msaac meeting sep 28 2021

MSAAC MeetingSeptember 28, 2021

State of Mutual FSAsFinancial Information as of June 30, 2021

Ernie KnottOCC Financial Analyst

2

• Portfolio Demographics-Ernie Knott

• Financial Performance-Ernie Knott and Ashley Hicks

• Supervisory Information-Cristina Im

Preface: The current mutual population as of June 30, 2021 is “held constant” for financial analysis. Mutual banks began filing the Call Report in 2012 unless they early adopted. Some charts use the median and others use weighted averages. For certain ratios, OCC created “unified” calculations. If the former Thrift Financial Report (TFR) contained the elements to calculate ratios on the current Uniform Bank Performance Report (UBPR), we are able to provide analysis using these calculations dating back to 2007.

Agenda

This presentation will focus on:

Mutual Overview and Trends

3Portfolio Demographics

OCC Charters by Institution TypeOCC supervised 1,194 institutions as of June 30, 2021. Federal Savings

Associations (FSAs) represent 22 percent of OCC charters.

749, 63%

112, 9%160, 13%

52, 4% 69, 6% 52, 4%

0%

15%

30%

45%

60%

75%

Nat'lBanks

MutualFSAs

StockFSAs

TrustBanks

SPs FederalBranches

76% National

Banks, $1.4 Tril (724 charters)

24% FSAs $441 Bil (269*

charters)

Midsize and Community Banks

* Excludes 3 FSAs in OCC's Large Bank Program

96%National

Banks $14.3 Tril (801 charters)

4% FSAs $611 Bil (272

charters)

OCC Supervised Institutions

4

• FSAs represent $611 billion or 4 percent of OCC supervised assets as of June 30, 2021.

• FSAs represent $441 billion or 24 percent of midsize and community bank assets as of June 30, 2021. Only three FSAs are supervised by OCC’s Large Bank Program, but all mutual FSAs are supervised by OCC’s Midsize and Community Bank Supervision Unit.

Portfolio Demographics

OCC Supervised Assets

$0

$185

$370

$555

$740

$925

0

150

300

450

600

750

2Q11 4Q12 4Q14 4Q15 4Q16 4Q17 4Q18 4Q19 4Q20 2Q21# Stock 430 352 277 243 226 209 182 176 163 160# Mutual 219 194 171 160 147 135 128 123 116 112Assets (B) $910 $719 $707 $679 $742 $769 $769 $780 $590 $611

Assets ($

)

Num

ber


FSA Charter TrendsThe number of mutual FSAs continues to decline but not as rapidly as

stock FSAs.

11, 50%

2, 9%

9, 41%

0%

15%

30%

45%

60%

75%

Mutual Stock FSAs inMHC structure

Stock

$10.4 Bil $10.9 Bil $5.2 Bil

Covered Savings Associations

112, 41%

26, 10%

134, 49%

0%

15%

30%

45%

60%

75%

Mutual Stock FSAs inMHC structure

Stock

$40.4 Bil $19.9 Bil $550.8 Bil

FSAs by Charter Type

6

• Mutual FSAs and stock FSAs in MHCs (that have not issued shares) represent 51 percent of OCC-regulated FSAs.

• FSAs with total assets of $20 billion or less as of December 31, 2017, may elect to operate as covered savings associations (CSAs). CSAs represented 22 or 8 percent of FSA charters and 4 percent of FSA assets as of June 30, 2021.


FSAs by Type


Mutual FSAs by StateMutual FSAs are concentrated in the Midwest and Northeast. There are three

states with 9 or more mutual FSAs: Ohio (17), Pennsylvania (11), and Illinois (9).

11

52 49

31 2520

33 51

0%

15%

30%

45%

60%

75%

Less Than 25Yrs 25 to 50 Yrs 50 to 75 Yrs 75 to 100

YrsGreater

Than 100 YrsStock 19% 16% 13% 21% 32%Mutual 0% 0% 10% 46% 44%

FSA Age Distribution 6/30/2021

35 3424

10 9

30 38

25

2641

0%

11%

22%

33%

44%

55%

Less Than$100Mil

$100Mil to$250Mil

$250Mil to$500Mil

$500Mil to$1Bil

GreaterThan $1Bil

Stock 19% 24% 16% 16% 26%Mutual 31% 30% 21% 9% 8%

FSA Asset Distribution 6/30/2021

8

• Mutual FSAs are typically smaller in size than their stock counterparts. Only 8 percent of mutual FSAs have total assets greater than $1 billion versus 26 percent of stock FSAs.

