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MidWestOne(MOFG) - 2024 Q4 - Annual Report

Employee Engagement and Development - The Company has been recognized as a Top Workplace in Iowa for twelve consecutive years and as a USA TODAY Top Workplace since 2021, reflecting high employee engagement and satisfaction[44] - The Company invests in employee development through formal and informal opportunities, including mentorship and community involvement initiatives[43] - The Company emphasizes diversity and equal opportunity in its workplace, aiming to foster an inclusive environment for all employees[46] - The Company has implemented various human capital strategies to drive impact for stakeholders, overseen by the Board through the Human Capital and Compensation Committee[41] - The Company offers a competitive total compensation package, including base salary, incentive compensation, and a broad array of benefits such as 401(k), medical, dental, and wellness programs[45] - The Company has implemented human capital strategies to engage and empower team members, ensuring alignment with career aspirations through development opportunities[43] Capital and Regulatory Compliance - As of December 31, 2024, the Bank was well-capitalized according to FDIC regulations, with regulatory capital exceeding Federal Reserve requirements and compliance with the Basel III Rule[63] - The Basel III Rule requires a minimum Common Equity Tier 1 Capital ratio of 4.5% of risk-weighted assets, with additional requirements for capital distributions[58] - The company is required to maintain a Common Equity Tier 1 Capital ratio of 6.5% or more, a Tier 1 Capital ratio of 8% or more, and a Total Capital ratio of 10% or more[66] - The company has not elected to use the Community Bank Leverage Ratio framework, which requires a CBLR greater than 9% for institutions with total consolidated assets of less than 10billion[65]TheFederalReserverequiresbankholdingcompaniestomaintainaleverageratioofTier1Capitaltototaladjustedaveragequarterlyassetsof510 billion[65] - The Federal Reserve requires bank holding companies to maintain a leverage ratio of Tier 1 Capital to total adjusted average quarterly assets of 5% or greater[66] - The Bank exceeded its capital requirements under applicable guidelines as of December 31, 2024[92] - The Federal Reserve may impose limitations on the company if it is determined to be not well-capitalized or well-managed[69] - The Company has seen an increase in regulatory scrutiny and compliance costs following the global financial crisis and the implementation of the Dodd-Frank Act, although recent reforms have provided some relief for community banks[50] Liquidity Management - The Liquidity Coverage Ratio (LCR) ensures that banking organizations maintain an adequate stock of unencumbered high-quality liquid assets to meet liquidity needs for a 30-calendar day stress scenario[90] - The Net Stable Funding Ratio (NSFR) promotes more medium- and long-term funding of assets and activities over a one-year horizon[90] - The liquidity risk management framework is crucial, especially after unprecedented deposit outflows in early 2023, emphasizing the need for sufficient liquidity to withstand stress events[89] - The Bank is reviewing its liquidity risk management policies in light of regulatory requirements and industry developments, including a 2024 FDIC request for information on deposit behavior[91] Regulatory Environment - The Company has experienced higher compliance costs due to CFPB regulations, although these rules have not significantly impacted operations[112] - The Bank is subject to periodic examination by the Federal Reserve and must file periodic reports regarding its operations[66] - The federal banking agencies have emphasized the importance of sound risk management processes and strong internal controls for FDIC-insured institutions[99] - The Bank is required to implement a comprehensive information security program to protect customer records and information[100] - The Bank must comply with stringent economic and trade sanctions regimes administered by the Office of Foreign Assets Control[108] - The Consumer Financial Protection Bureau (CFPB) has broad rulemaking authority affecting all providers of consumer financial products, including the Bank, particularly those with assets over 10 billion[110] - The Dodd-Frank Act significantly expanded underwriting requirements for residential mortgages, impacting all lenders, including banks and savings associations[111] - The CFPB's aggressive regulatory approach has led to increased compliance costs for the Bank, although it has not significantly impacted operations[112] - The Bank continues to comply with state consumer protection laws in addition to federal regulations[112] Market Competition - The Company competes in a highly competitive market, facing competition from commercial banks, credit unions, fintech companies, and other financial service providers[40] - The Company competes in a highly competitive market against various financial service providers, including fintech companies and credit unions, focusing on building long-lasting relationships with customers[40] Community Reinvestment Act (CRA) - The Community Reinvestment Act (CRA) requires the Bank to meet the credit needs of the community, with assessments impacting its activities and potential acquisitions[104] - The CRA Rule aims to modernize regulations to expand access to credit and improve evaluation metrics for CRA activities, although its effective date has been paused due to ongoing litigation[105] - The Bank is continuing to assess the impact of the CRA Rule on its lending and investment activities in its respective markets[105] - The Bank did not exceed the regulatory guidelines for commercial real estate (CRE) lending as of December 31, 2024, with CRE loans not exceeding 300% of capital and construction loans not exceeding 100% of capital[109]