which accounts for 7.0
percent of the population. However, there are 4 branches in moderate -income census tracts. The
percentage of branches in moderate -income geographies is 33.3 percent, which exceeds the
population of 24.9. The bank did not open any branches in the assessment area since the last
evaluation; however, a branch in a middle -income geography was closed. The bank provided an
adequate level of community development services. Specifically, the bank provided 22
community development services which equates to 0.7 community development services per
branch per year. The following are examples of community development services provided.
An employee conducted a financial literacy event in conjunction with a small business

development center. Topics discussed and presented included tax strategy, fundamentals
of company formation, retirement services, and succession planning.
An employee conducted a financial literacy event at the housing authority to discuss the
home application process.
An employee serves as the Treasurer for a child advocacy organization that serves low -
and moderate -income families.
294
CRA RATING FOR KANSAS CITY KS -MO MULTISTATE MSA: Satisfactory

SCOPE OF EVALUATION
The evaluation of the Kansas City KS -MO Multistate MSA performance considered a full -scope
review of the Kansas City MSA assessment area consisting of Johnson County, Kansas and
Jackson County, Missouri. The assessment area represents a portion of the Kansas City KS -MO
Multistate MSA. Small business loans constitute the primary loan type in the assessment area.
Home mortgage loans were limited, and no farm loans were reviewed in the assessment area.
Therefore, the conclusions were primarily based upon the small business lending performance.
DESCRIPTION OF INSTITUTION'S OPERATIONS IN KANSAS CITY MSA

ASSESSMENT AREA
The Kansas City KS -MO Multistate MSA has 14 counties. However, the bank only delineated
Johnson County in Kansas and Jackson County in Missouri as its assessment area. The bank
operates a branch each in each state, which together represents 0.4 percent of bank -wide
branches. The Kansas City assessment area accounts for 0.2 percent of bank -wide loans and 0.2
percent of deposits.
The 2015 ACS Census shows most of the owner -occupied housing units, businesses, and farms
are in middle- and upper -income census tracts. The following table presents demographic
295
Kansas City MSA Assessment Area
% of # % of # % of # % of # % of #

52th with 0.1 percent deposit market share. Competitor institutions include UMB Bank, NA,
Commerce Bank, and Bank of America, NA. Together, the three competitor institutions account
for 49.4 percent of the market share.
table reflects the average annual unemployment rates and trends for the Kansas City MSA
assessment area, states, and nation. Johnson County has unemployment rates below both the
Kansas and national average rates. Jackson County has unemployment rates above the state of
Missouri but consistent with national average rates.
Unemp oyment Rates

2016 2017 2018
Area
% %
Johnson County, KS 3.3 3.0 2.8
Jackson County, MO 4.9 4.4 3.8
Kansas 4.0 3.6 3.4
Missouri 4.6 3.7 3.4
296
and health services. The top employers were Cerner Corp, HCA Midwest Health System, The
University of Kansas Hospital, Saint Luke's Health System, and Ford Motor Company.
income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN KANSAS CITY MSA

ASSESSMENT AREA
LENDING TEST
The Lending Test rating for the Kansas City MSA assessment area is High Satisfactory. Lending
distribution reflects good penetration throughout the assessment area, and the borrower profile
reflects good distribution to borrowers of different incomes and businesses of different sizes. In
development loans.
Lending Activity
in Appendix D detail the number and dollar volume of HMDA and CRA loans in the Kansas
City MSA assessment area.
conclusions. In 2017, the bank originated two HMDA loans with one home purchase loan in a
moderate -income census tract and one home refinance loan in an upper -income census tract. In
2016, the bank originated three HMDA loans with one home purchase loan in a low-income
census tract and two home purchase loans in upper -income census tracts.
The geographic distribution of small business loans reflects good penetration throughout this
assessment area. Small business lending in low-income census tracts was below demographic
and aggregate lending data. However, lending in moderate -income census tracts was above
demographic and aggregate lending data.
297
Borrower Profile
The distribution of HMDA and small business loans is good to borrowers of different incomes
and businesses of different sizes.
conclusions. In 2017, the bank originated two HMDA loans with one home purchase loan to a
low-income borrower and one home refinance loan to a moderate -income borrower. None of
three home purchase loans in 2016 originated to low- or moderate -income borrower.
sizes. Small business lending to businesses with annual gross revenues of $1 million or less was
significantly below demographics and well above aggregate lending. Lending to small
businesses was higher in 2016 at 70.7 percent. Further, loans in amounts of $100,000 or less,
regardless of size, were 85.1 percent, which reflects excellent access to credit for very small
businesses.
First -Citizens Bank originated an adequate level of community development loans in the Kansas
City MSA assessment area. During this evaluation period, the bank originated three community
development loans totaling $185,000. This represents 0.9 percent by number and 0.0 percent by
dollar volume of bank -wide community development loans. All three community development
loans support affordable housing by providing financing to a non-profit organization that
develops affordable housing, supports neighborhood stabilization, and provides homeownership
counseling.
INVESTMENT TEST
The Investment Test performance is rated Outstanding in the Kansas City MSA assessment area.
The bank has an excellent level of qualified investments relative to the bank -wide operations.
Investments include LIHTC, which support three affordable housing projects totaling $8.1
million, $290,000 in SBA pools that support two small businesses, and three donations totaling
$2,000. Of these contributions, $1,000 benefitted community services, and $1,000 benefitted
economic development.
SERVICE TEST
The Service Test rating is Low Satisfactory in the Kansas City MSA assessment area. Delivery
systems are accessible to limited portions of the assessment area. The two branches in the
assessment area are located in upper -income geographies. Although there are no branches in
low- and moderate -income census tracts, First -Citizens Bank's service delivery systems,
particularly alternative systems, are available to all customers. The bank provided a relatively
high level of community development services. Specifically, the bank provided 10 community
298
development services which equates to 1.8 community development services per branch per
year. The following are examples of community development services provided.
An employee provided a financial literacy presentation focused on financing small

businesses in collaboration with a small business and technology development center.
An employee provided a financial literacy session on the 5 C's of credit and SBA
financing in collaboration with a community college small business resource center.
An employee provided a financial literacy session in conjunction with a housing authority
that focused on budgeting.
299
Atit'hiNDIA A
SCOPE OF Evaluation
The lending test included loans reported pursuant to the HMDA and
TIME PERIOD REVIEWED CRA data collection requirements for 2016 and 2017. Community
development lending and the investment and service tests covered
June 6, 2016 through March 26, 2019. The branch office
distribution period is from March 31, 2016 through December 31,
2018.
PRODUCTS
FINANCIAL INSTITUTION
REVIEWED
First -Citizens Bank & Trust Home mortgage loans small business loans, small farm loans,
Company community development loans, investments, and services
AFFILIATE(S) AFFILIATE PRODUCTS

RELATIONSHIP REVIEWED
None
List of Assessment Areas with Types of Evaluations, Breakdown of Loans, Deposits, and Branches
Loans* Deposits** Branches*** Branches
% Visited
Assessment Area % (Rated
% °A
S(000s) Area) $(000s) % (R ated 4
(Bank) (Bank) (Bank) Review
Area)
Level
Phoenix -Mesa -Scottsdale, None
AZ MSA+ Full
129,359 1.7 92.5 179,925 0.6 97.8 2 0.3
(Phoenix MSA) Scope
Tucson, AZ MSA 1 Limited None
10,433 0.1 7.5 4,099 0.0 2.2 0.2
(Tucson MSA) . Scope
Arizona Subtotal 139,792 1.8 100.0 184,024 0.6 100.0 3 0.5
Anaheim -Santa Ma -Irvine, None
Limited
CA MSA 55,262 0.7 14.8 275,975 1.0 20.1 3 0.5
Scope
(Anaheim MD)
Los Angeles -Long Beach- None
Full
Glendale, CA MD 95,678 1.3 25.5 212,692 0.7 15.5 4 0.7
Scope
(Los Angeles MD)
Oakland -Haywood- None
Berkeley, CA MD Limited
1,576 0.0 0.4 708 0.0 0.1 1 O.?
(Oakland MD) Scope
Riverside -San Bernardino- None

Limited
Ontario, CA MSA 28,998 0.4 7.7 165302 0.5 12.0 3 0.5
Scope
(Riverside MSA)
Sacramento -Roseville- None
Full
Arden -Arcade, CA MSA 63,618 0.8 17.0 368,208 1.2 26.8 3 0.5
Scope
(Sacramento MSA)
San Diego -Carlsbad, CA Full None
129,539 1.7 34.6 349,796 1.1 25.5 7 1.3
MSA (San Diego MSA) Scope
California Subtotal+ 374,671 4.9 100.0 1,372,681 4.5 100.0 21 3.7
Boulder, CO MSA Limited None

11,947 0.2 18.0 16,903 0.1 9.7 1 0.2
(Boulder MSA) Scope
None
Denver -Aurora -Lakeland,
Full
CO MSA 54,340 0.7 82.0 156,715 0.5 90.3 4 0.7
Scope
(Denver MSA)
Colorado Subtotal 66,287 0.9 100.0 173,618 0.6 100.0 5 0.9
300
Cape Coral -Fort Myers, FL None
2 Limited
MSA 23,059 0.3 10.9 93,051 0.3 7.8 0.4
(Cape Coral MSA) Scope
Fort Lauderdale -Pompano None

Beach -Deerfield, FL MSA 0.4 14.7 0.3
Limited
31,231 - 78,872 6.6 2 0.4
(Fort Lauderdale MSA) Scope
Jacksonville FL, MSA Full None
40,266 0.5 19.0 126,169 0.4 10.6 4 0.7
(Jacksonville MSA) Scope
Miami -Miami Beach- Yes
Kendall, FL MSA 22,374 Limited
0.3 10.6 60,167 0.2 5.1 1 0.2
(Miami MSA) Scope
Naples-Immokalee-Marco None
Island, FL MSA (Naples Limited
17,647 0.2 8.3 81,951 0.3 6.9 2 0.4
MSA) Scope
(Naples MSA)
North Port -Sarasota- None
Bradenton, FL MSA 6,033 0.1 2.9 42,999 3.6
Limited
0.1 1 0.2
(North Port MSA) Scope
Orlando, FL MSA 2,577 0.0 1.2 103,939 0.3 8.7 2 0.4 ++ None
Port St Lucie, FL MSA Limited None

10,694 0.2 5.0 24,285 0.1 2.0 1 0.2
(Port St. Lucie MSA) Scope
Tampa St. FL Pete, FL None
2,725 0.1 1.3 435,786 1.4 36.5 8 1.3 .4.±
MSA+
West Palm Beach -Boca None
Raton -Delray Beach, FL Full
55,398 0.7 26.1 145,223 0.5 12.2 3 0.5
MSA (West Palm Beach Scope
MSA)
Florida Subtotal 212,004 2.8 100.0 1,192,442 3.9 100.0 26 4.7
Athens -Clarke County, GA Limited None
8,776 0.1 2.8 94,667 0.3 8.7 3 0.5
MSA (Athens MSA) Scope
Atlanta -Sandy Spring- None
Roswell, GA MSA+ 250,187 Full
3.3 78.7 750,770 2.5 69.0 14 2.6
(Atlanta MSA) Scope
Savannah, GA MSA Limited None
26,082 0.4 8.2 40,775 0.1 3.8 1 0.2
(Savannah MSA) Scope
Georgia Non-MSA Limited None
32,834 0.4 10.3 201,749 0.7 18.5 5 0.9
(GA Non-MSA) Scope
Georgia Subtotal 317,879 4.2 100.0 1,087,961 3.6 100.0 23 4.2
Chicago, IL MSA 0 0.0 0 0 0.0 0.0 0 0.0 +++ None
Illinois Subtotal 0 0.0 0.0 0 0.0 0.0 0 0.0
Baltimore -Columbia- None

Townson, MD MSA 28,650 0.4 100.0 45,746 Full
0.2 100.0 2 0.4
(Baltimore MSA) Scope
Maryland Subtotal 28,650 0.4 100.0 45,746 0.2 100.0 2 0.4

Minnesota -St. Paul, MN None
513 0.0 100.0 0 0.0 0.0 0 0.0 +++
MSA
Minnesota Subtotal 513 0.0 100.0 0 0.0 0.0 0 0.0

Wilmington, NJ MSA 66 0.0 100.0 0 0.0 0.0 0 0.0 +++ None
New Jersey Subtotal 66 0.0 100.0 0 0.0 0.0 0 0.0

Albuquerque, NM MSA Full None
35,286 0.5 84.6 63,933 0.2 62.8 0.2
(Albuquerque MSA) 1
Scope
Santa Fe, NM MSA Limited None
6,436 0.1 15.4 37,909 0.1 37.2 0.2
(Santa Fe MSA) 1
Scope
New Mexico Subtotal 41,722 0.6 100.0 101,842 0.3 100.0 2 0.4
301
Asheville, NC MSA Full None
345,042 4.6 11.5 1,520,431 5.0 11.5 21 3.8
(Asheville MSA) Scope
Durham -Chapel Hill, NC Limited None
202,591 2.7 6.8 551,311 1.8 4.2 8 1.4
MSA (Durham MSA) Scope
Fayetteville, NC MSA Limited None
106,432 1.4 3.6 584,677 1.9 4.4 9 1.6
(Fayetteville MSA) Scope
Goldsboro, NC MSA Limited None
35,155 0.5 1.2 161,848 0.5 1.2 3 0.5
(Goldsboro MSA) Scope
Greensboro -High Point, NC None
Limited
MSA 201,072 2.7 6.7 735,538 2.4 5.6 14 2.5
Scope
(Greensboro MSA)
Greenville, NC MSA Limited None
101,288 1.3 3.4 297,376 1.0 2.2 6 1.1
(Greenville MSA) Scope
Hickory -Lenoir -Morganton, None
Limited
NC MSA 157,279 2.1 5.2 689,656 2.3 5.2 10 1.8
Scope
(Hickory MSA)
Jacksonville, NC MSA Limited None
59,600 0.8 2.0 455,312 1.5 3.4 7 1.3
(Jacksonville MSA) Scope
New Bern, NC MSA Limited None
116,932 1.5 3.9 382,829 1.2 2.9 6 1.1
(New Bern MSA) Scope
Raleigh, NC MSA Full Yes
616,315 8.1 20.6 3,034,251 10.0 22.9 33 6.0
(Raleigh MSA) Scope
Rocky Mount, NC MSA Limited None
8,583 0.1 0.3 79,752 0.3 0.6 1 0.2
(Rocky Mount MSA) Scope
Virginia Beach, NC MSA Limited None
3,354 0.0 0.1 23,985 0.1 0.2 1 0.2
(Virginia Beach MSA) Scope
Wilmington, NC MSA Limited None
230,424 3.0 7.7 779,442 2.5 5.9 10 1.8
(Wilmington MSA) Scope
Winston-Salem, NC MSA Limited None
119,322 1.6 4.0 549,716 1.8 4.1 10 1.8
(Winston-Salem MSA) Scope
North Carolina Non-MSA+ Full None
687,068 9.1 23.0 3,407,293 11.2 25.7 57 10.3
(NC Non-MSA) Scope
North Carolina Subtotal 2,990,457 39.5 100.0 13,253,417 43.5 100.0 196 35.4
Oklahoma City, OK MSA Full None

38,471 0.5 100.0 112,592 0.4 100.0 2 0.4
(Oklahoma City MSA) Scope
Oklahoma Subtotal 38,471 0.5 100.0 112,592 0.4 100.0 2 0.4

Full None
Portland, OR MSA 26,813 0.4 100.0 78,278 0.3 100.0 2 0.4
Scope
Oregon Subtotal 26,813 0.4 100.0 78,278 0.3 100.0 2 0.4
None
Montgomery County, PA 0.0 +++
1,721 0.0 51.9 0 0.0 0.0 0
MSA
None
Philadelphia, PA MSA 1,593 0.0 48.1 0 0.0 0.0 0 0.0 +++
Pennsylvania Subtotal 3,314 0.0 100.0 0 0.0 0.0 0 0.0

None
Charleston -North Full
Charleston, SC MSA 408,957 5.4 26.3 901,838 3.0 14.5 18 3.3
Scope
(Charleston MSA)
Columbia, SC MSA Full None

356,874 4.7 23.0 1,757,817 5.8 28.2 25 4.5
(Columbia MSA) Scope
Limited None
Florence, SC MSA 5.5 412,250
85,252 1.1 1.3 6.6 6 1.1
(Florence MSA) Scope
None
Greenville -Anderson-
Full
Mauldin, SC MSA 285,818 3.8 18.4 891,372 2.9 14.3 18 3.3
Scope
(Greenville MSA)
302
Hilton Head Island- None
Limited
Bluffton -Beaufort, SC MSA 38,596 0.5 2.4 142,590 0.5 2.3 3 0.5
Scope
(Hilton Head MSA)
Spartanburg, SC MSA Limited None
88,988 1.2 5.7 489,088 1.6 7.8 10 1.8
(Spartanburg MSA) Scope
Sumter, SC MSA None
Limited
35,691 0.5 2.3 143,897 0.5 2.3 3 0.5
(Sumter MSA) Scope
South Carolina Non-MSA Full None

254,551 3.3 16.4 1,501,936 4.9 24.0 . 32 5.8
(Sc Non-MSA) Scope
South Carolina Subtotal 1,554,727 20.5 100.0 6,240,788 20.5 100.0 115 20.8
Chattanooga, TN MSA Full None

24,873 0.4 33.8 21,904 0.1 20.6 1 0.2
(Chattanooga MSA) Scope
Johnson City, TN MSA Limited None

2,873 0.0 3.9 9,179 0.0 8.7 1 0.2
(Johnson MSA) Scope
Knoxville, TN MSA Full None
31,298 0.4 42.5 48,229 0.1 45.4 2 0.4
(Knoxville MSA) Scope
None
Nashville -Davidson-
Murfreesboro -Franklin, TN Limited
14,562 0.2 19.8 26,849 0.1 25.3 2 0.4
MSA Scope
(Nashville MSA)
Tennessee Subtotal+ 73,606 1.0 100.0 106,161 0.3 100.0 6 1.2
Austin -Round Rock, TX None

MSA
Full
69,643 0.9 67.7 153,214 0.6 65.3 3 0.5
Scope
(Austin MSA)
Dallas -Plano -Irving, TX None

Limited
MSA 11,480 0.2 11.2 36,219 0.1 15.4 2 0.4
(Dallas MSA) Scope
Houston -The Woodlands- None

Sugarland, TX MSA 21,745
Limited
0.3 21.1 45,291 0.1 19.3 2 0.4
(Houston MSA) Scope
Texas Subtotal 102,868 1.4 100.0 234,724 0.8 100.0 7 13

Blacksburg-Christiansburg- None
Radford, VA MSA 13,933 0.2 2.6
Limited
22,581 0.1 1.3 2 0.4
(Blacksburg MSA) Scope
Charlottesville, VA MSA Limited None

(Charlottesville MSA) 40,725 0.5 7.7 82,219 0.3 4.8 3 0.5
Scope
Harrisonburg, VA MSA Limited None
16,768 0.2 3.2 36,352 0.1 2.1 0.4
(Harrisonburg MSA) Scope
Lynchburg, VA MSA Limited None
MSA)Scope
49,833 0.7 9.5 198,448 0.7 11.5 4 0.7
(Lynchburg MSA) Scope
Richmond, VA MSA Limited None
65,545 0.8 12.5 265,996 0.9 15.5 6 1.1
(Richmond MSA) Scope
Roanoke, VA MSA Full None
163,217 2.1 31.1 284,742 0.9 16.6 7 1.3
(Roanoke
Staunton -Waynesboro, VA None
MSA Limited
11,669 0.2 2.2 42,942 0.1 2.5 1 0.2
(Staunton MSA) Scope
Washington, VA MSA Limited None

65,423 0.9 12.5 100,233 0.3 5.8 5 0.9
(Washington MSA) Scope
Winchester, VA MSA Limited None
(Winchester MSA) 8,228 0.1 1.6 16,126 0.1 0.9 1 0.2
Scope
Virginia Non-MSA Full None
(VA Non-MSA) 89,703 1.2 17.1 671,269 2.2 39.0 16 2.8
Scope
Virginia Subtotal 525,044 6.9 100.0 1,720,908 5.7 100.0 47 8.5
303
Olympia-Tumwater, WA None
Limited
MSA 9,141 0.1 8.2 109,964 0.4 34.5 1 0.2
Scope
(Olympia MSA)
Seattle -Bellevue -Everett, None
Full
WA MSA 80,282 1.1 71.7 107,246 0.3 33.6 3 0.5
Scope
(Seattle MSA)
None
Tacoma -Lakewood, WA
Limited
MSA 22,535 0.3 20.1 101,841 0.3 31.9 2 0.4
Scope
(Tacoma MSA)
Washington Subtotal 111,958 1.5 100.0 319,051 1.0 100.0 6 1.1
West Virginia Non-MSA Full None

13,637 0.2 100.0 131,016 0.4 100.0 5 0.9
(WV Non-MSA) Scope
West Virginia Subtotal 13,637 0.2 100.0 131,016 0.4 100.0 5 0.9
Milwaukee -Waukesha -West None

Full
Allis, WI MSA+ 4,770 0.0 100.0 441,844 1.4 94.3 13 2.3
Scope
(Milwaukee MSA)
Racine, WI MSA Limited None
0 0.0 0.0 26,924 0.1 5.7 1 0.2
(Racine MSA) Scope
Wisconsin Subtotal 4,770 0.0 100.0 468,768 1.5 100.0 14 2.5
Augusta -Richmond GA -SC Full None

101,894 1.3 100.0 523,213 1.7 100.0 12 2.1
Multi -State MSA Scope
None
Charlotte -Concord NC -SC Full
668,843 8.8 100.0 2,629,906 8.6 100.0 45 8.2
Kansas City KS -MO Multi- Full None
16.577 0.2 100.0 47,958 0.2 100.0 2 0.4
State MSA Scope
Myrtle -Beach NC -SC Full None
165,363 2.2 100.0 413,014 1.4 100.0 10 1.8
++
None
Vancouver, WA MSA+ 0 0.0 0.0 0.0 0.0 0.0 1 0.2
Total 7,579,926 100.0 30,438,108 100.0 552 100.0

*Source: 2016 & 2017 HMDA/CRA LARs
**FDIC Summary of Deposits as of 6/30/1
***Bank records as of 12/31/18
+ Branch percentages do not agree with branch percentages for similar branch total numbers due to rounding;
++ The bank added these assessment areas or counties in the latter half of 2018, so they are excluded from the scope of this evaluationfor
2016 and 2017 analyses;
+++ The bank entered these markets through FDIC assisted acquisitions, operated in these markets for approximately a year or less, and
ceased all banking activities as of December 31, 2018. Due to minimal lending and other banking activities in these states, examiners
excluded these states from the scope of the evaluation.
304
Description of Assessment Areas (As of December 31, 2018)
Assessment Area Counties in Assessment Area # of CTs # of Branches
Arizona
Phoenix MSA Maricopa County 916 2
Tucson MSA Pima County 241 1
California
Anaheim MD Orange County 583 3
Los Angeles MD Los Angeles County 2,346 4
Oakland MD Contra Costa County 208 1
Riverside MSA Riverside County 453 3
Sacramento MSA Placer and Sacramento Counties 402 3
San Diego MSA San Diego County 628 7
Colorado
Boulder MSA Boulder County 68 1
Denver MSA Adams, Arapahoe, Denver, and Douglas Counties 449 4

Florida
Cape Coral MSA Lee County 167 2
Fort Lauderdale MSA Broward County 362 2

Jacksonville MSA Duval and St. Johns County 215 4
Miami MSA Miami -Dade County 519 1
Naples MSA Collier County 74 2

North Port -Sarasota MSA Manatee and Sarasota Counties 174 1
Orlando MSA* Orange and Seminole Counties 293 2

Port St Lucie MSA Martin County 36 1
Tampa -St Pete MSA* Hillsborough and Pinellas Counties 567 8
West Palm Beach MSA Palm Beach County 338 3
Georgia
Athens MSA Madison County 6 3
Cherokee, Cobb, DeKalb, Forsyth, Fulton, and Gwinnett
Atlanta MSA 653 14
Counties
Savannah MSA Chatham County 72 1
GA Non-MSA Franklin, Hart, and Stephens, Counties 15 5
Illinois
Chicago -Naperville MSA+ Cook County 1319 0
Maryland
Anne Arundel (105 census tracts) and Howard Counties (55
Baltimore MSA 160 2
Census tracts)**
Minnesota
Minneapolis -St. Paul MSA+ Anoka County 83 0
New Jersey
Wilmington MSA+ Salem County 25 0
New Mexico
Albuquerque MSA Bernalillo County 153 1
Santa Fe MSA Santa Fe County 50 1
North Carolina
Asheville MSA Buncombe, Haywood, Henderson, and Madison Counties 105 21
Durham MSA Chatham, Durham, and Orange Counties 101 8
Fayetteville MSA Cumberland County 68 9

Goldsboro MSA Wayne County 26 3
305
Greensboro MSA Guilford, Randolph, and Rockingham Counties 168 14
Greensville MSA Pitt County 32 6
Hickory MSA Alexander, Burke, Caldwell, and Catawba Counties 73 10
Jacksonville MSA Onslow County 32 7

Craven County (21 census tracts); Jones County*** (3 census
New Bern MSA 29 6
tracts); and Pamlico (5 census tracts)
Raleigh MSA Franklin, Johnston, and Wake Counties 224 33
Rocky Mount MSA Nash County 18 1
Virginia Beach MSA Gates County 3 1
Wilmington MSA New Hanover and Pender Counties 61 10
Winston-Salem MSA Forsyth, Stokes, and Yadkin Counties 109 10

Allegany, Ashe, Avery, Beaufort, Bladen, Carteret, Cherokee,
Clay, Columbus, Duplin, Graham, Greene, Halifax, Harnett,
Jackson, Lee, Lenoir, McDowell, Macon, Martin, Moore,
NC Non-MSA 384 57
Pasquotank, Polk, Rutherford, Sampson, Stanly, Surry, Swain,
Transylvania, Vance, Warren, Watauga, Wilkes, Wilson, and
Yancey Counties
Oklahoma
Oklahoma City MSA Oklahoma County 241 2
Oregon****
Clackamas
Portland MSA 251 2
Multnomah
Pennsylvania
Montgomery County MSA+ Chester and Montgomery Counties 327
Philadelphia MSA+ Delaware 144
South Carolina
Charleston MSA Berkeley, Charleston, and Dorchester Counties 156 18
Columbia MSA Fairfield, Kershaw, Lexington, Richland, and Saluda Counties 188 25
Florence MSA Darlington and Florence Counties 49 6
Greenville MSA Anderson, Greenville, Laurens, and Pickens Counties 195 18
Hilton Head MSA Beaufort County 41 3
Spartanburg MSA Spartanburg County 69 10
Sumter MSA Sumter County 23 3

