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DEBT SECURITIES | 6 Months Ended
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Jun. 30, 2024
DEBT SECURITIES [Abstract] |
DEBT SECURITIES | NOTE 2 – DEBT SECURITIES Available-for-Sale Debt Securities The amortized cost, gross unrealized gains and losses, ACL, estimated fair value, and weighted-average yield of available-for-sale debt securities by contractual maturities as of June 30, 2024 and December 31, 2023 were as follows: June 30, 2024 Amortized cost (1) Gross Unrealized ACL Fair Value (2) Weighted- Gains Losses average yield% (Dollars in thousands) U.S. Treasury securities: Due within one year $ 100,370 $ - $ 2,156 $ - $ 98,214 0.70 After 1 to 5 years 19,901 - 1,042 - 18,859 0.65 U.S. government-sponsored entities' (“GSEs”) obligations: Due within one year 782,777 - 16,859 - 765,918 0.91 After 1 to 5 years 1,564,870 51 111,755 - 1,453,166 0.82 After 5 to 10 years 8,850 - 750 - 8,100 2.64 After 10 years 8,228 15 - - 8,243 5.69 Puerto Rico government obligation: After 10 years (3) 3,084 - 1,166 386 1,532 - United States and Puerto Rico government obligations 2,488,080 66 133,728 386 2,354,032 0.86 Mortgage-backed securities (“MBS”): Residential MBS: Freddie Mac (“FHLMC”) certificates: Due within one year 4 - - - 4 4.31 After 1 to 5 years 16,204 - 754 - 15,450 2.06 After 5 to 10 years 138,723 - 12,739 - 125,984 1.55 After 10 years 948,539 6 172,740 - 775,805 1.41 1,103,470 6 186,233 - 917,243 1.44 Ginnie Mae (“GNMA”) certificates: Due within one year 841 - 8 - 833 3.29 After 1 to 5 years 11,837 - 648 - 11,189 0.93 After 5 to 10 years 31,168 2 2,783 - 28,387 1.77 After 10 years 191,483 101 25,966 - 165,618 2.65 235,329 103 29,405 - 206,027 2.45 Fannie Mae (“FNMA”) certificates: After 1 to 5 years 26,921 - 1,236 - 25,685 2.11 After 5 to 10 years 272,851 - 23,789 - 249,062 1.74 After 10 years 988,450 2 165,091 - 823,361 1.36 1,288,222 2 190,116 - 1,098,108 1.45 Collateralized mortgage obligations (“CMOs”) issued or guaranteed by the FHLMC, FNMA, and GNMA: After 10 years 259,830 - 54,810 - 205,020 1.52 Private label: After 5 to 10 years 1,322 - 317 5 1,000 8.93 After 10 years 5,359 - 1,634 158 3,567 7.34 6,681 - 1,951 163 4,567 7.65 Total Residential MBS 2,893,532 111 462,515 163 2,430,965 1.55 Commercial MBS: After 1 to 5 years 44,240 9 7,121 - 37,128 2.18 After 5 to 10 years 22,121 - 2,795 - 19,326 2.16 After 10 years 146,191 - 31,331 - 114,860 1.98 Total Commercial MBS 212,552 9 41,247 - 171,314 2.04 Total MBS 3,106,084 120 503,762 163 2,602,279 1.58 Other: Due within one year 500 - - - 500 2.35 After 1 to 5 years 500 - - - 500 2.35 1,000 - - - 1,000 2.35 Total available-for-sale debt securities $ 5,595,164 $ 186 $ 637,490 $ 549 $ 4,957,311 1.26 (1) Excludes accrued interest receivable on available-for-sale debt securities that totaled $ 10.0 million as of June 30, 2024 reported as part of accrued interest receivable on loans and investment securities in the consolidated statements of financial condition, and excluded from the estimate of credit losses. (2) Includes $ 465.5 million (amortized cost - $ 538.5 million) that was pledged at the FHLB as collateral for borrowings and letters of credit as well as $ 2.7 billion (amortized cost - $ 3.1 billion) pledged as collateral for the uninsured portion of government deposits. The secured parties are not permitted to sell or repledge the collateral. (3) Consists of a residential pass-through MBS issued by the Puerto Rico Housing Finance Authority (the “PRHFA”) that is collateralized by certain second mortgages originated under a program launched by the Puerto Rico government in 2010 and is in nonaccrual status based on the delinquency status of the underlying second mortgage loans collateral. December 31, 2023 Amortized cost (1) Gross Unrealized ACL Fair value (2) Weighted- Gains Losses average yield% (Dollars in thousands) U.S. Treasury securities: Due within one year $ 80,314 $ - $ 2,144 $ - $ 78,170 0.66 After 1 to 5 years 60,239 - 3,016 - 57,223 0.75 U.S. GSEs’ obligations: Due within one year 542,847 - 15,832 - 527,015 0.77 After 1 to 5 years 1,899,620 49 135,347 - 1,764,322 0.86 After 5 to 10 years 8,850 - 687 - 8,163 2.64 After 10 years 8,891 8 2 - 8,897 5.49 Puerto Rico