The Company accounts for credit losses on loans in accordance with ASC 326 - Financial Instruments - Credit Losses, to determine the ACL. ASC 326 requires the Company to recognize estimates for lifetime losses on loans and unfunded loan commitments at the time of origination or acquisition. The recognition of losses at origination or acquisition represents the Company’s best estimate of the lifetime expected credit loss associated with a loan given the facts and circumstances associated with the particular loan, and involves the use of significant management judgement and estimates, which are subject to change based on management’s on-going assessment of the credit quality of the loan portfolio and changes in economic forecasts used in the model. The Company uses a discounted cash flow model when determining estimates for the ACL for commercial real estate loans and commercial loans, which comprise the majority of the loan portfolio, and uses a historical loss rate model for retail loans. The Company also utilizes proxy loan data in its ACL model where the Company’s own historical data is not sufficiently available.

The discounted cash flow model is applied on an instrument-by-instrument basis, and for loans with similar risk characteristics, to derive estimates for the lifetime ACL for each loan. The discounted cash flow methodology relies on several significant components essential to the development of estimates for future cash flows on loans and unfunded commitments. These components consist of: (i) the estimated probability of default, (ii) the estimated loss given default, which represents the estimated severity of the loss when a loan is in default, (iii) estimates for prepayment activity on loans, and (iv) the estimated exposure to the Company at default (“EAD”). These components are also heavily influenced by changes in economic forecasts employed in the model over a reasonable and supportable period. The Company’s ACL methodology for unfunded loan commitments also includes assumptions concerning the probability an unfunded commitment will be drawn upon by the borrower. These assumptions are based on the Company’s historical experience.

The Company’s discounted cash flow ACL model for commercial real estate and commercial loans uses internally derived estimates for prepayments in determining the amount and timing of future contractual cash flows to be collected. The estimate of future cash flows also incorporates estimates for contractual amounts the Company believes may not be collected, which are based on assumptions for PD, LGD, and EAD. EAD is the estimated outstanding balance of the loan at the time of default. It is determined by the contractual payment schedule and expected payment profile of the loan, incorporating estimates for expected prepayments and future draws on revolving credit facilities. The Company discounts cash flows using the effective interest rate on the loan. The effective interest rate represents the contractual rate on the loan; adjusted for any purchase premiums, purchase discounts, and deferred fees and costs associated with the origination of the loan. The Company has made an accounting policy election to adjust the effective interest rate to take into consideration the effects of estimated prepayments. The ACL for loans is determined by measuring the amount by which a loan’s amortized cost exceeds its discounted cash flows.

The PD for commercial real estate loans is based largely on a model provided by a third party, using proxy loan information. The PDs generated by this model are reflective of current and expected changes in economic conditions and conditions in the commercial real estate market, and how they are expected to impact loan level and property level attributes, and ultimately the likelihood of a default event occurring. Significant loan and property level attributes include: loan to value ratios, debt service coverage, loan size, loan vintage and property types.

The PD for commercial loans is based on an internally developed PD rating scale that assigns PDs based on the Company’s internal risk grades for loans. This internally developed PD rating scale is based on a combination of the Company’s own historical data and observed historical data from the Company’s peers, which consist of banks that management believes align with our business profile. As credit risk grades change for loans in the commercial segment, the PD assigned to them also changes. As with commercial real estate loans, the PD for commercial loans is also impacted by current and expected economic conditions.

LGDs for commercial real estate loans are derived from a third party, using proxy loan information, and are based on loan and property level characteristics in the Company’s loan portfolio, such as: loan to values, estimated time to resolution, property size, and current and estimated future market price changes for underlying collateral. The LGD is highly dependent upon loan to value ratios, and incorporates estimates for the expense associated with managing the loan through to resolution. LGDs also incorporate an estimate for the loss severity associated with loans where the borrower fails to meet their debt obligation at maturity, such as through a balloon payment or the refinancing of the loan through another lender. External factors that have an impact on LGDs include: changes in the CRE Price Index, GDP growth rate, unemployment rates and the Moody’s Baa rating corporate debt interest rate spread. LGDs are applied to each loan in the commercial real estate portfolio, and in conjunction with the PD, produce estimates for net cash flows not expected to be collected over the estimated term of the loan.