Abbeville, Barnwell, Chesterfield, Clarendon, Dillon,
SC Non-MSA Georgetown, Greenwood, Lee, McCormick, Marion, Marlboro, 148 32
Newberry, Oconee, Orangeburg, and Williamsburg Counties
Tennessee
Chattanooga MSA Hamilton County 82 1
Johnson City MSA Washington County 23 1
Knoxville MSA Knox County 112 2
Nashville MSA Davidson and Williamson Counties 198 2
Texas
Austin MSA Travis and Williamson Counties 307 3
Dallas County (529 census tracts) and Collin County (152
Dallas MSA 681 2
census tracts)**
Houston MSA Fort Bend and Harris Counties 862 2
Virginia
Blacksburg MSA Montgomery County 16 2
Charlottesville MSA Albemarle County; Charlottesville City 34 3
Harrisonburg MSA Rockingham County; Harrisonburg City 30 2
Lynchburg MSA Bedford and Campbell Counties; Lynchburg City 48 4
Richmond MSA Chesterfield and Henrico Counties; Richmond City 201 6
306
Roanoke MSA Botetourt and Roanoke Counties; Roanoke and Salem Cities 54 7
Staunton -Waynesboro MSA Augusta County; Staunton and Waynesboro Cities 24 1
Arlington, Fairfax, Loudoun, Spotsylvania and Warren Counties

Washington MSA 431 5
and Fairfax and Fredericksburg Cities
Winchester MSA Frederick County; Winchester City 19 1
Alleghany, Brunswick, Carroll, Greensville, Mecklenburg,

VA Non-MSA Nottoway, and Pittsylvania Counties; Covington, Danville, 72 16
Emporia, and Galax Cities
Washington
Olympia MSA Thurston County 50 1
Seattle MSA King County 398 3
Tacoma MSA Pierce County 172 2

West Virginia
WV Non-MSA Greenbrier and Pocahontas Counties 11 5
Wisconsin
Milwaukee MSA Milwaukee, Washington and Waukesha Counties 412 13
Racine MSA Racine County 45 1
Augusta -Richmond GA -SC Multi- Columbia, McDuffie, and Richmond, GA Counties; Aiken and
111 12
State MSA Edgefield, SC Counties
Charlotte -Concord -Gastonia NC -SC
Cabarrus, Iredell, Lincoln, Mecklenburg, and Union, NC
Multi -State MSA (Charlotte Multi- 444 45
Counties; Chester, Lancaster, and York, SC Counties
State MSA)
Kansas City KS -MO Multi -State
Johnson, KS County; Jackson, MO County 329 2
MSA
Myrtle -Beach NC -SC Multi -State
Brunswick, NC County; Horry, SC County 105 10
MSA
Vancouver, -WA MSA**** Clark County (WA) 104 1
TOTAL 552
Source: Bank Records as of December 31 2018 *The bank added these assessment areas in the latter half of 2018, so they are excluded from
the scope of this evaluation; **The bank entered these counties in the latter half of 2018, so they are excluded from the 2016 and 2017 Lending
Test; * * * The bank ceased operations in Jones County in the New Bern, NC MSA in November 2017; therefore, the county is included in the
evaluation for 2016 and 2017; ****Together, these MSAs form a multi -state MSA, but only the Portland, OR MSA was reviewed and is part of
the Oregon state rating, because the bank only started operations in Vancouver in Clark County (WA) in October 2018. No rating is assigned
for the Multi -state MSA; * The bank entered these markets through FDIC assisted acquisitions, operated in these markets for approximately a
year or less, and ceased all banking activities as of December 31, 2018. Due to minimal lending and other banking activities in these states,
examiners excluded these states from the scope of the evaluation.
307
APPENDIX B
SUMMARY OF STATE AND MULTISTATE METROPOLITAN AREA RATINGS
State or Multistate Metropolitan Lending Test Investment Test Service Test Overall State
Area Name Rating Rating Rating Rating
North Carolina High Satisfactory High Satisfactory High Satisfactory Satisfactory

South Carolina High Satisfactory High Satisfactory High Satisfactory Satisfactory
Virginia High Satisfactory Low Satisfactory High Satisfactory Satisfactory
California High Satisfactory Outstanding High Satisfactory Satisfactory
Georgia High Satisfactory Outstanding Low Satisfactory Satisfactory
Florida Low Satisfactory Outstanding High Satisfactory Satisfactory
Texas Low Satisfactory Outstanding Low Satisfactory Satisfactory
Arizona Low Satisfactory Outstanding High Satisfactory Satisfactory
Washington High Satisfactory Outstanding Low Satisfactory Satisfactory
Colorado Low Satisfactory Outstanding Needs to Improve Satisfactory
Tennessee Low Satisfactory Outstanding Low Satisfactory Satisfactory
Maryland Low Satisfactory Low Satisfactory Low Satisfactory Satisfactory
New Mexico Low Satisfactory High Satisfactory High Satisfactory Satisfactory
Oklahoma Low Satisfactory Needs to Improve Low Satisfactory Needs to Improve
Oregon High Satisfactory Outstanding High Satisfactory Satisfactory
West Virginia High Satisfactory Needs to Improve Low Satisfactory Satisfactory
Wisconsin Low Satisfactory Needs to Improve Low Satisfactory Needs to Improve
Charlotte -Concord -Gastonia NC- High Satisfactory Low Satisfactory Low Satisfactory Satisfactory
SC Multi -State MSA
Myrtle Beach -Conway -North Low Satisfactory Low Satisfactory High Satisfactory Satisfactory
Myrtle NC -SC Multi -State MSA
Augusta -Richmond County GA- High Satisfactory Needs to Improve Low Satisfactory Satisfactory
SC Multi -State MSA
Kansas City KS -MO Multi -State High Satisfactory Outstanding Low Satisfactory Satisfactory
MSA
308
APPENDIX C
GLOSSARY
Aggregate Lending: The number of loans originated and purchased by all reporting lenders in
specified income categories as a percentage of the aggregate number of loans originated and
purchased by all reporting lenders in the metropolitan area/assessment area.
Area Median Income: The median family income for the MSA, if a person or geography is
located in an MSA; or the statewide nonmetropolitan median family income, if a person or
geography is located outside an MSA.
Assessment Area: A geographic area delineated by the bank under the requirements of the
Community Reinvestment Act.
Census Tract: A small, relatively permanent statistical subdivision of a county. Census tract
boundaries normally follow visible features, but they may follow governmental unit boundaries
and other non -visible features in some instances. They always nest within counties. Census
tracts average about 4,000 persons, and their physical size varies widely depending upon
population density. Census tracts are designed to be homogenous for population characteristics,
economic status, and living conditions to allow for statistical comparisons.
Combined Statistical Area (CSA): A combination of several adjacent metropolitan statistical

areas or micropolitan statistical areas or a mix of the two, which are linked by economic ties.
Community Development: For loans, investments, and services to qualify as community

development activities, their primary purpose must:
(1) Support affordable housing for low- and moderate -income individuals;
(2) Target community services toward low- and moderate -income individuals;
(3) Promote economic development by financing small businesses or farms;
(4) Provide activities that revitalize or stabilize low- and moderate -income geographies,
designated disaster areas, or distressed or underserved nonmetropolitan middle -income
geographies; or
(5) Enable or facilitate projects or activities that address needs regarding foreclosed or
abandoned residential properties in designated target areas.
Community Development Corporation (CDC): A CDC allows banks and holding companies
to make equity type of investments in community development projects. Bank CDCs can
develop innovative debt instruments or provide near -equity investments tailored to the
development needs of the community. Bank CDCs are also tailored to their financial and
marketing needs. A CDC may purchase, own, rehabilitate, construct, manage, and sell real
property. Also, it may make equity or debt investments in development projects and in local
businesses. The CDC activities are expected to directly benefit low- and moderate -income
groups, and the investment dollars should not represent an undue risk on the banking
organization.
309
Community Development Financial Institutions (CDFIs): CDFIs are private intermediaries
(either for profit or nonprofit) with community development as their primary mission. A CDFI
facilitates the flow of lending and investment capital into distressed communities and to
individuals who have been unable to take advantage of the services offered by traditional
financial institutions. Some basic types of CDFIs include community development banks,
community development loan funds, community development credit unions, micro enterprise
funds, and community development venture capital funds.
A certified CDFI must meet eligibility requirements. These requirements include the following:
Having a primary mission of promoting community development;
Serving an investment area or target population;
Providing development services;
Maintaining accountability to residents of its investment area or targeted population through
representation on its governing board of directors, or by other means;
Not constituting an agency or instrumentality of the United States, of any state or political
subdivision of a state.
Community Development Loan: A loan that

(1) Has as its primary purpose community development; and
(2) Except in the case of a wholesale or limited purpose bank:
(i) Has not been reported or collected by the bank or an affiliate for consideration in the bank's
assessment area as a home mortgage, small business, small farm, or consumer loan, unless it is a
multifamily dwelling loan (as described in Appendix A to Part 203 of this title); and
(ii) Benefits the bank's assessment area(s) or a broader statewide or regional area including the
bank's assessment area(s).
Community Development Service: A service that

(1) Has as its primary purpose community development;
(2) Is related to the provision of financial services; and
(3) Has not been considered in the evaluation of the bank's retail banking services under §
345.24(d).
Consumer Loan(s): A loan(s) to one or more individuals for household, family, or other
personal expenditures. A consumer loan does not include a home mortgage, small business, or
small farm loan. This definition includes the following categories: motor vehicle loans, credit
card loans, home equity loans, other secured consumer loans, and other unsecured consumer
loans.
Core Based Statistical Area (CBSA): The county or counties or equivalent entities associated
with at least one core (urbanized area or urban cluster) of at least 10,000 population, plus
adjacent counties having a high degree of social and economic integration with the core as
measured through commuting ties with the counties associated with the core. Metropolitan and
Micropolitan Statistical Areas are the two categories of CBSAs.
310
Distressed Middle -Income Nonmetropolitan Geographies: A nonmetropolitan middle -
income geography will be designated as distressed if it is in a county that meets one or more of
the following triggers:
An unemployment rate of at least 1.5 times the national average;
A poverty rate of 20 percent or more; or
A population loss of 10 percent or more between the previous and most recent decennial census
or a net migration loss of 5 percent or more over the 5 -year period preceding the most recent
census.
Family: Includes a householder and one or more other persons living in the same household
who are related to the householder by birth, marriage, or adoption. The number of family
households always equals the number of families; however, a family household may also include
non -relatives living with the family. Families are classified by type as either a married -couple
family or other family. Other family is further classified into "male householder" (a family with
a male householder and no wife present) or "female householder" (a family with a female
householder and no husband present).
Family Income: Includes the income of all members of a family that are age 15 and older.
FFIEC-Estimated Income Data: The Federal Financial Institutions Examination Council

(FFIEC) issues annual estimates which update median family income from the metropolitan and
nonmetropolitan areas. The FFIEC uses American Community Survey data and factors in
information from other sources to arrive at an annual estimate that more closely reflects current
economic conditions.
Full -Scope Review: A full -scope review is accomplished when examiners complete all
applicable interagency examination procedures for an assessment area. Performance under
applicable tests is analyzed considering performance context, quantitative factors (for example,
geographic distribution, borrower profile, and total number and dollar amount of investments),
and qualitative factors (for example, innovativeness, complexity, and responsiveness).
Geography: A census tract delineated by the United States Bureau of the Census in the most
recent decennial census.
Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders
that do business or have banking offices in a metropolitan statistical area to file annual summary
reports of their mortgage lending activity. The reports include such data as the race, gender, and
the income of applicants; the amount of loan requested; and the disposition of the application
(approved, denied, and withdrawn).
Home Mortgage Disclosure Loan Application Register (HMDA LAR): The HMDA LARs
record all applications received for residential purchase, refinance, home improvement, and
temporary -to -permanent construction loans.
311
Home Mortgage Loans: Includes home purchase and home improvement loans as defined in
the HMDA regulation. This definition also includes multi -family (five or more families)
dwelling loans, loans to purchase manufactured homes, and refinancings of home improvement
and home purchase loans.
Household: Includes all persons occupying a housing unit. Persons not living in households are
classified as living in group quarters. In 100 percent tabulations, the count of households always
equals the count of occupied housing units.
Household Income: Includes the income of the householder and all other persons that are age
15 and older in the household, whether related to the householder or not. Because many
households are only one person, median household income is usually less than median family
income.
Housing Unit: Includes a house, an apartment, a mobile home, a group of rooms, or a single
room that is occupied as separate living quarters.
Limited -Scope Review: A limited -scope review is accomplished when examiners do not
complete all applicable interagency examination procedures for an assessment area.
Performance under applicable tests is often analyzed using only quantitative factors (for
example, geographic distribution, borrower profile, total number and dollar amount of
investments, and branch distribution).
Low -Income: Individual income that is less than 50 percent of the area median income, or a
median family income that is less than 50 percent in the case of a geography.
Low Income Housing Tax Credit: The Low -Income Housing Tax Credit Program is a housing
program contained within the Internal Revenue Code of 1986, as amended. It is administered by
the U.S. Department of the Treasury and the Internal Revenue Service. The U.S. Treasury
Department distributes low-income housing tax credits to housing credit agencies through the
Internal Revenue Service. The housing agencies allocate tax credits on a competitive basis.
Developers who acquire, rehabilitate, or construct low-income rental housing may keep their tax
credits. Or, they may sell them to corporations or investor groups, who, as owners of these
properties, will be able to reduce their own federal tax payments. The credit can be claimed
annually for ten consecutive years. For a project to be eligible, the developer must set aside a
specific percentage of units for occupancy by low-income residents. The set -aside requirement
remains throughout the compliance period, usually 30 years.
Market Share: The number of loans originated and purchased by the institution as a percentage
of the aggregate number of loans originated and purchased by all reporting lenders in the
metropolitan area/assessment area.
Median Income: The median income divides the income distribution into two equal parts, one
having incomes above the median and other having incomes below the median.
312
Metropolitan Division (MD): A county or group of counties within a CBSA that contain(s) an
urbanized area with a population of at least 2.5 million. A MD is one or more main/secondary
counties representing an employment center or centers, plus adjacent counties associated with
the main/secondary county or counties through commuting ties.
Metropolitan Statistical Area (MSA): CBSA associated with at least one urbanized area
having a population of at least 50,000. The MSA comprises the central county or counties or
equivalent entities containing the core, plus adjacent outlying counties having a high degree of
social and economic integration with the central county or counties as measured through
commuting.
Micropolitan Statistical Area: CBSA associated with at least one urbanized area having a
population of at least 10,000, but less than 50,000.
Middle -Income: Individual income that is at least 80 percent and less than 120 percent of the
area median income, or a median family income that is at least 80 and less than 120 percent in
the case of a geography.
Moderate -Income: Individual income that is at least 50 percent and less than 80 percent of the
area median income, or a median family income that is at least 50 and less than 80 percent in the
case of a geography.
Multi -family: Refers to a residential structure that contains five or more units.
Nonmetropolitan Area: All areas outside of metropolitan areas. The definition of

nonmetropolitan area is not consistent with the definition of rural areas. Urban and rural
classifications cut across the other hierarchies. For example, there is generally urban and rural
territory within metropolitan and nonmetropolitan areas.
Owner -Occupied Units: Includes units occupied by the owner or co-owner, even if the unit has
not been fully paid for or is mortgaged.
Qualified Investment: A lawful investment, deposit, membership share, or grant that has as its
primary purpose community development.
Rated Area: A rated area is a state or multistate metropolitan area. For an institution with
domestic branches in only one state, the institution's CRA rating would be the state rating. If an
institution maintains domestic branches in more than one state, the institution will receive a
rating for each state in which those branches are located. If an institution maintains domestic
branches in two or more states within a multistate metropolitan area, the institution will receive a
rating for the multistate metropolitan area.
Rural Area: Territories, populations, and housing units that are not classified as urban.
313
cities"; census designated place of 2,500 or more persons; and other territory, incorporated or
unincorporated, including in urbanized areas.
Small Business Investment Company (SBIC): SBICs are privately -owned investment
companies which are licensed and regulated by the Small Business Administration
(SBA). SBICs provide long-term loans and/or venture capital to small firms. Because money
for venture or risk investments is difficult for small firms to obtain, SBA provides assistance to
SBICs to stimulate and supplement the flow of private equity and long-term loan funds to small
companies. Venture capitalists participate in the SBIC program to supplement their own private
capital with funds borrowed at favorable rates through SBA's guarantee of SBIC debentures.
These SBIC debentures are then sold to private investors. An SBIC's success is linked to the
growth and profitability of the companies that it finances. Therefore, some SBICs primarily
assist businesses with significant growth potential, such as new firms in innovative
industries. SBICs finance small firms by providing straight loans and/or equity -type
investments. This kind of financing gives them partial ownership of those businesses and the
possibility of sharing in the companies' profits as they grow and prosper.
Small Business Loan: A loan included in "loans to small businesses" as defined in the
Consolidated Report of Condition and Income (Call Report). These loans have original amounts
of $1 million or less and are either secured by nonfarm nonresidential properties or are classified
as commercial and industrial loans.
Small Farm Loan: A loan included in "loans to small farms" as defined in the instructions for
preparation of the Consolidated Report of Condition and Income (Call Report). These loans
have original amounts of $500,000 or less and are either secured by farmland, including farm
residential and other improvements, or are classified as loans to finance agricultural production
and other loans to farmers.
Underserved Middle -Income Nonmetropolitan Geographies: A nonmetropolitan middle -

income geography will be designated as underserved if it meets criteria for population size,
density, and dispersion indicating the area's population is sufficiently small, thin, and distant
from a population center that the tract is likely to have difficulty financing the fixed costs of
meeting essential community needs.
Upper -Income: Individual income that is 120 percent or more of the area median income, or a
median family income that is 120 percent or more in the case of a geography.
Urban Area: All territories, populations, and housing units in urbanized areas and in places of
2,500 or more persons outside urbanized areas. More specifically, "urban" consists of territory,
persons, and housing units in places of 2,500 or more persons incorporated as cities, villages,
boroughs (except in Alaska and New York), and towns (except in the New England states, New
York, and Wisconsin).
"Urban" excludes the rural portions of "extended cities"; census designated place of 2,500 or
more persons; and other territory, incorporated or unincorporated, including in urbanized areas.
314
APPENDIX D
Institution ID: First -Citizens Bank & Trust Company
Table 1. Lending Volume
LENDING VOLUME Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
% of Rated Community Development % of Rated Area

Area Loans Home Mortgage Small Loans to Businesses Small Loans to Farms Loans*" Total Reported Loans Deposits in
(#) in MA/AA'"
Assessment Area (2017): MA/AA' # $ (000's) # $ (000's) # $ (000's) # $ (000's) # $(000's)
Full Review:
Asheville MSA 10.94 295 85,248 816 75,512 13 369 11 102,805 1,124 161,129 11.5
NC Non-MSA 27.61 684 147,751 1,855 134,447 298 31,479 35 114,588 2,837 313,677 25.7
Raleigh MSA 17.85 546 158,996 1,212 120,328 76 10,257 20 35,216 1,834 289,581 22.9
Limited Review:
Durham MSA 4.86 257 88,516 239 20,289 3 138 3 18,191 499 108,943 4.2
Fayetteville MSA 4.46 96 13,461 346 35,199 16 1,007 5 810 458 49,667 4.4
Goldsboro MSA 1.43 36 4,428 93 8,507 18 2,053 7 8,505 147 14,988 1.2
Greensboro MSA 6.16 238 48,081 393 43,994 2 12 1 50 633 92,087 5.6
Greenville MSA 3.15 76 12,742 234 31,311 14 1,725 4 5,286 324 45,778 2.2
Hickory MSA 5.86 180 28,931 419 40,116 3 311 4 5,620 602 69,358 5.2
Jacksonville MSA 2.43 33 5,689 211 23,759 6 240 1 100 250 29,688 3.4
New Bern MSA 2.95 142 32,431 146 16,392 15 1,510 0 0 303 50,333 2.9
Rocky Mount MSA 0.54 4 889 41 2,306 10 1,854 0 0 55 5,049 0.6
Virginia Beach MSA 0.16 1 57 8 213 7 1,101 0 0 16 1,371 0.2
Wilmington MSA 6.71 174 52,609 510 51,895 6 1,234 7 2,426 690 105,738 5.9
Winston-Salem MSA 4,90 142 28,122 348 25,766 14 807 2 320 504 54,695 4.1
Loan Data as of December 31, 2017. Rated area refers to either state or multi -state MA rating area.
" The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
*** Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
315
Table 2a. Geo ra hic Distribution of Home Purchase Loans
Geographic Distribution: HOME PURCHASE Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Purchase Low -Income Moderate -Income Middle -Income Upper -Income Aggregate HMDA Lending (%) by Tract
Loans Geographies Geographies Geographies Geographies Income*
Assessment Area: # % of % Owner % BANK % Owner % BANK % Owner % BANK % Owner % BANK
Total** Occ Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*** Units*** Units***
Full Review:
Asheville MSA 161 8.94 1.31 0.62 12.09 8.07 64.22 60.25 22.38 31.06 1.31 10.81 63.65 24.24
NC Non-MSA 402 22.33 0.34 0.00 14.17 6.47 62.82 52.99 22.68 40.55 0.16 7.79 54.21 37.84
Raleigh MSA 348 19.33 2.99 2.01 26.60 24.43 35.18 31.03 35.23 42.53 2.17 22.93 40.02 34.88
Limited Review:
Durham MSA 197 10.94 3.16 5.58 13.08 10.66 41.14 31.98 42.62 51.78 3.79 12.03 37.47 46.71
Fayetteville MSA 42 2.33 0.42 0.00 10.06 11.90 64.89 57.14 24.63 30.95 0.02 7.47 63.03 29.48
Goldsboro MSA 14 0.78 0.00 0.00 26.71 28.57 56.00 42.86 17.30 28.57 0.00 22.98 54.46 22.56
Greensboro MSA 146 8.11 2.69 2.74 17.18 13.70 45.84 45.21 34.28 38.36 1.44 13.68 42.66 42.22
Greenville MSA 53 2.94 4.47 11.32 19.48 7.55 40.33 33.96 35.72 47.17 7.21 9.89 45.92 36.98
Hickory MSA 92 5.11 0.00 0.00 10.51 10.87 67.50 55.43 21.99 33.70 0.00 8.73 60.51 30.76
Jacksonville MSA 19 1.06 0.00 0.00 3.84 0.00 76.30 57.89 19.85 42.11 0.00 2.50 79.67 17.83
New Bern MSA 112 6.22 2.09 3.57 13.31 5.36 53.66 40.18 30.93 50.89 2.75 5.63 49.24 42.37
Rocky Mount MSA 2 0.11 0.00 0.00 2.73 0.00 61.26 0.00 36.01 100.00 0.00 0.99 59.34 39.68
Virginia Beach MSA 0 0.00 0.00 0.00 37.99 0.00 62.01 0.00 0.00 0.00 0.00 30.66 69.34 0.00
Wilmington MSA 101 5.61 4.86 11.88 14.42 10.89 44.38 24.75 36.34 52.48 4.47 8.52 50.35 36.66
Winston-Salem MSA 111 6.17 3.76 0.90 18.70 17.12 37.33 38.74 40.21 43.24 1.92 13.63 33.98 50.47
" Based on 2017 Peer Mortgage Data -- US and PR

**Home purchase loans originated and purchased in the MAJAA as a percentage of all home purchase loans originated and purchased in the rated area.
Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing unitsin the area based
on 2015 ACS Census information.
**" Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
316
Table 3a. Geographic Distribution of Home Improvement Loans
Geographic Distribution: HOME IMPROVEMENT Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate HMDA Lending (%) by Tract Income*
Improvement Loans Geographies Geographies Geographies Geographies
Total" Occ Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*" Units*** Units*** Units***
Full Review:
Asheville MSA 22 13.02 1.31 0.00 12.09 9.09 64.22 50.00 22.38 40.91 2.27 12.46 64.31 20.96
NC Non-MSA 34 20.12 0.34 0.00 14.17 11.76 62.82 47.06 22.68 41.18 0.47 11.89 59.40 28.24
Raleigh MSA 36 21.30 2.99 5.56 26.60 22.22 35.18 16.67 35.23 55.56 2.24 22.64 36.65 38.47
Limited Review:
Durham MSA 18 10.65 3.16 5.56 13.08 11.11 41.14 27.78 42.62 55.56 4.54 14.47 39.29 41.70
Fayetteville MSA 11 6.51 0.42 0.00 10.06 27,27 64.89 54.55 24.63 18.18 0.51 7.87 65.74 25.89
Goldsboro MSA 1 0.59 0.00 0.00 26.71 0.00 56.00 0.00 17.30 100.00 0.00 30.00 48.00 22.00
Greensboro MSA 11 6.51 2.69 0.00 17.18 0.00 45.84 18.18 34.28 81.82 2.21 14.87 41.68 41.24
Greenville MSA 6 3.55 4.47 0.00 19.48 16.67 40.33 50.00 35.72 33.33 7.20 16.80 32.80 43.20
Hickory MSA 14 8.28 0.00 0.00 10.51 14.29 67.50 50.00 21.99 35.71 0,00 10.00 63.71 26.29
New Bern MSA 1 0.59 2.09 0.00 13.31 0.00 53.66 0.00 30.93 100.00 0.00 9.64 49.24 41.12
Rocky Mount MSA 0 0.00 0.00 0.00 2.73 0.00 61.26 0.00 36.01 0.00 0,00 0.00 63.55 36.45
Wilmington MSA 10 5.92 4.86 10.00 14.42 20.00 44.38 20.00 36.34 50.00 6.28 11.16 40.47 42.09
* Based on 2017 Peer Mortgage Data -- US and PR

- Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
- Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
- Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
317
Table 4a. Geographic Distribution of Home Mortgage Refinance Loans
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Geographies Moderate -Income Middle -Income Upper -Income Aggregate HMDA Lending (%) by Tract
Mortgage Geographies Geographies Geographies Income*
Assessment Area: Refinance Loans
% of Owner % BANK % Owner % BANK % Owner BANK % Owner % BANK
Total** Occ Units*** Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*** Units***
Full Review:
Asheville MSA 110 11.87 1.31 2.73 12.09 10.00 64.22 58.18 22.38 29.09 1.51 10.69 63.59 24.21
NC Non-MSA 247 26.65 0.34 0.00 14.17 8.91 62.82 57.49 22.68 33.60 0.21 9.40 57.16 33.23
Raleigh MSA 162 17.48 2.99 3.09 26.60 26.54 35.18 29.63 35.23 40.74 2.28 23.84 37.52 36.37
Limited Review:
Durham MSA 42 4.53 3.16 0.00 13.08 14.29 41.14 23.81 42.62 61.90 2.80 12.96 42.43 41.81
Goldsboro MSA 21 2.27 0.00 0.00 26.71 23.81 56.00 47.62 17.30 28.57 0.00 20.36 54.34 25.30
Greensboro MSA 81 8.74 2.69 2.47 17.18 14.81 45.84 35.80 34.28 46.91 1.35 13.10 44.65 40.90
Greenville MSA 15 1.62 4.47 0.00 19.48 0.00 40.33 60.00 35.72 40.00 5.95 10.79 39.32 43.94
Hickory MSA 72 7.77 0.00 0.00 10.51 6.94 67.50 59.72 21.99 33.33 0.00 9.84 61.90 28.26
New Bern MSA 28 3.02 2.09 7.14 13.31 10.71 53.66 32.14 30.93 50.00 1.27 9.26 47.69 41.78
Rocky Mount MSA 2 0.22 0.00 0.00 2.73 0.00 61.26 100.00 36.01 0.00 0.00 1.14 59.48 39.38
Wilmington MSA 63 6.80 4.86 0.00 14.42 11.11 44.38 28.57 36.34 60.32 4.84 9.58 45.83 39.76

- Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
**** Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
318
Table 6a. Geo ra hic Distribution of Small Loans to Businesses
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Business Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending (%) by Tract Income*
Loans Geographies Geographies Geographies Geographies
Assessment Area: # % of % of % % of % BANK % of % BANK % of % BANK
Total** Businesses BANK Businesses*"" Loans Businesses Loans Businesses*" Loans Low Mod Mid Upp
...
Loans
...
Full Review:
Asheville MSA 816 11.89 2.86 3.68 15.79 16.79 54.11 49.26 27.24 30.27 2.90 16.30 52.91 27.89
NC Non-MSA 1,855 27.02 0.98 0.38 16.39 13.53 58,55 62.48 24.07 23.61 0.57 14.70 57.82 26.91
Raleigh MSA 1,211 17.64 4.37 3.96 23.65 26.09 32.83 31.96 38.94 37.99 4.31 22.01 33.53 40.15
Limited Review:
Durham MSA 239 3,48 6.64 5.44 15.43 9.62 34.96 39.33 41.31 45.61 5.58 14.10 35.51 44.81
Fayetteville MSA 346 5,04 1.84 2.31 19.40 16.76 58.35 56.65 20,12 24.28 2.11 17.25 56.07 24.58
Goldsboro MSA 93 1.35 0.00 0.00 36.95 31.18 51.85 59.14 11.20 9.68 0.00 33.83 52.58 13.59
Greensboro MSA 393 5.72 4.22 2.80 21.81 22.14 36.53 33.33 37.29 41.73 3.96 21,68 36.23 38.13
Greenville MSA 234 3,41 17.17 25.21 16.97 14.53 36.73 33.76 29.13 26.50 13.92 15.11 39.04 31.94
Hickory MSA 419 6.10 0.00 0.00 15.05 18.85 59.70 55.37 25.25 25.78 0.00 16.42 55.44 28.13
New Bern MSA 146 2.13 8.66 11.64 10.51 10.96 53.72 45.21 27.11 32.19 6.96 11.16 52.94 28.93
Rocky Mount MSA 41 0.60 0.00 0.00 4.03 2.44 70,66 73.17 25.31 24.39 0.00 4.51 66.18 29.30
Wilmington MSA 510 7.43 13.52 14.12 12.13 15.10 33.65 29.41 40.43 41.37 11.09 10.47 37.74 40.70
* Based on 2017 Peer Small Business Data -- US and PR

**Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
- Source Data - Dun and Bradstreet (2017).
319
Table 7a. Geographic Distribution of Small Loans to Farms
Geographic Distribution: SMALL LOANS TO FARMS Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income*
Geog aphies Geographies Geographies Geographies
Assessment Area: # % of % of % BANK % of % BANK % of % BANK % of % BANK
Total** Farms*** Loans Farms** Loans Farms*" Loans Farms" Loans Low Mod Mid Upp
Full Review:
Asheville MSA 13 2.59 1.38 0.00 15.62 30.77 64.93 46.15 18.06 23.08 1.05 23.16 57.89 17.89
NC Non-MSA 298 59.48 0.15 0.00 15.03 20.13 65.97 69.80 18.83 10.07 0.00 18.51 69.04 12.45
Raleigh MSA 76 15.17 4.86 7.89 28.23 73.68 39.40 14.47 27.48 3.95 8.70 58.33 19.93 13.04
Limited Review:
Durham MSA 3 0.60 2.72 0.00 11.46 0.00 55.02 66.67 30.61 33.33 3.60 10.81 65.77 19.82
Goldsboro MSA 18 3.59 0.00 0.00 18.38 0.00 66.22 94.44 15.41 5.56 0.00 11.02 75.42 13.56
Greensboro MSA 2 0.40 1.67 0.00 13.54 50.00 53.16 0.00 31.56 50.00 0.64 14.01 70.06 15.29
Greenville MSA 14 2.79 4.42 0.00 17.40 57.14 46.41 14.29 31.77 28.57 0.00 24.24 34.85 40.91
Hickory MSA 3 0.60 0.00 0.00 9.85 0.00 68.81 33.33 21.34 66.67 0.00 3.03 83.33 13.64
New Bern MSA 15 2.99 1.39 0.00 19.94 6.67 57.06 93.33 21.61 0.00 0.00 22.73 73.86 3.41
Rocky Mount MSA 10 2.00 0.00 0.00 0.65 0.00 68.61 90.00 30.74 10.00 0.00 0.00 80.00 20.00
Wilmington MSA 6 1.20 7.18 16.67 25.92 16.67 37.48 50.00 29.25 16.67 7.50 47.50 17.50 27.50
Winston-Salem MSA 14 2.79 1.63 0.00 22.14 7.14 42,66 85.71 33.33 7.14 1.02 37.76 51.02 10.20
Based on 2017 Peer Small Business Data -- US and PR

- Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the rated area.
320
Table 8a. Borrower Distribution of Home Purchase Loans
Borrower Distribution: HOME PURCHASE Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Purchase Low -Income Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data'
Loans Borrowers Borrowers
Assessment Area: # % of % % BANK % Families' % BANK % % BANK % % BANK
Total- Families' Loans- Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Asheville MSA 161 8.94 20.24 3.21 18.57 9.62 20.51 14.10 40.69 73.08 4.77 18.04 24.83 52.36
NC Non-MSA 402 22.33 20.84 3.71 17.66 9.81 19.41 19.36 42.10 67.11 2.55 12.76 23.58 61.11
Raleigh MSA 348 19.33 22.27 11.78 17.36 17.83 19.16 15.29 41.21 55.10 7.75 20.75 25.35 46.15
Limited Review:
Durham MSA 197 10.94 22.51 6.22 16.20 15.03 17.59 15.54 43.69 63.21 4.22 17.77 23.62 54.39
Goldsboro MSA 14 0.78 22.81 9.09 17.87 36.36 19.42 9.09 39.90 45.45 2.23 10.08 30.25 57.44
Greensboro MSA 146 8.11 21.68 11.94 18.26 18.66 18.40 20.90 41.66 48.51 6.17 22.03 25.82 45.99
Greenville MSA 53 2.94 24.21 2.08 16.22 22.92 17.46 33.33 42.11 41.67 2.55 16.53 24.86 56.06
Hickory MSA 92 5.11 20.78 5.00 17.80 21.25 21.09 18.75 40.33 55.00 4.94 23.49 25.91 45,66
New Bern MSA 112 6.22 20.14 0.93 19.24 13.08 19.34 15.89 41.27 70.09 3.16 13.46 26.54 56.84
Rocky Mount MSA 2 0.11 18.91 0.00 15.39 0.00 20.53 0.00 45.17 100.00 3.70 16.40 27.72 52.17
Wilmington MSA 101 5.61 22.72 8.89 17.60 12.22 18.43 8.89 41.25 70.00 4.27 18.00 23.23 54.50
Winston-Salem MSA 111 6.17 23.16 15.89 16.59 26.17 18.30 16.82 41.95 41.12 5.53 21.26 26,97 46.24
Based on 2017 Peer Mortgage Data -- US and PR

- Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
- Percentage of Families is based on the 2015 ACS Census information.
*- As a percentage of loans with borrower income information available. No information was available for 7.1% of loans originated and purchased by BANK.
*, Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
321
Table 9a. Borrower Distribution of Home Improvement Loans
Borrower Distribution: HOME IMPROVEMENT Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Improvement Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Loans Borrowers
Assessment Area: # % of % % BANK % % BANK % % BANK % % BANK
Total- Families*** Loans"- Families2 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Asheville MSA 22 13.02 20.24 5.00 18.57 15.00 20.51 10.00 40.69 70.00 8.90 19.29 25.82 45.99
NC Non-MSA 34 20.12 20.84 3.70 17.66 14.81 19.41 18.52 42.10 62.96 6.28 13.73 21.80 58.19
Raleigh MSA 36 21.30 22.27 3.03 17.36 9.09 19.16 18.18 41.21 69.70 7.49 19.50 22.63 50.39
Limited Review:
Durham MSA 18 10.65 22.51 0.00 16.20 17.65 17.59 11.76 43.69 70.59 9.96 18.59 20.50 50.95
Goldsboro MSA 1 0.59 22.81 0.00 17.87 100.00 19.42 0.00 39.90 0.00 2.13 7.45 28.72 61.70
Greensboro MSA 11 6.51 21.68 0.00 18.26 0.00 18.40 20.00 41.66 80.00 8.19 17.17 23.78 50.87
Greenville MSA 6 3.55 24.21 0.00 16.22 0.00 17.46 0.00 42.11 100.00 8.93 11.61 25.00 54.46
Hickory MSA 14 8.28 20.78 0.00 17.80 0.00 21.09 45.45 40.33 54.55 9.20 17.51 22.85 50.45
Jacksonville MSA 2 1.18 18.25 0.00 18.56 0.00 23.89 0.00 39.31 100.00 5.03 13.82 21,61 59.55
New Bern MSA 1 0.59 20.14 0.00 19.24 0.00 19.34 100.00 41.27 0.00 3.59 7.69 22.05 66.67
Rocky Mount MSA 0 0.00 18.91 0.00 15.39 0.00 20.53 0.00 45.17 0.00 5.66 14.15 24.53 55.66
Wilmington MSA 10 5.92 22.72 0.00 17.60 0.00 18.43 55.56 41.25 44.44 4.36 17.19 23.49 54.96

"Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
*** Percentage of Families is based on the 2015 ACS Census information.
- As a percentage of loans with borrower income information available. No information was available for 17.2% of loans originated and purchased by BANK.
2 Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
322
Table 10a. Borrower Distribution of Home Mortgage Refinance Loans
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Mortgage Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Refinance Loans Borrowers
Total** Families*** Loans**** Families3 Loans**** Families"** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Asheville MSA 110 11.87 20.24 7.41 18.57 11.11 20.51 26.85 40.69 54.63 8.10 20.52 26.24 45.14
NC Non-MSA 247 26.65 20.84 1.76 17.66 11.01 19.41 21.15 42,10 66.08 5.29 12.27 22.56 59.89
Raleigh MSA 162 17.48 22.27 13.01 17.36 13,01 19.16 19.86 41.21 54.11 9.34 20.14 25.07 45.44
Limited Review:
Durham MSA 42 4.53 22.51 2.44 16.20 9.76 17.59 19.51 43.69 68.29 7.66 17.67 24.04 50.64
Fayetteville MSA 43 4.64 21.35 2.50 17.52 15.00 19.86 12.50 41,27 70.00 5.85 12.96 21.76 59.44
Goldsboro MSA 21 2.27 22.81 4.76 17.87 19.05 19.42 23.81 39.90 52.38 3.91 8.74 20.69 66.67
Greensboro MSA 81 8.74 21.68 8.86 18.26 13.92 18.40 17.72 41.66 59.49 7.11 16.31 23.97 52.60
Greenville MSA 15 1.62 24.21 14.29 16.22 14.29 17.46 14,29 42.11 57.14 5.19 12.82 21.04 60.95
Hickory MSA 72 7.77 20.78 9.68 17.80 20.97 21.09 12.90 40.33 56.45 6.70 19.23 24.60 49.46
New Bern MSA 28 3.02 20.14 3.85 19.24 19.23 19.34 15.38 41.27 61.54 3.92 15.02 25.60 55.46
Rocky Mount MSA 2 0.22 18.91 0.00 15.39 50.00 20.53 0.00 45.17 50.00 6,21 11.56 22.91 59.31
Virginia Beach MSA 1 0.11 27,86 100.00 23.36 0.00 20.83 0.00 27.95 0.00 18.06 34.72 25.00 22.22
Wilmington MSA 63 6.80 22.72 6.78 17.60 11.86 18.43 18.64 41.25 62.71 7.34 17.46 23.91 51.29
Winston-Salem MSA 28 3.02 23.16 4.00 16.59 4.00 18.30 28.00 41,95 64.00 7.82 17.57 25.94 48.67

Home refinance loans originated and purchased in the MPJAA as a percentage of all home refinance loans originated and purchased in the rated area.
-- As a percentage of loans with borrower income information available. No information was available for 7.0% of loans originated and purchased by BANK.
323
Table 11a. Borrower Distribution of Small Loans to Businesses
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Loans to Businesses With Revenues of $1 million Loans by Original Amount Regardless of Business Size Aggregate Lending Data'
Businesses or less
Assessment Area: # % of Total" % of Businesses % BANK Loans"- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Asheville MSA 816 11.88 86.78 68.75 81.99 7.35 10.66 9,813 5,304
NC Non-MSA 1,855 27,00 82.81 73.48 84.64 8.63 6.74 22,626 11,527
Raleigh MSA 1,212 17.64 85.96 68.81 78.71 9.49 11.80 28,583 15,389
Limited Review:
Durham MSA 239 3.48 84.90 74.48 85.77 5.02 9.21 10,089 5,674
Fayetteville MSA 346 5.04 83.91 73.41 80.64 7.80 11.56 3,846 2,022
Goldsboro MSA 93 1.35 80.25 64.52 78.49 10.75 10.75 1,372 634
Greensboro MSA 393 5.72 84.04 68.45 77.35 9.92 12.72 12,850 6,797
Greenville MSA 234 3.41 80.94 60.68 71.79 11.97 16.24 2,548 1,140
Hickory MSA 419 6.10 80.47 68.02 78.76 10.74 10.50 5,198 2,630
Jacksonville MSA 211 3.07 84.02 72.51 76.78 9.95 13.27 1,902 946
New Bern MSA 146 2.12 81.48 65,75 72.60 14.38 13.01 1,719 911
Rocky Mount MSA 41 0.60 79.61 75.61 90.24 2.44 7.32 1,210 527
Virginia Beach MSA 8 0.12 79.23 87.50 100.00 0.00 0.00 89 43
Wilmington MSA 510 7.42 84.05 61.76 79.61 9.02 11.37 6,968 3,481
Winston-Salem MSA 348 5.06 82.60 69.83 83.33 9.20 7.47 7,211 3,845

Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
- Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
-- Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 2.52% of
small loans to businesses originated and purchased by the bank.
324
Table 12a. Borrower Distribution of Small Loans to Farms
Borrower Distribution: SMALL LOANS TO FARMS Geography: NORTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Loans to Farms Farms With Revenues of $1 million or Loans by Original Amount Regardless of Farm Size Aggregate Lending Data*
less
Assessment Area: # % of Total** % of Farms*" % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Asheville MSA 13 2.59 96.83 100.00 . 92.31 7.69 0.00 97 51
NC Non-MSA 298 59.48 96.50 78.86 75.50 11.41 13.09 1,522 760
Raleigh MSA 76 15.17 94.43 68.42 59.21 21.05 19.74 279 155
Limited Review:
Durham MSA 3 0.60 96.24 100.00 100.00 0.00 0.00 111 40
Fayetteville MSA 16 3.19 96,13 68.75 75.00 18.75 6.25 38 21
Goldsboro MSA 18 3.59 94.32 77.78 61.11 27.78 11.11 118 51
Greensboro MSA 2 0.40 96.90 50.00 100.00 0.00 0.00 159 68
Greenville MSA 14 2.79 95.30 42.86 64.29 21.43 14.29 68 34
Hickory MSA 3 0.60 96.57 66.67 66.67 0.00 33.33 66 47
Jacksonville MSA 6 1.20 95.55 100.00 100.00 0.00 0.00 34 16
New Bern MSA 15 2.99 96.40 73.33 66.67 33.33 0.00 90 43
Rocky Mount MSA 10 2.00 91.91 50.00 50.00 30.00 20.00 70 36
Virginia Beach MSA 7 1.40 93.44 100.00 71.43 0.00 28.57 43 21
Wilmington MSA 6 1.20 94.22 66.67 33.33 33.33 33.33 40 21
Winston-Salem MSA 14 2.79 96.74 100.00 92.86 7.14 0.00 100 61

**Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the rated area.
***Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
-*Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 1.40% of small loans to
farms originated and purchased by the bank.
325
Table 15. Distribution of Branch Delivery System and Branch Openings/Closings
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: NORTH CAROLINA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019
Deposits Branches Branch Openings/Closings Population

% of # of % of Location of Branches by Net change in Location of Branches % of Population within Each Geography
Assessment Area: Rated BANK Rated Income of Geographies %) # of # of (+ or - )
Area Branches Area Branch Branch
Deposits Branches Low Mod Mid Upp Openings Closings Low Mod Mid Upp Low Mod Mid Upp
in AA in AA
Full Review:
Asheville MSA 11.5 21 10.71 0.00 14.29 61.90 23.81 0 1 0 0 -1 0 1.57 14.02 63.91 20.50
NC Non-MSA 25.7 57 29.08 1.76 19.30 61.40 17.54 0 3 0 0 -2 -1 1.04 16.54 61.48 20.94
Raleigh MSA 22.9 33 16.84 9.10 30.30 30.30 30.30 0 1 0 0 0 -1 6,46 29.57 32.48 31.12
Limited Review:
Durham MSA" 4.2 8 4.08 12.5 0.00 25.00 37.50 0 0 0 0 0 0 9.38 19.29 35.68 34.26
Fayetteville MSA* 4.4 9 4.59 0.00 11.11 66.67 11.11 0 1 0 0 -1 0 0.65 16.89 62.90 18.41
Goldsboro MSA 1.2 3 1.53 0.00 33.33 66.67 0.00 0 0 0 0 0 0 0.00 31.59 55.99 12.42
Greensboro MSA 5.6 14 7.14 0.00 42.86 28.57 28.57 0 0 0 0 0 0 5.73 23.32 42.80 28.15
Greenville MSA 2.2 6 3.06 33.33 16.67 33.33 16.67 0 1 0 0 -1 0 10.77 22.50 38.45 28.28
Hickory MSA 5.2 10 5.10 0.00 10.00 60.00 30.00 0 2 0 0 -1 -1 0.00 12.94 67.36 19.70
Jacksonville MSA 3.4 7 3.57 0.00 0.00 71.43 28.57 0 0 0 0 0 0 0.00 12.02 68.54 15.02
New Bern MSA 2.9 6 3.06 16.67 16.67 50.00 16.67 0 2 0 -1 0 -1 4.40 15.36 53.37 26.87
Rocky Mount MSA 0.6 1 0.52 0.00 0.00 100.0 0.00 0 0 0 0 0 0 0.00 5.56 63.77 30.66
Virginia Beach MSA 0.2 1 0.52 0.00 100.0 0.00 0.00 0 0 0 0 0 0 0.00 36.87 63.13 0.00
Wilmington MSA 5.9 10 5.10 20.00 20.00 30.00 30.00 0 0 0 0 0 0 13.16 17.00 40.14 29.69
Winston-Salem MSA 4.1 10 5.10 10.00 10.00 40.00 40.00 0 0 0 0 0 0 8.87 22.76 33.42 34.06
Two branches in the Durham MSA are located in geographies with no income designations. One branch in the Fayetteville MSA is located in a geographywith no income designation.
326
LENDING VOLUME Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

Area Loans Home Mortgage Small Loans to Businesses Small Loans to Farms Loans" Total Reported Loans Deposits in
(#) in MA/AA"'
Full Review:
Charleston MSA 16.27 546 156,744 349 35,865 4 118 5 27,450 899 192,727 14.5
Columbia MSA 27.04 499 93,498 984 67,786 11 658 18 23,685 1,494 161,942 28.2
Greenville MSA 18.95 389 76,735 652 61,005 6 89 10 5,625 1,047 137,829 14.3
SC Non-MSA 19.51 427 70,584 544 37,878 107 11,119 21 44,159 1,078 119,581 24.0
Limited Review:
Florence MSA 6.52 190 30,581 159 10,202 11 1,564 11 26,807 360 42,347 6.6
Hilton Head MSA 1.67 33 13,158 59 3,567 0 0 1 20,000 92 16,725 2.3
Spartanburg MSA 7.28 152 23,953 247 14,244 3 61 1 600 402 38,258 7.8
Sumter MSA 2.77 49 6,261 101 8,435 3 450 3 1,635 153 15,146 2.3
* Loan Data as of December 31, 2017. Rated area refers to either state or multi -state MA rating area.
** The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
327
Table 2a. Geographic Distribution of Home Purchase Loans
Geographic Distribution: HOME PURCHASE Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Charleston MSA 393 27.27 3.30 4.07 19.18 15.78 42.51 42.24 35.01 37.91 1.85 12.76 47.42 37.97
Columbia MSA 295 20.47 2.81 3.05 24.69 15.93 34.97 34.58 37.54 46.44 1.56 14.29 32.60 51.55
Greenville MSA 261 18.11 3.13 4.98 20.88 13.41 43.61 42.53 32.38 39.08 2.45 14.74 41.36 41.46
SC Non-M5A 251 17.42 0.35 0.00 16.23 8.37 58.14 51.39 25.28 40.24 0.06 9.96 46.90 43.08
Limited Review:
Florence MSA 122 8.47 1.31 0.00 16.51 6.56 51.87 36.07 30.31 57.38 0.33 10.88 46.79 41.99
Hilton Head MSA 20 1.39 0.00 0.00 16.94 10.00 51.42 65.00 31.64 25.00 0.00 10.17 62.14 27.69
Spartanburg MSA 78 5.41 2.25 1.28 15.62 7.69 47.07 48.72 35.05 42.31 1.01 9.27 46.14 43.58
Sumter MSA 21 1.46 0.00 0.00 15.42 19.05 64.12 52.38 20.46 28.57 0.00 7.37 61.46 31.17

**Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
328
Geographic Distribution: HOME IMPROVEMENT Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle -Income Upper -Income Aggregate HMDA Lending (%) by Tract Income*
Total" Occ Loans-* Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units- Units*** Units*** Units*""
Full Review:
Charleston MSA 13 11.61 3.30 0.00 19.18 23.08 42.51 38.46 35.01 38.46 2.61 16.90 44.23 36.26
Columbia MSA 30 26.79 2.81 3.33 24.69 16.67 34.97 36.67 37.54 43.33 1.90 21.49 32,24 44.37
Greenville MSA 17 15.18 3.13 0.00 20.88 17.65 43.61 35.29 32.38 47.06 3.60 18.86 41.86 35.68
SC Non-MSA 28 25.00 0.35 0.00 16.23 14.29 58.14 57.14 25.28 28.57 0.14 15.46 54.75 29.65
Limited Review:
Florence MSA 14 12.50 1.31 0.00 16.51 28.57 51.87 50.00 30.31 21.43 0.34 20.82 45.73 33.11
Hilton Head MSA 0 0.00 0.00 0.00 16.94 0.00 51.42 0.00 31.64 0.00 0.00 20.80 56.80 22.40
Spartanburg MSA 6 5.36 2.25 0.00 15.62 16.67 47.07 50.00 35.05 33.33 1.26 13.84 49.06 35.85
Sumter MSA 4 3.57 0.00 0.00 15.42 25.00 64.12 50.00 20.46 25.00 0.00 13.98 63.44 22,58

" Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
329
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Mortgage Geographies Geographies Geographies Income'
# % of % Owner % BANK % Owner % BANK % Owner % BANK % Owner % BANK
Total" Occ Units- Loans"" Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*"" Units*** Units"""
Full Review:
Charleston MSA 133 18.45 3.30 5.26 19,18 15.79 42.51 39.10 35.01 39.85 2.06 13.43 42.52 41.99
Columbia MSA 173 23.99 2.81 5.78 24.69 21.97 34.97 30.64 37.54 41.62 1.23 16.06 34.10 48.61
Greenville MSA 111 15.40 3.13 2.70 20.88 10.81 43.61 46.85 32.38 39.64 1.97 14.03 42.35 41.65
SC Non-MSA 146 20.25 0.35 0.00 16.23 14.38 58.14 53.42 25.28 32.19 0.10 10.31 47.45 42.14
Limited Review:
Florence MSA 53 7.35 1.31 0.00 16.51 13.21 51.87 32.08 30.31 54.72 0.43 10.31 46.08 43.18
Hilton Head MSA 13 1.80 0.00 0.00 16.94 15.38 51.42 46.15 31.64 38.46 0.00 9.87 56.51 33.61
Spartanburg MSA 68 9.43 2.25 1.47 15.62 8.82 47.07 50.00 35.05 39.71 1.06 10.54 44.58 43.81
Sumter MSA 24 3.33 0.00 0.00 15.42 4.17 64.12 54.17 20.46 41.67 0.00 8.44 62.37 29.19

Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
***Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
330
Table 6a. Geographic Distribution of Small Loans to Businesses
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Business Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income*
Total** Businesses BANK Businesses*** Loans Businesses Loans Businesses** Loans Low Mod Mid Upp
...
Loans
".
Full Review:
Charleston MSA 341 11.05 7.74 7.92 19.80 22.58 33.73 39.88 37.09 29,62 7.13 16.92 32.63 43.32
Columbia MSA 982 31.83 9.54 7.54 24.25 23.22 31.91 32.18 33.63 37.07 6.88 22.11 32.59 38.42
Greenville MSA 652 21.13 5.88 3.53 19.15 15.03 39.73 41.10 35.23 40.34 5.57 16.60 38.39 39.44
SC Non-MSA 544 17.63 0.72 0.37 17.88 20.77 51.37 50.92 30.02 27.94 0.47 14.00 47.73 37.80
Limited Review:
Florence MSA 159 5.15 3.99 3.77 25,20 25.16 40.00 35.85 30.70 35.22 3.00 20.68 40.33 35.99
Hilton Head MSA 59 1.91 0.00 0.00 16.97 16.95 54.35 52.54 28.68 30.51 0.00 14.78 53.42 31.80
Spartanburg MSA 247 8.01 2.50 0.81 21.74 23.08 41.12 48.58 34.64 27.53 1.65 19.11 42.74 36.50
Sumter MSA 101 3.27 0.00 0.00 37.02 35.64 50.10 53.47 12.87 10.89 0.00 40.30 48.71 11.00

" Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
331
Geographic Distribution: SMALL LOANS TO FARMS Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending (%) by Tract Income*
Geoa aphies Geographies Geographies Geographies
Total- Farms- Loans Farms** Loans Farms*" Loans Farms- Loans Low Mod Mid Upp
Full Review:
Charleston MSA 4 2.76 3.27 0.00 19.35 100.00 45.32 0.00 31.61 0.00 1.32 32.89 44.74 21.05
Columbia MSA 11 7.59 2.56 9.09 27.80 63.64 37.78 0.00 31.87 27.27 0.66 34,21 47.37 17.76
Greenville MSA 6 4.14 2.38 0.00 21.23 33.33 48.85 16.67 27.54 50.00 1.32 26.32 38.16 34.21
SC Non-MSA 107 73.79 0.07 0.00 15.43 20.56 65.33 69.16 19.17 10.28 0.00 18.06 69.53 12.42
Limited Review:
Florence MSA 11 7.59 0.27 0.00 13.82 9.09 59.62 81.82 26.29 9.09 0.00 21.62 54.05 24.32
Hilton Head MSA 0 0.00 0.00 0.00 23.99 0.00 56.70 0.00 19.31 0.00 0.00 46.67 46.67 6.67
Spartanburg MSA 3 2.07 1.35 0.00 17.12 0.00 50.23 100.00 31.31 0.00 0.00 14.29 50.00 35.71
Sumter MSA 3 2.07 0.00 0.00 14.95 33.33 73.71 66.67 11.34 0.00 0.00 10.00 70.00 20.00

***Source Data - Dun and Bradstreet (2017).
332
Borrower Distribution: HOME PURCHASE Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % % BANK % Families4 % BANK % % BANK % % BANK
Total** Families' Loans- Loans**** Families*** Loans"**" Families*** Loans**** Low Mod Mid Upp
Full Review:
Charleston MSA 396 27.40 22.61 9.35 16.71 23.12 19.85 19.22 40.83 48.31 5.10 21.36 26.19 47.34
Columbia MSA 296 20.48 23.01 11.85 16.68 22.30 19.43 20.91 40.89 44.95 9.90 24.22 26.49 39.39
Greenville MSA 261 18.06 22.90 10.00 17.07 20.40 18.82 22.40 41.22 47.20 4.77 20.64 25.13 49.46
SC Non-MSA 251 17.37 22.89 2.54 16.90 16.10 18.13 22.03 42.09 59.32 3.38 15.00 24.26 57.36
Limited Review:
Florence MSA 122 8.44 23,45 4.10 16.18 20.49 19,92 21.31 40.45 54.10 4.81 22.66 26.77 45.76
Hilton Head MSA 20 1.38 17.73 5.00 18.16 5.00 21.24 10.00 42.87 80.00 2.55 14.19 22.34 60.92
Spartanburg MSA 78 5.40 21.00 8.33 17.42 20.83 18.92 20.83 42.66 50.00 4.51 23.40 28.47 43.62
Sumter MSA 21 1.45 20.14 10.00 19.85 15.00 19.29 20.00 40.72 55.00 3.38 14.26 29.49 52.86

**** As a percentage of loans with borrower income information available. No information was available for 3.7% of loans originated and purchased by BANK.
333
Borrower Distribution: HOME IMPROVEMENT Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total- Families- Loans"" Families5 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Charleston MSA 13 11.61 22.61 15.38 16.71 23.08 19.85 23.08 40.83 38.46 10.94 18.39 23.10 47.57
Columbia MSA 30 26.79 23.01 17.86 16.68 17.86 19.43 14.29 40.89 50.00 8.56 16.98 22.42 52.04
Greenville MSA 17 15.18 22.90 0.00 17.07 6.67 18.82 13.33 41.22 80.00 8.85 17.95 21.84 51.36
SC Non-MSA 28 25.00 22.89 3.57 16.90 10.71 18.13 14.29 42.09 71.43 8.35 18.03 25.78 47.84
Limited Review:
Florence MSA 14 12.50 23,45 14.29 16.18 21.43 19.92 7.14 40.45 57.14 16.78 18.88 22.73 41.61
Hilton Head MSA 0 0.00 17.73 0.00 18.16 0.00 21.24 0.00 42.87 0.00 4.53 20.16 25.10 50.21
Spartanburg MSA 6 5.36 21.00 0.00 17,42 33.33 18.92 0.00 42.66 66.67 6.98 19.93 19.93 53.16
Sumter MSA 4 3.57 20.14 0.00 19.85 33.33 19.29 66.67 40.72 0.00 5.56 8.89 17.78 67.78
*Based on 2017 Peer Mortgage Data -- US and PR

**Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
** As a percentage of loans with borrower income information available. No information was available for 7.1% of loans originated and purchased by BANK.
334
Table 10a. Borrower Distribution of Home Mort a e Refinance Loans
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Mortgage Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data'
Total" Families"' Loans- Families6 Loans**** Families*** Loans**** Families*** Loans"*** Low Mod Mid Upp
Full Review:
Charleston MSA 136 18.78 22.61 9.77 16.71 20.30 19.85 14.29 40.83 55.64 6.58 18.52 25.43 49.47
Columbia MSA 173 23.90 23.01 10.53 16.68 20.47 19.43 25.15 40.89 43.86 8.93 18.63 24.95 47.50
Greenville MSA 111 15.33 22.90 12.62 17.07 18.45 18.82 16.50 41.22 52.43 6.80 17.08 25.37 50.75
SC Non-MSA 146 20.17 22.89 6.38 16.90 9.22 18.13 24,11 42.09 60.28 4.44 12.14 21.28 62.14
Limited Review:
Florence MSA 53 7.32 23.45 3.77 16.18 5.66 19.92 15.09 40.45 75.47 8.31 15.51 19.94 56.23
Hilton Head MSA 13 1,80 17.73 8.33 18.16 8.33 21.24 0.00 42.87 83.33 5.13 15.12 21.94 57.81
Spartanburg MSA 68 9.39 21.00 5.97 17.42 13.43 18.92 37.31 42.66 43.28 7.85 17.37 25.16 49.61
Sumter MSA 24 3.31 20.14 9.09 19.85 4.55 19.29 18,18 40.72 68.18 6.05 10.37 22.03 61.56

"Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
Percentage of Families is based on the 2015 ACS Census information.
-As a percentage of loans with borrower income information available. No information was available for 3.0% of loans originated and purchased by BANK.
335
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Loans to Businesses With Revenues of $1 million Loans by Original Amount Regardless of Business Size . Aggregate Lending Data*
Businesses or less
Assessment Area: # % of Total** % of Businesses"' % BANK Loans**** $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Charleston MSA 349 11.28 82.20 67.91 76.79 10.60 12.61 14,942 7,383
Columbia MSA 984 31.79 80.27 76.42 85.06 7.52 7.42 12,709 6,510
Greenville MSA 652 21.07 80.92 71.01 80.67 8.59 10.74 14,867 7,422
SC Non-MSA 544 17.58 80.28 73.35 85.48 7.54 6.99 6,304 3,180
Limited Review:
Florence MSA 159 5.14 78.94 69.18 85.53 8.18 6.29 2,299 1,001
Hilton Head MSA 59 1.91 84.40 72.88 86.44 8.47 5.08 4,250 2,182
Spartanburg MSA 247 7.98 79.75 80.16 87.04 6.48 6.48 4,501 2,220
Sumter MSA 101 3.26 81.54 68.32 82.18 10.89 6.93 1,117 519
*Based on 2017 Peer Small Business Data -- US and PR

- Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
336
Borrower Distribution: SMALL LOANS TO FARMS Geography: SOUTH CAROLINA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total" % of Farms- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Charleston MSA 4 2.76 93.82 75.00 100.00 0.00 0.00 80 32
Columbia MSA 11 7.59 96.01 100.00 90.91 0.00 9.09 153 68
Greenville MSA 6 4.14 96.72 100.00 100.00 0.00 0.00 79 35
SC Non-MSA 107 73.79 96.65 72.90 71.03 15.89 13.08 446 157
Limited Review:
Florence MSA 11 7.59 97.83 81.82 63.64 18.18 18.18 75 29
Hilton Head MSA 0 0.00 93.15 0.00 0.00 0.00 0.00 16 8
Spartanburg MSA 3 2.07 96.40 100.00 100.00 0.00 0.00 30 19
Sumter MSA 3 2.07 96.91 100.00 66.67 33.33 0.00 30 6

Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the rated area.
*Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
-*Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 2.07% of small loans to
337
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: SOUTH CAROLINA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

of # of % of Location of Branches by Net change in Location of Branches % of Population within Each Geography
Assessment Area: Rated BANK Rated Income of Geographies (%) # of # of (+ or - )
in AA in AA
Full Review:
Charleston MSA 14.5 18 15.65 0.00 33.33 33.33 33.33 1 2 -1 0 -1 +1 6.66 21.44 41.91 29.18
Columbia MSA 28.2 25 21.74 8.00 36.00 32.00 24.00 0 4 0 -2 -1 -1 5.93 27.30 32.76 31.73
Greenville MSA 14.3 18 15.65 11.11 16.67 38.89 33.33 0 1 0 -1 0 0 5.32 23.60 41.71 29.37
SC Non-MSA 24.0 32 27.83 0.00 18.75 46.88 34.37 2 5 0 0 -5 +2 0.81 19.28 57.42 22.01
Limited Review:
Florence MSA 6.6 6 5.23 0.00 50.00 16.67 33.33 0 2 0 -1 -1 0 2,88 20.35 49.27 27.49
Hilton Head MSA 2.3 3 2.60 0.00 33.33 66.67 0.00 0 0 0 0 0 0 0.00 26.60 50.33 23.07
Spartanburg MSA 7.8 10 8.70 0.00 30.00 40.00 30.00 0 1 0 0 0 -1 4.85 20.84 43.55 30.76
Sumter MSA 2.3 3 2.60 0.00 33.33 33.33 33.33 0 0 0 0 0 0 0.00 22.27 62.21 15.52
338
LENDING VOLUME Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

Area Loans Home Mortgage Small Loans to Businesses Small Loans to Farms Loans** Total Reported Loans Deposits in
(#) in MA/AA"'
Full Review:
VA Non-MSA 22.67 120 15,555 186 13,540 42 6,543 14 52,340 348 35,638 39.0
Roanoke MSA 28.66 93 16,058 344 54,079 3 285 12 2,568 440 70,422 16.6
Limited Review:
Blacksburg MSA 3.39 12 2,429 39 4,523 1 10 0 0 52 6,962 1.3
Charlottesville MSA 7.62 25 7,346 91 13,310 1 75 2 75 117 20,731 4.8

Harrisonburg MSA 2.87 13 4,535 31 4,165 0 0 1 1,500 44 8,700 2.1
Lynchburg MSA 7.82 40 8,034 79 10,659 1 400 3 1,802 120 19,093 11.5
Richmond MSA 12.70 20 6,088 174 22,258 1 2 1 15,207 195 28,348 15.5
Staunton -Waynesboro MSA 2.21 12 2,462 20 1,747 2 580 0 0 34 4,789 2.5
Washington MSA 10.23 14 4,889 141 15,938 2 301 2 1,145 157 21,128 5.8
Winchester MSA 1.82 2 654 26 3,518 0 0 0 0 28 4,172 0.9
" Loan Data as of December 31, 2017. Rated area refers to either state or multi -state MA rating area.
The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
** Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
339
Geographic Distribution: HOME PURCHASE Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Occ Loans-- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
VA Non-MSA 65 37.79 0.81 1.54 16.64 18.46 72.60 63.08 9.95 16.92 0.21 14.46 74.34 11.00
Roanoke MSA 38 22.09 1.80 0.00 12.06 18.42 47.36 31.58 38.78 50.00 1.21 10.02 49.28 39.49
Limited Review:
Blacksburg MSA 6 3.49 0.00 0.00 2.17 0.00 55.54 50.00 42.29 50.00 0.00 4.37 44.85 50.78
Charlottesville MSA 15 8.72 4.14 13.33 10.21 13.33 36.68 26.67 48.98 46.67 5.09 10.07 35.15 49.70
Harrisonburg MSA 6 3.49 0.41 0.00 9.97 0.00 76.88 66.67 12.74 33.33 2.33 13.72 68.70 15.25
Lynchburg MSA 20 11.63 1.87 0.00 14.16 10.00 59.67 45.00 24.30 45.00 1.11 17.52 53.35 28.02
Richmond MSA 15 8.72 5.20 0.00 17.29 20.00 36.39 20.00 41.13 60.00 4.63 17.36 33.55 44.46
Staunton -Waynesboro MSA 3 1.74 0.25 0.00 9.20 0.00 83.15 66.67 7.41 33.33 0.23 11.10 80.43 8.25
Washington MSA 4 2.33 1.42 0.00 10.21 50.00 32.86 25.00 55.51 25.00 1.51 10.24 33.37 54.89
Winchester MSA 0 0.00 0.00 0.00 10.67 0.00 57.87 0.00 31.45 0.00 0.00 8.64 65.59 25.77

-- Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
340
Geographic Distribution: HOME IMPROVEMENT Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Loans-- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*** Units*** Units"*"
Full Review:
VA Non-MSA 6 31.58 0.81 0.00 16.64 16.67 72.60 66.67 9.95 16.67 0.25 14.25 77.25 8.25
Roanoke MSA 6 31.58 1.80 0.00 12.06 16.67 47.36 33.33 38.78 50.00 2.94 16.44 46.54 34.08
Limited Review:
Blacksburg MSA 1 5.26 0.00 0.00 2.17 0.00 55.54 100.00 42.29 0.00 0.00 4.35 50.00 45.65
Lynchburg MSA 0 0.00 1.87 0.00 14.16 0.00 59.67 0.00 24.30 0.00 2.93 12.90 61.29 22.87
Richmond MSA 0 0.00 5.20 0.00 17.29 0.00 36.39 0.00 41.13 0.00 5.12 15.29 37.27 42.32
Washington MSA 1 5.26 1.42 0.00 10.21 0.00 32.86 0.00 55.51 100.00 2.01 10.96 31.23 55.80
Winchester MSA 0 0.00 0.00 0.00 10.67 0.00 57.87 0.00 31.45 0.00 0.00 6.96 64.35 28.70

341
Table 4a. Geo ra hic Distribution of Home Mort a e Refinance Loans
Geographic Distribution: HOME MORTGAGE REFINANCE Geog aphy: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
VA Non-MSA 49 31,41 0.81 0.00 16.64 16.33 72.60 73.47 9.95 10.20 0.28 13.03 76.43 10.27
Roanoke MSA 48 30.77 1.80 2.08 12.06 12.50 47.36 47.92 38.78 37.50 1.38 10.11 47.22 41.29
Limited Review:
Blacksburg MSA 5 3.21 0.00 0.00 2.17 0.00 55.54 20.00 42.29 80.00 0.00 2.61 49.10 48.29
Lynchburg MSA 19 12.18 1.87 0.00 14.16 0.00 59.67 94.74 24.30 5.26 1.22 15.04 56.94 26.80
Richmond MSA 5 3.21 5.20 0.00 17.29 20.00 36.39 20.00 41.13 60.00 3.85 15.99 37.48 42.68
Washington MSA 9 5.77 1.42 11.11 10.21 33.33 32.86 33.33 55.51 22.22 1.40 11.09 33.58 53.93
Winchester MSA 2 1.28 0.00 0.00 10.67 0.00 57.87 0.00 31.45 100.00 0.00 7.18 61.65 31.17

342
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
...
Loans
...
Full Review:
VA Non-MSA 186 16.46 0.71 0.00 19.90 24.73 67.60 60.75 11.43 14.52 0.68 18.94 69.13 11.25
Roanoke MSA 344 30.44 3.17 4.07 9.83 10.47 51.38 46.80 35.61 38.66 3.94 9.95 49.37 36.75
Limited Review:
Blacksburg MSA 39 3.45 0.00 0.00 2.39 0.00 58.28 56.41 38.65 43.59 0.00 1.72 58.30 39.98
Charlottesville MSA 91 8.05 4.12 2.20 11.75 21,98 31.35 35.16 52.27 40.66 5.77 12.17 30.42 51.64
Lynchburg MSA 79 6.99 1.49 2.53 22.10 35.44 52.19 37.97 24.22 24.05 1.07 19.66 50.93 28.33
Richmond MSA 173 15.31 6.62 7.51 22.56 16.18 31.01 27.75 39.38 48.55 5.87 20.19 30.53 43.41
Washington MSA 141 12.48 2.54 7.80 9.68 17.02 35.83 34.04 51.69 41.13 2.45 9.70 35.97 51.88
Winchester MSA 26 2.30 0.00 0.00 18.19 7.69 56.82 69.23 24.99 23.08 0.00 17.74 56.97 25.29

Source Data - Dun and Bradstreet (2017).
343
Geographic Distribution: SMALL LOANS TO FARMS Geog aphy: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate Lending %) by Tract Income'
Loans Geog aphies Geographies Geographies Geographies
Total*" Farms*** Loans Farms** Loans Farms** Loans Farms"* Loans Low Mod Mid Upp
Full Review:
VA Non-MSA 42 79.25 0.13 0.00 12.09 21.43 79.97 78.57 7.81 0.00 0.00 15.42 84.14 0.44
Roanoke MSA 3 5.66 1.83 33.33 6.88 0.00 42.20 33.33 49.08 33.33 4.55 0.00 40.91 54.55
Limited Review:
Blacksburg MSA 1 1.89 0.00 0.00 1.40 0.00 59.53 0.00 38.60 100.00 0.00 0.00 75.00 25.00
Lynchburg MSA 1 1.89 0.52 0.00 8.55 0.00 68.76 100.00 22.16 0.00 1.89 1.89 84.91 11.32
Richmond MSA 1 1.89 3.57 0.00 16.36 0.00 39.40 0.00 40.59 100.00 3.70 25.93 40.74 29.63
Washington MSA 2 3.77 2.28 0.00 11.89 0.00 32.64 0.00 53.08 100.00 0.00 13.27 27.43 59.29
Winchester MSA 0 0.00 0.00 0.00 10.33 0.00 61.25 0.00 28.41 0.00 0.00 7.69 66.67 25.64
" Based on 2017 Peer Small Business Data -- US and PR

344
Borrower Distribution: HOME PURCHASE Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % % BANK % Families? % BANK % % BANK % % BANK
Total- Families- Loans- Loans**** Families*** Loans""*" Families*** Loans**** Low Mod Mid Upp
Full Review:
VA Non-MSA 65 37.79 24.30 0.00 17.57 32.69 20.83 23.08 37.30 44.23 8.76 25.37 24.84 41.03
Roanoke MSA 38 22.09 19.22 12.50 17.04 21.88 22.37 18.75 41.37 46.88 10.05 26.44 26.10 37.41
Limited Review:
Blacksburg MSA 6 3.49 17.28 16.67 15,45 50.00 19.59 0.00 47.67 33.33 4.61 15.97 22.88 56.54
Lynchburg MSA 20 11.63 20.79 5.26 17.43 21.05 21.50 15.79 40.27 57.89 9.43 22.26 24.23 44.08
Richmond MSA 15 8.72 21.09 0.00 17.59 26.67 19.71 26.67 41.61 46.67 9.60 25.15 25.35 39.90
Washington MSA 4 2.33 16.96 25.00 14.25 0.00 19.66 0.00 49.13 75.00 5.50 18.55 26.10 49.85
Winchester MSA 0 0.00 19.69 0.00 16.33 0.00 19.45 0.00 44.52 0.00 5.66 20.79 25.95 47.60

"Home purchase loans originated and purchased in the MAJAA as a percentage of all home purchase loans originated and purchased in the rated area.
***Percentage of Families is based on the 2015 ACS Census information.
As a percentage of loans with borrower income information available. No information was available for 12.8% of loans originated and purchased by BANK.
345
Borrower Distribution: HOME IMPROVEMENT Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Improvement Loans Borrowers
Total- Families*** Loans"- Families8 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
VA Non-MSA 6 31.58 24.30 0.00 17.57 66.67 20.83 33.33 37.30 0.00 14.03 19.74 27.79 38.44
Roanoke MSA 6 31.58 19.22 0.00 17.04 25.00 22.37 0.00 41.37 75.00 13.79 27.40 26.86 31.94
Limited Review:
Blacksburg MSA 1 5.26 17.28 0.00 15.45 0.00 19.59 100.00 47.67 0.00 14.29 14.29 25.56 45.86
Charlottesville MSA 4 21.05 18.99 0,00 15.03 0.00 18.75 50.00 47.23 50.00 10.61 18.18 18.18 53.03
Lynchburg MSA 0 0.00 20.79 0.00 17.43 0.00 21.50 0.00 40.27 0.00 12.96 19.44 24.69 42.90
Richmond MSA 0 0.00 21.09 0.00 17.59 0.00 19.71 0.00 41.61 0.00 9.99 24.01 25.11 40.90
Washington MSA 1 5.26 16.96 0.00 14.25 0.00 19.66 100.00 49.13 0.00 7.24 14.66 22.46 55.65
Winchester MSA 0 0.00 19.69 0.00 16.33 0.00 19.45 0.00 44.52 0.00 8.64 20.00 21.82 49.55

** Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
-Percentage of Families is based on the 2015 ACS Census information.
346
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Mortgage Borrowers
it % of % % BANK % % BANK % % BANK % % BANK
Total** Families*** Loans*- Families9 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
VA Non-MSA 49 31.41 24.30 8.70 17.57 21.74 20.83 26.09 37.30 43.48 9.61 19.57 24.29 46.53
Roanoke MSA 48 30.77 19.22 2.17 17.04 26.09 22.37 26.09 41.37 45.65 12.05 22.26 26.74 38.96
Limited Review:
Blacksburg MSA 5 3.21 17.28 0.00 15.45 20.00 19.59 0.00 47,67 80.00 6.81 15.37 22.18 55.64
Lynchburg MSA 19 12.18 20.79 5.56 17.43 27.78 21.50 22.22 40.27 44.44 9.74 22.04 24.68 43.55
Richmond MSA 5 3.21 21.09 0.00 17.59 0.00 19.71 33,33 41.61 66.67 11.07 21.74 25.68 41.51
Staunton -Waynesboro MSA 7 4,49 19.70 14.29 18.35 14.29 22.71 14.29 39.23 57.14 9.44 24.16 27.87 38.54
Washington MSA 9 5.77 16.96 0.00 14.25 37.50 19.66 0.00 49.13 62.50 7.49 16.70 24.87 50.93
Winchester MSA 2 1.28 19.69 0.00 16.33 0.00 19.45 50.00 44.52 50.00 7.94 16.31 23.72 52.03

** Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
347
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Loans to Businesses With Revenues of $1 million Loans by Original Amount Regardless of Business Size Aggregate Lending Data*
Businesses or less
Assessment Area: # % of Total" % of Businesses- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
VA Non-MSA 186 16.45 80.17 69.89 84.41 7.53 8.06 2,243 1,182
Roanoke MSA 344 30.42 80.63 61.92 63.08 15.99 20.93 4,241 2,398
Limited Review:
Blacksburg MSA 39 3.45 80.39 66.67 82.05 2.56 15.38 1,025 565
Charlottesville MSA 91 8.05 83.82 50.55 64.84 16.48 18.68 3,337 1,720
Harrisonburg MSA 31 2.74 82.25 45.16 74.19 6.45 19.35 1,738 967
Lynchburg MSA 79 6.98 83.47 63.29 69.62 12.66 17.72 2,949 1,614
Richmond MSA 174 15.38 84.19 49.43 71.26 15.52 13.22 17,100 9,304
Staunton -Waynesboro MSA 20 1.77 82.53 50.00 75.00 20.00 5.00 1,687 903
Washington MSA 141 12.47 85.67 63.83 76.60 8.51 14.89 51,025 28,599
Winchester MSA 26 2.30 82.55 38.46 61.54 19.23 19.23 1,943 999

Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
- Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 2.65% of
348
Borrower Distribution: SMALL LOANS TO FARMS Geography: VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms % BANK Loans**** $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
VA Non-MSA 42 79.25 98.24 52.38 50.00 28.57 21.43 230 112
Roanoke MSA 3 5.66 95.18 66.67 66.67 33.33 0.00 22 9
Limited Review:
Blacksburg MSA 1 1.89 95.81 100,00 100.00 0.00 0.00 36 11
Charlottesville MSA 1 1.89 97.85 100.00 100.00 0.00 0.00 58 25
Harrisonburg MSA 0 0.00 97.08 0.00 0.00 0.00 0.00 148 113
Lynchburg MSA 1 1.89 97.91 0.00 0.00 0.00 100.00 53 37
Richmond MSA 1 1.89 96.27 100.00 100.00 0.00 0.00 28 17
Staunton -Waynesboro MSA 2 3.77 97.29 HO 50.00 0.00 50.00 150 114
Washington MSA 2 3.77 93.50 0.00 50.00 0.00 50.00 114 57
Winchester MSA 0 0.00 95.20 0.00 0.00 0.00 0.00 41 25

- Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
-- Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
349
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: VIRGINIA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
VA Non-MSA 39.0 16 34.04 0.00 37.50 50.00 12.50 0 0 0 0 0 0 1.53 19.49 67.99 8.69
Roanoke MSA 16.6 7 14.89 0.00 14.28 42.86 42.86 0 0 0 0 0 0 4.20 15.46 47.06 33.28
Limited Review:
Blacksburg MSA 1.3 2 4.23 0.00 0.00 100.00 0.00 0 0 0 0 0 0 0.00 7.79 47.56 36.02
Charlottesville MSA 4.8 3 6.38 0.00 33.33 33.33 33.33 0 0 0 0 0 0 6.24 19.65 31.85 39.67
Harrisonburg MSA 2.1 2 4.26 0.00 100.00 0.00 0.00 0 0 0 0 0 0 4.57 15.07 66.33 14.03
Lynchburg MSA 11.5 4 8.51 0.00 25.00 50.00 25.00 0 0 0 0 0 0 2.28 21.29 55.35 21.08
Richmond MSA 15.5 6 12.77 0.00 0.00 33.33 66.67 7 3 0 0 +2 +2 10.25 22.00 33.15 34.18
Staunton -Waynesboro MSA 2.5 1 2.14 0.00 0.00 100.00 0.00 0 0 0 0 0 0 1.09 11.96 79.59 7.37
Washington MSA 5.8 5 10.64 40.00 20.00 20.00 20.00 0 0 0 0 0 0 3.86 12.92 34.85 48.24
Winchester MSA 0.9 1 2.14 0.00 0.00 0.00 100.00 0 0 0 0 0 0 0.00 17.39 55.73 26.88
350
LENDING VOLUME Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA-
Assessment Area (2017): MA/AA* # $ (000's) # $ (000's) # $ (000's) # $ (000's) # $(000's)
Full Review:
Los Angeles MD 25.47 8 5,995 287 31,259 0 0 16 22,257 295 37,254 15.5
Sacramento MSA 13.56 2 220 155 23,991 0 0 11 2,372 157 24,211 26.8
San Diego MSA 35.32 2 1,065 407 48,730 0 0 20 10,223 409 49,795 25.5
Limited Review:
Anaheim MD 10.62 1 88 122 13,889 0 0 4 20,057 123 13,977 20.1
Oakland MD 0.26 0 0 3 200 0 0 0 0 3 200 0.1
Riverside MSA 14.77 2 941 169 11,065 0 0 2 200 171 12,006 12.0
- Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
351
Geographic Distribution: HOME PURCHASE Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units- Units*** Units*** Units***
Full Review:
Los Angeles MD 3 50.00 2.43 0.00 17.21 33.33 26.58 0.00 53.77 66.67 3.32 19.72 25.79 51.17
Sacramento MSA 1 16.67 5.23 0.00 19.91 0.00 35.43 0.00 39.43 100.00 7.65 20.86 33.51 37.97
San Diego MSA 1 16.67 2.79 0.00 15.14 100.00 35.45 0.00 46.62 0.00 3.48 16.83 35.54 44.16
Limited Review:
Anaheim MD 0 0.00 3.28 0.00 18.58 0.00 29.92 0.00 48.23 0.00 3.03 17.14 30.41 49.42
Oakland MD 0 0.00 5.08 0.00 20.03 0.00 29.38 0.00 45.50 0.00 6.14 21.44 34.38 38.04
Riverside MSA 1 16.67 2.23 0.00 20.07 0.00 36.00 100.00 41.71 0.00 1.40 17.99 37.26 43.35

352
Geographic Distribution: HOME IMPROVEMENT Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units- Units"- Units*** Units***
Full Review:
Los Angeles MD 2 50.00 2.43 0.00 17.21 0.00 26.58 0.00 53.77 100.00 2,74 18.59 27.48 51.20
Sacramento MSA 0 0.00 5.23 0.00 19.91 0.00 35.43 0.00 39.43 0.00 5.20 19.02 35.58 40.20
San Diego MSA 1 25.00 2.79 0.00 15.14 0.00 35.45 0.00 46.62 100.00 4.30 17.11 37.08 41.51
Limited Review:
Anaheim MD 0 0.00 3.28 0.00 18.58 0.00 29.92 0.00 48.23 0.00 3.11 20.40 32.72 43.76
Oakland MD 0 0.00 5.08 0.00 20.03 0,00 29.38 0.00 45.50 0.00 5.84 21.68 33.66 38.81
Riverside MSA 1 25.00 2.23 0.00 20.07 0.00 36.00 100.00 41.71 0.00 0.89 14.67 34.73 49.71

-Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
353
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Units*** Loans**** Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units""* Units*"* Units***
Full Review:
Los Angeles MD 1 33.33 2.43 0.00 17.21 0.00 26.58 0.00 53.77 100.00 2.78 18.65 27.59 50.99
Sacramento MSA 1 33.33 5.23 0.00 19.91 0.00 35.43 100.00 39.43 0.00 4.82 19.73 36.07 39.38
San Diego MSA 0 0.00 2.79 0.00 15.14 0.00 35.45 0.00 46.62 0.00 3.13 15.66 35.85 45.36
Limited Review:
Anaheim MD 1 33.33 3.28 0.00 18.58 0.00 29.92 0.00 48.23 100.00 2.99 18.34 31.18 47.49
Oakland MD 0 0.00 5.08 0.00 20.03 0.00 29.38 0.00 45.50 0.00 5.54 20.36 33.80 40.29
Riverside MSA 0 0.00 2.23 0.00 20.07 0.00 36.00 0.00 41.71 0.00 1.15 15.43 35.94 47.49

354
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Geographies Geographies Geogra hies Geographies
Total- Businesses
***
BANK
Loans
Businesses"** Loans
-
Businesses Loans Businesses** Loans Low Mod Mid Upp
Full Review:
Los Angeles MD 284 25.00 4.72 5.28 19.05 28.87 21.71 16.20 52.05 49.65 4.23 19.43 22.64 53.70
Sacramento MSA 152 13.38 9.59 6.58 22.40 19.08 31.74 22.37 33.94 51.97 8.92 21.57 30.24 39.27
San Diego MSA 407 35.83 5.44 3.93 15.07 18.67 35.08 33.42 44.23 43.98 4.74 14.40 34.90 45.95
Limited Review:
Anaheim MD 121 10.65 5.80 4.96 20.48 14.88 35.47 42.98 37.73 37.19 6.15 20.42 35.16 38.26
Oakland MD 3 0.26 6.67 0.00 18.05 0.00 29.16 0.00 46.12 100.00 5.77 17.65 28.45 48.13
Riverside MSA 169 14.88 3.03 2.37 23.70 20.71 35.01 37.87 38.27 39.05 2.34 22.92 34.24 40.50

-Source Data - Dun and Bradstreet (2017).
355
Geographic Distribution: SMALL LOANS TO FARMS Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geog, aphies Geographies Geographies Geographies
Total** Farms*** Loans Farms*" Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Los Angeles MD 0 0.00 2.57 0.00 16.87 0.00 25.54 0.00 53.94 0.00 5.17 14.37 23.28 57.18
Sacramento MSA 0 0.00 6.17 0.00 20.69 0.00 32.50 0.00 39.93 0.00 4.00 13.82 31.64 50.55
San Diego MSA 0 0.00 3.51 0.00 17.65 0.00 38.59 0.00 40.23 0.00 2.44 16.38 39.72 41.46
Limited Review:
Anaheim MD 0 0.00 5.69 0.00 22.42 0.00 33.56 0.00 38.15 0.00 6.67 16.67 35.00 41.67
Oakland MD 0 0.00 5.93 0.00 18.14 0.00 30.15 0.00 45.77 0.00 3.57 7.14 32.14 57.14
Riverside MSA 0 0.00 4.22 0.00 23.56 0.00 37.48 0.00 34.74 0.00 4.78 22.01 30.14 43.06

Small loans to farms originated and purchased in the MAJAA as a percentage of all small loans to farms originated and purchased in the rated area.
356
Borrower Distribution: HOME PURCHASE Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Purchase Low -Income Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Assessment Area: # % of % % BANK % Familiesw % BANK % % BANK % % BANK
Total** Families* Loans-- Loans-** Families*** Loans"**" Families*** Loans**** Low Mod Mid Upp
Full Review:
Los Angeles MD 3 50.00 24.54 0.00 16.32 0.00 16.71 0.00 42.43 100.00 0.71 4.35 14.41 80.54
Sacramento MSA 1 16.67 24.44 0.00 16.44 0.00 18.52 0.00 40.61 0.00 2.44 16.40 26.96 54.20
San Diego MSA 1 16.67 23.58 0.00 16.93 0.00 17.82 0.00 41.67 0.00 0.93 7.50 23.71 67.86
Limited Review:
Anaheim MD 0 0.00 23.81 0.00 16.27 0.00 17.92 0.00 42.00 0.00 1.17 7.44 19.94 71.45
Oakland MD 0 0.00 23.00 0.00 16,44 0.00 18.26 0.00 42.29 0.00 1.76 12.59 25.72 59.93
Riverside MSA 1 16.67 21.45 0.00 16.81 0.00 18.68 0.00 43.07 100.00 1.52 9.00 24.64 64.83

Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
357
Borrower Distribution: HOME IMPROVEMENT Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families*** Loans- Families11 Loans**** Families*** Loans"*** Families"** Loans**"* Low Mod Mid Upp
Full Review:
Los Angeles MD 2 50.00 24.54 0.00 16.32 0.00 16,71 0.00 42.43 100.00 3.35 8.55 18.95 69,14
Sacramento MSA 0 0.00 24.44 0.00 16.44 0.00 18.52 0.00 40.61 0.00 5.82 16.44 26.28 51.47
San Diego MSA 1 25.00 23.58 0.00 16.93 0.00 17.82 0.00 41.67 100.00 4.34 12.28 24.62 58.75
Limited Review:
Anaheim MD 0 0.00 23.81 0.00 16.27 0.00 17.92 0.00 42.00 0.00 5.49 14.09 23.98 56.43
Oakland MD 0 0.00 23.00 0.00 16.44 0.00 18.26 0.00 42.29 0.00 5.82 18,26 23.10 52.82
Riverside MSA 1 25.00 21.45 0.00 16.81 0.00 18.68 0.00 43.07 100.00 3.27 11.33 21.42 63.97

-"Percentage of Families is based on the 2015 ACS Census information.
-"As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
358
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of c/o % BANK % % BANK % % BANK % % BANK
Total** Families- Loans- Families12 Loans**** Families*"" Loans***" Families*** Loans**** Low Mod Mid Upp
Full Review:
Los Angeles MD 1 33.33 24.54 0.00 16.32 0.00 16.71 0.00 42.43 0.00 3.39 8.39 18.65 69.57
Sacramento MSA 1 33.33 24.44 0.00 16.44 100.00 18.52 0.00 40.61 0.00 5.73 17.79 26.39 50.10
San Diego MSA 0 0.00 23.58 0.00 16.93 0.00 17.82 0.00 41.67 0.00 4.37 12.01 22.98 60.64
Limited Review:
Anaheim MD 1 33.33 23.81 0.00 16.27 0.00 17.92 0.00 42.00 0.00 4.70 12.31 22.68 60.31
Oakland MD 0 0.00 23.00 0.00 16.44 0,00 18.26 0.00 42.29 0.00 6.26 17.48 24.98 51.28
Riverside MSA 0 0.00 21.45 0.00 16.81 0.00 18.68 0.00 43.07 0.00 4.06 11.90 22.53 61.51

" Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
359
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Los Angeles MD 287 25.11 87.21 57.84 78.75 7.67 13.59 313,577 167,836
Sacramento MSA 155 13.56 85.63 48.39 69.68 10.97 19.35 41,769 21,233
San Diego MSA 407 35.61 87.59 53.07 73.46 12.29 14.25 91,494 46,921
Limited Review:
Anaheim MD 122 10.67 85.94 59.84 76.23 9.84 13.93 114,192 58,804
Oakland MD 3 0.26 87.06 66.67 100.00 0.00 0.00 26,195 13,623
Riverside MSA 169 14.79 87.24 63.31 86.98 5.92 7.10 48,637 25,305

-Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
360
Borrower Distribution: SMALL LOANS TO FARMS Geography: CALIFORNIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Loans to Farms Farms With Revenues of $1 million or Loans by Original Amount Regardless of Farm Size Aggregate Lending Data'
less
Assessment Area: # % of Total** % of Farms- % BANK Loans*- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Los Angeles MD 0 0.00 93.70 0.00 0.00 0.00 0.00 367 194
Sacramento MSA 0 0.00 94.35 0.00 0.00 0.00 0.00 289 180
A t. -
San Diego MSA 0 0.00 94.29 0.00 0.00 0.00 0.00 314 170
Limited Review:
Anaheim MD 0 0.00 92.48 0.00 0.00 0.00 0.00 124 64
Oakland MD 0 0.00 94.68 0.00 0.00 0.00 0.00 94 52
Riverside MSA 0 0.00 92.42 0.00 0.00 0.00 0.00 216 121

361
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: CALIFORNIA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Los Angeles MSA 15.5 4* 19.05 0.00 25.00 0.00 50.00 0 0 0 0 0 0 8.59 29.32 26.26 35.06
Sacramento MSA 26.8 3 14.29 33.33 0.00 33.33 33.33 0 0 0 0 0 0 10.25 25.02 33.99 30.62
San Diego MSA 25.5 7 33.33 28.57 0.00 14.29 57.14 0 0 0 0 0 0 8.89 23.56 32.53 34.69
Limited Review:
Anaheim MD 20.1 3 14.29 0.00 33.33 33.33 33.33 0 0 0 0 0 0 8.55 27.65 28.97 34.80
Oakland MSA 0.1 1 4.75 0.00 0.00 100.0 0.00 1 0 0 0 +1 0 11.41 22.22 30.11 36.25
Riverside MSA 12.0 3 14.29 0.00 66.67 0.00 33.33 0 0 0 0 0 0 4.32 25.85 34.54 34.99
*One of the branches in the Los Angeles MSA is located in a geography with no income designation.
362
Table 1, Lending Volume
LENDING VOLUME Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA-
Full Review:
Atlanta MSA 65.25 60 22,452 599 69,318 0 0 7 37,588 659 91,770 69.0
Limited Review:
GA Non-MSA 21.78 56 8,572 153 5,796 11 306 1 2,000 220 14,674 18.5
Athens MSA 8.12 22 2,622 48 911 12 520 0 0 82 4,053 8.7
Savannah MSA 4.85 20 4,587 29 3,422 0 0 0 0 49 8,009 3.8
- The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community DevelopmentLoans.
363
Geographic Distribution: HOME PURCHASE Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Geographies Geographies Geographies Geographies Income'
Units"' Units""" Units*** Units***
Full Review:
Atlanta MSA 36 40.91 3.84 0.00 16.00 16.67 28.81 19.44 51.35 63.89 3.84 15.87 30.41 49.89
Limited Review:
GA Non-MSA 31 35.23 0.00 0.00 16.22 16.13 56.60 64.52 27.17 19.35 0.00 15.30 54.41 30.29
Athens MSA 9 10.23 0.00 0.00 44.41 44.44 55.59 55.56 0.00 0.00 0.00 30.83 69.17 0.00
Savannah MSA 12 13.64 5.58 8.33 21.21 33.33 33.46 8.33 39.75 50.00 2.73 14.28 32.62 50.37

-*Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
364
Table 3a. Geoctraphic Distribution of Home Improvement Loans
Geographic Distribution: HOME IMPROVEMENT Geog aphy: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Occ Loans**** Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*"" Units*** Units*""
Full Review:
Atlanta MSA 4 36.36 3.84 0.00 16.00 0.00 28.81 0.00 51.35 100.00 2.73 12.92 26.85 57.51
Limited Review:
GA Non-MSA 2 18.18 0.00 0.00 16.22 0.00 56.60 100.00 27.17 0.00 0.00 22.22 49.21 28.57
Athens MSA 4 36.36 0.00 0.00 44.41 50.00 55.59 50.00 0.00 0.00 0.00 29.27 70.73 0.00
Savannah MSA 1 9.09 5.58 0.00 21.21 100.00 33.46 0.00 39.75 0.00 5.41 25.14 29.73 39.73

"" Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
365
Table 4a. Geo ra hic Distribution of Home Mortgage Refinance Loans
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Occ Units". Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units"** Unite' Units***
Full Review:
Atlanta MSA 20 34.48 3.84 0.00 16.00 5.00 28.81 20.00 51.35 75.00 2.63 12.86 30.50 54.00
Limited Review:
GA Non-MSA 23 39.66 0.00 0.00 16.22 26.09 56.60 52.17 27.17 21.74 0.00 14.46 55.61 29.93
Athens MSA 9 15.52 0.00 0.00 44.41 44.44 55.59 55.56 0.00 0.00 0.00 37.92 62.08 0.00
Savannah MSA 6 10.34 5.58 0.00 21.21 0.00 33.46 50.00 39.75 50.00 2.95 16.52 36.22 44.30

Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
366
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
... ",,
Loans
Full Review:
Atlanta MSA 598 72.22 5.79 5.52 18.59 14.21 26.21 18.90 48.69 61.37 4.78 17.33 24.95 52.95
Limited Review:
GA Non-MSA 153 18.48 0.00 0.00 25.91 17.65 52.19 62.09 21.89 20.26 0.00 22.34 54.29 23.37
Athens MSA 48 5.80 0.00 0.00 39.77 47.92 60.23 52.08 0.00 0.00 0.00 41.74 58.26 0.00
Savannah MSA 29 3.50 8.86 10.34 23.67 27.59 33.88 31.03 33.16 31.03 9.83 21.87 33.51 34.79

367
Geographic Distribution: SMALL LOANS TO FARMS Geog aphy: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans . Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income*
Geog, aphies Geographies Geographies Geographies
Total- Farms- Loans Farms** Loans Farms** Loans Farms*" Loans Low Mod Mid Upp
Full Review:
Atlanta MSA 0 0.00 4.22 0.00 16.19 0.00 30.69 0.00 48.78 0.00 1.19 11.31 24.40 63.10
Limited Review:
GA Non-MSA 11 47.83 0.00 0.00 10.88 18.18 56.46 36.36 32.65 45.45 0.00 16.90 52.11 30.99
Athens MSA 12 52.17 0.00 0.00 51.52 33.33 48.48 66.67 0.00 0.00 0.00 52.50 47.50 0.00
Savannah MSA 0 0.00 5.26 0.00 23.95 0.00 39.21 0.00 31.58 0.00 7.14 3.57 10.71 78.57

368
Borrower Distribution: HOME PURCHASE Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families' Loans- Loans**** Families*** Loans"""" Families*** Loans**** Low Mod Mid Upp
Full Review:
Atlanta MSA 36 40,91 21.81 6.67 15.46 20.00 16.76 16.67 45.97 56.67 4.86 18.20 22.98 53.96
Limited Review:
GA Non-MSA 31 35,23 21.45 3.45 18.40 34.48 17.22 17.24 42.93 44.83 3.14 16.99 23.53 56.34
Athens MSA 9 10.23 26.36 33.33 18.53 22.22 20.06 11.11 35.05 33.33 10.43 33.33 30.03 26.21
Savannah MSA 12 13.64 25.13 8.33 16.55 0.00 20.16 8.33 38.16 83.33 4.84 18.55 27.47 49.13

" Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
369
Borrower Distribution: HOME IMPROVEMENT Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Pp

Total** Families*** Loans- Families14 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Atlanta MSA 4 36.36 21.81 0.00 15,46 0.00 16.76 0.00 45.97 100.00 4.79 13.71 19.95 61.54
Limited Review:
GA Non-MSA 2 18.18 21.45 0.00 18.40 0.00 17.22 50.00 42.93 50.00 0.00 11.67 16.67 71.67
Athens MSA 4 36.36 26.36 0.00 18.53 25.00 20.06 75.00 35,05 0.00 17.50 10.00 42.50 30.00
Savannah MSA 1 9.09 25.13 0.00 16.55 0.00 20.16 0.00 38.16 100.00 6.61 16.09 25.29 52.01

**Home improvement loans originated and purchased in the MAJAA as a percentage of all home improvement loans originated and purchased in the rated area.
****As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
370
6R -
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families*** Loans- Families15 Loans**** Families*** Loans"' Families*** Loans**** Low Mod Mid Upp
Full Review:
Atlanta MSA 20 34.48 21.81 0.00 15.46 10.00 16.76 25.00 45.97 65.00 6,48 15.39 22.11 56.02
Limited Review:
GA Non-MSA 23 39.66 21,45 4.55 18.40 4.55 17.22 22.73 42,93 68.18 7,19 11.76 18.95 62.09
Athens MSA 9 15.52 26.36 0.00 18.53 22.22 20,06 22.22 35.05 55.56 7.10 20.77 27.32 44.81
Savannah MSA 6 10.34 25.13 0.00 16.55 20.00 20,16 20.00 38.16 60.00 8.49 15.02 24.62 51.86

371
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Atlanta MSA 599 72.26 87.46 63.94 74.79 12.35 12.85 114,003 60,497
Limited Review:
GA Non-MSA 153 18.46 82.20 79.74 90.85 7.19 1.96 1,083 484
Athens MSA 48 5.79 89.84 89.58 97.92 2.08 0.00 337 161
Savannah MSA 29 3.50 81.88 62.07 79.31 6.90 13.79 6,059 2,814

372
Borrower Distribution: SMALL LOANS TO FARMS Geography: GEORGIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms- % BANK Loans"- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Atlanta MSA 0 0.00 94.59 0.00 0.00 0.00 0.00 171 99
Limited Review:
GA Non-MSA 11 47.83 96.94 90.91 90.91 9.09 0.00 71 25
Athens MSA 12 52.17 97.73 83.33 83.33 16.67 0.00 41 21
Savannah MSA 0 0.00 95.26 0.00 0.00 0.00 0.00 29 9

" Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the rated area.
- Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
373
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: GEORGIA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019
of # of % of Location of Branches by Net change in Location of Branches % of Population within Each Geography
Assessment Area: Rated BANK Rated Income of Geographies %) # of # of (+ or - ) 1

in AA in AA
Full Review:
Atlanta MSA 69.0 14 60.87 7.14 0.00 28.57 64.29 1 0 0 0 +1 0 8.89 21.79 27.59 41.30
Limited Review:
GA Non-MSA 18.5 5 21.74 20.00 0.00 60.00 20.00 0 1 0 0 -1 0 0.00 18.52 55.02 26.47
Athens MSA 8.7 3 13.04 0.00 33.33 66.67 0.00 0 1 0 0 -1 0 0.00 41.75 58.25 0.00
Savannah MSA 3.8 1 4.35 0.00 0.00 0.00 100.0 0 0 0 0 0 0 10.13 29.80 28.99 31.07
374
LENDING VOLUME Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA-
Full Review:
Jacksonville MSA 28.81 11 3,476 197 18,942 0 0 0 0 208 22,418 19.3
West Palm Beach MSA 22.85 10 7,026 155 17,025 0 0 5 125 165 24,051 223
Limited Review:
Cape Coral MSA 9.28 0 0 67 9,850 0 0 0 0 67 9,850 14.3
Fort Lauderdale MSA 15.24 5 3,576 104 10,373 1 49 0 0 110 13,998 12.1
Miami MSA 9.97 2 1,028 70 7,677 0 0 2 3,790 72 8,705 9.2
Naples MSA 6.51 1 775 46 5,503 0 0 0 0 47 6,278 12.5
North Port -Sarasota MSA 2.22 3 1,014 13 3,960 0 0 0 0 16 4,974 6.6
Port St Lucie MSA 5.12 3 595 34 4,667 0 0 1 45 - 37 5,262 3.7
375
Geographic Distribution: HOME PURCHASE Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
West Palm Beach MSA 7 30.43 3.15 0.00 23.40 0.00 32.80 42,86 40.66 57.14 2.81 22.41 35.27 39.51
Limited Review:
Cape Coral MSA 0 0.00 2.08 0.00 18.59 0.00 44.21 0.00 35.12 0.00 1.71 21.71 44.52 32.05
Fort Lauderdale MSA 3 13.04 2.79 33.33 24.85 0.00 33.99 0.00 38.37 66.67 3.06 23.04 35.20 38.70
Miami MSA 1 4.35 1.99 0.00 21.50 100.00 31.99 0.00 44.52 0.00 1.54 19.97 31.96 46.53
Naples MSA 1 4.35 2.27 0.00 16.31 0.00 41.34 100.00 40,09 0.00 1.32 17.26 41.79 39.64
North Port -Sarasota MSA 2 8.70 1.04 0.00 18.34 0.00 50.74 50.00 29.88 50.00 0.65 13.25 45.39 40.71
Port St Lucie MSA 2 8.70 0.00 0.00 6.97 0.00 36.25 50.00 56.78 50.00 0.00 4.49 34.21 61.30

376
Geographic Distribution: HOME IMPROVEMENT Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: It % of % Owner % BANK % Owner % BANK % Owner % BANK % Owner % BANK
Units- Units*** Units"" Units***
Full Review:
West Palm Beach MSA 0 0.00 3.15 0.00 23.40 0.00 32.80 0.00 40.66 0.00 2.73 17.92 35.98 43.36
Limited Review:
Cape Coral MSA 0 0.00 2.08 0.00 18.59 0.00 44.21 0.00 35.12 0.00 1.64 17.49 53.04 27.83
Miami MSA 0 0.00 1.99 0.00 21.50 0.00 31.99 0.00 44.52 0.00 1.66 19.83 30.22 48.28
Naples MSA 0 0.00 2.27 0.00 16.31 0.00 41.34 0.00 40.09 0.00 0.46 16.63 44.11 38.80
Port St Lucie MSA 0 0.00 0.00 0.00 6.97 0.00 36.25 0.00 56.78 0.00 0.00 4.76 34.73 60.50

377
Table 4a. Geographic Distribution of Home Mort a e Refinance Loans
Geographic Distribution: HOME MORTGAGE REFINANCE Geog aphy: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Limited Review:
Cape Coral MSA 0 0.00 2.08 0.00 18.59 0.00 44.21 0.00 35.12 0.00 1.10 17.18 50.12 31.60
Miami MSA 1 9.09 1.99 0.00 21.50 0.00 31.99 0.00 44.52 100.00 1.19 17.05 31.97 49.80
Naples MSA 0 0.00 2.27 0.00 16.31 0.00 41.34 0.00 40.09 0.00 0.95 15.82 44.77 38.45
Port St Lucie MSA 1 9.09 0.00 0.00 6.97 0.00 36.25 0.00 56.78 100.00 0.00 4.50 32.68 62.82

"" Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
378
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Business Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income'
Total- Businesses BANK Businesses*** Loans Businesses Loans Businesses** Loans Low Mod Mid Upp
- Loans
",,
Full Review:
Limited Review:
Cape Coral MSA 67 9.80 2.71 2.99 21.66 17.91 40.11 37.31 35.34 41.79 2.22 22.26 39.03 36.49
Miami MSA 68 9.94 3.09 5.88 21.32 22.06 25.86 26.47 47.40 45.59 3.04 21.47 25.73 49.75
Naples MSA 46 6.73 2.89 0.00 12.99 19.57 39.31 34.78 44.81 45.65 2.74 10.83 39.63 46.80
Port St Lucie MSA 34 4.97 0.00 0.00 15.23 47.06 34.50 32.35 50.27 20.59 0.00 18.68 31.71 49.60

** Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
379
Table 7a. Geo ra hic Distribution of Small Loans to Farms
Geographic Distribution: SMALL LOANS TO FARMS Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geogaphies Geographies Geographies Geographies
Total" Farms*" Loans Farms*" Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Limited Review:
Cape Coral MSA 0 0.00 2.95 0.00 25.53 0.00 46.16 0.00 25.32 0.00 1.49 14.93 44.78 38.81
Miami MSA 0 0.00 3.27 0.00 22.70 0.00 26.95 0.00 46.36 0.00 1.59 14.68 20.24 63.49
Naples MSA 0 0.00 5.39 0.00 19.71 0.00 44.25 0.00 30.65 0.00 24.32 18.92 24.32 32.43
North Port -Sarasota 0 0.00 1.82 0.00 18.99 0.00 43.64 0.00 35.55 0.00 0.00 11.29 25.81 62.90
MSA
Port St Lucie MSA 0 0.00 0.00 0.00 22.07 0.00 26.62 0.00 51.31 0.00 0.00 33.33 3.70 62.96

