WEST TOWN BANK & TRUST Community Reinvestment Act .

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WEST TOWN BANK & TRUSTCommunity Reinvestment Act Strategic PlanAUGUST 10, 2018 – AMENDED FOR SALE OF NC BRANCHESDECEMBER 7, 2018 – RESUBMITTED AMENDMENTFEBRUARY 26, 2019 – RESUBMITTED AMENDMENTThis is the Community Reinvestment Act Strategic Plan (“Strategic Plan” or “Plan”))adopted by West Town Bank & Trust (the “Bank”), an Illinois state bank that provides deposit andbanking services insured by the Federal Deposit Insurance Corporation (“FDIC”). The Bank isthe wholly owned subsidiary of West Town Bancorp, Inc. a North Carolina corporation and aFederal Reserve Board approved financial holding company. The Bank adopted this StrategicPlan in conformity with alternatives available to financial institutions under the CommunityReinvestment Act of 1977 (“CRA” or the “Act”) and is requesting an amendment to the Plan asoutlined below and throughout the Plan.Certain Definitions: Home mortgage loan means a “home improvement loan,” “homepurchase loan,” or a “refinancing” as defined in §1003.2 that appears in Regulation C - HomeMortgage Disclosure Act (HMDA)Small business loan means a loan included in “loans to small businesses” as defined in theinstructions for preparation of the Consolidated Report of Condition and Income.AMENDMENT REQUEST SUMMARYThe Bank has sold its two North Carolina branches located in Winterville (Pitt County)and Edenton (Chowan County) North Carolina to its sister bank Sound Bank headquartered inMorehead City North Carolina. Since these locations represent two of the Bank’s three CRAassessment areas all with area specific goals it is necessary to amend the current CRA StrategicPlan. The lending and investment goals under the approved Plan are percentage based as comparedto total assets and the community service hours are based on the number of Bank employees bothof which (total assets and total bank employees) are based on December 31st results of theimmediate preceding year. This will not change in the proposed amended Plan, however, thereduction of assets to total assets due to the sale of the branches will be the factor used to increasethe goals for both the lending and investment tests in the remaining assessment area. For example,the Bank reduced its assets by 11.71% with the branch sale and for Plan years 2019-2021 the Bankwill increase its goals by 11.71% in both the lending and investment tests as follows:1

The two branches were sold in October of 2018 however the plan does not consideramending the testing methodology for this event and the 2018 Plan year and will be graded underthe approved Plan without any adjustments.The amended plan calls for the removal of the “State” test and the removal of theassessment area weighting as the Bank will only have one assessment area in Illinois. A moredetailed review of grading the Bank for CRA purposes in Plan years 2019-2021 is outlined furtherin this amended Plan and accompanying exhibits.2

I.INTRODUCTION: THE COMMUNITY REINVESTMENT ACTRegulated financial institutions such as the Bank are required by law to demonstrate thatthey serve the financial services needs of the communities in which their offices are located,including adequately addressing both the deposit services and credit needs of the communities inwhich they are chartered to do business. This affirmative obligation to help meet the credit needsof the local communities served by each financial institution is the premise underlying the CRA,which was signed into law to address the deteriorating conditions of American cities - particularlylower-income and minority areas – and the perceived shortage of credit available to low- andmoderate-income neighborhoods.Community development is an important element of the CRA. Community developmenttargets community service to LMI individuals; encompasses affordable housing (includingmultifamily rental housing) for LMI individuals; activities that promote economic developmentby financing businesses or farms that meet the size eligibility standards of the Small BusinessAdministration’s Development Company or Small Business Investment Company programs orhave gross annual revenues of 1 million or less; or activities that revitalize or stabilize LMIgeographies, designated disaster areas or distressed or underserved non-metropolitan middleincome geographies designated by the Board of Governors, FDIC and OCC.Financial regulators such as the FDIC review the CRA performance of banks operating inthe United States and evaluate compliance with the Act utilizing criteria that varies with the sizeof the institution. For small banks, such as the Bank, evaluation of performance for compliancewith the material provisions of the CRA is typically reviewed in the bank-designated area (the“Assessment Area”) served by its full service banking offices, and measures such criteria as thebank's loan-to-deposit ratio, geographic distribution of loans, percentage of loans and lendingactivities in the Assessment Area, record of lending to borrowers of different income levels andbusinesses of different sizes, and responses to consumer complaints.Before the advent of developments such as online banking and access to credit fromdiversified financial services providers via the Internet, small banks like the Bank designated theirAssessment Area based on the location of their full service banking offices and limited theirlending efforts to these, often small, geographic areas. In the 39 years since the CRA was adopted,however, technology and modern financial systems have enabled small banks, including the Bank,to expand their operations beyond the limited geographic reach of their traditional bankinglocations.As discussed in more detail later in this Strategic Plan, the Bank has, in the past eight years,developed a business strategy that focuses on making the Bank’s residential mortgage loanproducts available to individuals and families throughout the United States as well its commercialoriented Government Guaranteed Lending Department focused on SBA 7(a) and USDAB&I/REAP loans throughout the United States Department of Agriculture (“USDA”). Thisnationwide lending strategy is driven by the business operations and expertise of the investmentgroups that recapitalized the Bank (outlined below), portfolio diversification goals, lendingopportunities (including low- and moderate-income lending) outside of the communities servedby the Bank’s retail banking facilities, and the Bank’s mortgage banking and government3

