The Corporation was formed in 1974 as a bank holding company. The Corporation
is a financial holding company under the Gramm-Leach-Bliley Act of 1999 (GLB
Act). The Corporation has four reportable business segments: Community Banking,
Wealth Management, Insurance and Consumer Finance. As of December 31, 2015,
the Corporation had 288 Community Banking offices in Pennsylvania, Ohio, Maryland
and West Virginia and 76 Consumer Finance offices in Pennsylvania, Ohio, Tennessee
and Kentucky.
As a diversified financial services holding company, the Corporation, through
its subsidiaries, provides a full range of financial services, principally to
consumers, corporations, governments and small- to medium-sized businesses in
its market areas. The Corporation’s business strategy focuses primarily
on providing quality, consumer- and commercial-based financial services adapted
to the needs of each of the markets it serves. The Corporation seeks to maintain
its community orientation by providing local management with certain autonomy
in decision making, enabling them to respond to customer requests more quickly
and to concentrate on transactions within their market areas. However, while
the Corporation seeks to preserve some decision making at a local level, it
has centralized legal, loan review and underwriting, accounting, investment,
audit, loan operations, deposit operations and data processing functions. The
centralization of these processes enables the Corporation to maintain consistent
quality of these functions and to achieve certain economies of scale.
The Corporation’s Credit Policy requires, among other things, that all
commercial loans be underwritten to document the borrower’s financial
capacity to support the cash flow required to repay the loan. The Credit Policy
also contains additional guidelines and requirements applicable to specific
loan products or lines of business. The Corporation has developed a proprietary
underwriting system for all corporate business loan relationships and utilizes
a third party solution for small business loan relationships, with both platforms
allowing for consistency in underwriting across the entire footprint that also
generally permits credit decisions at the local and regional level. As part
of this underwriting, the Corporation requires clear and concise documentation
of the borrower’s ability to repay the loan based on current financial
statements and/or tax returns, plus pro-forma financial statements, as appropriate.
Specific guidelines for loan terms and conditions are outlined in the Corporation’s
Credit Policy. The guidelines also detail the collateral requirements for various
loan types. It is the Corporation’s general practice to obtain personal
guarantees, supported by current personal financial statements and/or tax returns,
to reduce the credit risk, as appropriate.
The Corporation’s revolving home equity lines of credit (HELOC) are generally
variable rate loans underwritten based on fully indexed rates. For home equity
loans, the Corporation’s policy is to generally require a LTV ratio not
in excess of 85% and FICO scores of not less than 660. In certain circumstances,
the Corporation will extend credit to borrowers with a LTV ratio over 85% on
a limited and closely monitored basis. The Corporation’s underwriters
evaluate a borrower’s debt service capacity on all line of credit applications
by utilizing an interest shock rate of 3% over the prevailing variable interest
rate at origination. The borrower’s debt-to-income ratio must remain within
the Corporation’s guidelines under the shock rate repayment formula. The
Corporation has elected, with the onset of the qualified mortgage (QM) rules
established by the Consumer Financial Protection Bureau (CFPB) in 2014, to tightly
limit the origination of non-QM loans.
Regency originates three general types of loans: direct real estate, direct
non-real estate and indirect sales finance. Regency has written policies and
procedures that it distributes to each Regency branch office defining underwriting,
pricing and loan servicing guidelines. Regency issues written credit authority
limits based upon the individual loan underwriter’s capability. On a monthly
basis, Regency evaluates specific metrics relating to Regency’s origination
and servicing of its loan portfolio. Regency also uses a quality control program
to review, in an independent manner, loan origination and servicing on a monthly
basis to ensure adherence with compliance and credit criteria standards.