380
Borrower Distribution: HOME PURCHASE Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families* Loans-- Loans*""" Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
West Palm Beach MSA 7 30.43 22,78 0.00 17.32 33.33 17.83 0.00 42.07 66.67 3.46 17.03 23.40 56.11
Limited Review:
Cape Coral MSA 0 0.00 20.74 0.00 18.49 0.00 19.65 0.00 41.11 0.00 2.36 16.97 23.40 57.27
Miami MSA 1 4.35 24,02 0.00 16,55 0.00 16.88 0.00 42.55 0.00 0.56 6.31 21.84 71.30
Naples MSA 1 4.35 20.85 0.00 17.67 0.00 19.30 0.00 42.19 100.00 2.22 12.80 18.84 66.14
MSA
Port St Lucie MSA 2 8.70 14,29 0.00 17.10 0.00 17.47 50.00 51.14 50.00 2.27 10.12 19.18 68.43

381
Borrower Distribution: HOME IMPROVEMENT Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families*** Loans"- Families17 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Limited Review:
Cape Coral MSA 0 0.00 20.74 0.00 18.49 0.00 19.65 0.00 41.11 0.00 5.80 15.77 25.92 52.51
Miami MSA 0 0.00 24.02 0.00 16.55 0.00 16.88 0.00 42.55 0.00 3.63 8.59 17.76 70.03
Naples MSA 0 0.00 20.85 0.00 17.67 0.00 19.30 0.00 42.19 0.00 4.32 16.31 22.78 56.59
MSA
Port St Lucie MSA 0 0.00 14.29 0.00 17.10 0.00 17.47 0.00 51.14 0.00 4.06 10.43 16.23 69.28

382
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of °A % BANK % % BANK % % BANK % % BANK
Total- Families- Loans-- Families18 Loans"- Families*** Loans**** Families' Loans"' Low Mod Mid Upp
Full Review:
Jacksonville MSA 4 36.36 22.75 0.00 17.03 25.00 19.54 0.00 40.67 75.00 7,91 17.33 24.59 50.17
West Palm Beach 2 18.18 22.78 0.00 17.32 0.00 17.83 50.00 42,07 50.00 6.87 16.12 23.20 53.80
MSA
Limited Review:
Cape Coral MSA 0 0.00 20.74 0.00 18.49 0.00 19.65 0.00 41.11 0.00 6.16 17.97 24.32 51.54
Fort Lauderdale MSA 2 18.18 22.25 0.00 17.32 0.00 18.73 0.00 41.69 100.00 5,37 14.09 22.80 57.74
Miami MSA 1 9.09 24,02 0,00 16.55 0.00 16.88 0.00 42,55 100.00 3.20 8.57 19.01 69.22
Naples MSA 0 0.00 20.85 0.00 17.67 0.00 19.30 0.00 42.19 0.00 5.63 15.36 22.22 56.79
North Port -Sarasota 1 9.09 19.41 0.00 19.10 0.00 20,99 0.00 40.50 100.00 9,36 20.56 24.32 45.76
MSA
Port St Lucie MSA 1 9.09 14.29 0.00 17.10 0.00 17.47 0.00 51.14 100.00 4.98 10.35 21.40 63.27

383
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses- % BANK Loans'". $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Jacksonville MSA 197 28.72 87.81 70.56 81.73 8.63 9.64 25,071 12,734
West Palm Beach MSA 155 22.59 90.97 64.52 76.13 11.61 12.26 53,902 28,515
Limited Review:
Cape Coral MSA 67 9.77 90.05 56.72 70.15 10.45 19.40 17,781 8,735
Fort Lauderdale MSA 104 15.16 91.21 62.50 75.96 13.46 10.58 71,939 37,820
Miami MSA 70 10.20 90.88 62.86 80.00 10.00 10.00 101,678 53,914
Naples MSA 46 6.71 90.89 60.87 78.26 8.70 13.04 11,377 5,711
North Port -Sarasota MSA 13 1.90 90.61 84.62 46.15 7.69 46.15 21,937 11,616
Port St Lucie MSA 34 4.96 89.79 55.88 64.71 17.65 17.65 5,498 2,753

*- Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 8.75% of
384
Borrower Distribution: SMALL LOANS TO FARMS Geography: FLORIDA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms- % BANK Loans'"" $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Jacksonville MSA 0 0.00 96.45 0.00 0.00 0.00 0.00 61 35
West Palm Beach MSA 0 0.00 95.77 0.00 0.00 0.00 0.00 157 80
Limited Review:
Cape Coral MSA 0 0.00 97.05 0.00 0.00 0.00 0.00 69 42
Fort Lauderdale MSA 1 100.00 96.98 0.00 100.00 0.00 0.00 87 57
Miami MSA 0 0.00 96.06 0.00 0.00 0.00 0.00 257 147
Naples MSA 0 0.00 94.21 0.00 0.00 0.00 0.00 37 25
North Port -Sarasota MSA 0 0.00 96.05 0.00 0.00 0.00 0.00 64 31
Port St Lucie MSA 0 0.00 95.17 0.00 0.00 0.00 0.00 27 12

-*Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
*** Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
385
Tabl 15. Distribution of Branch Delivery System and Branch Openings/Closings
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geog aphy: FLORIDA Evaluation Period: JUNE6, 2016 - MARCH 26, 2019
Assessment Area: Rated BANK Rated Income of Geographies_(%) # of # of (+ or - )
in AA in AA
Full Review:
Jacksonville MSA 19.3 4 25.00 0.00 0.00 0.00 100.0 0 0 0 0 0 0 6.54 25.02 35.79 32.65
West Palm Beach MSA 22.3 3 18.75 0.00 33.33 66.67 0.00 1 2 0 +1 -1 -1 7.30 27.47 30.87 33.93
Limited Review:
Cape Coral MSA 14.3 2 12.5 0.00 0.00 50.00 50.00 0 0 0 0 0 0 4.68 27.13 42.27 25,92
Fort Lauderdale MSA 12.1 2 12.5 0.00 0.00 0.00 100.0 0 0 0 0 0 0 5.06 28.93 32.71 33.29
Miami MSA 9.2 1 6.25 0.00 0.00 0.00 100.0 0 0 0 0 0 0 5.50 29.65 30.91 33.20
Naples MSA 12.5 2 12.5 0.00 0.00 50.00 50.00 0 0 0 0 0 0 7.15 23.51 38.00 31.34
North Port -Sarasota MSA 6.6 1 6.25 0.00 0.00 0.00 100.0 1 1 0 -1 0 0 2.78 23.65 47.54 26.02
Port St Lucie MSA 3.7 1 6.25 0.00 100.0 0.00 0.00 0 0 0 0 0 0 0.00 14.83 35.27 49.91
386
LENDING VOLUME Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Assessment Area (2017): MA/AA' # $ (000's) # $ (000's) # $ (000's) # $ (000's) 4 $(000's)
Full Review:
Austin MSA 57.55 8 3,378 213 24,692 0 0 4 6,920 221 28,070 65.3
Limited Review:
Dallas MSA 11.46 0 0 44 3,520 0 0 4 150 44 3,520 15.4
Houston MSA 30.99 1 115 118 4,871 0 0 3 150 119 4,986 19.3
- The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
387
Geographic Distribution: HOME PURCHASE Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units"** Units*"" Units"'
Full Review:
Austin MSA 6 85.71 4.36 0.00 15.07 0.00 37.88 16.67 42.68 83.33 3.88 12.71 41.78 41.63
Limited Review:
Dallas MSA 0 0.00 10.01 0.00 33.46 0.00 25.66 0.00 30.88 0.00 9.63 26.53 29.54 34.30
Houston MSA 1 14.29 6.39 0.00 22.71 100.00 27.43 0.00 43.46 0.00 2.95 13.50 27.95 55.60

388
Geographic Distribution: HOME IMPROVEMENT Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units- Units"** Units*** Units**"
Full Review:
Austin MSA 0 0.00 4.36 0.00 15.07 0.00 37.88 0.00 42.68 0.00 3.80 12.96 39.16 44.08
Limited Review:
Dallas MSA 0 0.00 10.01 0.00 33.46 0.00 25.66 0.00 30.88 0.00 6.23 25.44 27.11 41.23
Houston MSA 0 0.00 6.39 0.00 22.71 0.00 27.43 0.00 43.46 0.00 4.68 18.25 25.86 51.21

389
Table 4a. Geoctraphic Distribution of Home Mort a e Refinance Loans
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Occ Units- Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units- Units*** Units***
Full Review:
Austin MSA 2 100.00 4.36 0.00 15.07 0.00 37.88 0.00 42.68 100.00 3.54 13.57 40.48 42.41
Limited Review:
Dallas MSA 0 0.00 10.01 0.00 33.46 0.00 25.66 0.00 30.88 0.00 5.13 25.87 30.87 38.13
Houston MSA 0 0.00 6.39 0.00 22.71 0.00 27.43 0.00 43.46 0.00 2.99 15.70 30.60 50.71

-"Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
390
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Geogra hies Geographies Geographies Geographies
Total- Businesses BANK Businesses*"" Loans Businesses Loans Businesses** Loans Low Mod Mid Upp
..* ***
Loans
Full Review:
Austin MSA 211 56.87 7.02 6.16 12.42 9.00 31.82 33.65 47.28 51.18 7.50 13.22 33.27 46.01
Limited Review:
Dallas MSA 44 11.86 10.70 22.73 27.26 9.09 25.80 15.91 34.91 52.27 11.18 28.53 25.41 34.88
Houston MSA 116 31.27 11.78 6.90 20.19 13.79 21.74 23.28 46.05 56.03 11.77 19.83 22.15 46.26

Small loans to businesses originated and purchased in the MAJAA as a percentage of all small loans to businesses originated and purchased in the rated area.
391
Geographic Distribution: SMALL LOANS TO FARMS Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate Lending (%) by Tract Income*
Total** Farms- Loans Farms** Loans Farms** Loans Farms- Loans Low Mod Mid Upp
Full Review:
Austin MSA 0 0.00 5.29 0.00 15.09 0.00 37.16 0.00 42.10 0.00 3.83 24.90 42.91 28.35
Limited Review:
Dallas MSA 0 0.00 9.93 0.00 28.82 0.00 24.88 0.00 35.49 0.00 7.34 22.02 18.35 52.29
Houston MSA 0 0.00 7.33 0.00 18.29 0.00 26.10 0.00 48.19 0.00 5.17 11.24 28.99 54.61

**Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the ratedarea.
392
Borrower Distribution: HOME PURCHASE Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families* Loans- Loans**"* Families*** Loans**** Families*** Loans-- Low Mod Mid Upp
Full Review:
Austin MSA 6 85.71 22.12 0.00 16.25 20.00 19.59 0.00 42.03 80.00 3.22 16.22 23.47 57.09
Limited Review:
Dallas MSA 0 0.00 31.52 0.00 18.94 0.00 17.37 0.00 32.17 0.00 6.07 19.43 22.04 52.47
Houston MSA 1 14.29 25.67 0.00 16.39 0.00 16.88 0.00 41.06 0.00 3.74 16.53 23.79 55.94

393
Borrower Distribution: HOME IMPROVEMENT Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families- Loans- Families20 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Austin MSA 0 0.00 22.12 0.00 16.25 0.00 19.59 0.00 42.03 0.00 5.87 15.31 22.04 56.79
Limited Review:
Dallas MSA 0 0.00 31.52 0.00 18.94 0.00 17.37 0.00 32.17 0.00 8.52 17.17 22.85 51.46
Houston MSA 0 0.00 25.67 0.00 16.39 0.00 16.88 0.00 41.06 0.00 6.99 12.54 18.42 62.05

Home improvement loans originated and purchased in the MAJAA as a percentage of all home improvement loans originated and purchased in the rated area.
394
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of °/.0 % BANK % % BANK % % BANK % % BANK
Total- Families*** Loans- Families21 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Austin MSA 2 100.00 22.12 0.00 16.25 0.00 19.59 0.00 42.03 100.00 5.76 17.17 22.73 54.35
Limited Review:
Dallas MSA 0 0.00 31.52 0.00 18.94 0.00 17.37 0.00 32.17 0.00 9.03 17.48 24.10 49.39
Houston MSA 0 0.00 25.67 0.00 16.39 0.00 16,88 0.00 41.06 0.00 6.97 14.87 23.37 54.80

395
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses- % BANK Loans* $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Austin MSA 213 56.80 85.86 50.70 77,46 10.80 11.74 45,032 22,626
Limited Review:
Dallas MSA 44 11.73 83.82 59.09 88.64 2.27 9.09 59,476 26,094
Houston MSA 118 31.47 84.99 77.97 94.92 3.39 1.69 123,072 56,068

396
Borrower Distribution: SMALL LOANS TO FARMS Geography: TEXAS Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms- % BANK Loans"- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Austin MSA 0 0.00 95.75 0.00 0.00 0.00 0.00 266 158
Limited Review:
Dallas MSA 0 0.00 94.14 0.00 0.00 0.00 0.00 111 56
Houston MSA 0 0.00 94.18 0.00 0.00 0.00 0.00 461 256

**** Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
397
Table 15. Distribution of Branch Delivery System and Branch 0 enin s/Closin s
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: TEXAS Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

Deposits Branche Low Mod Mid Upp Openings Closings Low Mod Mid Upp Low Mod Mid Upp
in AA sinAA
Full Review:
Austin MSA 65.3 3 42.86 0.00 0.00 0.00 100.00 0 0 0 0 0 0 11.21 19.39 35.43 32.68
Limited Review:
Dallas MSA 15.4 2 28.57 0.00 0.00 0.00 100.00 1 1 0 0 0 0 19.04 37.93 22.38 20.48
Houston MSA 19.3 2 28.57 0.00 0.00 0.00 100.00 0 0 0 0 0 0 13.96 27.80 25.59 32.27
398
LENDING VOLUME Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

Area Loans Home Mortgage Small Loans to Businesses Small Loans to Farms Loans- Total Reported Loans Deposits in
(#) in MA/AA"'
Full Review:
Phoenix MSA 92.7 14 7,853 254 39,774 0 0 2 70 268 47,627 97.8
Limited Review:
Tucson MSA 7.3 2 1,252 19 2,289 0 0 0 0 21 3,541 2.2
399
Geographic Distribution: HOME PURCHASE Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units"' Units*** Units*** Units***
Full Review:
Phoenix MSA 9 81.82 4.55 0.00 18.85 0.00 34.69 11.11 41.91 88.89 4.18 16.37 36.49 42.96
Limited Review:
Tucson MSA 2 18.18 4.73 0.00 21.42 0.00 32.88 0.00 40.97 100.00 3.50 15.69 32.64 48.17

*" Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
400
Geographic Distribution: HOME IMPROVEMENT Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle- ncome Upper- ncome Aggregate HMDA Lending (%) by Tract Income*
Total** Occ Loans"- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*"" Units*** Units***
Full Review:
Phoenix MSA 0 0.00 4.55 0.00 18.85 0.00 34.69 0.00 41.91 0.00 3.25 14.23 34.05 48.47
Limited Review:
Tucson MSA 0 0.00 4.73 0.00 21.42 0.00 32.88 0.00 40.97 0.00 3.17 13.85 34.67 48.31

Home improvement loans originated and purchased in the MA/AA as a percentage of all home improvement loans originated and purchased in the rated area.
*** Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
401
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Occ Units*" Loans"- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Phoenix MSA 4 100.00 4.55 0.00 18.85 0.00 34.69 50.00 41.91 50.00 3.02 14.80 35.36 46.82
Limited Review:
Tucson MSA 0 0.00 4.73 0.00 21.42 0.00 32.88 0.00 40.97 0.00 3.42 16.20 33.36 47.02

402
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % of % of % BANK % of % BANK % of % BANK
.
%
...
Loans
Full Review:
Phoenix MSA 252 92.99 6.55 5.95 16.20 6.35 28.22 27.78 48.47 59.92 7.19 16.84 27.15 48.83
Limited Review:
Tucson MSA 19 7.01 6.26 15.79 23.65 21.05 29.69 15.79 39.36 47.37 6.56 25.81 29.66 37.97

403
Geographic Distribution: SMALL LOANS TO FARMS Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate Lending %) by Tract Income*
Total- Farms- Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Phoenix MSA 0 0.00 5.77 0.00 18.90 0.00 29.24 0.00 45.71 0.00 3.44 17.50 28.75 50.31
Limited Review:
Tucson MSA 0 0.00 4.38 0.00 22.09 0.00 34.54 0.00 38.78 0.00 1.49 7.46 61.19 29.85

-*Source Data - Dun and Bradstreet (2017).
404
Borrower Distribution: HOME PURCHASE Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Families' Loans* Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Phoenix MSA 9 81.82 21.77 0.00 16.87 0.00 19.18 22.22 42.18 77.78 5.29 18.34 26.63 49.73
Limited Review:
Tucson MSA 2 18.18 22.19 0.00 17.33 0.00 19.11 0.00 41.37 100.00 5.85 19.30 26.11 48.74
fr.

405
Borrower Distribution: HOME IMPROVEMENT Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families*** Loans- Families23 Loans**** Families"** Loans***" Families""* Loans"""* Low Mod Mid Upp
Full Review:
Phoenix MSA 0 0.00 21.77 0.00 16.87 0.00 19.18 0.00 42.18 0.00 6.67 15.42 22.39 55.52
Limited Review:
Tucson MSA 0 0.00 22.19 0.00 17.33 0.00 19.11 0.00 41.37 0.00 6.43 15.90 23.64 54.03

406
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Phoenix MSA 4 100.00 21.77 0.00 16.87 0.00 19.18 25.00 42.18 75.00 7.81 17.83 25.87 48.48
Limited Review:
Tucson MSA 0 0.00 22.19 0.00 17.33 0.00 19.11 0.00 41.37 0.00 7.96 17.08 24.69 50.28

" Home refinance loans originated and purchased in the MAJAA as a percentage of all home refinance loans originated and purchased in the rated area.
407
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses- % BANK Loans*- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Phoenix MSA 254 93.04 87.74 52.76 65.75 14.17 20.08 96,633 48,792
Limited Review:
Tucson MSA 19 6.96 86.03 63.16 73.68 10.53 15.79 17,027 8,399

*- Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 9.52% of
408
Borrower Distribution: SMALL LOANS TO FARMS Geography: ARIZONA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: % of Total- % of Farms- % BANK Loans"" >$250,000 to
# $100,000 or less >$100,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Phoenix MSA 0 0.00 93.86 0.00 0.00 0.00 0.00 333 160
Limited Review:
Tucson MSA 0 0.00 95.69 0.00 0.00 0.00 0.00 71 31

409
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geog aphy: ARIZONA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Phoenix MSA 97.80 2 66.67 0.00 0.00 0.00 100.00 0 0 0 0 0 0 11.08 22.91 31.29 34.41
Limited Review:
Tucson MSA 2,20 1* 33.33 0.00 0.00 0.00 0.00 1* 0 0 0 0 0 9.06 27.07 31.24 32.10
* The Tucson branch is new since the last evaluation and is located in a geography with no income designation.
410
LENDING VOLUME Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA***
Assessment Area (2017): MA/AA" # $ (000's) # $ (000's) # $ (000's) # $ (000's) # $(000's)
Full Review:
Seattle MSA 59.37 4 2,539 183 22,923 0 0 3 2,622 187 25,462 33.6
Limited Review:
Olympia MSA 14.92 0 0 47 3,623 0 0 1 40 47 3,623 34.5
Tacoma MSA 25.71 1 280 80 9,496 0 0 1 50 81 9,776 31.9
411
Geographic Distribution: HOME PURCHASE Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % Owner % BANK % Owner `)/0 BANK % Owner % BANK % Owner % BANK
Full Review:
Seattle MSA 1 50.00 2.69 0.00 15.23 0.00 40.38 0.00 41.70 100.00 2.90 16.51 42.45 38.14
Limited Review:
Olympia MSA 0 0.00 0.00 0.00 18.04 0.00 54.80 0.00 27.16 0.00 0.00 18.77 55.93 25.30
Tacoma MSA 1 50.00 1.42 0.00 16.59 0.00 51.25 0.00 30.74 100.00 1.29 17.59 51.65 29.47

412
Geographic Distribution: HOME IMPROVEMENT Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units*"" Units"*" Units*""
Full Review:
Seattle MSA 0 0.00 2.69 0.00 15.23 0.00 40.38 0.00 41.70 0.00 2.25 16.80 41.89 39.06
Limited Review:
Olympia MSA 0 0.00 0.00 0.00 18.04 0.00 54.80 0.00 27.16 0.00 0.00 20.37 54.80 24.82
Tacoma MSA 0 0.00 1.42 0.00 16.59 0.00 51.25 0.00 30.74 0.00 0.93 15.87 49.02 34.18

413
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Seattle MSA 3 100.00 2.69 0.00 15.23 33.33 40.38 0.00 41.70 66.67 2.59 17.06 41.52 38.83
Limited Review:
Olympia MSA 0 0.00 0.00 0.00 18.04 0.00 54.80 0.00 27.16 0.00 0.00 15.84 58.69 25.47
Tacoma MSA 0 0.00 1.42 0.00 16.59 0.00 51.25 0.00 30.74 0.00 1.02 18.11 52.03 28.84

**Home refinance loans originated and purchased in the MA/AA as a percentage of all home refinance loans originated and purchased in the rated area.
414
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Business Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending (%) by Tract Income'
Total"
.
Businesses BANK
Loans
Businesses*** Loans
-
Businesses Loans Businesses** Loans Low Mod Mid Upp
Full Review:
Seattle MSA 183 59.03 5.29 3.28 16.28 17.49 34.70 33.88 43.15 45.36 5.45 16.06 35.65 42.84
Limited Review:
Olympia MSA 47 15.16 0.00 0.00 25.44 40.43 53.89 53.19 20.67 6.38 0.00 23.35 53.45 23.20
Tacoma MSA 80 25.81 5.33 6.25 20.29 6.25 48.06 60.00 26.31 27.50 4.51 18.71 48.35 28.44

"Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
415
Geographic Distribution: SMALL LOANS TO FARMS Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geographies Geographies Geographies Geographies
Total** Farms*" Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Seattle MSA 0 0.00 3.35 0.00 14.41 0.00 41.21 0.00 40.86 0.00 0.64 5.13 56.41 37.82
Limited Review:
Olympia MSA 0 0.00 0.00 0.00 22.54 0.00 47.14 0.00 30.32 0.00 0.00 32.50 32.50 35.00
Tacoma MSA 0 0.00 2.24 0.00 17.65 0.00 51.35 0.00 28.76 0.00 1.54 9.23 41.54 47.69

416
Borrower Distribution: HOME PURCHASE Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Families* Loans- Loans**** Families*** Loans**** Families*** Loans"*" Low Mod Mid Upp
Full Review:
Seattle MSA 1 50.00 21.00 0.00 16.39 0.00 19.48 0.00 43.14 0.00 2.89 13.31 22.29 61.50
Limited Review:
Olympia MSA 0 0.00 19.72 0.00 17.75 0.00 23.55 0.00 38.97 0.00 3.29 22.24 33.82 40.65
Tacoma MSA 1 50.00 20.24 0.00 18.01 0.00 21,50 100.00 40.25 0.00 2.71 20.01 33.07 44.22

417
Borrower Distribution: HOME IMPROVEMENT Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families- Loans- Families26 Loans**** Families""" Loans"""" Families*"" Loans**** Low Mod Mid Upp
Full Review:
Seattle MSA 0 0.00 21.00 0.00 16.39 0.00 19.48 0.00 43.14 0.00 5.41 17.98 25.91 50.70
Limited Review:
Olympia MSA 0 0.00 19.72 0.00 17.75 0.00 23.55 0.00 38,97 0.00 6.28 17.15 33.33 43.24
Tacoma MSA 0 0.00 20.24 0.00 18.01 0.00 21.50 0.00 40.25 0.00 4.10 15.70 30.18 50.03

418
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families- Loans- Families27 Loans"*"* Families"** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Seattle MSA 3 100.00 21.00 0.00 16.39 0.00 19.48 0.00 43,14 100.00 5,72 17.92 25.28 51.07
Limited Review:
Olympia MSA 0 0.00 19,72 0.00 17.75 0.00 23.55 0.00 38.97 0.00 6.97 18.61 30.07 44.34
Tacoma MSA 0 0.00 20.24 0.00 18.01 0.00 21.50 0.00 40.25 0.00 5.27 17.65 29.97 47.12

419
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses*** % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Seattle MSA 183 59.03 85.36 56.28 74.32 13.11 12.57 53,058 26,729
Limited Review:
Olympia MSA 47 15.16 84.85 78.72 85.11 4.26 10.64 3,911 1,967
Tacoma MSA 80 25.81 85.21 63.75 80.00 2.50 17.50 13,580 6,746

***Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
**** Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 2.58% of
420
Borrower Distribution: SMALL LOANS TO FARMS Geography: WASHINGTON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Seattle MSA 0 0.00 94.87 0.00 0.00 0.00 0.00 166 94
Limited Review:
Olympia MSA 0 0.00 96.03 0.00 0.00 0.00 0.00 43 24
Tacoma MSA 0 0.00 94.58 0.00 0.00 0.00 0.00 69 32

** Small loans to farms originated and purchased in the MA/AA as a percentage of all small loans to farms originated and purchased in the rated area.
421
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: WASHINGTON Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

°A) of # of % of Location of Branches by Net change in Location of Branches % of Population within Each Geography
in AA in AA
Full Review:
Seattle MSA 33.6 3 50.00 33.33 0.00 0.00 66.67 1 0 +1 0 0 0 5.13 20.53 38.03 35.93
Limited Review:
Olympia MSA 34.5 1 16.67 0.00 100.00 0.00 0.00 0 2 0 0 -2 0 0.00 20.86 57.28 21.86
Tacoma MSA 31.9 2 33.33 0.00 0.00 100.00 0.00 0 0 0 0 0 0 4.38 22.28 49.05 24.10
422
LENDING VOLUME Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Denver MSA 81.08 10 8,232 169 12,733 1 25 . 4 175 180 20,990 90.3
Limited Review:
Boulder MSA 18.92 0 0 42 5,504 0 0 0 0 42 5,504 9.7
423
Geographic Distribution: HOME PURCHASE Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Occ Loans"" Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Denver MSA 9 100.00 6.05 11.11 21.49 11.11 30.51 11.11 41.95 66.67 6.44 20.83 32.22 40.51
Limited Review:
Boulder MSA 0 0.00 3.01 0.00 18.04 0.00 45.61 0.00 33.33 0.00 3.87 18.86 47.40 29.86

** Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
424
Table 3a. Geo ra hic Distribution of Home Improvement Loans
Geographic Distribution: HOME IMPROVEMENT Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units"' Units*** Units"*" Units***
Full Review:
Denver MSA 0 0.00 6.05 0.00 21.49 0.00 30.51 0.00 41.95 0.00 6.16 22.62 31.69 39.53
Limited Review:
Boulder MSA 0 0.00 3.01 0.00 18.04 0.00 45.61 0.00 33.33 0.00 4.81 21.20 46.47 27.52

425
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Denver MSA 1 100.00 6.05 0.00 21.49 100.00 30.51 0.00 41.95 0.00 5.94 24.50 33.71 35.85
Limited Review:
Boulder MSA 0 0.00 3.01 0.00 18.04 0.00 45.61 000 33.33 0.00 4.81 20.54 46.28 28.37

**Home refinance loans originated and purchased in the MAIAA as a percentage of all home refinance loans originated and purchased in the rated area.
426
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
*If *
." Loans
Full Review:
Denver MSA 169 80.09 8.29 3.55 18.90 15.98 29.54 37.28 42.85 43.20 10.29 19.84 28.85 41.03
Limited Review:
Boulder MSA 42 19.91 3.75 4.76 27.97 33.33 38.26 54.76 30.02 7.14 3.88 29.79 36.65 29.68

" Small loans to businesses originated and purchased in the MAJAA as a percentage of all small loans to businesses originated and purchased in the rated area.
427
Geographic Distribution: SMALL LOANS TO FARMS Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Farms*" Loans Farms** Loans Farms** Loans Farms"* Loans Low Mod Mid Upp
Full Review:
Denver MSA 1 100.00 9.95 0.00 19.68 0.00 29.51 0.00 40.33 100.00 1.09 11.59 42.03 45.29
Limited Review:
Boulder MSA 0 0.00 4.40 0.00 21.62 0.00 44.32 0.00 29.65 0.00 2.67 24.00 49.33 24.00

**Small loans to farms originated and purchased in the MAJAA as a percentage of all small loans to farms originated and purchased in the rated area.
428
Borrower Distribution: HOME PURCHASE Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families* Loans- Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Denver MSA 9 100.00 22.97 0.00 17.59 0.00 19.98 25.00 39.46 75.00 4.20 23.49 27.69 44.62
Limited Review:
Boulder MSA 0 0.00 22.28 0.00 17.02 0.00 19.88 0.00 40.82 0.00 5.30 16.51 22.81 55.38

429
Borrower Distribution: HOME IMPROVEMENT Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Imp ovement Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Loans Borrowers
Total** Families- Loans"" Families29 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Denver MSA 0 0.00 22.97 0.00 17.59 0.00 19.98 0.00 39.46 0.00 9.89 23.90 25.69 40.52
Limited Review:
Boulder MSA 0 0.00 22.28 0.00 17.02 0.00 19.88 0.00 40.82 0.00 11.48 19.65 27.20 41.67

430
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Denver MSA 1 100.00 22.97 0.00 17.59 0.00 19.98 0.00 39.46 0.00 9.83 26.04 27.22 36.91
Limited Review:
Boulder MSA 0 0.00 22.28 0.00 17.02 0.00 19.88 0.00 40.82 0.00 12.09 21.08 24.90 41.92

Home refinance loans originated and purchased in the MAJAA as a percentage of all home refinance loans originated and purchased in the rated area.
431
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses*" % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Denver MSA 169 80.09 88.00 59.17 86.39 7.10 6.51 58,377 30,608
Limited Review:
Boulder MSA 42 19.91 89.75 59.52 76.19 4.76 19.05 11,050 6,035

***Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
432
Borrower Distribution: SMALL LOANS TO FARMS Geography: COLORADO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms*** % BANK Loans*- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Denver MSA 1 100.00 94.81 100.00 100.00 0.00 0.00 285 187
Limited Review:
Boulder MSA 0 0.00 96.77 0.00 0.00 0.00 0.00 76 54

433
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: COLORADO Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Denver MSA 90.3 4 80.00 0.00 0.00 75.00 25.00 1 1 -1 0 +1 0 10.99 26.87 29.26 32.84
Limited Review:
Boulder MSA 9.7 1 20.00 0.00 0.00 100.0 0.00 0 0 0 0 0 0 6.75 22.25 43.09 27.91
434
LENDING VOLUME Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Chattanooga MSA 36.57 8 5,741 56 6,392 0 0 1 50 64 12,133 20.6
Knoxville MSA 44.00 4 3,629 73 11,704 0 0 1 50 77 15,333 45.4
Limited Review:
Johnson City MSA 6.29 1 312 10 917 0 0 0 0 11 1,229 8.7
Nashville MSA 13.14 9 4,284 14 1,029 0 0 2 20 23 5,313 25,3
435
Geographic Distribution: HOME PURCHASE Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units*** Units"*" Units***
Full Review:
Chattanooga MSA 7 38.89 4.24 0.00 11.70 14.29 37.16 14.29 46.90 71.43 3.06 8.89 36.52 51.53
Knoxville MSA 3 16.67 3.21 0.00 12.13 0.00 42.62 33.33 42.04 66.67 1.75 10.08 41.99 46.18
Limited Review:
Johnson City MSA 1 5.56 0.00 0.00 8.39 0.00 55.14 0.00 36.47 100.00 0.00 7.56 48.49 43.95
Nashville MSA 7 38.89 5.50 0.00 15.06 14.29 31.18 14.29 48.26 71.43 8.53 14.67 29.53 47.26

-*Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
436
Geographic Distribution: HOME IMPROVEMENT Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units- Units*** Units""* Units***
Full Review:
Chattanooga MSA 0 0.00 4.24 0.00 11.70 0.00 37.16 0.00 46.90 0.00 5.78 13.73 36.27 44.22
Knoxville MSA 1 100.00 3.21 0.00 12.13 0.00 42.62 0.00 42.04 100.00 3.93 15.82 41.88 38.37
Limited Review:
Johnson City MSA 0 0.00 0.00 0.00 8.39 0.00 55.14 0.00 36.47 0.00 0.00 11.32 50.94 37.74
Nashville MSA 0 0.00 5.50 0.00 15.06 0.00 31.18 0.00 48.26 0.00 5.98 18.43 33.80 41.79

437
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Chattanooga MSA 1 33.33 4.24 0.00 11.70 0.00 37.16 0.00 46.90 100.00 3.34 10.09 36.29 50.28
Knoxville MSA 0 0.00 3.21 0.00 12.13 0.00 42.62 0.00 42.04 0.00 2.06 9.72 42.34 45.88
Limited Review:
Johnson City MSA 0 0.00 0.00 0,00 8.39 0.00 55.14 0.00 36.47 0.00 0.00 7.72 51.83 40.45
Nashville MSA 2 66.67 5.50 0.00 15.06 0.00 31.18 0.00 48.26 100.00 6.46 15.86 30.85 46.84

438
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Businesses BANK Businesses*** Loans Businesses Loans Businesses** Loans Low Mod Mid Upp
... ***
Loans
Full Review:
Chattanooga MSA 56 36.60 8.17 3.57 15.76 12.50 35.66 37.50 40.11 46.43 8.95 13.78 35.19 42.08
Knoxville MSA 73 47.71 5.01 0.00 14,97 15.07 32.87 17.81 46.60 67.12 3.95 12.68 32.41 50.96
Limited Review:
Johnson City MSA 10 6.54 0.00 0.00 15.63 20.00 40.48 10.00 43.54 70.00 0.00 15.34 38.43 46.24
Nashville MSA 14 9.15 9.06 0.00 17.44 14.29 21.74 14.29 50.36 71.43 9.45 17.44 19.53 53.58

439
Geographic Distribution: SMALL LOANS TO FARMS Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate Lending %) by Tract Income*
Geopphies Geographies Geographies Geographies
Total** Farms- Loans Farms*" Loans Farms"" Loans Farms** Loans Low Mod Mid Upp
Full Review:
Chattanooga MSA 0 0.00 4.47 0.00 12.09 0.00 39.57 0.00 43.87 0.00 0.00 5.26 21.05 73.68
Knoxville MSA 0 0.00 2.95 0.00 12.27 0.00 39.13 0.00 44.41 0.00 0.00 15.79 36.84 47.37
Limited Review:
Johnson City MSA 0 0.00 0.00 0.00 6.78 0.00 58.90 0.00 34.32 0.00 0.00 0.00 82.98 17.02
Nashville MSA 0 0.00 4.86 0.00 15.34 0.00 26.21 0.00 52.74 0.00 4.17 9.72 11.11 75.00

440
Borrower Distribution: HOME PURCHASE Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % % BANK `)/0 Families31 % BANK % % BANK % % BANK
Total" Families' Loans-- Loans**** Families*** Loans***" Families*** Loans**** Low Mod Mid Upp
Full Review:
Chattanooga MSA 7 38.89 20.15 0.00 17.01 0.00 18.88 0.00 43.95 100.00 4.94 18.54 23.75 52.77
Knoxville MSA 3 16.67 20,07 0.00 15.38 0.00 18.86 0.00 45.69 100.00 7.28 21.85 23.85 47.03
Limited Review:
Johnson City MSA 1 5.56 19.14 0.00 14.97 0.00 21.50 0.00 44.39 100.00 4.08 15.16 25.83 54.93
Nashville MSA 7 38.89 21.45 0.00 15.37 0.00 18.03 16.67 45.15 83.33 3.75 16.23 20.96 59.06

441
Borrower Distribution: HOME IMPROVEMENT Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families*** Loans**** Families32 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Chattanooga MSA 0 0.00 20.15 0.00 17.01 0.00 18.88 0.00 43.95 0.00 9.36 19.97 20.28 50.39
Knoxville MSA 1 100.00 20.07 0.00 15.38 0.00 18.86 0.00 45.69 100.00 10.10 20.08 18.03 51.79
Limited Review:
Johnson City MSA 0 0.00 19.14 0.00 14.97 0.00 21.50 0.00 44.39 0.00 14.56 17.48 19.90 48.06
Nashville MSA 0 0.00 21.45 0.00 15.37 0.00 18.03 0.00 45.15 0.00 6.13 16.52 24.85 52.50

442
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Families*" Loans"" Families33 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Chattanooga MSA 1 33.33 20.15 0.00 17.01 0.00 18.88 0.00 43.95 100.00 7.76 16.24 25.82 50.18
Knoxville MSA 0 0.00 20.07 0.00 15.38 0.00 18.86 0.00 45.69 0.00 8.61 18.60 24.20 48.58
Limited Review:
Johnson City MSA 0 0.00 19.14 0.00 14.97 0.00 21.50 0.00 44.39 0.00 7.08 16.94 23.26 52.72
Nashville MSA 2 66.67 21.45 0.00 15.37 0.00 18.03 0.00 45.15 100.00 7.11 18.21 22.92 51.76

443
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total" % of Businesses- % BANK Loans-. $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Chattanooga MSA 56 36.60 83.14 66.07 69.64 25.00 5.36 6,492 3,003
Knoxville MSA 73 47.71 79.08 52.05 58.90 19.18 21.92 7,604 3,742
Limited Review:
Johnson City MSA 10 6.54 80.97 60.00 70.00 20.00 10.00 1,767 935
Nashville MSA 14 9.15 81.28 50.00 78.57 21.43 0.00 21,931 11,403

444
Borrower Distribution: SMALL LOANS TO FARMS Geography: TENNESSEE Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms" % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Chattanooga MSA 0 0.00 96.69 0.00 0.00 0.00 0.00 19 11
Knoxville MSA 0 0.00 93.94 0.00 0.00 0.00 0.00 19 10
Limited Review:
Johnson City MSA 0 0.00 95.34 0.00 0.00 0.00 0.00 48 43
Nashville MSA 0 0.00 93.68 0.00 0.00 0.00 0.00 74 45

Small loans to farms originated and purchased in the MAJAA as a percentage of all small loans to farms originated and purchased in the rated area.
*** Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
445
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: TENNESSEE Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Chattanooga MSA 20.6 1 16.67 0.00 0.00 100.00 0.00 0 0 0 0 0 0 8.76 13,55 35.92 41.77
Knoxville MSA 45.4 2 33.33 0.00 0.00 0.00 100.00 0 0 0 0 0 0 6.51 16.56 39.14 36.51
Limited Review:
Johnson City MSA 8,7 1 16.67 0.00 0.00 0.00 100.00 0 0 0 0 0 0 0.00 13.42 51.62 33.40
Nashville MSA 25.3 2 33.33 50.00 0.00 0.00 50.00 1 1 +1 0 0 -1 10.83 21.48 29.06 38.47
446
LENDING VOLUME Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Baltimore MSA 100.00 0 0 55 11,732 0 0 1 200 55 11,732 100.0
447
Geographic Distribution: HOME PURCHASE Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total"' Occ Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Baltimore MSA 0 0.00 0.00 0.00 8.47 0.00 37.78 0.00 53.75 0.00 0.00 9.91 42.23 47.87

A
448
Table 3a. G o ra hic Distribution of Home Improvement Loans
Geographic Distribution: HOME IMPROVEMENT Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle- ncome Upper- ncome Aggregate HMDA Lending (%) by Tract Income*
Units*** Units"* Units*** Units***
Full Review:
Baltimore MSA 0 0.00 0.00 0.00 8.47 0.00 37.78 0.00 53.75 0.00 0.00 7.79 34.41 57.79

- Home improvement loans originated and purchased in the MAJAA as a percentage of all home improvement loans originated and purchased in the rated area.
449
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units**" Units*** Units"**
Full Review:
Baltimore MSA 0 0.00 0.00 0.00 8.47 0.00 37.78 0.00 53.75 0.00 0.00 7.64 38.41 53.94

*** Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
450
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Businesses BANK Businesses"* Loans Businesses Loans Businesses** Loans Low Mod Mid Upp
... *
Loans ***
Full Review:
Baltimore MSA 55 100.00 0.00 0.00 7.39 3.64 37.26 30.91 55.13 65.45 0.00 7.23 35.99 56.78

- Small loans to businesses originated and purchased in the MAIAA as a percentage of all small loans to businesses originated and purchased in the rated area.
*** Source Data - Dun and Bradstreet (2017).
451
Geographic Distribution: SMALL LOANS TO FARMS Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Farms- Loans Farms** Loans Farms** Loans Farms"" Loans Low Mod Mid Upp
Full Review:
Baltimore MSA 0 0.00 0.00 0.00 8.48 0.00 30.66 0.00 60.74 0.00 0.00 0.00 22.73 77.27

452
Borrower Distribution: HOME PURCHASE Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families* Loans"" Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Baltimore MSA 0 0.00 14.85 0.00 15.67 0.00 20.60 0.00 48.88 0.00 5.34 22.72 28.27 43.67

** Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
453
Borrower Distribution: HOME IMPROVEMENT Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total- Families*** Loans-- Families35 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Baltimore MSA 0 0.00 14.85 0.00 15.67 0.00 20.60 0.00 48.88 0.00 8.98 17.28 23.49 50.25

454
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families-- Loans-- Families36 Loans**** Families*"* Loans"*** Families*** Loans-- Low Mod Mid Upp
Full Review:
Baltimore MSA 0 0.00 14.85 0.00 15.67 0.00 20.60 0.00 48.88 0.00 7.65 18.54 25.16 48.65

- As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK
455
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Baltimore MSA 55 100.00 83.73 40.00 45.45 27.27 27.27 11,908 5,894

"Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
**" Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
*"* Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 9.09% of
456
Borrower Distribution: SMALL LOANS TO FARMS Geography: MARYLAND Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area:
# % of Total" % of Farms- % BANK Loans*- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Baltimore MSA 0 0.00 93.96 0.00 0.00 0.00 0.00 44 21

Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
457
Table 15. Distribution of Branch Delivery System and Branch Openings/Closincts
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: MARYLAND Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Baltimore MSA 100.0 2 100.0 0.00 0.00 0.00 100.0 1* 0 0 0 0 +1 0.00 14.01 37.49 47.56
* The new branch was opened in Anne Arundel County in the latter part of 2018. As noted in the rated area analyses, the currentevaluation excluded Anne Arundel from the analyses because of the timing of
the bank's entry into the Baltimore MSA assessment area.
4 N.,
458
LENDING VOLUME Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Albuquerque MSA 75.18 2 1,119 101 15,643 0 0 3 3001 103 16,762 62.8
Limited Review:
Santa Fe MSA 24.82 0 0 34 3,706 0 0 6 1,847 34 3,706 37.2
*" The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
459
Geographic Distribution: HOME PURCHASE Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Loans**** Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units*** Units*** Units*"* Units***
Full Review:
Albuquerque MSA 2 100.00 2.77 0.00 28.49 0.00 28.61 0.00 40.14 100.00 2.25 25.04 28.90 43.81
Limited Review:
Santa Fe MSA 0 0.00 2.56 0.00 17.42 0.00 45.80 0.00 34.22 0.00 1.78 12.19 45.77 40.26

460
Geographic Distribution: HOME IMPROVEMENT Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Albuquerque MSA 0 0.00 2.77 0.00 28.49 0.00 28.61 0.00 40.14 0.00 2.89 25.85 30.11 41.15
Limited Review:
Santa Fe MSA 0 0.00 2.56 0.00 17.42 0.00 45.80 0.00 34.22 0.00 1.59 18.52 41.27 38.62

461
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Occ Units*** Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units"** Units"** Units***
Full Review:
Albuquerque MSA 0 0.00 2.77 0.00 28.49 0.00 28.61 0.00 40.14 0.00 2.14 24.47 31.04 42.35
Limited Review:
Santa Fe MSA 0 0.00 2.56 0.00 17.42 0.00 45.80 0.00 34.22 0.00 1.85 10.84 46.73 40.58

462
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Businesses BANK Businesses*** Loans Businesses Loans Businesses*" Loans Low Mod Mid Upp
... ***
Loans
Full Review:
Albuquerque MSA 101 74.81 10.87 18.81 25.61 17.82 29.74 27.72 32.76 35.64 11.97 27.49 26.12 34.42
Limited Review:
Santa Fe MSA 34 25.19 4.52 2.94 14.77 14.71 38.45 47.06 42.25 35.29 5.55 15.05 35.56 43.84

** Small loans to businesses originated and purchased in the MAJAA as a percentage of all small loans to businesses originated and purchased in the rated area.
***Source Data - Dun and Bradstreet (2017).
463
Geographic Distribution: SMALL LOANS TO FARMS Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Farms*** Loans Farms** Loans Farms** Loans Farms" Loans Low Mod Mid Upp
Full Review:
Albuquerque MSA 0 0.00 6.01 0.00 27.73 0.00 27.98 0.00 38.16 0.00 20.45 18.18 18.18 43.18
Limited Review:
Santa Fe MSA 0 0.00 1.93 0.00 18.18 0.00 45.45 0.00 34.44 0.00 0.00 0.00 82.35 17.65

464
Borrower Distribution: HOME PURCHASE Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families* Loans- Loans**** Families"** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Albuquerque MSA 2 100.00 25.10 0.00 15.34 0.00 17.81 0.00 41.76 100.00 6.65 22.91 25.62 44.82
Limited Review:
Santa Fe MSA 0 0.00 22.76 0.00 16.91 0.00 18.35 0.00 41.98 0.00 3.69 12.57 22.36 61.38

*As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
465
Borrower Distribution: HOME IMPROVEMENT Geography NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total- Families- Loans- Families38 Loans"""" Families*** Loans**"* Families*** Loans**** Low Mod Mid Upp
Full Review:
Albuquerque MSA 0 0.00 25.10 0.00 15.34 0.00 17.81 0.00 41.76 0.00 10.08 15.25 24.94 49.74
Limited Review:
Santa Fe MSA 0 0.00 22.76 0.00 16.91 0.00 18.35 0.00 41.98 0.00 8.94 8.38 24.02 58.66

466
Borrower Distribution: HOME MORTGAGE REFINANCE Geography. NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Albuquerque MSA 0 0.00 25.10 0.00 15.34 0.00 17.81 0.00 41.76 0.00 8.12 18.66 25.50 47.73
Limited Review:
Santa Fe MSA 0 0.00 22.76 0.00 16.91 0.00 18.35 0.00 41.98 0.00 6.52 12.81 23.45 57.22

467
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
$250,000 $1,000,000 Less
Full Review:
Albuquerque MSA 101 74.81 83.80 55.45 69.31 15,84 14.85 11,337 5,774
Limited Review:
Santa Fe MSA 34 25.19 86.23 52.94 73.53 17.65 8.82 3,501 1,854

- Small loans to businesses originated and purchased in the MAJAA as a percentage of all small loans to businesses originated and purchased in the rated area.
468
Borrower Distribution: SMALL LOANS TO FARMS Geography: NEW MEXICO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms- % BANK Loans "' $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Albuquerque MSA 0 0.00 95.21 0.00 0.00 0.00 0.00 44 29
Limited Review:
Santa Fe MSA 0 0.00 98.07 0.00 0.00 0.00 0.00 18 6

469
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: NEW MEXICO Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Albuquerque MSA 62.8 1 50.00 0.00 100.0 0.00 0.00 0 0 0 0 0 0 6.57 32.80 27.12 33.03
Limited Review:
Santa Fe MSA 37.2 1 50.00 0.00 0.00 0.00 100.0 0 0 0 0 0 0 3.88 23.00 44.60 28.52
470
LENDING VOLUME Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AK"
Full Review:
Oklahoma City MSA 100.00 7 729 93 9,690 1 325 2 35 101 10,744 100.0
** The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
471
Geographic Distribution: HOME PURCHASE Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*" Units*** Units*"* Units"**
Full Review:
Oklahoma City MSA 7 100.00 6.13 0.00 25.86 28.57 32.54 14.29 35.48 57.14 3.06 20.72 32.08 44.14

"" Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
472
Geographic Distribution: HOME IMPROVEMENT Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle -Income Upper -Income Aggregate HMDA Lending (%) by Tract Income'
Full Review:
Oklahoma City MSA 0 0.00 6.13 0.00 25.86 0.00 32.54 0.00 1 35.48 0.00 5.09 26.38 35.35 33.18

473
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Units- Loans"" Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Oklahoma MSA 0 0.00 6.13 0.00 25.86 0.00 32.54 0.00 35.48 0.00 3.86 19.32 32.62 44.20

474
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Business Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income*
Assessment Area: # % of % of % °A) of % BANK % of % BANK % of % BANK
- Loans
*Irk
Full Review:

475
Geographic Distribution: SMALL LOANS TO FARMS Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geoaaphies Geographies Geographies Geographies
Total** Farms- Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:

476
Borrower Distribution: HOME PURCHASE Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:

477
Borrower Distribution: HOME IMPROVEMENT Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total- Families*" Loans- Families:" Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Oklahoma City MSA 0 0,00 24.67 0.00 17.88 0.00 19.12 0.00 38.33 0.00 10.27 22.05 24.36 43.32

478
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % % BANK % % BANK % % BANK °A % BANK
Total** Families*** Loans- Families42 Loans"' Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:

479
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses- % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Oklahoma City MSA 93 100.00 83.14 58.06 76.34 10.75 12.90 15,039 6,957

*** Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 1.08% of
480
Borrower Distribution: SMALL LOANS TO FARMS Geography: OKLAHOMA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rey$ 1 Million or
$250,000 $500,000 Less
Full Review:
Oklahoma City MSA 1 100.00 94.90 0.00 0.00 0.00 100.00 146 110

**** Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
481
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geog aphy: OKLAHOMA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

Assessment Area: Rated BANK Income of Geographies %)
Rated # of # of (+ or - )
Deposits Branch Low Mod Mid Upp Openings Closings Low Mod Mid Upp Low Mod Mid Upp
in AA es in
AA
Full Review:
Oklahoma MSA 100.00 2 100.00 0.00 50.00 0.00 50.00 0 0 0 0 0 0 10.61 32.35 29.73 26.92
482
LENDING VOLUME Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
of Rated Community Development % of Rated Area

(#) in MA/AA."
Full Review:
Portland MSA 100.00 3 1,064 98 9,383 0 0 5 3,708 101 10,447 100.0
"The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
483
Geographic Distribution: HOME PURCHASE Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Portland MSA 2 100.00 0.91 0.00 21.49 50.00 41.48 0.00 36.12 50.00 1.04 24.35 40.78 33.82

484
Geographic Distribution: HOME IMPROVEMENT Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Occ Loans-- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Units"' Units*** Units*** Units***
Full Review:
Portland MSA 1 100.00 0.91 0.00 21.49 0.00 41.48 0.00 36.12 100.00 1.06 22.80 44.74 31.41

Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing unitsin the area based
485
Geographic Distribution: HOME MORTGAGE REFINANCE Geog aphy: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Geographies Moderate -Income. Middle -Income Upper -Income Aggregate HMDA Lending (%) by Tract
Units*** Units*** Units**"
Full Review:
Portland MSA 0 0.00 0.91 0.00 21.49 0.00 41.48 0.00 36.12 0.00 1.00 24.10 43.36 31.54

486
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
**.
Loans ***
Full Review:
Portland MSA 96 100.00 1.40 2.08 19.65 22.92 36.40 33.33 38.22 41.67 1.33 20.91 38.19 39.57

" Small loans to businesses originated and purchased in the MAJAA as a percentage of all small loans to businesses originated and purchased in the rated area.
487
Geographic Distribution: SMALL LOANS TO FARMS Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Farms*** Loans Farms*" Loans Farms"" Loans Farms" Loans Low Mod Mid Upp
Full Review:
Portland MSA 0 0.00 0.98 0.00 14.27 0.00 48.11 0.00 35.39 0.00 0.31 9.09 52.98 37.62

488
Borrower Distribution: HOME PURCHASE Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Portland MSA 2 100.00 22.14 0,00 17.14 0.00 19.97 0.00 40.75 100.00 2.15 13.85 26,35 57.65

*-* As a percentage of loans with borrower income information available. No information was available for 50.0% of loans originated and purchased by BANK.
489
Borrower Distribution: HOME IMPROVEMENT Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total- Families- Loans- Families44 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Portland MSA 1 100.00 22.14 0.00 17.14 0.00 19.97 0.00 40.75 100.00 5.99 17.21 28.46 48.35

" Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
490
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Families*** Loans- Families45 Loans**** Families""* Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Portland MSA 0 0.00 22.14 0.00 17.14 0.00 19.97 0.00 40.75 0.00 5.15 17.50 28.24 49.11

491
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Portland MSA 98 100.00 87.66 56.12 81.63 10.20 8.16 30,445 16,153

*" Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the rated area.
492
Borrower Distribution: SMALL LOANS TO FARMS Geography: OREGON Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total" % of Farms"' % BANK Loans**** $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Portland MSA 0 0.00 95.01 0.00 0.00 0.00 0.00 335 219