government obligation: After 10 years (3) 3,156 - 1,346 395 1,415 - United States and Puerto Rico government obligations 2,603,917 57 158,374 395 2,445,205 0.85 MBS: Residential MBS: FHLMC certificates: After 1 to 5 years 19,561 - 868 - 18,693 2.06 After 5 to 10 years 153,308 - 12,721 - 140,587 1.55 After 10 years 991,060 15 161,197 - 829,878 1.41 1,163,929 15 174,786 - 989,158 1.44 GNMA certificates: Due within one year 254 - 3 - 251 3.27 After 1 to 5 years 16,882 - 872 - 16,010 1.19 After 5 to 10 years 27,916 8 2,247 - 25,677 1.62 After 10 years 206,254 87 22,786 - 183,555 2.57 251,306 95 25,908 - 225,493 2.38 FNMA certificates: After 1 to 5 years 32,489 - 1,423 - 31,066 2.11 After 5 to 10 years 293,492 - 23,146 - 270,346 1.70 After 10 years 1,047,298 83 156,344 - 891,037 1.37 1,373,279 83 180,913 - 1,192,449 1.46 CMOs issued or guaranteed by the FHLMC, FNMA, and GNMA: After 10 years 273,539 - 52,263 - 221,276 1.54 Private label: After 10 years 7,086 - 2,185 116 4,785 7.66 Total Residential MBS 3,069,139 193 436,055 116 2,633,161 1.55 Commercial MBS: After 1 to 5 years 45,022 - 6,898 - 38,124 2.17 After 5 to 10 years 22,386 - 2,685 - 19,701 2.16 After 10 years 122,830 - 29,037 - 93,793 1.36 Total Commercial MBS 190,238 - 38,620 - 151,618 1.64 Total MBS 3,259,377 193 474,675 116 2,784,779 1.55 Total available-for-sale debt securities $ 5,863,294 $ 250 $ 633,049 $ 511 $ 5,229,984 1.24 (1) Excludes accrued interest receivable on available-for-sale debt securities that totaled $ 10.6 million as of December 31, 2023 reported as part of accrued interest receivable on loans and investment securities in the consolidated statements of financial condition, and excluded from the estimate of credit losses. (2) Includes $ 477.9 million (amortized cost - $ 527.2 million) that was pledged at the FHLB as collateral for borrowings and letters of credit as well as $ 2.8 billion (amortized cost - $ 3.2 billion) pledged as collateral for the uninsured portion of government deposits. The secured parties are not permitted to sell or repledge the collateral. (3) Consists of a residential pass-through MBS issued by the PRHFA that is collateralized by certain second mortgages originated under a program launched by the Puerto Rico government in 2010 and is in nonaccrual status based on the delinquency status of the underlying second mortgage loans collateral. During the second quarter of 2024, the Corporation purchased approximately $ 28.0 million of Community Reinvestment Act qualified investments, which were classified as available-for-sale debt securities. Maturities of available-for-sale debt securities are based on the period of final contractual maturity. Expected maturities might differ from contractual maturities because they may be subject to prepayments and/or call options. The weighted-average yield on available-for-sale debt securities is based on amortized cost and, therefore, does not give effect to changes in fair value. The net unrealized loss on available-for-sale debt securities is presented as part of accumulated other comprehensive loss in the consolidated statements of financial condition. The following tables present the fair value and gross unrealized losses of the Corporation’s available-for-sale debt securities, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position, as of June 30, 2024 and December 31, 2023. The tables also include debt securities for which an ACL was recorded. As of June 30, 2024 Less than 12 months 12 months or more Total Unrealized Unrealized Unrealized Fair Value Losses Fair Value Losses Fair Value Losses (In thousands) U.S. Treasury and U.S. GSEs’ obligations $ 875 $ - $ 2,338,381 $ 132,562 $ 2,339,256 $ 132,562 Puerto Rico government obligation - - 1,532 1,166 (1) 1,532 1,166 MBS: Residential MBS: FHLMC 1,191 15 915,156 186,218 916,347 186,233 GNMA 11,188 123 188,231 29,282 199,419 29,405 FNMA 8,135 99 1,088,394 190,017 1,096,529 190,116 CMOs issued or guaranteed by the FHLMC, FNMA, and GNMA - - 202,963 54,810 202,963 54,810 Private label - - 4,567 1,951 (1) 4,567 1,951 Commercial MBS 28,715 428 136,652 40,819 165,367 41,247 $ 50,104 $ 665 $ 4,875,876 $ 636,825 $ 4,925,980 $ 637,490 (1) Unrealized losses do not include the credit loss component recorded as part of