LGDs for commercial loans are also derived from a third party that has a considerable database of credit related information specific to the financial services industry and the type of loans within this segment, and is used to generate annual default information for commercial loans. These proxy LGDs are dependent upon data inputs such as: credit quality, borrower industry, region, borrower size, and debt seniority. LGDs are then applied to each loan in the commercial portfolio, and in conjunction with the PD, produce estimates for net cash flows not expected to be collected over the estimated term of the loan.

U.S. GAAP requires the Company to develop reasonable and supportable forecasts of future conditions, and estimate how those forecasts are expected to impact a borrower’s ability to satisfy their obligation to the Bank and the ultimate collectability of future cash flows over the life of the loan. The Company uses economic scenarios from an independent third party, Moody’s Analytics, in its estimation of a borrower’s ability to repay a loan in future periods. These scenarios are based on past events, current conditions, and the likelihood of future events occurring. These scenarios typically are comprised of: (1) a base-case scenario, (2) an upside scenario, representing slightly better economic conditions than currently experienced and, (3) a downside scenario, representing recessionary conditions. Management periodically evaluates economic scenarios and may decide that a particular economic scenario or a combination of probability-weighted economic scenarios should be used in the Company’s ACL model. The economic scenarios chosen for the model, the extent to which more than one scenario is used, and the weights that are assigned to them, are based on the Company’s estimate of the probability of each scenario occurring, which is based in part on analysis performed by an independent third-party. Economic scenarios chosen, as well as the assumptions within those scenarios, and whether to use a probability-weighted multiple scenario approach, can vary from one period to the next based on changes in current and expected economic conditions, and due to the occurrence of specific events such as the on-going COVID-19 pandemic. The Company recognizes the non-linearity of credit losses relative to economic performance and thus the Company believes consideration of and, if appropriate under the circumstances, use of multiple probability-weighted economic scenarios is appropriate in estimating credit losses over the forecast period. This approach is based on certain assumptions. The first assumption is that no single forecast of the economy, however detailed or complex, is completely accurate over a reasonable forecast time-frame, and is subject to revisions over time. By considering multiple scenario outcomes

As of January 1, 2020, upon the adoption of ASC 326, the Company’s ACL model used three probability-weighted scenarios representing a base-case scenario, an upside scenario, and a downside scenario. The weightings assigned to each scenario were as follows: the base-case scenario, or most likely scenario, was assigned a weighting of 40%, while the upside and downside scenarios were each assigned weightings of 30%. As of September 30, 2020, the Company’s ACL model used the same three probability weighted scenarios, updated for current expected economic conditions, including the current and estimated future impact associated with the on-going COVID-19 pandemic. The use of three probability-weighted scenarios in the third quarter of 2020 is consistent with the approach used in the Company’s ACL model during the second quarter of 2020. The Company evaluated the weightings of each economic scenario in the current period with the assistance of Moody's Analytics, and determined the current weightings of 40% for the base-case scenario, and 30% for each of the upside and downside scenarios appropriately reflect the likelihood of outcomes for each scenario given the current economic environment.

The Company currently forecasts economic conditions over a two-year period, which we believe is a reasonable and supportable period. Beyond the point which the Company can provide for a reasonable and supportable forecast, economic variables revert to their long-term averages. The Company has reflected this reversion over a period of three years in each of its economic scenarios used to generate the overall probability-weighted forecast. Changes in economic forecasts impact the PD, LGD, and EAD for each loan, and therefore influence the amount of future cash flows for each loan the Company does not expect to collect.

The Company derives the economic forecasts it uses in its ACL model from Moody's Analytics that has a large team of economists, data-base managers and operational engineers with a history of producing monthly economic forecasts for over 25 years. The forecasts produced by this third party have been widely used by banks, credit unions, government agencies and real estate developers. These economic forecasts cover all states and metropolitan areas in the Unites States, and reflect changes in economic variables such as: GDP growth, interest rates, employment rates, changes in wages, retail sales, industrial production, metrics associated with the single-family and multifamily housing markets, vacancy rates, changes in equity market prices, and energy markets.

