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Loans and Allowance for Credit Losses
3 Months Ended
Mar. 31, 2022
Receivables [Abstract]  
Loans and Allowance for Credit Losses Loans and Allowance for Credit Losses
The Bank makes loans to customers primarily in the Washington, D.C. metropolitan area and surrounding communities. A substantial portion of the Bank's loan portfolio consists of loans to businesses secured by real estate and other business assets.
Loans, net of unamortized net deferred fees, at March 31, 2022 and December 31, 2021 are summarized by type as follows:
March 31, 2022December 31, 2021
(dollars in thousands, except amounts in the footnote)Amount%Amount%
Commercial$1,377,615 19 %$1,354,317 19 %
PPP loans35,744 %51,105 %
Income-producing - commercial real estate3,543,795 50 %3,385,298 48 %
Owner-occupied - commercial real estate1,104,982 15 %1,087,776 15 %
Real estate mortgage - residential72,238 %73,966 %
Construction - commercial and residential783,101 11 %896,319 13 %
Construction - C&I (owner-occupied)140,282 %159,579 %
Home equity54,804 %55,811 %
Other consumer1,246 — 1,427 — 
Total loans7,113,807 100 %7,065,598 100 %
Less: allowance for credit losses(71,505)(74,965)
Net loans (1)
$7,042,302 $6,990,633 

(1)Excludes accrued interest receivable of $36.9 million and $38.6 million at March 31, 2022 and December 31, 2021, respectively, which were recorded in other assets on the Consolidated Balance Sheets.
Unamortized net deferred fees amounted to $23.7 million and $26.9 million at March 31, 2022 and December 31, 2021, respectively.
As of March 31, 2022 and December 31, 2021, the Bank serviced $339.5 million and $351.1 million, respectively, of multifamily FHA loans, SBA loans and other loan participations that are not reflected as loan balances on the Consolidated Balance Sheets.
Real estate loans are secured primarily by duly recorded first deeds of trust or mortgages. In some cases, the Bank may accept a recorded junior trust position. In general, borrowers will have a proven ability to build, lease, manage and/or sell a commercial or residential project and demonstrate satisfactory financial condition. Additionally, an equity contribution toward the project is customarily required.
Construction loans require that the financial condition and experience of the general contractor and major subcontractors be satisfactory to the Bank. Guaranteed, fixed price contracts are required whenever appropriate, along with payment and performance bonds or completion bonds for larger scale projects.
Loans intended for residential land acquisition, lot development and construction are made on the premise that the land: 1) is or will be developed for building sites for residential structures, and 2) will ultimately be utilized for construction or improvement of residential zoned real properties, including the creation of housing. Residential development and construction loans will finance projects such as single family subdivisions, planned unit developments, townhouses, and condominiums. Residential land acquisition, development and construction loans generally are underwritten with a maximum term of 36 months, including extensions approved at origination.
Commercial land acquisition and construction loans are secured by real property where loan funds will be used to acquire land and to construct or improve appropriately zoned real property for the creation of income producing or owner user commercial properties. Borrowers are generally required to put equity into each project at levels determined by the appropriate approval authority. Commercial land acquisition and construction loans generally are underwritten with a maximum term of 24 months.
Substantially all construction draw requests must be presented in writing on American Institute of Architects documents and certified either by the contractor, the borrower and/or the borrower's architect. Each draw request shall also include the borrower's soft cost breakdown certified by the borrower or their Chief Financial Officer. Prior to an advance, the Bank or its contractor inspects the project to determine that the work has been completed, to justify the draw requisition.
Commercial permanent loans are generally secured by improved real property which is generating income in the normal course of operation. Debt service coverage, assuming stabilized occupancy, must be satisfactory to support a permanent loan. The debt service coverage ratio is ordinarily at least 1.15 to 1.0. As part of the underwriting process, debt service coverage ratios are stress tested assuming a 200 basis point increase in interest rates from their current levels.
Commercial permanent loans generally are underwritten with a term not greater than 10 years or the remaining useful life of the property, whichever is lower. The preferred term is between 5 to 7 years, with amortization to a maximum of 25 years.