the ACL. As of June 30, 2024, the PRHFA bond and private label MBS had an ACL of $ 0.4 million and $ 0.2 million, respectively. As of December 31, 2023 Less than 12 months 12 months or more Total Unrealized Unrealized Unrealized Fair Value Losses Fair Value Losses Fair Value Losses (In thousands) U.S. Treasury and U.S. GSEs’ obligations $ 2,544 $ 2 $ 2,428,784 $ 157,026 $ 2,431,328 $ 157,028 Puerto Rico government obligation - - 1,415 1,346 (1) 1,415 1,346 MBS: Residential MBS: FHLMC 9 - 988,092 174,786 988,101 174,786 GNMA 12,257 100 202,390 25,808 214,647 25,908 FNMA - - 1,183,275 180,913 1,183,275 180,913 CMOs issued or guaranteed by the FHLMC, FNMA, and GNMA - - 221,276 52,263 221,276 52,263 Private label - - 4,785 2,185 (1) 4,785 2,185 Commercial MBS 11,370 18 140,248 38,602 151,618 38,620 $ 26,180 $ 120 $ 5,170,265 $ 632,929 $ 5,196,445 $ 633,049 (1) Unrealized losses do not include the credit loss component recorded as part of the ACL. As of December 31, 2023, the PRHFA bond and private label MBS had an ACL of $ 0.4 million and $ 0.1 million, respectively. Assessment for Credit Losses Debt securities issued by U.S. government agencies, U.S. GSEs, and the U.S. Treasury, including notes and MBS, accounted for substantially all of the total available-for-sale portfolio as of June 30, 2024, and the Corporation expects no credit losses on these securities, given the explicit and implicit guarantees provided by the U.S. federal government. Because the decline in fair value is attributable to changes in interest rates, and not credit quality, and because, as of June 30, 2024, the Corporation did not have the intent to sell these U.S. government and agencies debt securities and determined that it was likely that it will not be required to sell these securities before their anticipated recovery, the Corporation does not consider impairments on these securities to be credit related. The Corporation’s credit loss assessment was concentrated mainly on private label MBS and on Puerto Rico government debt securities, for which credit losses are evaluated on a quarterly basis. Private label MBS held as part of the Corporation’s available for sale portfolio consist of trust certificates issued by an unaffiliated party backed by fixed-rate, single-family residential mortgage loans in the U.S. mainland with original FICO scores over 700 and moderate loan-to-value ratios (under 80 %), as well as moderate delinquency levels. The interest rate on these private label MBS is variable, tied to 3-month CME Term Secured Overnight Financing Rate (“SOFR”) plus a tenor spread adjustment of 0.26161 % and the original spread limited to the weighted-average coupon of the underlying collateral. The Corporation determined the ACL for private label MBS based on a risk-adjusted discounted cash flow methodology that considers the structure and terms of the instruments. The Corporation utilized probability of default (“PDs”) and loss-given default (“LGDs”) that considered, among other things, historical payment performance, loan-to-value attributes, and relevant current and forward-looking macroeconomic variables, such as regional unemployment rates and the housing price index. Under this approach, expected cash flows (interest and principal) were discounted at the U.S. Treasury yield curve as of the reporting date. See Note 17 – “Fair Value ” for the significant assumptions used in the valuation of the private label MBS as of June 30, 2024 and December 31 2023. For the residential pass-through MBS issued by the PRHFA held as part of the Corporation’s available-for-sale portfolio backed by second mortgage residential loans in Puerto Rico, the ACL was determined based on a discounted cash flow methodology that considered the structure and terms of the debt security. The expected cash flows were discounted at the U.S. Treasury yield curve plus a spread as of the reporting date and compared to the amortized cost. The Corporation utilized PDs and LGDs that considered, among other things, historical payment performance, loan-to-value attributes, and relevant current and forward-looking macroeconomic variables, such as regional unemployment rates, the housing price index, and expected recovery from the PRHFA guarantee. PRHFA, not