• Mutual FSAs represent some of the oldest financial institutions in the United States. Forty-four percent of mutual FSAs were formed more than 100 years ago. Ninety percent have operated for 75 years or more.


Mutual FSAs Asset Size and Age

41

35

2320 19

0

9

18

27

36

45

1 Office 2‐3 Ofcs 4‐5 Ofcs 6‐8 Ofcs > 8 Ofcs

Branch Categories of Mutuals

663 663 681 694 700 715 722 740

0

10

20

30

40

50

0

150

300

450

600

750

2014 2015 2016 2017 2018 2019 2020 21Q2

Mutual Branch and Deposit Trends

# Branches Core Deps $Bil

9

• Thirty percent of mutual FSAs operate from one location, and 55 percent have three locations or less. Thirty-six mutual FSAs or 26 percent have changed their branch configuration since 2014. Five mutual FSAs have fewer offices today versus 2014.

• Since 2014, the number of mutual FSA office locations has grown 12 percent, but core deposits have grown 41 percent (13 percent through 2019 or pre-pandemic).


Mutual FSA Branches

The Community Bank Leverage Ratio (CBLR) is an optional simple leverage capital measure that became effective January 1, 2020. The CARES Act provided temporary relief and a gradual phase-in through 2021 due to the pandemic.

10Capital

Cannot be an advanced approaches banking

organization

Total trading assets plus

liabilities of 5 percent or less of consolidated

assets

Leverage ratio greater than 8.5 percent (2021) and 9 percent

(2022)

Total off‐balance sheet (OBS)

exposures of 25 percent or less of consolidated

assets

Total consolidated assets of less

than $10 billion

CBLR Framework – Now Being Phased In

14.3715.13

14.06

11.8012.56

11.79

10.00

11.50

13.00

14.50

16.00

17.50

Mutual Leverage Capital Ratio

OCC FDIC

Asset Category FDIC OCCUnder $50MM 12.55 16.74$50MM ‐ $100MM 12.25 14.07$100MM ‐ $250MM 11.77 14.09$250MM ‐ $500MM 12.17 13.66$500MM ‐ $1B 11.29 13.44Greater than $1B 11.35 11.00

Median 11.79 14.06

Leverage Ratio ‐ June 30, 2021

11

• Mutual FSA capital levels remain strong but lower this year. The gap between federal and state charters remains wide but narrowed to 227 basis points this quarter.

• In general, the smaller mutual charters have the highest levels of capital.

Capital

Capital Levels Remain Solid

25.11

29.33 29.27

20.19 20.18

17.9316.00

19.00

22.00

25.00

28.00

31.00

Mutual Total RBC Capital Ratio

OCC FDIC

100.00%

0.00% 0.00% 0.00% 0.00%0

30

60

90

120

150

Well AdeqWith

AdeqWithout Under Sig

UnderPCA Category 138 0 0 0 0

Num

ber

Mutual FSA PCA Categories‐6/30/2021

12

• Mutual FSA total risk-based capital levels increased in 2021 and are back to their pre-pandemic level. The gap between federal and state charters has widened to over 1,100 basis points this year.

• All mutual FSAs met the “well-capitalized” definition contained in Prompt Corrective Action as of June 30, 2021.

Capital

Mutual FSAs are “Well-capitalized”

66% 66% 63% 61%

33% 32% 35% 38%

1% 2% 2% 2%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2

1 Rated 2 Rated 3/4 Rated

13Capital

Capital Ratings Remain StrongNinety-nine percent of mutual FSAs are rated 1 or 2 for capital. Only two

mutual FSAs are rated 3. There are no mutual FSAs rated 4 or 5 for capital this quarter.