"Small loans to farms originated and purchased in the MAJAA as a percentage of all small loans to farms originated and purchased in the rated area.
"-Small loans to farms with revenues of $1 million or less as a percentage of all loans reported as small loans to farms. No information was available for 0.00% of small loans to
493
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geog aphy: OREGON Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Portland MSA* 100.0 2* 50,00 0.00 0.00 0.00 50.00 0 0 0 0 0 0 2.05 27.77 39.67 30.24
*One branch is located in a geography without an income designation.
494
LENDING VOLUME Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA-
Assessment Area (2017): MA/AA` # $ (000's) # $ (000's) # $ (000's) # $ (000's) # $(000's)
Full Review:
WV Non-MSA 100.00 22 2,326 35 3,270 5 790 7 300 62 6,386 100.0
Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
495
Geographic Distribution: HOME PURCHASE Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units"*" Units"*" Units***
Full Review:
WV Non-MSA 8 100.00 0.00 0.00 0.00 0.00 84.05 75.00 15.95 25.00 0.00 0.00 80.62 19.38

496
Geographic Distribution: HOME IMPROVEMENT Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle -Income Upper- ncome Aggregate HMDA Lending (%) by Tract Income'
Units- Units*** Units** Units***
Full Review:
WV Non-MSA 1 100.00 0.00 0.00 0.00 0.00 84.05 100.00 15.95 0.00 0.00 0.00 67.12 32.88

497
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Units*** Loans"" Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
WV Non-MSA 13 100.00 0.00 0.00 0.00 0.00 84.05 84.62 15.95 15.38 0.00 0.00 80.26 19.74

498
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
... ***
Loans
Full Review:
WV Non-MSA 35 100.00 0.00 0.00 0.00 0.00 69.74 65.71 30.26 34.29 0.00 0.00 71.40 28.60

499
Geographic Distribution: SMALL LOANS TO FARMS Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geog aphies Geographies Geographies Geographies
Total" Farms- Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
WV Non-MSA 5 100.00 0.00 0.00 0.00 0.00 88.89 100.00 11.11 0.00 0.00 0.00 81.25 18.75

500
Borrower Distribution: HOME PURCHASE Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
WV Non-MSA 8 100.00 19.71 12.50 16.05 0.00 24,83 25.00 39.41 62.50 5.12 16.98 27.22 50.67

501
Borrower Distribution: HOME IMPROVEMENT Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Total** Families"- Loans- Families47 Loans*"** Families*** Loans**** Families*** Loans"- Low Mod Mid Upp
Full Review:
WV Non-MSA 1 100.00 19.71 0.00 16.05 100.00 24.83 0.00 39.41 0.00 4.23 16.90 18.31 60.56

--As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
502
Borrower Distribution: HOME MORTGAGE REFINANCE Geography WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families*** Loans-- Familieso Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
WV Non-MSA 13 100.00 19.71 0.00 16.05 38.46 24.83 23,08 39.41 38.46 7,63 14.89 19,47 58.02

503
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses* % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
WV Non-MSA 35 100.00 78.17 68.57 80.00 11.43 8.57 549 258

-*Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
**- Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 0.00% of
504
Borrower Distribution: SMALL LOANS TO FARMS Geography: WEST VIRGINIA Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: % BANK Loans- >$100,000 to
# % of Total- % of Farms $100,000 or less >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
WV Non-MSA 5 100.00 96.53 100.00 40.00 20.00 40.00 48 20

505
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: WEST VIRGINIA Evaluation Period: JUNE 6, 2016 - MARCH 26, 2017

% of # of % of Location o Branches by Net change in Location of Branches % of Population within Each Geography
in AA in AA
Full Review:
WV Non-MSA 100.0 5 100.00 0.00 0.00 80.00 20.00 0 0 0 0 0 0 0.00 0.00 85.24 14.76
506
LENDING VOLUME Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Assessment Area (2017): MA/AA" # $ (000's) # $ (000's) # $ (000's) # $ (000's) # $(000's)
Full Review:
Milwaukee MSA 100.00 3 918 3 1,174 0 0 0 0 6 2,092 94.3
Limited Review:
Racine MSA 0.00 0 0 0 0 0 0 0 0 0 0 5.7
-*Deposit Data as of June 30, 2018. Rated Area refers to either the state, multi -state MA, or institution, as appropriate.
507
Geographic Distribution: HOME PURCHASE Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units*** Units"' Units**"
Full Review:
Milwaukee MSA 2 100.00 7.88 0.00 12.81 0.00 36.08 0.00 43.23 100.00 3.83 13.63 39.62 42.92
Limited Review:
Racine MSA 0 0.00 210 0.00 16.16 0.00 57.46 0.00 23.68 0.00 0.78 16.07 60.91 22.24

508
Geographic Distribution: HOME IMPROVEMENT Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Milwaukee MSA 0 0.00 7.88 0.00 12.81 0.00 36.08 0.00 43.23 0.00 5.89 10.77 34.53 48.80
Limited Review:
Racine MSA 0 0.00 2.70 0.00 16.16 0.00 57.46 0.00 23.68 0.00 1.16 10.47 67.05 21.32

509
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
# % of % Owner % BANK % Owner % BANK % Owner `1/0 BANK % Owner % BANK
Total- Occ Units' Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Milwaukee MSA 1 100.00 7.88 0.00 12.81 0.00 36.08 100.00 43.23 0.00 3.98 10.80 36.60 48.62
Limited Review:
Racine MSA 0 0.00 2.70 0.00 16.16 0.00 57.46 0.00 23.68 0.00 1.33 14.80 57.50 26.37

*- Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
510
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Businesses BANK Businesses*** Loans Businesses Loans Businesses*" Loans Low Mod Mid Upp
...
Loans *-
Full Review:
Milwaukee MSA 3 100.00 11.89 33.33 12.81 33.33 35.50 33.33 39.75 0.00 8.33 10.75 34.08 46.84
Limited Review:
Racine MSA 0 0.00 5.13 0.00 18.23 0.00 54.44 0.00 19.39 0.00 5.65 16.16 55.51 22.68

511
Geographic Distribution: SMALL LOANS TO FARMS Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geog_ aphies Geographies Geographies Geographies
Total- Farms- Loans Farms*" Loans Farms** Loans Farms"" Loans Low Mod Mid Upp
Full Review:
Milwaukee MSA 0 0.00 6.07 0.00 8.43 0.00 37.64 0.00 47.86 0.00 2.74 4.11 39.73 53.42
Limited Review:
Racine MSA 0 0.00 1.77 0.00 5.81 0.00 55.81 0.00 36.36 0.00 0.00 0.00 50.00 50.00

512
Borrower Distribution: HOME PURCHASE Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % % BANK % Families49 % BANK % % BANK % `)/0 BANK
Total** Families* Loans- Loans**** Families*** Loans***" Families*** Loans**** Low Mod Mid Upp
Full Review:
Milwaukee MSA 2 100.00 24.36 0.00 16.34 0.00 19.39 0,00 39.91 100.00 7.90 20.69 26.45 44.96
At
Limited Review:
Racine MSA 0 0.00 19.97 0.00 17.80 0.00 21.90 0.00 40.33 0.00 8.21 25.33 26.13 40.34

513
Borrower Distribution: HOME IMPROVEMENT Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Loans Borrowers
Full Review:
Milwaukee MSA 0 0.00 24.36 0.00 16.34 0.00 19.39 0.00 39.91 0.00 8.26 14.86 24.82 52.06
Limited Review:
Racine MSA 0 0.00 19.97 0.00 17.80 0.00 21.90 0.00 40.33 0.00 6.56 16.80 30.74 45.90

****As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
514
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families- Loans-- Families51 Loans*"" Families"*" Loans*"*" Families"' Loans"' Low Mod Mid Upp
Full Review:
Milwaukee MSA 1 100.00 24.36 0.00 16.34 0.00 19,39 0.00 39.91 100.00 6.12 17.13 26.76 49.99
Limited Review:
Racine MSA 0 0.00 19.97 0.00 17.80 0.00 21.90 0.00 40.33 0.00 7.17 18.77 27.76 46.30

"" As a percentage of loans with borrower income information available. No information was available for 0.0% of loans originated and purchased by BANK.
515
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses- % BANK Loans'"" $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Milwaukee MSA 3 100.00 78.38 0.00 0.00 33.33 66.67 24,513 12,038
Limited Review:
Racine MSA 0 0.00 81.37 0.00 0.00 0.00 0.00 2,624 1,199

**** Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 66.67% of
516
Borrower Distribution: SMALL LOANS TO FARMS Geography: WISCONSIN Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total" % of Farms- % BANK Loans"'- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Milwaukee MSA 0 0.00 93.10 0.00 0.00 0.00 0.00 147 81
Limited Review:
Racine MSA 0 0.00 95.20 0.00 0.00 0.00 0.00 54 37
,
' Based on 2017 Peer Small Business Data -- US and PR

517
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geog aphy: WISCONSIN Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

Assessment Area: Rated BANK Rated Income of Geographies (°/0) # of # of (+ or - )
in AA in AA
Full Review:
Milwaukee MSA 94.3 13 92.86 15.38 7.69 69.24 7.69 13 2 0 +1 +9 +1 17.70 15.73 33.30 33.28
Limited Review:
Racine MSA 5.7 1 7.14 0.00 100.00 0.00 0.00 1 0 0 +1 0 0 6.67 20.32 53.28 18.91
518
LENDING VOLUME Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA***
Full Review:
Charlotte NC -SC MSA 100.00 736 158,413 1,397 142,722 25 2,858 18 50,493 2,158 303,993 100.0
519
Geographic Distribution: HOME PURCHASE Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units*** Units*** Unite**
Full Review:
Charlotte NC -SC MSA 496 100.00 3.50 3.83 18.54 24.60 36.24 34.68 41.72 36.90 2.66 15.87 33.25 48.21

-"Data shown includes only One to Four -family and manufactured housing. (Property type of 1 or 2)
520
Geographic Distribution: HOME IMPROVEMENT Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Charlotte NC -SC MSA 36 100.00 3.50 11.11 18.54 11.11 36.24 38,89 41.72 38.89 273 15.18 32,07 50.02

521
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Mortgage Geographies Geographies Geographies Income`
Full Review:

522
h

Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % of °A) % of % BANK % of % BANK % of % BANK
...
Loans "`
Full Review:
Charlotte NC -SC MSA 1,389 100.00 7.22 7.27 19.04 21.60 27.31 29.37 45.58 41.76 6.57 16.82 28.52 48.10

Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the ratedarea.
523
Geographic Distribution: SMALL LOANS TO FARMS Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending %) by Tract Income*
Loans Geomphies Geographies Geographies Geographies
Total** Farms*** Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:

524
Borrower Distribution: HOME PURCHASE Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families* Loans- Loans**"* Families*** Loans**** Families"- Loans-- Low Mod Mid Upp
Full Review:

525
Borrower Distribution: HOME IMPROVEMENT Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families*** Loans**** Families53 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Charlotte NC -SC MSA 36 100.00 21.61 10.00 16.49 10.00 18.55 33.33 4336 46.67 7.86 15.27 20.72 56.15

-*As a percentage of loans with borrower income information available. No information was available for 16.7% of loans originated and purchased by BANK.
526
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data'
Mortgage Borrowers
# % of % % BANK % % BANK % % BANK % % BANK
Total- Families- Loans"- Families54 Loans**** Families*** Loans**** Families*"" Loans**** Low Mod Mid Upp
Full Review:

527
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total** % of Businesses*** % BANK Loans**** $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Charlotte NC -SC MSA 1,397 100.00 83.80 60.92 78.53 9.66 11.81 44,599 22,999

"-Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
"-Small loans to businesses with revenues of $1 million or less as a percentage of all loans reported as small loans to businesses. No information was available for 5.30% of
528
Borrower Distribution: SMALL LOANS TO FARMS Geography: CHARLOTTE NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Charlotte NC -SC MSA 25 100.00 95.51 68.00 68.00 16.00 16.00 303 146

" Small loans to farms originated and purchased in the MAIAA as a percentage of all small loans to farms originated and purchased in the rated area.
529
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: CHARLOTTE NC -SC Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

Assessment Area: Rated BANK Rated Income of Geographies_(°/o) # of # of (+ or - )
in AA in AA
Full Review:
Charlotte NC -SC MSA 100.0 45 100.00 6.67 22.22 28.89 42.22 0 3 -2 -1 0 0 7.63 22.87 32.69 36.44
530
LENDING VOLUME Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Myrtle Beach NC -SC MSA 100.00 218 56,228 288 20,505 11 1,029 3 2,980 517 77,762 I 100.0
531
Geographic Distribution: HOME PURCHASE Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Myrtle Beach NC -SC MSA 152 100.00 0.41 0.00 16.15 13.16 64.99 51.32 18.45 35.53 0.55 11.45 65.04 22.96

532
Table 3a. G o ra hic Distribution of Home Improvement Loans
Geographic Distribution: HOME IMPROVEMENT Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Moderate -Income Middle- ncome Upper -Income Aggregate HMDA Lending (%) by Tract Income*
Full Review:

533
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Occ Units*** Loans-- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:

534
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Or**
*** Loans
Full Review:

535
Geographic Distribution: SMALL LOANS TO FARMS Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Geoq aphies Geographies Geographies Geographies
Assessment Area: # % of % of % BANK % of % BANK % of % BANK % of `1/0 BANK
Total** Farms*** Loans Farms** Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Myrtle Beach NC -SC 11 100.00 1.05 0.00 25.64 45.45 59.13 54.55 13.58 0.00 0.00 36.51 58.73 4.76
MSA

536
Borrower Distribution: HOME PURCHASE Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families* Loans-- Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
MSA

537
Borrower Distribution: HOME IMPROVEMENT Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families*** Loans- Families56 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
MSA

" Home improvement loans originated and purchased in the MAJAA as a percentage of all home improvement loans originated and purchased in the rated area.
538
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families*** Loans**** Families57 Loans**** Families*** Loans***" Families*** Loans"** Low Mod Mid Upp
Full Review:
Myrtle Beach NC -SC 60 100.00 20.09 1.69 18.40 11.86 21.25 27.12 40,26 59.32 5.86 15.30 22.57 56.26
MSA

539
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total" % of Businesses % BANK Loans"' $100,000 or less 4100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Myrtle Beach NC -SC MSA 288 100.00 84.22 69.79 82.64 10.07 7.29 9,716 5,440

-*Businesses with revenues of $1 million or less as a percentage of all businesses (Source D&B - 2017).
540
Borrower Distribution: SMALL LOANS TO FARMS Geography: MYRTLE BEACH NC -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total- % of Farms" % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Myrtle Beach NC -SC 11 100.00 97.42 90.91 63.64 36.36 0.00 129 74
MSA

-Farms with revenues of $1 million or less as a percentage of all farms (Source D&B - 2017).
541
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: MYRTLE BEACH NC -SC Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Myrtle -Beach NC -SC MSA 100.0 10 100.0 10.00 20.00 50.00 20.00 0 0 0 0 0 0 1.49 18.97 63.57 15.73
542
LENDING VOLUME Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Augusta GA -SC MSA 100.00 115 20,178 248 27,504 13 1,854 2 600 376 49,536 100.0
**The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
543
Geographic Distribution: HOME PURCHASE Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # `1/0 of % Owner % BANK % Owner % BANK % Owner % BANK % Owner % BANK
Total" Occ Loans-- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 64 100.00 3.93 0.00 22.33 21.88 39.65 37.50 34.09 40.63 1.46 11.26 39.36 47.91

544
Geographic Distribution: HOME IMPROVEMENT Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Augusta GA -SC MSA 9 100.00 3.93 0.00 22.33 33.33 39.65 44.44 34.09 22.22 3.28 20.05 41.02 35.65

545
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Occ Units- Loans"" Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 41 100.00 3.93 2.44 22.33 26.83 39.65 48.78 34.09 21.95 1.60 14.82 42.07 41.52

546
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
... ",,,
Loans
Full Review:
Augusta GA -SC MSA 248 100.00 7.62 4.84 22.98 29.44 33.20 37.50 36.19 28.23 6.73 18.64 32.09 42.54

Small loans to businesses originated and purchased in the MA/AA as a percentage of all small loans to businesses originated and purchased in the ratedarea.
*** Source Data - Dun and Bradstreet (2017).
547
Geographic Distribution: SMALL LOANS TO FARMS Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending (%) by Tract Income'
Loans Geogaphies Geographies Geographies Geographies
Total** Farms"' Loans Farms** Loans Farms** Loans Farms" Loans Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 13 100.00 3.74 0.00 23.79 61.54 41.19 30.77 31.17 7.69 0.83 31.40 57.85 9.92

548
Borrower Distribution: HOME PURCHASE Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families' Loans- Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 64 100.00 23.83 8.33 16.03 10.00 18.11 13.33 42.03 68.33 5.32 20.22 28.65 45.80

549
Borrower Distribution: HOME IMPROVEMENT Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total** Families** Loans- Families59 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 9 100.00 23.83 0.00 16.03 22.22 18.11 44.44 42.03 33.33 11.88 19.20 23.76 45.17

550
institution ID: First -Citizens Bank & Trust Company
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data'
Mortgage Refinance Borrowers
Assessment Area: Loans
# % of % % BANK % % BANK % % BANK % % BANK
Total- Families- Loans- Families60 Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Augusta GA -SC MSA 41 100.00 23.83 2.50 16.03 12.50 18.11 30.00 42.03 55.00 8.63 18,12 24.01 49.24

551
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
$250,000 $1,000,000 Less
Full Review:
Augusta GA -SC MSA 248 100.00 83.02 66.94 78.63 8.47 12.90 7,683 3,794

552
Borrower Distribution: SMALL LOANS TO FARMS Geography: AUGUSTA GA -SC Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: % of Farms"' % BANK Loans-
# % of Total** $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Augusta GA -SC MSA 13 100.00 96.96 84.62 53.85 30.77 15.38 123 54

553
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: AUGUSTA GA -SC Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Augusta GA -SC MSA 100.0 12 100.00 0.00 33.33 41.67 25.00 0 1 0 0 -1 0 6.96 24.92 38.94 29.18
554
LENDING VOLUME Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017

(#) in MA/AA"'
Full Review:
Kansas City KS -M0 MSA 100.00 2 316 94 6,811 0 0 3 185 96 7,127 100.0
*Loan Data as of December 31, 2017. Rated area refers to either state or multi -state MA rating area.
**The evaluation period for Community Development Loans is from June 06, 2016 to March 26, 2019. Total reported loans do not include Community Development Loans.
555
Geographic Distribution: HOME PURCHASE Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Full Review:
Kansas City KS -MO MSA 1 100.00 6.21 0.00 16.11 100.00 33.39 0.00 44.29 0.00 2.86 14.41 35.41 47.32
6,0

** Home purchase loans originated and purchased in the MA/AA as a percentage of all home purchase loans originated and purchased in the rated area.
556
Geographic Distribution: HOME IMPROVEMENT Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Units*** Units""* Units' Units***
Full Review:

557
Geographic Distribution: HOME MORTGAGE REFINANCE Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total" Occ Units"' Loans- Occ Loans Occ Loans Occ Loans Low Mod Mid Upp
Full Review:

-*Percentage of Owner Occupied Units is the number of owner occupied units in a particular geography divided by the number of owner occupied housing units in the area based
558
Geographic Distribution: SMALL LOANS TO BUSINESSES Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of % of % % of % BANK % of `)/0 BANK % of % BANK
Loans
".-
Full Review:

559
Geographic Distribution: SMALL LOANS TO FARMS Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Small Farm Loans Low -Income Moderate -Income Middle -Income Upper -Income Aggregate Lending (%) by Tract Income'
Total" Farms- Loans Farms"* Loans Farms** Loans Farms** Loans Low Mod Mid Upp
Full Review:
Kansas City KS -MO 0 0.00 5.12 0.00 14.22 0.00 34.41 0.00 45.97 0.00 5.03 7.55 28.30 59.12
MSA
' Based on 2017 Peer Small Business Data -- US and PR

560
Borrower Distribution: HOME PURCHASE Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total- Families' Loans"" Loans**** Families*** Loans**** Families*** Loans**** Low Mod Mid Upp
Full Review:
Kansas City KS -MO 1 100.00 20.40 100.00 16.61 0.00 19.54 0.00 43.44 0.00 7.64 21.51 24.48 46.37
MSA

" Home purchase loans originated and purchased in the MAJAA as a percentage of all home purchase loans originated and purchased in the rated area.
561
Borrower Distribution: HOME IMPROVEMENT Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Total Home Imp ovement Low -Income Borrowers Moderate -Income Middle -Income Borrowers Upper -Income Borrowers Aggregate Lending Data*
Loans Borrowers
Total** Families*** Loans- Families62 Loans"*" Families*"" Loans"*** Families""* Loans*"" Low Mod Mid Upp
Full Review:
Kansas City KS -MO 0 0.00 20.40 0.00 16.61 0.00 19.54 0.00 43.44 0.00 7.53 15.70 25.56 51.21
MSA

562
Borrower Distribution: HOME MORTGAGE REFINANCE Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Assessment Area: # % of °A % BANK % % BANK % % BANK % % BANK
Total- Families- Loans- Families63 Loans"" Families*** Loans*""" Families""" Loans"*"" Low Mod Mid Upp
Full Review:
Kansas City KS -MO 1 100.00 20.40 0.00 16.61 100.00 19.54 0.00 43,44 0.00 8.55 18.18 26.15 47.12
MSA

563
Borrower Distribution: SMALL LOANS TO BUSINESSES Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
Businesses or less
Assessment Area: # % of Total- % of Businesses- % BANK Loans- $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $1,000,000 Less
Full Review:
Kansas City KS -MO MSA 94 100.00 82.38 63.83 85.11 11.70 3.19 26,062 12,147

564
Borrower Distribution: SMALL LOANS TO FARMS Geography: KANSAS CITY KS -MO Evaluation Period: JANUARY 1, 2017 TO DECEMBER 31, 2017
less
Assessment Area: # % of Total** % of Farms- % BANK Loans $100,000 or less >$100,000 to >$250,000 to All Rev$ 1 Million or
$250,000 $500,000 Less
Full Review:
Kansas City KS -MO MSA 0 0.00 94.64 0.00 0.00 0.00 0.00 160 86

565
DISTRIBUTION OF BRANCH DELIVERY SYSTEM AND BRANCH OPENINGS/CLOSINGS Geography: KANSAS CITY KS -MO Evaluation Period: JUNE 6, 2016 - MARCH 26, 2019

in AA in AA
Full Review:
Kansas City KS -MO MSA 100.0 2 100.00 0.00 0.00 0.00 100.0 0 0 0 0 0 0 9.88 19.93 32.11 37.75
566

First Citizens 2019 CRA Performance Evaluation

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First Citizens 2019 CRA Performance Evaluation

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ATL 8/27/2019

March 26, 2019

COMMUNITY REINVESTMENT ACT

First -Citizens Bank & Trust Company

239 Fayetteville Street

Federal Deposit Insurance Corporation

10 Tenth Street, Northeast, Suite 800

Performance Test Ratings Table 1

Summary of Major Factors Supporting Rating 1

North Carolina Non -Metropolitan State-wide Area (Full -Scope)

Raleigh, NC Metropolitan Area (Full -Scope)

Asheville, NC Metropolitan Area (Full -Scope)

Other North Carolina Assessment Areas (Limited -Scope)

Wilmington, NC Metropolitan Area (Limited -Scope)

Greensboro -High Point, NC Metropolitan Area (Limited -Scope)

Hickory -Lenoir -Morganton, NC Metropolitan Area (Limited -Scope)

Durham -Chapel Hill, NC Metropolitan Area (Limited -Scope)

Fayetteville, NC Metropolitan Area (Limited -Scope)

Goldsboro, NC Metropolitan Area (Limited -Scope)

Greenville, NC Metropolitan Area (Limited -Scope)

Jacksonville, NC Metropolitan Area (Limited -Scope)

New Bern, NC Metropolitan Area (Limited -Scope)

Rocky Mount, NC Metropolitan Area (Limited -Scope)

Winston-Salem, NC Metropolitan Area (Limited -Scope)

Charleston -North Charleston, SC Metropolitan Area (Full -Scope)

Greenville -Anderson -Mauldin, SC Metropolitan Area (Full -Scope)

South Carolina Non -Metropolitan State-wide Area (Full -Scope)

Other South Carolina Assessment Areas (Limited -Scope)

Spartanburg, SC Metropolitan Area (Limited -Scope)

Florence, SC Metropolitan Area (Limited -Scope)

Hilton Head Island -Bluffton -Beaufort, SC Metropolitan Area (Limited -Scope)

Sumter, SC Metropolitan Area (Limited -Scope)

Roanoke, VA Metropolitan Area (Full -Scope)

Other Virginia Assessment Areas (Limited -Scope)

Lynchburg, VA Metropolitan Area (Limited -Scope)

Richmond, VA Metropolitan Area (Limited -Scope)

Blacksburg-Christiansburg-Radford, VA Metropolitan Area (Limited -Scope)

Charlottesville, VA Metropolitan Area (Limited -Scope)

Harrisonburg, VA Metropolitan Area (Limited -Scope)

Staunton -Waynesboro, VA Metropolitan Area (Limited -Scope)

Winchester, VA Metropolitan Area (Limited -Scope)

Los Angeles -Long Beach -Glendale, CA Metropolitan Division (Full -Scope)

Sacramento -Roseville -Arden -Arcade, CA Metropolitan Area (Full -Scope)

Other California Assessment Areas (Limited -Scope)

Anaheim -Santa Ana -Irvine Metropolitan Division (Limited -Scope)

Oakland -Haywood -Berkeley, CA Metropolitan Division (Limited -Scope)

Riverside -San Bernardino -Ontario, CA Metropolitan Area (Limited -Scope)

Atlanta -Sandy Spring -Roswell, GA Metropolitan Area (Full -Scope)

Other Georgia Assessment Areas (Limited -Scope)

Georgia Non -Metropolitan State-wide Area (Limited -Scope)

Savannah, GA Metropolitan Area (Limited -Scope)

Jacksonville, FL Metropolitan Area (Full -Scope)

Other Florida Assessment Areas (Limited -Scope)

Fort Lauderdale -Pompano Beach -Deerfield, FL Metropolitan Division (Limited -Scope)

Cape Coral -Fort Myers, FL Metropolitan Area (Limited -Scope)

Miami -Miami Beach -Kendall, FL Metropolitan Division (Limited -Scope)

Naples-Immokalee-Marco Island, FL Metropolitan Area (Limited -Scope)

Port St Lucie, FL Metropolitan Area (Limited -Scope)

Austin -Round Rock, TX Metropolitan Area (Full -Scope)

Other Texas Assessment Areas (Limited -Scope)

Dallas -Plano -Irving, TX Metropolitan Division (Limited -Scope)

Houston -The Woodlands-Sugarland, TX Metropolitan Area (Limited -Scope)

Phoenix -Mesa -Scottsdale, AZ Metropolitan Area (Full -Scope)