guaranteed lending operations that require lending volumes that exceed what can be originated inthe Banks primary Assessment Area of Cook County, Illinois alone. In view of the Bank’s currentbusiness strategy, the Bank believes the CRA’s small bank lending test does not adequatelymeasure the lending performance of the Bank, which serves a wide range of customers throughoutthe country including LMI borrowers and LMI census tracts. As an alternative to the standardevaluation method, and as a result of changes adopted by the Bank, the Act permits the Bank tocomply with the CRA by electing to implement an approved CRA Strategic Plan. Accordingly,the Bank has elected to operate under this Strategic Plan in order to satisfactorily fulfill its CRAobligations.II.WEST TOWN BANK & TRUST HISTORY AND BUSINESS OVERVIEWMISSION STATEMENTThe Bank is dedicated to serving the financial needs of its customers and the communitiesin which its offices are located while exercising profitable stewardship over the resources of theBank. The Bank is committed to providing personal banking services, affordable lending productsin a sound, cost-effective way, assisting in making the dream of home ownership a reality forindividuals and families, make loans available to small business and to contributing to theeconomic stability and growth of the neighborhoods in which the Bank does business.This Mission Statement reflects the Bank’s 90 year history of providing financial servicesto its local communities, and will continue to serve as the framework for the Bank’simplementation of this Strategic Plan.HISTORIC PRESENCE AND EXPANDED CAPABILITIESOn January 1, 1922, the Bank opened its doors with a mission to serve the banking needsof families in the Cicero, Illinois community. For most of its history, the Bank grew slowly byproviding traditional savings and deposit services to the residents of Cicero and a number ofsurrounding towns. The Bank’s lending programs focused on conventional mortgage loans, homeequity lines of credit and second mortgages to residents in the local communities served by theBank that required a minimum of a twenty (20%) percent down payment or significant equity inthe property. In 1999, the Bank opened its North Riverside, Illinois branch to expand its servicearea, and continued its focus on providing traditional banking and residential mortgage loanproducts. In 2014 the Bank commenced operations through its branch in Winterville, NorthCarolina and opened its Edenton, North Carolina branch in March 2016.Effective August 31, 2014 the Bank converted from an Illinois savings bank to an Illinoisstate bank. On January 1, 2016 the Bank became a wholly owned subsidiary of West TownBancorp, Inc., a North Carolina corporation, and a Federal Reserve Board approved bank holdingcompany.By 2009, the Bank had grown to 60 million in assets – very small in comparison to mostmodern financial institutions. Rather than sell the Bank and have its offices become branches ofa much larger regional or national bank, the Bank merged its operations with North Carolina4