0.38 0.42

0.50 0.57

0.00

0.15

0.30

0.45

0.60

0.75

ROAA (Adj for Sub S)

OCC FDIC

Asset Category 2021Q2 2020Q4Under $50MM 0.18 0.06$50MM ‐ $100MM 0.27 0.37$100MM ‐ $250MM 0.37 0.30$250MM ‐ $500MM 0.50 0.45$500MM ‐ $1B 0.56 0.62Greater than $1B 0.53 0.65

Median 0.42 0.38

Mutual FSA ROAA by Asset Group

14

• ROAAs for mutual FSAs increased four basis points to 0.42 percent in 2021 and lag FDIC-regulated bank performance.

• In general, the larger the mutual FSA, the better the ROAA.

Earnings

ROAA Up This Year

2.75

2.92

2.60

2.75

2.90

3.05

3.20

3.35

Net Interest Margin

OCC FDIC

3.57 3.32 3.102.89

0.00

1.00

2.00

3.00

4.00

5.00

% Avg Assets

Mutual FSA Net Operating Revenue

Net Int Inc Non Int Inc

15

• Mutual FSA net operating revenue fell 43 basis points since year-end 2019. Net interest income fell 46 basis points to 2.58 percent. Fee income rose three basis points to 0.31 percent. Higher fee income remains a key distinction between smaller and larger banks.

• Net interest margins (NIM) continue to compress. NIMs fell 47 basis points since 2019, 22 basis points since 2020, and five basis points since last quarter.

Earnings

Net Interest Margin Sharply Lower

2021Q2 2020Q2 Δ 1 Yr $ Δ 1 Yr %Int Income 853,421 907,478 ‐54,057 ‐5.96Int Expense 120,489 194,514 ‐74,025 ‐38.06Net Int Inc 732,932 712,964 19,968 2.80Non Int Inc 185,009 175,261 9,748 5.56Non Int Exp 719,000 683,479 35,521 5.20Provsion Exp 6,295 35,581 ‐29,286 ‐82.31Gains on Secs 8,143 6,843 1,300 19.00Income Tax 46,250 39,936 6,314 15.81Net Income 154,520 136,059 18,467 13.57

Mutual FSA Income Statement ($000's)

2.805.56

5.20

‐82.31

19.00 15.8113.57

‐40,000

‐20,000

0

20,000

40,000

60,000

Net IntInc

Non IntInc

Non IntExp

ProvsionExp

Gains onSecs

IncomeTax

NetIncome

Change in Net Income2021 vs 2020

16

• Despite margin compression, mutual FSA net income increased in 2021 due mainly to lower provision expenses.

Earnings

Mutual Net Income Up 13.6 Percent

65 67 68 66 61

10 9 10 13 15

18 18 17 15 176 6 6 6 6

0

20

40

60

80

100

2017Q4 2018Q4 2019Q4 2020Q4 2021Q2

% Mutual Earning Asset Trends ‐ 6/30/2021

Loans Int Bk Bals+FFS Secs+Trade Acct NonEarn Assets

34.6

17.010.1

31.0

17.58.6

0.0

13.0

26.0

39.0

52.0

65.0

Ln&Ls Sale NetGains

Deposit ServiceCharges

Bank InterchangeFees

Top Noninterest Income Sources

2021Q2 % 2020Q2 %

0.55%0.53%0.47%0.53%0.57%0.53%0.53%

0.57%

0.75%0.63%

0

100,000

200,000

300,000

400,000

500,000

Mutual FSA Noninterest Income

17

• Fee income is up 6 percent versus one year ago. While fee income to average assets is up from pre-pandemic levels, 62 mutual FSAs or 45 percent reported fee income of 0.25 percent or less this quarter. Lack of fee income diversity has hurt smaller charters.

• At 34.6 percent, loan and lease sales is the top noninterest income category. It has grown 18 percent since last year. Deposit service charges is second and has grown 3 percent since last year.

Earnings

Noninterest Income Improving

56.0

13.8

30.2

57.4

13.3

29.3

0.0

13.0

26.0

39.0

52.0

65.0

Personnel Expense OccupancyExpense

Other OperExpense

Noninterest Expense Sources

2021Q2 % 2020Q2 %

2.50%2.54%2.55%2.57%2.62%2.62%2.67%2.68%2.59%2.43%

0

300,000

600,000

900,000

1,200,000

1,500,000

Mutual FSA Noninterest Expense

18

• Noninterest expense is up 5 percent compared to the same time last year. Noninterest expense to average assets has increased steadily to 2019 but fell sharply in 2020 due to the rapid asset growth from the pandemic.