The Company's loan portfolio includes acquisition, development and construction ("ADC") real estate loans including both investment and owner occupied projects. ADC loans amounted to $1.5 billion at March 31, 2022. A portion of the ADC portfolio, both speculative and non-speculative, includes loan-funded interest reserves at origination. ADC loans that provide for the use of interest reserves represent approximately 57.2% of the outstanding ADC loan portfolio at March 31, 2022. The decision to establish a loan-funded interest reserve is made upon origination of the ADC loan and is based upon a number of factors considered during underwriting of the credit including: (1) the feasibility of the project; (2) the experience of the sponsor; (3) the creditworthiness of the borrower and guarantors; (4) the borrower equity contribution; and (5) the level of collateral protection. When appropriate, an interest reserve provides an effective means of addressing the cash flow characteristics of a properly underwritten ADC loan. The Company recognizes that one of the risks inherent in the use of interest reserves is the potential masking of underlying problems with the project and/or the borrower's ability to repay the loan. In order to mitigate these inherent risks, the Company employs a series of reporting and monitoring mechanisms on all ADC loans, whether or not an interest reserve is provided, including: (1) construction and development timelines which are monitored on an ongoing basis which track the progress of a given project to the timeline projected at origination; (2) a construction loan administration department independent of the lending function; (3) third party independent construction loan inspection reports; (4) monthly interest reserve monitoring reports detailing the balance of the interest reserves approved at origination and the days of interest carry represented by the reserve balances as compared to the then current anticipated time to completion and/or sale of speculative projects; and (5) quarterly commercial real estate construction meetings among senior Company management, which includes monitoring of current and projected real estate market conditions. If a project has performed as expected, it is the customary practice of the Company to increase loan-funded interest reserves.
The following tables detail activity in the allowance for credit losses by portfolio segment for the three months ended March 31, 2022 and 2021. PPP loans are excluded from these tables since they do not carry an allowance for credit loss, as these loans are fully guaranteed as to principal and interest by the SBA, whose guarantee is backed by the full faith and credit of the U.S. Government. Allocation of a portion of the allowance to one category of loans does not restrict the use of the allowance to absorb losses in other categories.

Income-Producing -Owner-Occupied -Real EstateConstruction -
CommercialCommercialMortgage -Commercial andHomeOther
(dollars in thousands)CommercialReal EstateReal EstateResidentialResidentialEquityConsumerTotal
Three Months Ended March 31, 2022
Allowance for credit losses:
Balance at beginning of period$14,475 $38,287 $12,146 $449 $9,099 $474 $35 $74,965 
Loans charged-off(514)— — — — — — (514)
Recoveries of loans previously charged-off54 — — — — — 55 
Net loans charged-off(460)— — — — — (459)
Provision for (reversal of) credit losses(1,069)906 (1,631)(68)(1,126)(7)(6)(3,001)
Ending balance$12,946 $39,193 $10,515 $381 $7,973 $467 $30 $71,505 
Three Months Ended March 31, 2021
Allowance for credit losses:
Balance at beginning of period$26,569 $55,385 $14,000 $1,020 $11,529 $1,039 $37 $109,579 
Loans charged-off(4,150)(1,000)— — (206)— (1)(5,357)
Recoveries of loans previously charged-off96 — — — — — 13 109 
Net loans (charged-off) recovered(4,054)(1,000)— — (206)— 12 (5,248)
Provision for (reversal of) credit losses1,186 (2,875)315 (101)(640)(132)(14)(2,261)
Ending balance23,701 51,510 14,315 919 10,683 907 35 102,070 
The following table presents the amortized cost basis of collateral-dependent loans by class of loans as of March 31, 2022 and December 31, 2021:

March 31, 2022December 31, 2021
(dollars in thousands)Business/Other AssetsReal EstateBusiness/Other AssetsReal Estate
Commercial$2,222 $6,784 $3,098 $6,821 
PPP loans106 — 1,365 — 
Income-producing - commercial real estate3,120 19,316 3,193 19,378 
Owner-occupied - commercial real estate— 33 — 42 
Real estate mortgage - residential— 1,698 — 1,779 
Construction - commercial and residential— — — 3,093 
Home equity— 365 — 366 
Total$5,448 $28,196 $7,656 $31,479 

Credit Quality Indicators
The Company uses several credit quality indicators to manage credit risk in an ongoing manner. The Company's primary credit quality indicators inform an internal credit risk rating system that categorizes loans into pass, watch, special mention, or classified categories. Credit risk ratings are applied individually to those classes of loans that have significant or unique credit characteristics that benefit from a case-by-case evaluation. These are typically loans to businesses or individuals in the classes which comprise the commercial portfolio segment. Groups of loans that are underwritten and structured using standardized criteria and characteristics, such as statistical models (e.g., credit scoring or payment performance), are typically risk rated and monitored collectively. These are typically loans to individuals in the classes which comprise the consumer portfolio segment.