investors that shared its same commitment to the promotion of home ownership andentrepreneurial activities of small businesses. From 2009-2010, the Bank and the investorscompleted a series of private placement stock offerings and merger transactions, whichsignificantly increased the Bank’s capital and has allowed for expansion of banking and lendingoperations.The past six years have been a time of growth and change for the Bank. December 31,2017, the Bank’s assets grew to 336 million. The Bank’s new investors have brought renewedenergy and dedication to the Bank’s historic operations. With new investor capital, the Bank hasadded modern banking services such as direct deposit, online banking, telephone banking, ATMand debit cards, and credit cards to its time-honored personal checking, savings and Certificate ofDeposit offerings. Local business customers have also benefited from the Bank’s addition ofremote deposit capture, online banking, and merchant payment processing to the checking anddeposit accounts traditionally available to neighborhood business and commercial customers.During this time, the Bank has remained dedicated to its core mission of providing personal andresponsive service and banking products in a sound, cost-effective manner to enable the Bank’scustomers to achieve their personal financial objectives, home ownership goals and small businessgrowth.LENDING OPERATIONS , LOAN PROGRAMS AND PORTFOLIO COMPOSITIONWith the Bank’s recapitalization, the Bank has been able to expand its operations bydeveloping the Bank’s Mortgage Loan Department as a direct national residential lender and theBank’s mortgage loan services are now available to individuals and families throughout the UnitedStates. The growth in the Bank’s ability to meet a diverse spectrum of home financing needs isfounded upon the Bank’s decision to offer more loan choices than the conventional twenty (20%)percent down payment / 20% equity products that were the hallmark of its historic operations. TheBank now offers a wide variety of lending programs to finance the purchase of a home or refinancean existing residential loan. These loan options can provide low cost and affordable entrance toand maintenance of home ownership and include the following: Federal Housing Administration (FHA) guaranteed loan programs;Veteran’s Administration (VA) guaranteed loan programs;Conventional and insured low-down payment programs; andWhile bigger banks primarily focus on larger customers, the Bank remains committed tomeeting the banking and home ownership financing needs of individuals and families. The chartbelow summarizes the types and net value of loans held in the Bank’s loan portfolio as ofDecember 31, 2017:Single family 1-4 unit residential closed-end loans secured by first lienmortgagesSingle family 1-4 unit residential closed-end loans secured by second lienmortgagesSingle family 1-4 unit residential open-end loans extended under revolving linesof credit secured by mortgagesConsumer loans, including auto and installmentResidential multifamily (5 or more units) secured by mortgages5 000.4%0.7%

Other real estate secured loans, including construction, land development andcommercial real estate loans104,975,00036.7%Commercial, industrial and agriculture loans125,283,00043.8%The Bank is also a provider of government guaranteed commercial loans through the SmallBusiness Administration (“SBA”) 7(a) loan program nationally, the Business and Industrial(“B&I”) loan program and the Rural Energy for America Program (“REAP”) both sponsored bythe USDA financing in qualifying rural area across the country. Traditionally the Bank’s primaryfocus has been solely to promote savings and home ownership but has since expanded this intosmall business landing as well with a national footprint. As a community bank, the Bank isdedicated to helping its customers realize the American dream of home ownership and facilitatesmall business ownership as the Bank believes this promotes neighborhood stability, strengthenslocal communities, and contributes to local economic growth in the areas that it serves.III.REQUIRED ELEMENTS OF THE STRATEGIC PLANThe Bank will take advantage of its existing residential lending expertise, small businesslending products and financial services experience to meet the Bank’s obligations under CRA.The Bank’s business strategies are focused on its national lending activities, but the Bank’s CRAStrategic Plan concentrates on residential and small businesses lending programs and communityinvolvement designed to support home ownership, housing opportunities and small businessgrowth within its designated Assessment Area of Cook County, Illinois. In response to the Bank’sefforts to ascertain the credit needs of the communities that surround its traditional bankingfacilities and as discussed in more detail below, comments and suggestions received by the Bankconfirm that the current economic cycle has had a devastating effect on housing opportunities inthe Bank’s traditional market area. Therefore, the Bank’s Strategic Plan was designed to increasethe residential lending activities to LMI borrowers and in LMI census tracts in Chicago and thesuburban communities of Cook County, Illinois area. Following is a discussion of elements of theBank’s Strategic Plan.DELINEATION OF ASSESSMENT AREA – COOK COUNTY, ILLINOISThe Bank historically designated Cook and DuPage Counties in Illinois, which are part ofthe Chicago – Naperville – Joliet, Illinois Metropolitan Statistical Area (“MSA”), as the Bank’sAssessment Area. Prior to the adoption of this Strategic Plan, the Bank identified an AssessmentArea that extended beyond the communities traditionally served by the Bank’s banking offices dueto the intense competition in the communities of Cicero and North Riverside. In the Cook CountyAssessment Area there are 3,031 offices of 226 different banking institutions providing bankingand lending services. With the Bank’s increased lending authorities and capital added in 2009 &2010, the Bank now believes it can effectively meet its lending goals in its Assessment Area witha wider array of lending products for both residential and commercial customers. The Bank’soriginal Strategic Plan (circa 2012) identified Cook County, Illinois as its sole delineatedAssessment Area. With the establishment of the Bank’s branch office in Winterville, Pitt County,North Carolina in 2014, and its branch office in Edenton, Chowan County, North Carolina in 2016,the Bank applied and received approval for a new CRA Strategic Plan for 5 years (2017–2021)and to include Pitt County and Chowan County, North Carolina (Metropolitan Statistical Area –6

