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Note 2 - INVESTMENT SECURITIES | 6 Months Ended
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Jun. 30, 2025
INVESTMENT SECURITIES |
INVESTMENT SECURITIES | NOTE 2– INVESTMENT SECURITIES The amortized cost and fair value of investment securities as of June 30, 2025 and December 31, 2024 are summarized as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | Allowance |  | Gross | ​ | Gross | ​ | ​ | ​ | ​
​ | ​ | Amortized | ​ | for Credit |  | Unrealized | ​ | Unrealized | ​ | Fair | ​
​ |  | Cost |  | (Losses) |  | Gains |  | (Losses) |  | Value |
​ | ​ | (dollars in thousands) | ​
June 30, 2025: |  | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |
Securities HTM: |  | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |
Municipal securities | ​ | $ | 879,663 | ​ | $ | (254) | ​ | $ | 11,203 | ​ | $ | (120,662) | ​ | $ | 769,950 | ​
Corporate securities | ​ | ​ | 28,585 | ​ | ​ | (8) | ​ | ​ | 3,991 | ​ | ​ | — | ​ | ​ | 32,568 | ​
Other securities | ​ |  | 1,050 | ​ |  | (1) | ​ |  | — | ​ |  | (2) | ​ |  | 1,047 | ​
​ | ​ | $ | 909,298 | ​ | $ | (263) | ​ | $ | 15,194 | ​ | $ | (120,664) | ​ | $ | 803,565 | ​
​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​
Securities AFS: | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​
U.S. treasuries and govt. sponsored agency securities | ​ | $ | 16,268 | ​ | $ | — | ​ | $ | 3 | ​ | $ | (2,004) | ​ | $ | 14,267 | ​
Residential mortgage-backed and related securities | ​ |  | 63,364 | ​ |  | — | ​ |  | 6 | ​ |  | (4,506) | ​ |  | 58,864 | ​
Municipal securities | ​ |  | 204,038 | ​ |  | — | ​ |  | — | ​ |  | (50,059) | ​ |  | 153,979 | ​
Asset-backed securities | ​ | ​ | 6,599 | ​ | ​ | — | ​ | ​ | 85 | ​ | ​ | — | ​ | ​ | 6,684 | ​
Corporate securities | ​ |  | 39,373 | ​ |  | — | ​ |  | 33 | ​ |  | (1,683) | ​ |  | 37,723 | ​
​ | ​ | $ | 329,642 | ​ | $ | — | ​ | $ | 127 | ​ | $ | (58,252) | ​ | $ | 271,517 | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | Allowance | ​ | Gross | ​ | Gross | ​ | ​ | ​
​ | ​ | Amortized | ​ | for Credit | ​ | Unrealized | ​ | Unrealized | ​ | Fair | ​
​ |  | Cost | ​ | (Losses) | ​ | Gains |  | (Losses) | ​ | Value | ​
​ | ​ | (dollars in thousands) | ​
December 31, 2024: |  | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  | ​ | ​ | ​ |
Securities HTM: |  | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  | ​ | ​ | ​ |
Municipal securities | ​ | $ | 806,992 | ​ | $ | (254) | ​ | $ | 23,292 | ​ | $ | (63,164) | ​ | $ | 766,866 | ​
Corporate securities | ​ | ​ | 28,018 | ​ | ​ | (8) | ​ | ​ | 4,665 | ​ | ​ | — | ​ | ​ | 32,675 | ​
Other securities | ​ |  | 1,050 | ​ |  | (1) | ​ |  | — | ​ |  | (7) | ​ |  | 1,042 | ​
​ | ​ | $ | 836,060 | ​ | $ | (263) | ​ | $ | 27,957 | ​ | $ | (63,171) | ​ | $ | 800,583 | ​
​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​
Securities AFS: | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​
U.S. treasuries and govt. sponsored agency securities | ​ | $ | 23,113 | ​ | $ | — | ​ | $ | 7 | ​ | $ | (2,529) | ​ | $ | 20,591 | ​
Residential mortgage-backed and related securities | ​ |  | 55,641 | ​ |  | — | ​ |  | 3 | ​ |  | (5,602) | ​ |  | 50,042 | ​
Municipal securities | ​ |  | 204,664 | ​ |  | — | ​ |  | — | ​ |  | (40,089) | ​ |  | 164,575 | ​
Asset-backed securities | ​ | ​ | 9,053 | ​ | ​ | — | ​ | ​ | 171 | ​ | ​ | — | ​ | ​ | 9,224 | ​
Corporate securities | ​ |  | 38,866 | ​ |  | — | ​ |  | 4 | ​ |  | (2,193) | ​ |  | 36,677 | ​
