Loans and Allowance for Credit Losses | Note 5. 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 June 30, 2020 (unaudited) and December 31, 2019 are summarized by type as follows: June 30, 2020 December 31, 2019 (dollars in thousands) Amount % Amount % Commercial $ 1,607,056 20 % $ 1,545,906 20 % PPP loans 456,476 6 % — — Income producing - commercial real estate 3,678,946 46 % 3,702,747 50 % Owner occupied - commercial real estate 964,077 12 % 985,409 13 % Real estate mortgage - residential 93,601 1 % 104,221 1 % Construction - commercial and residential 995,550 12 % 1,035,754 14 % Construction - C&I (owner occupied) 149,845 2 % 89,490 1 % Home equity 74,921 1 % 80,061 1 % Other consumer 1,289 — 2,160 — Total loans 8,021,761 100 % 7,545,748 100 % Less: allowance for credit losses (108,796) (73,658) Net loans $ 7,912,965 (1) $ 7,472,090 (1) Excludes accrued interest receivable of $36.2 million and $21.3 million at June 30, 2020 and December 31, 2019, respectively, which is recorded in other assets. Unamortized net deferred fees amounted to $34.8 million and $25.2 million at June 30, 2020 and December 31, 2019, respectively. As of June 30, 2020 and December 31, 2019, the Bank serviced $96 million and $99 million, respectively, of multifamily FHA loans, SBA loans and other loan participations which are not reflected as loan balances on the Consolidated Balance Sheets. Loan Origination / Risk Management The Company’s goal is to mitigate risks in the event of unforeseen threats to the loan portfolio as a result of economic downturn or other negative influences. Plans for mitigating inherent risks in managing loan assets include: carefully enforcing loan policies and procedures, evaluating each borrower’s business plan during the underwriting process and throughout the loan term, identifying and monitoring primary and alternative sources for loan repayment, and obtaining collateral to mitigate economic loss in the event of liquidation. Specific loan reserves are established based upon credit and/or collateral risks on an individual loan basis. A risk rating system is employed to proactively estimate loss exposure and provide a measuring system for setting general and specific reserve allocations. The composition of the Company’s loan portfolio is heavily weighted toward commercial real estate, both owner occupied and income producing real estate. At June 30, 2020, owner occupied - commercial real estate and construction – Commercial and Industrial (“C&I”) (owner occupied) represent approximately 14% of the loan portfolio . At June 30, 2020, non-owner occupied commercial real estate and real estate construction represented approximately 58% of the loan portfolio. The combined owner occupied and commercial real estate and construction loans represent approximately 72% of the loan portfolio. Real estate also serves as collateral for loans made for other purposes, resulting in 79% of all loans being secured by real estate. These loans are underwritten to mitigate lending risks typical of this type of loan such as declines in real estate values, changes in borrower cash flow and general economic conditions. The Bank typically requires a maximum loan to value of 80% and minimum cash flow debt service coverage of 1.15 to 1.0. Personal guarantees may be required, but may be limited. In making real estate commercial mortgage loans, the Bank generally requires that interest rates adjust not less frequently than five years. The Company is also an active traditional commercial lender providing loans for a variety of purposes, including working capital, equipment and account receivable financing. This loan category represents approximately 20% of the loan portfolio at June 30, 2020 and was generally variable or adjustable rate. Commercial loans meet reasonable underwriting standards, including appropriate collateral and cash flow necessary to support debt service. Personal