the Puerto Rico government, provides a guarantee in the event of default and subsequent foreclosure of the properties underlying the second mortgage loans. In the event that the second mortgage loans default and the collateral is insufficient to satisfy the outstanding balance of this residential pass-through MBS, PRHFA’s ability to honor such guarantee will depend on, among other factors, its financial condition at the time such obligation becomes due and payable. Deterioration of the Puerto Rico economy or fiscal health of the PRHFA could impact the value of this security, resulting in additional losses to the Corporation. The following tables present a roll-forward of the ACL on available-for-sale debt securities by major security type for the quarters and six-month periods ended June 30, 2024 and 2023: Quarter Ended June 30, 2024 2023 Private label MBS Puerto Rico Government Obligation Total Private label MBS Puerto Rico Government Obligation Total (In thousands) Beginning balance $ 116 $ 326 $ 442 $ 83 $ 366 $ 449 Provision for credit losses – expense (benefit) - 60 60 - (16) (16) Net recoveries 47 - 47 - - - ACL on available-for-sale debt securities $ 163 $ 386 $ 549 $ 83 $ 350 $ 433 Six-Month Period Ended June 30, 2024 2023 Private label MBS Puerto Rico Government Obligations Total Private label MBS Puerto Rico Government Obligations Total (In thousands) Beginning balance $ 116 $ 395 $ 511 $ 83 $ 375 $ 458 Provision for credit losses - benefit - (9) (9) - (25) (25) Net recoveries 47 - 47 - - - ACL on available-for-sale debt securities $ 163 $ 386 $ 549 $ 83 $ 350 $ 433 Held-to-Maturity Debt Securities The amortized cost, gross unrecognized gains and losses, estimated fair value, ACL, weighted-average yield and contractual maturities of held-to-maturity debt securities as of June 30, 2024 and December 31, 2023 were as follows: June 30, 2024 Amortized cost (1) (2) Gross Unrecognized Fair value Weighted- Gains Losses ACL average yield% (Dollars in thousands) Puerto Rico municipal bonds: Due within one year $ 3,178 $ - $ 18 $ 3,160 $ 37 9.30 After 1 to 5 years 51,424 972 620 51,776 468 7.72 After 5 to 10 years 36,253 3,393 201 39,445 451 7.03 After 10 years 16,595 350 - 16,945 311 8.78 Total Puerto Rico municipal bonds 107,450 4,715 839 111,326 1,267 7.70 MBS: Residential MBS: FHLMC certificates: After 5 to 10 years 14,243 - 578 13,665 - 3.03 After 10 years 17,879 - 1,146 16,733 - 4.35 32,122 - 1,724 30,398 - 3.76 GNMA certificates: After 10 years 15,047 - 951 14,096 - 3.30 FNMA certificates: After 10 years 64,591 - 3,927 60,664 - 4.19 CMOs issued or guaranteed by FHLMC, FNMA, and GNMA: After 10 years 26,855 - 1,640 25,215 - 3.49 Total Residential MBS 138,615 - 8,242 130,373 - 3.86 Commercial MBS: After 1 to 5 years 9,352 - 301 9,051 - 3.48 After 10 years 89,018 - 6,078 82,940 - 3.15 Total Commercial MBS 98,370 - 6,379 91,991 - 3.18 Total MBS 236,985 - 14,621 222,364 - 3.58 Total held-to-maturity debt securities $ 344,435 $ 4,715 $ 15,460 $ 333,690 $ 1,267 4.86 (1) Excludes accrued interest receivable on held-to-maturity debt securities that totaled $ 4.8 million as of June 30, 2024 reported as part of accrued interest receivable on loans and investment securities in the consolidated statements of financial condition, and excluded from the estimate of credit losses. (2) Includes $ 189.7 million (fair value - $ 184.4 million) that serves as collateral for the uninsured portion of government deposits. The secured parties are not permitted to sell or repledge the collateral. December 31, 2023 Amortized cost (1) (2) Gross Unrecognized Fair value Weighted- Gains Losses ACL average yield% (Dollars in thousands) Puerto Rico municipal bonds: Due within one year $ 3,165 $ 8 $ 38 $ 3,135 $ 50 9.30 After 1 to 5 years 51,230 994 710 51,514 1,266 7.78 After 5 to 10 years 36,050 3,540 210 39,380 604 7.13 After 10 years 16,595 269 - 16,864 277 8.87 Total Puerto Rico municipal bonds 107,040 4,811 958 110,893 2,197 7.78 MBS: Residential MBS: FHLMC certificates: After 5 to 10 years 16,469 - 556 15,913 - 3.03 After 10 years 18,324 - 714 17,610 - 4.32 34,793 - 1,270 33,523 - 3.71 GNMA certificates: After 10 years 16,265 - 789 15,476 - 3.32 FNMA certificates: After 10 years 67,271 - 2,486 64,785 - 4.18 CMOs