​ | ​ | $ | 331,337 | ​ | $ | — | ​ | $ | 185 | ​ | $ | (50,413) | ​ | $ | 281,109 | ​
​ The Company's HTM municipal securities consist largely of private issues of municipal debt. The large majority of the municipalities are located within the Midwest. The municipal debt investments are underwritten using specific guidelines with ongoing monitoring. ​ The Company's residential mortgage-backed and related securities portfolio consists entirely of government sponsored or government guaranteed securities. The Company has not invested in private mortgage-backed securities or pooled trust preferred securities. Gross unrealized losses and fair value, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position as of June 30, 2025, and December 31, 2024, are summarized in the tables below. Securities AFS, for which an allowance for credit losses has been provided, are not included in these disclosures as there are no unrealized losses remaining after consideration of the ACL. ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Less than 12 Months | ​ | 12 Months or More | ​ | Total
​ | ​ | ​ | ​ | Gross | ​ | ​ | ​ | Gross | ​ | ​ | ​ | Gross
​ | ​ | Fair | ​ | Unrealized | ​ | Fair | ​ | Unrealized | ​ | Fair | ​ | Unrealized
​ |  | Value |  | Losses |  | Value |  | Losses |  | Value |  | Losses
​ | ​ | (dollars in thousands)
June 30, 2025: |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |
Securities HTM: |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |
Municipal securities | ​ | $ | 276,990 | ​ | $ | (48,221) | ​ | $ | 279,489 | ​ | $ | (72,441) | ​ | $ | 556,479 | ​ | $ | (120,662)
Other securities | ​ | ​ | 500 | ​ | ​ | (1) | ​ | ​ | 548 | ​ | ​ | (1) | ​ | ​ | 1,048 | ​ | ​ | (2)
​ | ​ | $ | 277,490 | ​ | $ | (48,222) | ​ | $ | 280,037 | ​ | $ | (72,442) | ​ | $ | 557,527 | ​ | $ | (120,664)
​ | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |
Securities AFS: | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |
U.S. treasuries and govt. sponsored agency securities | ​ | $ | 62 | ​ | $ | (1) | ​ | $ | 13,643 | ​ | $ | (2,003) | ​ | $ | 13,705 | ​ | $ | (2,004)
Residential mortgage-backed and related securities | ​ |  | 13,977 | ​ |  | (152) | ​ |  | 35,931 | ​ |  | (4,354) | ​ |  | 49,908 | ​ |  | (4,506)
Municipal securities | ​ |  | 1,400 | ​ |  | (44) | ​ |  | 152,579 | ​ |  | (50,015) | ​ |  | 153,979 | ​ |  | (50,059)
Asset-backed securities | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | —
Corporate securities | ​ |  | — | ​ |  | — | ​ |  | 31,503 | ​ |  | (1,683) | ​ |  | 31,503 | ​ |  | (1,683)
​ | ​ | $ | 15,439 | ​ | $ | (197) | ​ | $ | 233,656 | ​ | $ | (58,055) | ​ | $ | 249,095 | ​ | $ | (58,252)
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Less than 12 Months | ​ | 12 Months or More | ​ | Total
​ | ​ | ​ | ​ | Gross | ​ | ​ | ​ | Gross | ​ | ​ | ​ | Gross
​ | ​ | Fair | ​ | Unrealized | ​ | Fair | ​ | Unrealized | ​ | Fair | ​ | Unrealized
​ |  | Value |  | Losses |  | Value |  | Losses |  | Value |  | Losses
​ | ​ | (dollars in thousands)
December 31, 2024: |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |
Securities HTM: |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |  | ​ |
Municipal securities | ​ | $ | 162,914 | ​ | $ | (14,382) | ​ | $ | 253,818 | ​ | $ | (48,782) | ​ | $ | 416,732 | ​ | $ | (63,164)
Other securities | ​ |  | 500 | ​ | ​ | — | ​ | ​ | 543 | ​ | ​ | (7) | ​ | ​ | 1,043 | ​ | ​ | (7)
​ | ​ | $ | 163,414 | ​ | $ | (14,382) | ​ | $ | 254,361 | ​ | $ | (48,789) | ​ | $ | 417,775 | ​ | $ | (63,171)