The following are the definitions of the Company's credit quality indicators:
Pass:Loans in all classes that comprise the commercial and consumer portfolio segments that are not adversely rated, are contractually current as to principal and interest, and are otherwise in compliance with the contractual terms of the loan agreement. Management believes that there is a low likelihood of loss related to those loans that are considered pass.
Watch:Loan paying as agreed with generally acceptable asset quality; however the obligor's performance has not met expectations. Balance sheet and/or income statement has shown deterioration to the point that the obligor could not sustain any further setbacks. Credit is expected to be strengthened through improved obligor performance and/or additional collateral within a reasonable period of time.
Special Mention:Loans in the classes that comprise the commercial portfolio segment that have potential weaknesses that deserve management's close attention. If not addressed, these potential weaknesses may result in deterioration of the repayment prospects for the loan. The special mention credit quality indicator is not used for classes of loans that comprise the consumer portfolio segment. Management believes that there is a moderate likelihood of some loss related to those loans that are considered special mention.
Classified:
Classified (a) Substandard – Loans inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral pledged, if any. Loans so classified have a well-defined weakness or weaknesses that jeopardize the liquidation of the debt. They are characterized by the distinct possibility that the company will sustain some loss if the deficiencies are not corrected. Loss potential, while existing in the aggregate amount of substandard loans, does not have to exist in individual loans classified substandard.
Classified (b) Doubtful – Loans that have all the weaknesses inherent in a loan classified substandard, with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions, and values, highly questionable and improbable. The possibility of loss is extremely high, but because of certain important and reasonably specific pending factors, which may work to the advantage and strengthening of the assets, its classification as an estimated loss is deferred until its more exact status may be determined.
The Company's credit quality indicators are generally updated annually, and; however, credits rated watch or below are reviewed more frequently. Based on the most recent analysis performed, amortized cost basis of loans by risk category, class and year of origination are as follows:

March 31, 2022 (dollars in thousands)Prior20182019202020212022Revolving Loans Amort. Cost BasisRevolving Loans Convert. to TermTotal
Commercial
Pass219,550 98,054 86,957 76,823 243,084 14,286 573,964 216 1,312,934 
Watch12,922 1,964 297 4,167 2,903 — 22,753 — 45,006 
Special Mention9,074 351 — — — — 662 — 10,087 
Substandard1,415 418 421 — — — 7,334 — 9,588 
Total242,961 100,787 87,675 80,990 245,987 14,286 604,713 216 1,377,615 
PPP loans
Pass— — — 6,587 29,051 — — — 35,638 
Substandard— — — 106 — — — — 106 
Total— — — 6,693 29,051 — — — 35,744 
Income producing - commercial real estate
Pass988,558 465,207 530,134 317,332 550,262 67,095 190,847 369 3,109,804 
Watch123,945 — — 35,320 — — — — 159,265 
Special Mention101,260 46,887 4,250 — — — 47,686 — 200,083 
Substandard65,981 3,120 5,542 — — — — — 74,643 
Total1,279,744 515,214 539,926 352,652 550,262 67,095 238,533 369 3,543,795 
Owner occupied - commercial real estate
Pass479,223 228,705 81,347 42,715 188,852 6,453 2,341 — 1,029,636 
Watch23,557 11,708 6,789 — — — 13,571 — 55,625 
Substandard19,721 — — — — — — — 19,721 
Total522,501 240,413 88,136 42,715 188,852 6,453 15,912 — 1,104,982 
Real estate mortgage - residential
Pass20,520 12,856 13,038 3,421 16,438 1,208 — — 67,481 
Watch3,059 — — — — — — — 3,059 