It is important to note that the Company’s ACL model relies on multiple economic variables, which are used under several economic scenarios. Although no one economic variable can fully demonstrate the sensitivity of the ACL calculation to changes in the economic variables used in the model, the Company has identified certain economic variables that have significant influence in the Company’s model for determining the ACL. As of September 30, 2020, the Company’s ACL model incorporated the following assumptions for key economic variables in the base-case and downside scenarios:

The Company recognizes that historical information used as the basis for determining future expected credit losses may not always, by themselves, provide a sufficient basis for determining future expected credit losses. The Company, therefore, periodically considers the need for qualitative adjustments to the ACL. Qualitative adjustments may be related to and include, but not be limited to, factors such as: (i) management’s assessment of economic forecasts used in the model and how those forecasts align with management’s overall evaluation of current and expected economic conditions, (ii) organization specific risks such as credit concentrations, collateral specific risks, regulatory risks and external factors that may ultimately impact credit quality, (iii) potential model limitations such as limitations identified through back-testing, and other limitations associated with factors such as underwriting changes, acquisition of new portfolios and changes in portfolio segmentation and (iv) management’s overall assessment of the adequacy of the ACL, including an assessment of model data inputs used to determine the ACL. As of September 30, 2020, qualitative adjustments included in the ACL totaled $15.0 million. These adjustments relate to potential limitations in the model. Management determined through additional review that certain key model drivers are potentially underestimating the impact of the on-going COVID-19 pandemic may have on small and medium sized businesses, and may not be fully reflecting the potential for a more turbulent economic recovery. In addition, the qualitative adjustment relates to, in part, the lack of additional economic stimulus from the federal government as of September 30, 2020. Many economists point to the need for additional stimulus to help ensure the recovery in economic conditions, as a whole, does not begin to wane. Management reviews the need for and appropriate level of qualitative adjustments on a quarterly basis, and as such, the amount and allocation of qualitative adjustments may change in future periods.


	Three Months Ended September 30, 2020

	Beginning ACL Balance		Charge-offs		Recoveries		Provision for Credit Losses		Ending ACL Balance
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner occupied	$	63,007	$	(443)	$	—	$	(8,459)	$	54,105
Multifamily	63,511		—		—		3,825		67,336
Construction and land	18,804		(377)		—		(2,870)		15,557
SBA secured by real estate	2,010		(145)		34		3,428		5,327
Business loans secured by real estate
CRE owner-occupied	48,213		(1,739)		21		2,171		48,666
Franchise real estate secured	13,060		—		—		(1,072)		11,988
SBA secured by real estate	4,368		—		76		1,716		6,160
Commercial loans
Commercial and industrial	41,967		(2,437)		10		8,374		47,914
Franchise non-real estate secured	21,676		(207)		865		(2,185)		20,149
SBA non-real estate secured	600		(10)		8		353		951

Retail loans
Single family residential	1,479		—		2		(238)		1,243
Consumer loans	3,576		(129)		1		(341)		3,107
Totals	$	282,271	$	(5,487)	$	1,017	$	4,702	$	282,503


	Nine Months Ended September 30, 2020

	Beginning ACL Balance (1)		Adoption of ASC 326		Initial ACL Recorded for PCD Loans		Charge-offs		Recoveries		Provision for Credit Losses		Ending ACL Balance
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner occupied	$	1,899	$	8,423	$	3,025	$	(830)	$	—	$	41,588	$	54,105
Multifamily	729		9,174		8,710		—		—		48,723		67,336
Construction and land	4,484		(124)		2,051		(377)		—		9,523		15,557
SBA secured by real estate	1,915		(1,401)		—		(699)		34		5,478		5,327
Business loans secured by real estate
CRE owner-occupied	2,781		20,166		3,766		(1,739)		44		23,648		48,666
Franchise real estate secured	592		5,199		—		—		—		6,197		11,988
SBA secured by real estate	2,119		2,207		235		(315)		147		1,767		6,160
Commercial loans
Commercial and industrial	13,857		87		2,325		(5,213)		37		36,821		47,914
Franchise non-real estate secured	5,816		9,214		—		(1,434)		865		5,688		20,149
SBA non-real estate secured	445		218		924		(803)		13		154		951

Retail loans
Single family residential	655		541		206		(62)		3		(100)		1,243
Consumer loans	406		1,982		—		(137)		2		854		3,107
Totals	$	35,698	$	55,686	$	21,242	$	(11,609)	$	1,145	$	180,341	$	282,503