​ | ​ | ​ |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |
Securities AFS: | ​ |  |  | ​ |  | ​ | ​ |  |  | ​ |  |  | ​ |  |  | ​ |  |
U.S. govt. sponsored agency securities | ​ | $ | 6,522 | ​ | $ | (2) | ​ | $ | 13,369 | ​ | $ | (2,527) | ​ | $ | 19,891 | ​ | $ | (2,529)
Residential mortgage-backed and related securities | ​ |  | 1,337 | ​ |  | (24) | ​ |  | 48,520 | ​ |  | (5,578) | ​ |  | 49,857 | ​ |  | (5,602)
Municipal securities | ​ |  | 798 | ​ |  | (6) | ​ |  | 163,777 | ​ |  | (40,083) | ​ |  | 164,575 | ​ |  | (40,089)
Corporate securities | ​ | ​ | — | ​ |  | — | ​ |  | 35,712 | ​ |  | (2,193) | ​ |  | 35,712 | ​ |  | (2,193)
​ | ​ | $ | 8,657 | ​ | $ | (32) | ​ | $ | 261,378 | ​ | $ | (50,381) | ​ | $ | 270,035 | ​ | $ | (50,413)
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ On June 30, 2025, the investment portfolio included 677 securities. Of this number, 574 securities were in an unrealized loss position. The aggregate losses of these securities totaled approximately 15.01% of the total amortized cost of the portfolio. Of these 574 securities, there were 464 securities that were in an unrealized loss position for twelve months or more. Management has concluded unrealized losses as of June 30, 2025 were temporary due to the changing interest rate environment. ​ During 2023, the Company’s impairment evaluation determined that one publicly traded debt security experienced a decline in fair value due to credit quality, rather than market factors. As a result, the Company recognized a credit loss expense of $989 thousand in the first quarter of 2023 and established an ACL on the related AFS security. For the six months ended June 30, 2024, the remaining ACL on the related AFS security was removed as the security had been sold. ​ The following table presents the activity in the allowance for credit losses for held to maturity and available for sale securities by major security type for the three and six months ended June 30, 2025 and 2024: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Three Months Ended | ​ | ​ | ​
​ | ​ | June 30, 2025 | ​ | June 30, 2024
​ | ​ | Securities HTM | ​ | Securities AFS | ​ | Securities HTM | ​ | Securities AFS
​ | ​ | Municipal | ​ | Corporate | ​ | Other | ​ | ​ | ​ | Corporate | ​ | Municipal | ​ | Other | ​ | ​ | ​ | Corporate
​ |  | securities |  | securities | ​ | securities |  | Total | ​ | securities | ​ | securities | ​ | securities | ​ | Total | ​ | securities
​ |  | (dollars in thousands) | ​ | ​ | ​
Allowance for credit losses: | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Beginning balance | ​ | $ | 254 | ​ | $ | 8 | ​ | $ | 1 | ​ | $ | 263 | ​ | $ | — | ​ | $ | 202 | ​ | $ | 1 | ​ | $ | 203 | ​ | $ | —
Provision | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | —
Balance, ending | ​ | $ | 254 | ​ | $ | 8 | ​ | $ | 1 | ​ | $ | 263 | ​ | $ | — | ​ | $ | 202 | ​ | $ | 1 | ​ | $ | 203 | ​ | $ | —
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Six Months Ended
​ | ​ | June 30, 2025 | ​ | June 30, 2024
​ | ​ | Securities HTM | ​ | Securities AFS | ​ | Securities HTM | ​ | Securities AFS
​ | ​ | Municipal | ​ | ​ | Corporate | Other | ​ | ​ | ​ | ​ | Corporate | ​ | Municipal | ​ | Other | ​ | ​ | ​ | ​ | Corporate
​ | ​ | securities |  | ​ | securities | securities |  | Total | ​ | securities | ​ | securities | ​ | securities | ​ | Total | ​ | securities
​ | ​ | (dollars in thousands)