Substandard1,698 — — — — — — — 1,698 
Total25,277 12,856 13,038 3,421 16,438 1,208 — — 72,238 
Construction - commercial and residential
Pass57,078 112,990 86,863 180,491 98,376 73,655 129,231 — 738,684 
Watch44,417 — — — — — — — 44,417 
Total101,495 112,990 86,863 180,491 98,376 73,655 129,231 — 783,101 
Construction - C&I (owner occupied)
Pass14,219 7,391 44,884 62,084 779 — 6,612 — 135,969 
Watch1,059 3,254 — — — — — — 4,313 
Total15,278 10,645 44,884 62,084 779 — 6,612 — 140,282 
Home equity
Pass2,081 — — 101 547 — 50,011 1,597 54,337 
Watch58 — — — — — — — 58 
Substandard308 — 44 — — — 57 — 409 
Total2,447 — 44 101 547 — 50,068 1,597 54,804 
Other consumer
Pass338 — — — — — 853 — 1,191 
Watch— — — — — — 50 — 50 
Substandard— — — — — — — 
Total338 — — — — — 908 — 1,246 
Total Recorded Investment$2,190,041 $992,905 $860,566 $729,147 $1,130,292 $162,697 $1,045,977 $2,182 7,113,807 
December 31, 2021 (dollars in thousands)Prior20172018201920202021Revolving Loans Amort. Cost BasisRevolving Loans Convert. to TermTotal
Commercial
Pass$180,877 $58,693 $103,058 $90,874 $87,515 $211,563 $549,055 $6,023 $1,287,658 
Watch5,896 6,567 1,020 996 4,268 3,137 18,336 627 40,847 
Special Mention— 9,515 363 — — — 901 — 10,779 
Substandard4,205 778 1,850 437 — — 7,763 — 15,033 
Total190,978 75,553 106,291 92,307 91,783 214,700 576,055 6,650 1,354,317 
PPP loans
Pass— — — — 16,840 32,900 — — 49,740 
Substandard— — — — 1,365 — — — 1,365 
Total— — — — 18,205 32,900 — — 51,105 
Income producing - commercial real estate
Pass572,550 333,394 418,489 495,808 337,178 549,356 198,210 — 2,904,985 
Watch58,334 73,760 — 43,561 35,094 — — — 210,749 
Special Mention101,580 — 41,936 4,264 — — 47,692 — 195,472 
Substandard60,059 — 8,491 5,542 — — — — 74,092 
Total792,523 407,154 468,916 549,175 372,272 549,356 245,902 — 3,385,298 
Owner occupied - commercial real estate
Pass353,471 127,687 210,348 81,604 41,135 184,529 16,838 1,922 1,017,534 
Watch22,710 4,581 11,783 7,026 — — 62 — 46,162 
Special Mention— — — 2,122 — — — — 2,122 
Substandard21,958 — — — — — — — 21,958 
Total398,139 132,268 222,131 90,752 41,135 184,529 16,900 1,922 1,087,776 
Real estate mortgage - residential
Pass14,645 5,854 12,956 15,546 3,436 16,495 — — — 68,932 
Watch3,255 — — — — — — — — 3,255 
Substandard1,698 — — 81 — — — — — 1,779 
Total19,598 5,854 12,956 15,627 3,436 16,495 — — 73,966 
Construction - commercial and residential
Pass32,815 139,756 171,152 142,599 160,952 71,799 127,956 — 1,773 848,802 
Watch506 43,918 — — — — — — — 44,424 
Substandard— — — 3,093 — — — — — 3,093 
Total33,321 183,674 171,152 145,692 160,952 71,799 127,956 1,773 896,319 
Construction - C&I (owner occupied)
Pass19,710 1,754 25,163 39,803 61,408 768 6,648 — — 155,254 
Watch680 390 3,255 — — — — — — 4,325 
Total20,390 2,144 28,418 39,803 61,408 768 6,648 — 159,579 
Home equity
Pass1,474 — — — 70 702 52,077 — 883 55,206 
Watch193 — — — — — — — — 193 
Substandard46 — — 45 — — 58 — 263 412 
Total1,713 — — 45 70 702 52,135 1,146 55,811 
Other consumer
Pass370 — — — — — 1,002 — — 1,372 
Substandard— — — — — — 55 — — 55 
Total370 — — — — — 1,057 — 1,427 
Total Recorded Investment$1,457,032 $806,647 $1,009,864 $933,401 $749,261 $1,071,249 $1,026,653 $11,491 $7,065,598 
Nonaccrual and Past Due Loans
As part of the Company's comprehensive loan review process, management committees carefully evaluate loans that are past-due 30 days or more. The committees make a thorough assessment of the conditions and circumstances surrounding each delinquent loan. The Bank's loan policy requires that loans be placed on nonaccrual if they are 90 days past-due, unless they are well secured and in the process of collection. Additionally, Credit Administration specifically analyzes the status of development and construction projects, sales activities and utilization of interest reserves in order to carefully and prudently assess potential increased levels of risk requiring additional reserves.