guarantees are generally required, but may be limited. SBA loans represent approximately 1.3% of the commercial loan category. In originating SBA loans, the Company assumes the risk of non-payment on the unguaranteed portion of the credit as well as potential repairs to the SBA guarantees. The Company generally sells the guaranteed portion of the loan generating noninterest income from the gains on sale, as well as servicing income on the portion participated. SBA loans are subject to the same cash flow analyses as other commercial loans. SBA loans are subject to a maximum loan size established by the SBA as well as internal loan size guidelines. Approximately 6% of the loan portfolio at June 30, 2020 consists of PPP loans to eligible customers. PPP loans are expected to primarily be repaid via forgiveness from the SBA. These loans are fully guaranteed as to principal and interest by the SBA and ultimately by the full faith and credit of the U.S. Government; as a result, they were approved utilizing different underwriting standards than the Bank's other commercial loans. PPP loans are included in the CECL model but do not carry an allowance for credit loss due to the aforementioned government guarantees. Approximately 1% of the loan portfolio at June 30, 2020 consists of home equity loans and lines of credit and other consumer loans. These credits, while making up a small portion of the loan portfolio, demand the same emphasis on underwriting and credit evaluation as other types of loans advanced by the Bank. Approximately 1% of the loan portfolio consists of residential mortgage loans. The repricing duration of these loans was 16 months. These credits represent first liens on residential property loans originated by the Bank. While the Bank’s general practice is to originate and sell (servicing released) loans made by its Residential Lending department, from time to time certain loan characteristics do not meet the requirements of third party investors and these loans are instead maintained in the Bank’s portfolio until they are resold to another investor at a later date or mature. 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 Loan Committee. 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 $1.47 billion at June 30, 2020. 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 59% of the outstanding ADC loan portfolio at June 30, 2020. 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 this inherent risk, 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 not performed as expected, it is not 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 and six months ended June 30, 2020 and 2019. 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 preclude its availability to absorb losses in other categories. Income Producing - Owner Occupied - Real Estate Construction - Commercial Commercial Mortgage - Commercial and Home Other (dollars in thousands) Commercial Real Estate Real Estate Residential Residential Equity Consumer Total Three Months Ended June 30, 2020 Allowance for credit losses: Balance at beginning of period $ 27,346 $ 43,551 $ 9,867 $ 1,369 $ 13,341 $ 818 $ 44 96,336 Loans charged-off (7,145) — — — — — — (7,145) Recoveries of loans previously charged-off 5 — — — — — 1 6 Net loans charged-off (7,140) — — — — — 1 (7,139) Provision for credit losses 7,872 8,312 2,474 181 467 294 (1) 19,599 Ending balance $ 28,078 $ 51,863 $ 12,341 $ 1,550 $ 13,808 $ 1,112 $ 44 $ 108,796 Six Months Ended June 30, 2020 Allowance for credit losses: Balance at beginning of period, prior to adoption of ASC 326 $ 15,857 $ 28,034 $ 6,242 $ 965 $ 18,175 $ 599 $ 72 $ 69,944 Impact of adopting ASC 326 892 11,230 4,674 (301) (6,143) 245 17 10,614 Loans charged-off (7,145) (550) — — (1,768) — — (9,463) Recoveries of loans previously charged-off 74 — — — — — 4 78 Net loans (charged-off) recoveries (7,071) (550) — — (1,768) — 4 (9,385) Provision for credit losses 18,400 