Allowance for credit losses: | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Beginning balance | ​ | $ | 254 | ​ | ​ | 8 | ​ | $ | 1 | ​ | $ | 263 | ​ | $ | — | ​ | $ | 202 | ​ | $ | 1 | ​ | $ | 203 | ​ | $ | 989
Reduction due to sales | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | (544)
Provision for credit loss expense | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | — | ​ | ​ | (445)
Balance, ending | ​ | $ | 254 | ​ | ​ | 8 | ​ | $ | 1 | ​ | $ | 263 | ​ | $ | — | ​ | $ | 202 | ​ | $ | 1 | ​ | $ | 203 | ​ | $ | —
​ Trading securities had a fair value of $82.9 million as of June 30, 2025 and $83.5 million as of December 31, 2024 and consist of retained beneficial interests acquired in conjunction with Freddie Mac securitizations completed by the Company in 2023 and 2024. The change in fair value on trading securities for the six months ended June 30, 2025 was a net loss of $77 thousand. The change in market value on trading securities for the six months ended June 30, 2024 was a net gain of $253 thousand. See also Note 4 to the Consolidated Financial Statements for details of these securitizations. There were no transfers of securities between classifications during both the six months ended June 30, 2025 and 2024. There were no sales of securities during both the three and six months ended June 30, 2025. There were no sales of securities during the three months ended June 30, 2024. There was one security sold during the six months ended June 30, 2024 which was identified as AFS. Information on proceeds received, as well as the gains and losses from the sale of securities, are as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | Three Months Ended |  | Six Months Ended |
​ | ​ | ​ | ​ | ​ | June 30, 2025 | ​ | June 30, 2024 | ​ | June 30, 2025 | ​ | June 30, 2024 | ​
​ | ​ | ​ | ​ | ​ | ​ | (dollars in thousands) | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Proceeds from sales of securities | ​ | ​ | ​ | ​ | $ | — | ​ | $ | — | ​ | $ | — | ​ | $ | 445 | ​
Gross gains from sales of securities | ​ | ​ | ​ | ​ |  | — | ​ |  | — | ​ |  | — | ​ |  | — | ​
Gross losses from sales of securities | ​ | ​ | ​ | ​ |  | — | ​ |  | — | ​ |  | — | ​ |  | — | ​
​ The amortized cost and fair value of securities as of June 30, 2025 by contractual maturity are shown below. Expected maturities of residential mortgage-backed and related securities and asset-backed securities may differ from contractual maturities because the residential mortgages underlying the securities may be prepaid without any penalties. Therefore, these securities are not included in the maturity categories in the following table: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | Amortized Cost |  | Fair Value
​ | ​ | (dollars in thousands)
Securities HTM: |  | ​ |  |  | ​ |
Due in one year or less | ​ | $ | 359 | ​ | $ | 357
Due after one year through five years | ​ |  | 28,143 | ​ |  | 26,320
Due after five years | ​ |  | 880,796 | ​ |  | 776,888
​ | ​ | $ | 909,298 | ​ | $ | 803,565
Securities AFS: | ​ |  |  | ​ |  |
Due in one year or less | ​ | $ | — | ​ | $ | —
Due after one year through five years | ​ |  | 21,598 | ​ |  | 20,870
Due after five years | ​ |  | 238,081 | ​ |  | 185,099
​ | ​ | ​ | 259,679 | ​ | ​ | 205,969
Residential mortgage-backed and related securities | ​ | ​ | 63,364 | ​ | ​ | 58,864
Asset-backed securities | ​ |  | 6,599 | ​ |  | 6,684
​ | ​ | $ | 329,642 | ​ | $ | 271,517