The table presents, by class of loan, an aging analysis and the recorded investments in loans past due as of March 31, 2022 and December 31, 2021:
LoansLoansLoansTotal Recorded
30-59 Days60-89 Days90 Days orTotal PastCurrentNonaccrualInvestment in
(dollars in thousands)Past DuePast DueMore Past DueDue LoansLoansLoansLoans
March 31, 2022
Commercial$2,368 $853 $— $3,221 $1,366,403 $7,991 $1,377,615 
PPP loans2,462 544 — 3,006 32,632 106 35,744 
Income producing - commercial real estate8,540 — — 8,540 3,521,924 13,331 3,543,795 
Owner occupied - commercial real estate136 — — 136 1,104,813 33 1,104,982 
Real estate mortgage - residential1,572 — — 1,572 68,740 1,926 72,238 
Construction - commercial and residential— — — — 783,101 — 783,101 
Construction - C&I (owner occupied)2,310 — — 2,310 137,972 — 140,282 
Home equity— — — — 54,439 365 54,804 
Other consumer— — 1,243 — 1,246 
Total$17,391 $1,397 $— $18,788 $7,071,267 $23,752 $7,113,807 
December 31, 2021
Commercial$1,462 $672 $— $2,134 $1,343,307 $8,876 $1,354,317 
PPP loans1,765 825 — 2,590 47,150 1,365 51,105 
Income producing - commercial real estate— — — — 3,371,842 13,456 3,385,298 
Owner occupied - commercial real estate419 19,108 — 19,527 1,068,207 42 1,087,776 
Real estate mortgage – residential1,372 — — 1,372 70,584 2,010 73,966 
Construction - commercial and residential— — — — 893,226 3,093 896,319 
Construction- C&I (owner occupied)— — — — 159,579 — 159,579 
Home equity33 187 — 220 55,225 366 55,811 
Other consumer— — — — 1,427 — 1,427 
Total$5,051 $20,792 $— $25,843 $7,010,547 $29,208 $7,065,598 
The following presents the nonaccrual loans as of March 31, 2022 and December 31, 2021:
Nonaccrual withNonaccrual withTotal
No Allowancean AllowanceNonaccrual
(dollars in thousands)for Credit Lossfor Credit LossLoans
March 31, 2022
Commercial$5,546 $2,445 $7,991 
PPP loans (1)
106 — 106 
Income producing - commercial real estate3,869 9,462 13,331 
Owner occupied - commercial real estate33 — 33 
Real estate mortgage - residential1,698 228 1,926 
Home equity365 — 365 
Total (1)(2)
$11,617 $12,135 $23,752 
December 31, 2021
Commercial$5,806 $3,070 $8,876 
PPP loans (1)
1,365 — 1,365 
Income producing - commercial real estate3,920 9,536 13,456 
Owner occupied - commercial real estate42 — 42 
Real estate mortgage - residential1,779 231 2,010 
Construction - commercial and residential3,093 — 3,093 
Home equity366 — 366 
Total (1)(2)
$16,371 $12,837 $29,208 

(1)The CARES Act created the PPP, a program designed to aid small- and medium-sized businesses through federally guaranteed loans distributed through banks. These loans are intended to guarantee payroll and other costs to help those businesses remain viable and allow their workers to pay their bills.
(2)Excludes TDRs that were performing under their restructured terms totaling $10.1 million and $10.2 million at March 31, 2022 and December 31, 2021, respectively.
(3)Gross interest income of $325 thousand and approximately $800 thousand would have been recorded for the three months ended March 31, 2022 and 2021, respectively, if nonaccrual loans shown above had been current and in accordance with their original terms, while no interest income was actually recorded on such loans for the three months ended March 31, 2022 and 2021 respectively. See Note 1 to the Consolidated Financial Statements for a description of the Company's policy for placing loans on nonaccrual status.