• At 56.0 percent, personnel is the top noninterest expense category. It has grown 3 percent since last year. Occupancy is much lower at 13.8 percent of noninterest expense and growing faster at 9 percent.

Earnings

Noninterest Expense Growing

80, 71%

19, 17%

5, 4% 5, 4% 2, 2% 1, 1%0%

15%

30%

45%

60%

75%

Resi RealEstate

DiverseLender

Comm'lReal Estate

Non‐Lender Ag Lender BusinessLender

Mutual FSA Lender Peer

0.40

0.69

0.34

‐0.33

‐0.70

‐0.35

0.00

0.35

0.70

1.05

2013 2014 2015 2016 2017 2018 2019 2020 21Q2

Mutual FSA ROAA by Lender Peer

Comm'l RE Diverse Resi RE Non‐Lender

19

• In addition to asset size and geography, OCC also analyzes mutual FSA performance by peer lender. Most mutual FSAs or 71 percent are residential real estate lenders and 17 percent are diversified lenders.

• Diversified lenders have enjoyed higher ROAAs in recent years.

Earnings

Diverse Lenders Enjoy Higher ROAAs

82.17 81.16

79.52 76.99

70.00

73.00

76.00

79.00

82.00

85.00

Efficiency Ratio

OCC FDIC

Asset Category FDIC OCCUnder $50MM 96.86 95.05$50MM ‐ $100MM 83.05 85.65$100MM ‐ $250MM 82.54 79.83$250MM ‐ $500MM 78.34 80.36$500MM ‐ $1B 75.29 77.47Greater than $1B 70.82 77.69

Median 76.99 81.16

Efficiency Ratio ‐ June 30, 2021

20

• The mutual FSA efficiency ratio peaked in 2016 and has declined in recent years but remains elevated and has hovered above 80 percent since 2014.

• In general, the smaller mutual charters have the highest efficiency ratios. Forty-three of 138 mutual FSAs or 31 percent reported efficiency ratios over 90 percent for second quarter 2021.

Earnings

Efficiency Ratio Remains High

17% 21% 22% 20%

70% 68% 67%65%

13% 12% 11% 15%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2

1 Rated 2 Rated 3/4/5 Rated

21Earnings

Mutual FSA Earnings Ratings WorsenEarnings ratings have shown some slippage and continue to lag ratings in

other safety and soundness areas. Only 85 percent of mutual FSAs are rated 1 or 2 for earnings.

0.000.00

0.00

0.04

0.08

0.12

0.16

0.20

Net Losses to Average Total Loans

OCC FDIC

63.1

5.7 5.6 13.2 5.8 5.0 1.5

‐3

3

‐20

10 9 142

‐50.0

‐25.0

0.0

25.0

50.0

75.0

1‐4 FamLoans

ConsLoans

Comm'lLoans

NonfarmNonresi

MultiFamily

C&DLoans

OtherLoans

Mutual FSA Loan Mix and % Growth

Composition Annual Growth

22

• Mutual FSA loan portfolios are heavily concentrated in residential mortgages. Loan growth was highest for C&D loans at 14 percent.

• Net loan losses are at decade-low levels with a median of 0.00 percent and a weighted average of 0.01 percent. Most losses emanate from consumer loans.

Asset Quality

Residential Mortgages Dominate Loan Mix

0.51

2.24

0.66 0.60 0.57

0.66 0.730.62

0.00

0.50

1.00

1.50

2.00

2.50

Noncurrent Lns & OREO to Lns & OREO

OCC FDIC

0.460.29

0.37 0.220.00

0.50

1.00

1.50

2.00

2.50

% Loans & Leases 30‐89 Days Past Due

OCC FDIC

23

• The noncurrent loans plus OREO ratio for mutual FSAs peaked in 2012 and has been on a steady downward trajectory since then.

• While past dues remain low and declining, modification programs in the CARES Act are masking delinquencies for some credits. Fortunately, that pool of loans is declining.

Asset Quality

Past Due Levels are Low

0.92

0.98

0.50

0.61

0.72

0.83

0.94

1.05

ALLL to Loans & Leases Not HFS

OCC FDIC

3.254.03

9.91

14.74

9.457.48

6.195.41

4.35

0.00

3.00

6.00

9.00

12.00

15.00

Bank Provided Asset Quality Ratios

Classified Assets Special Mention

24

• The bank provided classified assets to tier 1 capital plus the ALLL ratio continues to edge lower.