	For the Three Months Ended September 30, 2019
	Beginning ALLL Balance		Charge-offs		Recoveries		Provision for Credit Losses		Ending ALLL Balance
	(Dollars in thousands)

Investor loans secured by real estate
CRE non-owner-occupied	$	1,765	$	(86)	$	—	$	199	$	1,878
Multifamily	705		—		—		10		715
Construction and land	5,408		—		—		(617)		4,791
SBA secured by real estate	1,322		—		—		468		1,790
Business loans secured by real estate
CRE owner-occupied	2,299		—		8		257		2,564
Franchise real estate secured	579		—		—		(12)		567
SBA secured by real estate	1,611		(61)		21		539		2,110
Commercial loans
Commercial and industrial	13,796		(290)		54		(664)		12,896
Franchise non-real estate secured	6,186		(995)		—		975		6,166
SBA non-real estate secured	430		(82)		41		92		481
Retail loans
Single family residential	704		—		1		(14)		691
Consumer loans	221		(11)		9		132		351
Totals	$	35,026	$	(1,525)	$	134	$	1,365	$	35,000


	For the Nine Months Ended September 30, 2019
	Beginning ALLL Balance		Charge-offs		Recoveries		Provision for Credit Losses		Ending ALLL Balance
	(Dollars in thousands)

Investor loans secured by real estate
CRE non-owner-occupied	$	1,624	$	(574)	$	—	$	828	$	1,878
Multifamily	740		—		—		(25)		715
Construction and land	5,964		—		—		(1,173)		4,791
SBA secured by real estate	1,827		(721)		—		684		1,790
Business loans secured by real estate
CRE owner-occupied	1,908		—		31		625		2,564
Franchise real estate secured	743		(1,376)		—		1,200		567
SBA secured by real estate	1,824		(315)		21		580		2,110
Commercial loans
Commercial and industrial	13,695		(985)		168		18		12,896
Franchise non-real estate secured	6,066		(1,155)		—		1,255		6,166
SBA non-real estate secured	654		(326)		45		108		481
Retail loans
Single family residential	808		—		2		(119)		691
Consumer loans	219		(16)		10		138		351
Totals	$	36,072	$	(5,468)	$	277	$	4,119	$	35,000

The increase in the ACL for loans held for investment during the three months ended September 30, 2020 of $232,000 is reflective of a $4.7 million in provision for credit losses and $4.5 million in net charge-offs. The provision for credit losses for the three months ended September 30, 2020 is reflective of unfavorable, but improving economic forecasts used in the Company’s ACL model. The change in the ACL for the nine months ended September 30, 2020 of $246.8 million is reflective of a $55.7 million addition associated with the Company’s adoption of ASC 326 on January 1, 2020, which was recorded through a cumulative effect adjustment to retained earnings, as well as a $180.3 million provision for credit losses on loans, net charge-offs of $10.5 million, and the establishment of $21.2 million in net ACL for PCD loans previously mentioned. The provision for credit losses of $180.3 million during the nine months ended September 30, 2020 is inclusive of $75.9 million related to the initial ACL required for the acquisition of non-PCD loans in the Opus acquisition. Under ASC 326, the Company is required to record an ACL for estimates of life-time credit losses on loans at the time of acquisition. For non-PCD loans, the initial ACL is established through a charge to provision for credit losses at the time of acquisition. However, the ACL for PCD loans is established through an adjustment to the loan’s purchase price (or initial fair value). Excluding the impact of the Opus acquisition, the provision for credit losses for the nine months ended September 30, 2020 is also reflective of unfavorable economic forecasts used in the Company’s ACL model driven by the COVID-19 pandemic.

The Company maintains an allowance for credit losses on off-balance sheet commitments related to unfunded loans and lines of credit, which is included in other liabilities of the consolidated balance sheets. The allowance for off-balance sheet commitments was $21.5 million at September 30, 2020 and $3.3 million at December 31, 2019. The change in the allowance for off-balance sheet commitments can be attributed to several factors, including: (i) an $8.3 million increase in the first quarter of 2020 attributed to the Company’s adoption of ASC 326, (ii) a $8.6 million provision for credit losses in the second quarter of 2020 related to the initial ACL on off-balance sheet loan commitments that the Company was required to establish at the time of acquisition of Opus, and (iii) a $1.4 million in provision for credit losses for the first nine months of 2020 related primarily to the deterioration in economic forecasts, primarily in the second quarter of 2020, used in the Company’s CECL model. The total provision for credit losses for off-balance sheet commitments reflected a recapture of $492,000 and a provision of $10.0 million for the three and nine months ended September 30, 2020, respectively. The reversal of provision for credit losses for off-balance sheet commitments for the three months ended September 30, 2020 can be attributed to lower outstanding unfunded balance in certain loan segments where a higher reserve allocation has been assigned.