Modifications
A modification of a loan constitutes a TDR when the borrower is experiencing financial difficulty and the modification constitutes a concession. The Company offers various types of concessions when modifying a loan. Commercial and industrial loans modified in a TDR often involve temporary interest-only payments, term extensions, and converting revolving credit lines to term loans. Additional collateral, a co-borrower, or a guarantor is often requested.
Commercial mortgage and construction loans modified in a TDR often involve reducing the interest rate for the remaining term of the loan, extending the maturity date at an interest rate lower than the current market rate for new debt with similar risk, or substituting or adding a new borrower or guarantor. Construction loans modified in a TDR may also involve extending the interest-only payment period. As of March 31, 2022 and December 31, 2021, all performing TDRs were categorized as interest-only modifications.
Loans modified in a TDR for the Company may have the financial effect of increasing the specific allowance associated with the loan. An allowance for consumer and commercial loans that have been modified in a TDR is measured based on the present value of expected future cash flows discounted at the loan's effective interest rate, the loan's observable market price, or the estimated fair value of the collateral, less any selling costs, if the loan is collateral dependent. Management exercises significant judgment in developing these estimates.
In response to the COVID-19 pandemic and its economic impact to our customers, we implemented a short-term modification program that complied with the CARES Act and ASC 310-40 to provide temporary payment relief to those borrowers directly impacted by COVID-19 who were not more than 30 days past due as of December 31, 2019. This program allowed for a deferral of payments for 90 days, which we extended for an additional 90 days for certain borrowers, for a maximum of 180 days on a cumulative and successive basis. The deferred payments along with interest accrued during the deferral period are due and payable on the maturity date. Additionally, none of the deferrals are reflected in the Company's asset quality measures (i.e. non-performing loans) due to the provision of the CARES Act that permits U.S. financial institutions to temporarily suspend the GAAP requirements to treat such short-term loan modifications as TDR. Similar provisions have also been confirmed by interagency guidance issued by the federal banking agencies and confirmed with staff members of the Financial Accounting Standards Board. As of March 31, 2022, substantially all of the borrowers granted deferrals under this program have returned to regular payment status.
The following table presents by class, the recorded investment of loans modified in TDRs held by the Company for the three months ended March 31, 2022 and 2021.
Income
NumberProducing -
ofCommercial
(dollars in thousands)LoansCommercialReal EstateTotal
Three Months Ended March 31, 2022
Troubled debt restructurings      
Restructured accruing$1,016 $9,105 $10,121 
Restructured nonaccruing— 6,342 6,342 
Total$1,016 $15,447 $16,463 
Individually-evaluated allowance$170 $2,285 $2,455 
Restructured and subsequently defaulted$— $6,342 $6,342 
Three Months Ended March 31, 2021
Troubled debt restructurings
Restructured accruing$1,157 $9,171 $10,328 
Restructured nonaccruing101 6,342 6,443 
Total$1,258 $15,513 $16,771 
Individually-evaluated allowance$547 $2,976 $3,523 
Restructured and subsequently defaulted$101 $6,342 $6,443 
The Company had seven TDRs at March 31, 2022 totaling approximately $16.5 million. Five of these loans totaling approximately $10.1 million were performing under their modified terms as of March 31, 2022.
For the first three months of 2022 there were two performing TDR loans that defaulted on their modified terms. For the first three months of 2021, one performing TDR loan, with a balance of $101 thousand, defaulted on its modified terms and was placed on nonaccrual status.
For the three months ended March 31, 2021, one previously nonperforming restructured loan had its collateral sold and all principal collected along with partial collection of delinquent interest; in addition, one restructured loan purchased as part of the 2014 acquisition of Virginia Heritage Bank has now had its full carrying value collected, while additional payments will recover previously written off principal and interest, and zero nonperforming restructured loan was charged off. No similar transactions occurred during the three months ended March 31, 2022.
Commercial and consumer loans modified in a TDR are closely monitored for delinquency as an early indicator of possible future default. If loans modified in a TDR subsequently default, the Company evaluates the loan for possible further loss. The allowance may be increased, adjustments may be made in the allocation of the allowance, or partial charge-offs may be taken to further write-down the carrying value of the loan.