Large Bank Examination Workshop February 2026

“ Vendors should provide appropriate testing results that show their product works as expected. They should also clearly indicate the model’s limitations and assumptions and where the product’s use may be problematic. ” The sample transaction testing demonstrated that the Model works as expected. Detailed testing information is included in the workpapers produced during this certification and is available for review. No transactions types that would be commonly expected for depository financial institutions were found to be problematic in the testing process.

“ Banks should expect vendors to conduct ongoing performance monitoring and outcomes analysis, with disclosure to their clients, and to make appropriate modifications and updates over time. ”

The results of a previous validation conducted by the Office of Thrift Supervision (OTS) were reviewed to ensure that opportunities for improvement identified during that review were incorporated into the Model. Also, periodic model updates and change control logs were reviewed to ensure that continuous and ongoing improvements were incorporated into the Model over time. This documentation is available for review by clients and other interested parties such as regulators.

Certification of Model Methodology and Process Integrity

Based on an extensive evaluation of the Model’s methodology as well as a review of THC’s supporting operational processes to acquire client data and assumptions to generate interest rate risk sensitivity reports, Angel Oak Advisory Services certifies that the THC Decisions Model possesses the necessary theoretical components and operational controls to accurately assess the interest rate risk sensitivity of a depository financial institution’s economic capital and earnings . This certification is presented in the context of universally accepted regulatory requirements as well as widely recognized risk management best practices. Institutions that utilize the model by providing financial data that accurately reflects the current composition of assets and liabilities along with reasonable assumptions regarding historical and future customer behaviors can have confidence that the Model can be used for its intended purpose. This certification provides support for a depository financial institution’s efforts to implement appropriate model validation processes and procedures but does not replace the firm’s own internal efforts to ensure that their utilization of this model conforms to regulatory requirements and industry best practices.

___________________________

Robert McDonough, Senior Managing Director

Angel Oak Advisory Services

September 27th, 2011

3

Page 10 of 39