• ALLL levels for mutual FSAs remain stable this year at 0.92 percent of total loans.

Asset Quality

Classified Assets Lower and ALLL Elevated

‐6.06

‐2.20

‐0.05

‐8.00

‐4.00

0.00

4.00

8.00

12.00

Loan Growth ‐ 1 Year

OCC FDIC

Asset Category FDIC OCCUnder $50MM ‐1.23 ‐3.34$50MM ‐ $100MM ‐0.01 ‐2.04$100MM ‐ $250MM ‐1.38 ‐0.64$250MM ‐ $500MM 0.33 ‐3.16$500MM ‐ $1B 1.01 ‐1.55Greater than $1B ‐0.08 ‐3.51

Median ‐0.05 ‐2.20

Loan Growth Ratio ‐ June 30, 2021

25

• Mutual FSA loan growth fell to -2.20 percent compared to 0.12 percent for the prior year. Adjusting for the Paycheck Protection Program (PPP), median mutual FSA loan growth improved to -2.10 percent.

• Loan growth was negative for most mutual bank groups. Normally, loan growth is highest for banks with total assets over $1 billion and lowest for the smallest banks.

Asset Quality

Loan Growth Weak

44% 42% 44% 42%

53% 56% 54% 56%

4% 2% 2% 2%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2


26Asset Quality

Mutual FSA Asset Quality Ratings StrongNinety-eight percent are rated 1 or 2 for asset quality.

4.65

1.341.31

9.80

4.142.78

0.00

2.00

4.00

6.00

8.00

10.00

Reliance on Wholesale Funding

OCC FDIC

38.81

31.73

0.00

8.00

16.00

24.00

32.00

40.00

On‐Hand Liquidity to Total Liabilities

OCC FDIC

8 9 9 10 11 11 11 1214 15

0

11

22

33

44

55

Billion

s $

% Mutual FSA Nonint Deps to Tot Deps

Interest Bearing Deposits Noninterest Deposits

27

• Mutual FSA deposits grew 13 percent year-over-year and free funds rose to 15 percent. On-hand liquidity ratios are sharply higher and above pre-crisis and pre-pandemic levels. As a result, mutual banks are relying less on wholesale funding sources.

Liquidity

Mutual FSAs are Flush with Liquidity

59% 54% 58% 58%

40% 45% 41% 40%

1% 1% 1% 2%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2


28Liquidity

Mutual FSA Liquidity Ratings Remain StrongNinety-eight percent are rated 1 or 2. Only two mutual FSAs are

rated 3.

30.72

77.9159.56

95.33

0.00

25.00

50.00

75.00

100.00

125.00

Nonmaturity Deposits to Long Assets

OCC FDIC

9.913.06

73.8665.26

0.00

15.00

30.00

45.00

60.00

75.00

Mutual FSA Maturities > 3 Years

Liabs Mat>3 Yrs to TA Lns&Secs Mat>3 Yrs to TA

29

• Loans and securities over three years after declining for two consecutive years, rose to 65.26 percent. Only 3.06 percent of mutual FSA liabilities mature or reprice in more than 3 years.

• Nonmaturity deposits to long-term assets for mutual FSAs have increased during the pandemic and are at their highest levels in more than a decade.

Sensitivity to Market Risk

Funding Gap Expands and NMD Up in 2021

31% 29% 28% 27%

68% 70% 72% 70%

1% 1% 4%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2


30Sensitivity to Market Risk

Sensitivity to market risk for mutual FSAs remains adequately controlled. Last year, no mutual FSAs were rated worse than 1 or 2.

This year, four are rated 3.

Sensitivity is Adequately Controlled

26% 24% 25% 27%

71% 72% 72% 68%

3% 4% 3% 5%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2


31Supervisory Information

Ninety-five percent of mutual FSAs are rated 1 or 2 for management.

Management Ratings are Satisfactory

16%

2%

31% 29%

81%

2%

67% 70%

3% 2% 1%

0%

20%

40%

60%

80%

100%

IT Asset Mgmt Consumer CRA

1 Rated 2 Rated 3/4 Rated


Only four mutual FSAs have trust powers (96 percent are not rated for asset management).