	December 31, 2019
	Loans Evaluated Individually for Impairment		ALLL Attributed to Individually Evaluated Loans		Loans Evaluated Collectively for Impairment		ALLL Attributed to Collectively Evaluated Loans
	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied	$	1,088	$	—	$	2,069,053	$	1,899
Multifamily	—		—		1,575,726		729
Construction and land	—		—		438,786		4,484
SBA secured by real estate	390		—		68,041		1,915
Business loans secured by real estate
CRE owner-occupied	—		—		1,846,554		2,781
Franchise real estate secured	—		—		353,240		592
SBA secured by real estate	1,517		—		86,864		2,119
Commercial loans
Commercial and industrial	7,529		—		1,385,741		13,857
Franchise non-real estate secured	10,834		—		553,523		5,816
SBA non-real estate secured	1,118		—		16,308		445
Retail loans
Single family residential	366		—		254,658		655
Consumer loans	—		—		50,975		406
Totals	$	22,842	$	—	$	8,699,469	$	35,698


	Commercial Real Estate Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
September 30, 2020	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied
0% - 5.00%	$	188,404	$	543,940	$	374,636	$	265,887	$	266,967	$	792,295	$	10,788	$	—	$	2,442,917
>5.00% - 10.00%	—		7,015		102,566		10,874		17,282		25,791		243		—		163,771
Greater than 10%	2,297		15,900		202		37,864		6,447		37,973		559		—		101,242
Multifamily
0% - 5.00%	630,900		1,709,927		935,659		723,886		399,890		618,503		574		—		5,019,339
>5.00% - 10.00%	4,251		11,286		14,944		14,708		2,836		2,102		—		—		50,127
Greater than 10%	3,198		14,022		14,137		12,513		10,167		18,566		—		—		72,603
Construction and Land
0% - 5.00%	24,862		56,858		12,550		22,362		—		6,448		—		—		123,080
>5.00% - 10.00%	—		36,289		10,750		466		—		—		—		—		47,505
Greater than 10%	378		52,562		82,297		10,195		19,932		1,549		374		—		167,287
SBA secured by real estate
0% - 5.00%	494		10,412		12,584		15,540		7,111		10,204		—		—		56,345
>5.00% - 10.00%	—		—		—		—		—		—		—		—		—
Greater than 10%	—		163		591		—		—		511		—		—		1,265
Total investor loans secured by real estate	$	854,784	$	2,458,374	$	1,560,916	$	1,114,295	$	730,632	$	1,513,942	$	12,538	$	—	$	8,245,481
Business loans secured by real estate
CRE owner-occupied
0% - 5.00%	$	202,228	$	368,034	$	299,843	$	296,647	$	197,043	$	426,513	$	520	$	—	$	1,790,828
>5.00% - 10.00%	8,434		37,617		58,314		53,967		39,056		78,666		3,826		—		279,880
Greater than 10%	—		22,362		3,636		7,285		5,793		9,507		497		—		49,080
Franchise real estate secured
0% - 5.00%	19,753		85,363		73,100		102,756		31,512		42,346		—		—		354,830
>5.00% - 10.00%	754		—		631		—		—		—		—		—		1,385
Greater than 10%	—		2,386		728		—		—		—		—		—		3,114
SBA secured by real estate
0% - 5.00%	2,643		7,658		13,375		15,993		6,150		22,077		95		—		67,991
>5.00% - 10.00%	—		—		679		1,117		3,493		4,679		—		—		9,968
Greater than 10%	—		—		22		1,994		914		3,237		—		—		6,167
Total business loans secured by real estate	$	233,812	$	523,420	$	450,328	$	479,759	$	283,961	$	587,025	$	4,938	$	—	$	2,563,243


	Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
September 30, 2020	(Dollars in thousands)
Investor loans secured by real estate
CRE non-owner-occupied
55% and below	$	100,859	$	238,182	$	190,263	$	156,791	$	192,044	$	602,788	$	11,031	—		$	1,491,958
>55-65%	71,824		220,089		110,830		136,117		84,644		217,812		559		—		841,875
>65-75%	18,018		105,825		171,532		18,946		13,796		30,887		—		—		359,004
Greater than 75%	—		2,759		4,779		2,771		212		4,572		—		—		15,093
Multifamily
55% and below	147,694		347,848		303,801		252,662		90,318		294,211		574		—		1,437,108
>55-65%	233,564		742,570		406,271		234,044		169,033		242,603		—		—		2,028,085
>65-75%	257,091		628,393		244,007		262,512		153,542		96,542		—		—		1,642,087
Greater than 75%	—		16,424		10,661		1,889		—		5,815		—		—		34,789
Construction and land
55% and below	24,116		129,160		66,830		26,261		19,932		7,997		374		—		274,670
>55-65%	1,124		13,254		23,699		6,762		—		—		—		—		44,839
>65-75%	—		3,295		15,068		—		—		—		—		—		18,363
Greater than 75%	—		—		—		—		—		—		—		—		—
SBA secured by real estate
55% and below	—		2,070		653		673		330		785		—		—		4,511
>55-65%	—		2,433		1,643		4,017		621		4,482		—		—		13,196
>65-75%	—		3,905		5,075		4,185		4,795		1,897		—		—		19,857
Greater than 75%	494		2,167		5,804		6,665		1,365		3,551		—		—		20,046
Total investor loans secured by real estate	$	854,784	$	2,458,374	$	1,560,916	$	1,114,295	$	730,632	$	1,513,942	$	12,538	$	—	$	8,245,481
Business loan secured by real estate
CRE owner-occupied
55% and below	$	56,954	$	156,880	$	171,740	$	203,875	$	133,740	$	357,734	$	4,843	—		$	1,085,766
>55-65%	56,139		93,895		97,245		94,359		73,389		80,933		—		—		495,960
>65-75%	55,932		155,872		80,898		46,241		32,547		50,458		—		—		421,948
Greater than 75%	41,637		21,366		11,910		13,424		2,216		25,561		—		—		116,114
Franchise real estate secured
55% and below	7,462		13,322		14,407		21,162		11,592		20,549		—		—		88,494
>55-65%	—		9,981		15,893		23,658		7,784		5,862		—		—		63,178
>65-75%	3,972		53,584		21,750		9,768		11,017		14,697		—		—		114,788
Greater than 75%	9,073		10,862		22,409		48,168		1,119		1,238		—		—		92,869
SBA secured by real estate
55% and below	1,355		1,633		5,376		5,683		3,175		15,281		95		—		32,598
>55-65%	104		513		1,802		1,719		3,706		5,665		—		—		13,509
>65-75%	264		3,148		751		4,193		2,340		5,401		—		—		16,097
Greater than 75%	920		2,364		6,147		7,509		1,336		3,646		—		—		21,922

Total business loans secured by real estate	$	233,812	$	523,420	$	450,328	$	479,759	$	283,961	$	587,025	$	4,938	$	—	$	2,563,243


	Term Loans by Vintage
	2020		2019		2018		2017		2016		Prior		Revolving		Revolving Converted to Term During the Period		Total
September 30, 2020	(Dollars in thousands)
Retail Loans
Single family residential
Greater than 740	$	4,469	$	7,198	$	12,719	$	9,658	$	29,291	$	91,460	$	22,566	—		$	177,361
>680 - 740	—		1,187		2,253		4,763		2,641		28,625		7,919		—		47,388
>580 - 680	—		—		—		463		3,142		11,113		932		—		15,650
Less than 580	—		—		—		—		—		2,925		35		—		2,960
Consumer loans
Greater than 740	63		85		54		46		10		2,648		1,670		—		4,576
>680 - 740	—		40		6		37,991		—		480		1,665		—		40,182
>580 - 680	—		17		—		—		2		144		59		—		222
Less than 580	—		—		—		—		—		26		28		—		54
Total retail loans	$	4,532	$	8,527	$	15,032	$	52,921	$	35,086	$	137,421	$	34,874	$	—	$	288,393