issued or guaranteed by FHLMC, FNMA, and GNMA: After 10 years 28,139 - 1,274 26,865 - 3.49 Total Residential MBS 146,468 - 5,819 140,649 - 3.84 Commercial MBS: After 1 to 5 years 9,444 - 297 9,147 - 3.48 After 10 years 91,226 - 5,783 85,443 - 3.15 Total Commercial MBS 100,670 - 6,080 94,590 - 3.18 Total MBS 247,138 - 11,899 235,239 - 3.57 Total held-to-maturity debt securities $ 354,178 $ 4,811 $ 12,857 $ 346,132 $ 2,197 4.84 (1) Excludes accrued interest receivable on held-to-maturity debt securities that totaled $ 4.8 million as of December 31, 2023 reported as part of accrued interest receivable on loans and investment securities in the consolidated statements of financial condition, and excluded from the estimate of credit losses. (2) Includes $ 126.6 million (fair value - $ 125.9 million) that serves as collateral for the uninsured portion of government deposits. The secured parties are not permitted to sell or repledge the collateral. The following tables present the Corporation’s held-to-maturity debt securities’ fair value and gross unrecognized losses, aggregated by category and length of time that individual securities had been in a continuous unrecognized loss position, as of June 30, 2024 and December 31, 2023, including debt securities for which an ACL was recorded: As of June 30, 2024 Less than 12 months 12 months or more Total Unrecognized Unrecognized Unrecognized Fair Value Losses Fair Value Losses Fair Value Losses (In thousands) Puerto Rico municipal bonds $ - $ - $ 26,147 $ 839 $ 26,147 $ 839 MBS: Residential MBS: FHLMC certificates - - 30,398 1,724 30,398 1,724 GNMA certificates - - 14,096 951 14,096 951 FNMA certificates - - 60,664 3,927 60,664 3,927 CMOs issued or guaranteed by FHLMC, FNMA, and GNMA - - 25,215 1,640 25,215 1,640 Commercial MBS - - 91,991 6,379 91,991 6,379 Total held-to-maturity debt securities $ - $ - $ 248,511 $ 15,460 $ 248,511 $ 15,460 As of December 31, 2023 Less than 12 months 12 months or more Total Unrecognized Unrecognized Unrecognized Fair Value Losses Fair Value Losses Fair Value Losses (In thousands) Puerto Rico municipal bonds $ - $ - $ 34,682 $ 958 $ 34,682 $ 958 MBS: Residential MBS: FHLMC certificates - - 33,523 1,270 33,523 1,270 GNMA certificates - - 15,476 789 15,476 789 FNMA certificates - - 64,785 2,486 64,785 2,486 CMOs issued or guaranteed by FHLMC, FNMA, and GNMA - - 26,865 1,274 26,865 1,274 Commercial MBS - - 94,590 6,080 94,590 6,080 Total held-to-maturity debt securities $ - $ - $ 269,921 $ 12,857 $ 269,921 $ 12,857 The Corporation classifies the held-to-maturity debt securities portfolio into the following major security types: MBS issued or guaranteed by GSEs and underlying collateral and Puerto Rico municipal bonds. The Corporation does not recognize an ACL for MBS issued or guaranteed by GSEs since they are highly rated by major rating agencies and have a long history of no credit losses. In the case of Puerto Rico municipal bonds, the Corporation determines the ACL based on the product of a cumulative PD and LGD, and the amortized cost basis of the bonds over their remaining expected life as described in Note 1 – “Nature of Business and Summary of Significant Accounting Policies,” to the audited financial statements included in the 2023 Annual Report on Form 10-K. The Corporation performs periodic credit quality reviews on these issuers. All of the Puerto Rico municipal bonds were current as to scheduled contractual payments as of June 30, 2024. The ACL of Puerto Rico municipal bonds decreased to $ 1.3 million as of June 30, 2024, from $ 2.2 million as of December 31, 2023, mostly related to updated financial information of a bond issuer received during the first quarter of 2024. The following tables present the activity in the ACL for held-to-maturity debt securities by major security type for the quarters and six-month periods ended June 30, 2024 and 2023: Puerto Rico Municipal Bonds Quarter Ended June 30, 2024 2023 (In thousands) Beginning balance $ 1,235 $ 7,646 Provision for credit losses – expense 32 755 ACL on held-to-maturity debt securities $ 1,267 $ 8,401 Puerto Rico Municipal Bonds Six-Month Period Ended June 30, 2024 2023 (In thousands) Beginning Balance $ 2,197 $ 8,286 Provision for credit losses - (benefit) expense (930) 115 ACL on held-to-maturity debt securities $ 1,267 $ 8,401 During the second quarter of 2019, the oversight board established by PROMESA announced the designation of Puerto Rico’s 78 municipalities as covered instrumentalities under PROMESA. Municipalities may be affected by the negative economic and other effects resulting from expense, revenue, or cash management measures taken by the Puerto Rico government to address its fiscal situation, or measures included in its fiscal plan or fiscal plans of other government entities. Given the inherent uncertainties about the fiscal situation of the Puerto Rico central government and the measures taken, or to be taken, by other government entities in response to economic and fiscal challenges, the Corporation cannot be certain whether future charges to the ACL on these securities will be required. From time to time, the Corporation has held-to-maturity securities with an original maturity of three months or less that are considered cash and cash equivalents and are classified as money market investments in the consolidated statements of financial condition. As of June 30, 2024 and December 31, 2023, the Corporation had no outstanding held-to-maturity securities that were classified as cash and cash equivalents. Credit Quality Indicators: The held-to-maturity debt securities portfolio consisted of GSEs’ MBS and financing arrangements with Puerto Rico municipalities issued in bond form. As previously mentioned, the Corporation expects no credit losses on GSEs’ MBS. The Puerto Rico municipal bonds are accounted for as securities but are underwritten as loans with features that are typically found in commercial loans. Accordingly, the Corporation monitors the credit quality of these municipal bonds through the use of internal credit-risk ratings, which are generally updated on a quarterly basis. The Corporation considers a municipal bond as a criticized asset if its risk rating is Special Mention, Substandard, Doubtful, or Loss. Puerto Rico municipal bonds that do not meet the criteria for classification as criticized assets are considered to be Pass-rated securities. For the definitions of the internal-credit ratings, see Note 3 – “Debt Securities,” to the audited consolidated financial statements included in the 2023 Annual Report on Form 10-K. The Corporation periodically reviews its Puerto Rico municipal bonds to evaluate if they are properly classified, and to measure credit losses on these securities. The frequency of these reviews will depend on the amount of the aggregate outstanding debt, and the risk rating classification of the obligor. The Corporation has a Loan Review Group that reports directly to the Corporation’s Risk Management Committee and administratively to the Chief Risk Officer. The Loan Review Group performs annual comprehensive credit process reviews of the Bank’s commercial loan portfolios, including the above-mentioned Puerto Rico municipal bonds accounted for as held-to-maturity debt securities. The objective of these loan reviews is to assess accuracy of the Bank’s determination and maintenance of loan risk rating and its adherence to lending policies, practices and procedures. The monitoring performed by this group contributes to the assessment of compliance with credit policies and underwriting standards, the determination of the current level of credit risk, the evaluation of the effectiveness of the credit management process, and the identification of any deficiency that may arise in the credit- granting process. Based on its findings, the Loan Review Group recommends corrective actions, if necessary, that help in maintaining a sound credit process. The Loan Review Group reports the results of the credit process reviews to the Risk Management Committee. As of June 30, 2024 and December 31, 2023, all Puerto Rico municipal bonds classified as held-to-maturity were classified as Pass. No held-to-maturity debt securities were on nonaccrual status, 90 days past due and still accruing, or past due as of June 30, 2024 and December 31, 2023. A security is considered to be past due once it is 30 days contractually past due under the terms of the agreement.

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