13,149 1,425 886 3,544 268 (49) 37,623 Ending balance $ 28,078 $ 51,863 $ 12,341 $ 1,550 $ 13,808 $ 1,112 $ 44 $ 108,796 As of June 30, 2020 Allowance for credit losses: Individually evaluated for impairment $ 8,797 $ 5,260 $ 405 $ 746 $ 1,383 $ 107 $ 3 $ 16,701 Collectively evaluated for impairment 19,281 46,603 11,936 804 12,425 1,005 41 92,095 Ending balance $ 28,078 $ 51,863 $ 12,341 $ 1,550 $ 13,808 $ 1,112 $ 44 $ 108,796 Three Months Ended June 30, 2019 Allowance for credit losses: Balance at beginning of period $ 17,195 $ 26,765 $ 5,980 $ 681 $ 18,469 $ 605 $ 248 $ 69,943 Loans charged-off (1) (1,847) — — — — (2) (1,850) Recoveries of loans previously charged-off 37 302 2 2 37 — 13 393 Net loans charged-off 36 (1,545) 2 2 37 — 11 (1,457) Provision for credit losses 905 1,790 (226) 672 500 (24) (17) 3,600 Ending balance $ 18,136 $ 27,010 $ 5,756 $ 1,355 $ 19,006 $ 581 $ 242 $ 72,086 Six Months Ended June 30, 2019 Allowance for credit losses: Balance at beginning of period $ 15,857 $ 28,034 $ 6,242 $ 965 $ 18,175 $ 599 $ 72 $ 69,944 Loans charged-off (5) (5,343) — — — — (2) (5,350) Recoveries of loans previously charged-off 167 302 2 3 37 — 21 532 Net loans (charged-off) recoveries 162 (5,041) 2 3 37 — 19 (4,818) Provision for credit losses 2,117 4,017 (488) 387 794 (18) 151 6,960 Ending balance $ 18,136 $ 27,010 $ 5,756 $ 1,355 $ 19,006 $ 581 $ 242 $ 72,086 As of June 30, 2019 Allowance for credit losses: Individually evaluated for impairment $ 7,905 $ 1,000 $ 475 $ 650 $ — $ — $ — $ 10,030 Collectively evaluated for impairment 10,231 26,010 5,281 705 19,006 581 242 62,056 Ending balance $ 18,136 $ 27,010 $ 5,756 $ 1,355 $ 19,006 $ 581 $ 242 $ 72,086 During the first quarter of 2020, we adopted ASU 2016-13, which replaced the incurred loss methodology for determining our provision for credit losses and allowance for credit losses with an expected loss methodology that is referred to as the CECL model. Upon adoption, the allowance for credit losses was increased by $14.7 million, which included a $4.1 million increase to the allowance for unfunded commitments, with no impact to the consolidated statement of operations. We recorded a $19.7 million and $34.0 million provision for credit losses for the three and six months ended second June 30, 2020 under CECL. We recorded $7.1 million and $9.4 million in net charge-offs during the three and six months ended June 30, 2020, respectively, compared to $1.5 million and $4.8 million during the three and six months ended June 30, 2019. A loan is considered collateral-dependent when the borrower is experiencing financial difficulty and repayment is expected to be provided substantially through the operation or sale of the collateral. The following table presents the amortized cost basis of collateral-dependent loans by class of loans as of June 30, 2020: Business/Other (dollars in thousands) Assets Real Estate Commercial $ 15,105 $ 2,895 Income producing - commercial real estate 3,193 24,102 Owner occupied - commercial real estate — 10,815 Real estate mortgage - residential — 7,960 Construction - commercial and residential — 5,385 Construction - C&I (owner occupied) — — Home equity — 600 Other consumer 6 — Total $ 18,304 $ 51,757 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 are to use 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 Classified (b) Doubtful Based on the most recent analysis performed, the risk category of loans by class of loans and year of origination is as follows: June 30, 2020 (dollars in thousands) 2016 2017 2018 2019 2020 Prior Total Commercial Pass 128,724 316,829 275,852 227,726 140,233 439,707 1,529,071 Watch 362 16,583 — 2,275 — 18,743 37,963 Special Mention — — 10,977 — — 933 11,910 Substandard 4,667 2,128 2,565 459 — 18,293 28,112 Total 133,753 335,540 289,394 230,460 140,233 477,676 1,607,056 PPP loans Pass — — — — 456,476 — 456,476 Total — — — — 456,476 — 456,476 Income producing - commercial real estate Pass 412,724 520,542 726,838 807,571 208,386 970,544 3,646,605 Watch — — — 4,324 — 721 5,045 Special Mention 800 — — — — 4,843 5,643 Substandard — 4,656 4,883 5,542 — 6,572 21,653 Total 413,524 525,198 731,721 817,437 208,386 982,680 3,678,946 Owner occupied - commercial real estate Pass 107,303 117,523 221,811 92,496 15,673 358,051 912,857 Watch — — — — — 40,465 40,465 Substandard 803 — 360 — — 9,592 10,755 Total 108,106 117,523 222,171 92,496 15,673 408,108 964,077 Real estate mortgage - residential Pass 3,423 10,394 15,429 28,234 5,701 21,844 85,025 Watch — — — — — 617 617 Substandard 4,154 2,619 — — — 1,186 7,959 Total 7,577 13,013 15,429 28,234 5,701 23,647 93,601 Construction - commercial and residential Pass 71,957 431,635 317,131 108,584 25,385 35,473 990,165 Substandard 2,298 408 — — — 2,679 5,385 Total 74,255 432,043 317,131 108,584 25,385 38,152 995,550 Construction - C&I (owner occupied) Pass 11,689 5,482 41,084 27,557 17,441 32,612 135,865 Watch — 2,124 11,087 — — 769 13,980 Total 11,689 7,606 52,171 27,557 17,441 33,381 149,845 Home Equity Pass 4,859 8,942 8,658 4,468 3,785 42,416 73,128 Watch — — — — — 944 944 Substandard — — — — — 849 849 Total 4,859 8,942 8,658 4,468 3,785 44,209 74,921 Other Consumer Pass 177 85 121 106 28 764 1,281 Substandard — — — — — 8 8 Total 177 85 121 106 28 772 1,289 Total Recorded Investment $ 753,940 $ 1,439,950 $ 1,636,796 $ 1,309,342 $ 873,108 $ 2,008,625 $ 8,021,761 The Company’s credit quality indicators are generally updated annually; however, credits rated watch or below are reviewed more frequently. The following table presents by class and by credit quality indicator, the recorded investment in the Company’s loans and leases as of December 31, 2019: Total (dollars in thousands) Pass Watch Special Mention Substandard Doubtful Loans December 31, 2019 Commercial $ 1,470,636 $ 38,522 $ 11,460 $ 25,288 $ — $ 1,545,906 Income producing - commercial real estate 3,667,585 16,069 — 19,093 — 3,702,747 Owner occupied - commercial real estate 925,800 53,146 — 6,463 — 985,409 Real estate mortgage - residential 98,228 628 — 5,365 — 104,221 Construction - commercial and residential 1,113,734 — — 11,510 — 1,125,244 Home equity 78,626 948 — 487 — 80,061 Other consumer 2,160 — — — — 2,160 Total $ 7,356,769 $ 109,313 $ 11,460 $ 68,206 $ — $ 7,545,748 Nonaccrual and Past Due Loans As part of its comprehensive loan review process, the Loan Committee or Credit Review Committee carefully evaluate loans which 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 ninety 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 following table presents, by class of loan, an aging analysis and the recorded investments in loans past due as of June 30, 2020 and December 31, 2019: Loans Loans Loans Total Recorded 30-59 Days 60-89 Days 90 Days or Total Past Current Investment in (dollars in thousands) Past Due Past Due More Past Due Due Loans Loans Non-Accrual Loans June 30, 2020 Commercial $ 603 $ 3,046 $ — $ 3,649 $ 1,586,686 $ 16,721 $ 1,607,056 PPP loans — — — — 456,476 — $ 456,476 Income producing - commercial real estate — 14,203 — 14,203 3,647,464 17,279 3,678,946 Owner occupied - commercial real estate 542 212 — 754 952,568 10,755 964,077 Real estate mortgage - residential — — — — 85,385 8,216 93,601 Construction - commercial and residential — 751 — 751 989,414 5,385 995,550 Construction - C&I (owner occupied) — — — — 149,845 — 149,845 Home equity 263 254 — 517 73,804 600 74,921 Other consumer — 3 — 3 1,280 6 1,289 Total $ 1,408 $ 18,469 $ — $ 19,877 $ 7,942,922 $ 58,962 $ 8,021,761 December 31, 2019 Commercial $ 3,063 $ 781 $ — $ 3,844 $ 1,527,134 $ 14,928 $ 1,545,906 Income producing - commercial real estate — 5,542 — 5,542 3,687,494 9,711 3,702,747 Owner occupied - commercial real estate 13,008 — — 13,008 965,938 6,463 985,409 Real estate mortgage – residential 3,533 — — 3,533 95,057 5,631 104,221 Construction - commercial and residential — — — — 1,113,735 11,509 1,125,244 Home equity 136 192 — 328 79,246 487 80,061 Other consumer — 9 — 9 2,151 — 2,160 Total $ 19,740 $ 6,524 $ — $ 26,264 $ 7,470,755 $ 48,729 $ 7,545,748 The following presents the nonaccrual loans as of June 30, 2020 and December 31, 2019: June 30, 2020 December 31, 2019 Nonaccrual with Nonaccrual with Total Total No Allowance an Allowance Nonaccrual Nonaccrual (dollars in thousands) for Credit Loss for Credit Loss Loans Loans Commercial 1,507 15,214 16,721 14,928 PPP loans — — — — Income producing - commercial real estate 8,544 8,735 17,279 9,711 Owner occupied - commercial real estate 7,065 3,690 10,755 6,463 Real estate mortgage - residential 5,503 2,713 8,216 5,631 Construction - commercial and residential 2,298 3,087 5,385 11,509 Home equity 50 550 600 487 Other consumer — 6 6 — Total $ 24,967 $ 33,995 $ 58,962 $ 48,729 (1) Excludes TDRs that were performing under their restructured terms totaling $12.3 million at June 30, 2020 and $16.6 million at December 31, 2019. (2) Gross interest income of $ 1.7 million and $1.2 million would have been recorded for the six months ended June 30, 2020 and 2019, respectively, if nonaccrual loans shown above had been current and in accordance with their original terms, while the interest actually recorded on such loans was $57 thousand and $86 thousand for the six months ended June 30, 2020 and 2019, respectively. See Note 1 to the Consolidated Financial Statements for a description of the Company’s policy for placing loans on nonaccrual status. Pre Adoption of CECL Loans were considered impaired when, based on current information and events, it was probable the Company would be unable to collect all amounts due in accordance with the original contractual terms of the loan agreement, including scheduled principal and interest payments. If a loan was impaired, a specific valuation allowance was allocated, if necessary, so that the loan was reported at the present value of estimated future cash flows using the loan’s existing rate or at the fair value of collateral if repayment was expected solely from the collateral. The Bank’s loan policy requires that loans be placed on nonaccrual if they are ninety days past-due, unless they are well secured and in the process of collection. Impaired loans, or portions thereof, were charged-off when deemed uncollectible. The following table presents, by class of loan, information related to impaired loans at December 31, 2019: Unpaid Recorded Recorded Average Recorded Interest Income Contractual Investment Investment Total Investment Recognized Principal With No With Recorded Related Year Year (dollars in thousands) Balance Allowance Allowance Investment Allowance To Date To Date December 31, 2019 Commercial $ 15,814 $ 11,858 $ 3,956 $ 15,814 $ 5,714 $ 15,682 $ 270 Income producing - commercial real estate 14,093 2,713 11,380 14,093 2,145 18,133 382 Owner occupied - commercial real estate 7,349 6,388 961 7,349 415 6,107 197 Real estate mortgage - residential 5,631 3,175 2,456 5,631 650 5,638 — Construction - commercial and residential 11,509 11,101 408 11,509 100 8,211 92 Home equity 487 — 487 487 100 487 — Other consumer — — — — — — — Total $ 54,883 $ 35,235 $ 19,648 $ 54,883 $ 9,124 $ 54,258 $ 941 Modifications A modification of a loan constitutes a TDR when a 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. The most common change in terms provided by the Company is an extension of an interest only term. As of June 30, 2020, 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 impaired 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 complies 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 allows for a deferral of payments for 90 days, which we may extend for an additional 90 days, for a maximum of 180 days on a cumulative and successive basis. The deferred payments along with interest accrued during the |