Mutual FSA Specialty Ratings are Strong

31% 30% 32% 33%

67% 68% 65% 62%

2% 2% 3% 5%

0%

20%

40%

60%

80%

100%

2018Q2 2019Q2 2020Q2 2021Q2



Ninety-five percent of mutual FSAs have a composite 1 or 2 rating. There are no mutual FSAs rated 4 or 5 this quarter.

Mutual FSA Composite Ratings are Strong

0%

20%

40%

60%

80%

100%

COMP CREDIT IRR LIQ OPER PRICE REP STRATLow 62% 53% 37% 68% 47% 92% 85% 57%Moderate 37% 45% 54% 30% 48% 7% 13% 38%High 2% 3% 9% 2% 4% 1% 2% 5%


The interest rate risk and strategic categories have the most mutual FSAs designated with high risk. Six of the eight risks are predominately

rated as low.

Mutual FSA Aggregate Level of Risk Low

0%

4%

8%

12%

16%

20%

24%

COMP CREDIT IRR LIQ OPER PRICE REP STRAT2020Q2 7% 14% 13% 7% 19% 2% 4% 16%2021Q2 6% 20% 19% 7% 19% 4% 5% 21%


Below are the percentages of mutual FSAs designated with either high or moderate and increasing risk. The top four risks are strategic, credit,

IRR, and operational. Of the top risks, strategic, credit, and IRR are showing year-over-year increases.

Some Risks Increasing

7%

26%18%

93%

74%82%

0%

20%

40%

60%

80%

100%

Mutuals Stock All FSAs12‐month 18‐month


Ninety-three percent of mutual FSAs are on the 18-month supervisory cycle.

Most Mutuals on Expanded Exam Cycle

1%

29%

0%

23%

3%

19%

5%

16%

4%

0%

27%

5%

4%

5%

30%

16%

11%

2%

0% 8% 16% 24% 32%

Asset Management

Bank Information Technology

BSA/AML

Capital Markets

Compliance

Commercial Credit

Retail Credit

Enterprise Governance

Earnings and Capital

TTM as of 6/30/2021 TTM as of 6/30/2020


Mutual MRAs in the trailing twelve months ending June 30, 2021, decreased by 21 percent. More than half were centered in Bank

Information Technology at 29 percent and Capital Markets at 23 percent.

MRA Volume Down for Mutuals in 2021

33

25

13

24

14

2

34

34

142

63

2

0 3 6 9 12 15

CompositeCapital

Asset QualityManagement

EarningsLiquidity

SensitivityInformation Technology

TrustCompliance

CRAUpgrade Downgrade


Over the last four quarters, rating downgrades exceeded upgrades. There were 30 upgrades and 41 downgrades, which translates to a net

downgrade of 11. Most downgrades were for earnings. Most upgrades were for management.

Mutual Rating Downgrades > Upgrades

39Conclusions

• Composite ratings for mutual FSAs remain satisfactory. Ninety-five percent of mutual FSAs are rated 1 or 2. No mutual FSA is rated 4 or 5. Six of the eight risk categories are rated predominately as low.

• Capital remains strong. Leverage capital ratios are lower this year due to rapid asset growth from the pandemic but remain much higher than peer. Total risk-based capital ratios increased in 2021 and are back to pre-pandemic levels. The gap between federal and state charters expanded to over 1,100 basis points.

• Asset quality is good. Total noncurrent loans fell to a decade low of 0.57 percent. Loan growth is weak. The ALLL is adequate and well above pre-pandemic levels.

• Earnings are adequate. Despite NIM compression, ROAA rose four basis points due to lower provision expenses. More mutual FSAs are adversely rated for earnings than any other rating category. Earnings saw the most downgrades over the last year.

• Liquidity is strong. Mutual banks are flush with liquidity due to pandemic related deposits and a higher consumer savings rate.

• Sensitivity to market risk is adequately controlled. Mutual banks are holding higher levels of nonmaturity deposits relative to long-term assets making them less vulnerable to increases in interest rates.

Key Observations – June 30, 2021

40

Questions

Thank You

msaac meeting sep 28 2021

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