​ Portions of the U.S. government sponsored agency securities and municipal securities contain call options, which, at the discretion of the issuer, terminate the security at par and at predetermined dates prior to the stated maturity, summarized as follows as of June 30, 2025: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | Amortized Cost |  | Fair Value
​ | ​ | (dollars in thousands)
Securities HTM: |  | ​ |  |  | ​ |
Municipal securities | ​ | $ | 254,089 | ​ | $ | 244,000
Corporate securities | ​ | ​ | 28,585 | ​ | ​ | 32,567
​ | ​ | $ | 282,674 | ​ | $ | 276,567
​ | ​ |  |  | ​ |  |
Securities AFS: | ​ |  |  | ​ |  |
Municipal securities | ​ | $ | 203,893 | ​ | $ | 153,844
Corporate securities | ​ |  | 35,408 | ​ |  | 33,739
​ | ​ | $ | 239,301 | ​ | $ | 187,583
​ As of June 30, 2025, the Company's municipal securities portfolios were comprised of general obligation bonds issued by 81 issuers with fair values totaling $104.1 million and revenue bonds, issued by 163 issuers, primarily consisting of states, counties, towns, villages and school districts with fair values totaling $819.0 million. The Company also held investments in general obligation bonds in 18 states, including 10 states in which the aggregate fair value exceeded $5.0 million, and in revenue bonds in 31 states, including 14 states in which the aggregate fair value exceeded $5.0 million. As of December 31, 2024, the Company's municipal securities portfolios were comprised of general obligation bonds issued by 79 issuers with fair values totaling $103.5 million and revenue bonds, issued by 165 issuers, primarily consisting of states, counties, towns, villages and school districts with fair values totaling $828.0 million. The Company held investments in general obligation bonds in 18 states, including nine states in which the aggregate fair value exceeded $5.0 million, and in revenue bonds in 31 states, including 13 states in which the aggregate fair value exceeded $5.0 million. The Company monitors the investments and concentration closely. Both general obligation and revenue bonds are diversified across many issuers. As of June 30, 2025 and December 31, 2024, the Company did not hold general obligation bonds of any single issuer, that in aggregate exceed 10% of the Company’s stockholders’ equity. Of the general obligation and revenue bonds in the Company's portfolio, the majority are unrated bonds that represent small, private issuances. All unrated bonds were underwritten according to the Company’s loan underwriting standards and have an average loan risk rating of 2, indicating very high quality. Additionally, many of these bonds are funding essential municipal services such as water, sewer, education, and medical facilities. The Company's municipal securities are owned by the four charters, whose investment policies set forth limits for various subcategories within the municipal securities portfolio. The investments of each charter are monitored individually, and as of June 30, 2025, all were within policy limitations approved by the Company’s board of directors. Policy limits are calculated as a percentage of each charter's total risk-based capital. As of June 30, 2025, the Company's standard monitoring of its municipal securities portfolio had not uncovered any facts or circumstances resulting in significantly different credit ratings than those assigned by a nationally recognized statistical rating organization, or in the case of unrated bonds, the rating assigned using the credit underwriting standards.

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