Greenville, North Carolina Metro Area). The Bank has recently entered into a purchase saleagreement with its sister organization, Sound Bank, to sell both the Winterville and Edenton, NorthCarolina branch offices as they are in contiguous markets. This amended Strategic Plancontemplates the sale of both of the Bank’s North Carolina branches resulting in a sole AssessmentArea of Cook County Illinois for the Bank.COOK COUNTY, ILLINOISASCERTAINING THE H OUSING CREDIT NEEDS OF THE BANK’SCOOK COUNTY ASSESSMENT AREAIn order to fulfill the Bank’s affirmative obligation to help meet the credit needs of thelocal communities in Cook County, Illinois to be served by the Bank, particularly in low- andmoderate-income area, representatives of the Bank contacted municipal officials and housing andsocial service providers throughout the Assessment Area with emphasis on outreach efforts in theCicero, Berwyn and North Riverside communities. As a result of the Bank’s discussions withmunicipal leaders and organizations active in these communities, the Bank determined that therecent economic climate has had a highly negative impact on housing gains made over the last tenyears.The economic picture for the Assessment Area is slowly improving, with small gains inthe Cook County employment rates seen in recent months. Although the Assessment Area is nowclimbing out of recession, Cook County continues to struggle with high rates of unemploymentand high foreclosure although the number of foreclosures has experienced a decline in the last fewyears.Local communities’ determination that housing credit and home ownership support isneeded in the Assessment Area served by the Bank is confirmed by State of Illinois and CookCounty officials, who have joined with Assessment Area cities and towns to address the housingcrisis.This Strategic Plan recognizes affordable housing credit and home ownership support isneeded throughout the Assessment Area and is designed to address those needs.RECENT MARKET CONDITIONSDue to increasing distressed sales, housing supply continues to increase and put downwardpressure on sale prices. Price stability has a direct relationship to the number of distressed salesand the unemployment rate in a neighborhood. In the Assessment Area market, distressed saleshave accounted for a large percentage of transactions. Residential remodeling activity, however,is expected to increase, providing opportunities in Home Equity lending.PUBLIC PARTICIPATION AND COMMUNITY OUTREACH ACTIVITIESUSED IN DEVELOPMENT OF THE S TRATEGIC PLAN7

The Bank has invited community contacts to participate in the development of the Bank’sStrategic Plan by providing insight into the local community and its needs, particularly with respectto: affordable housing; community services; economic development; and the revitalization or stabilization of low- to moderate-income areaswithin the Bank’s Assessment Area.The Bank also has solicited input from entities, organizations, government agencies andother community development groups by participating in various outreach activities within thetargeted local communities. The Bank has used the information obtained through publicparticipation and its own community outreach activities to assess the credit needs of theAssessment Area and to assist the Bank in the development of this Strategic Plan. The Bank hasfocused outreach activities on entities, organizations, and government agencies within the targetedcommunities of the Assessment Area that offer innovative, flexible programs designed to meet thehousing, medical, and family support needs of low- and moderate-income families and individualsresiding in the Assessment

1 WEST TOWN BANK & TRUST Community Reinvestment Act Strategic Plan AUGUST 10, 2018 – AMENDED FOR SALE OF NC BRANCHES DECEMBER 7, 2018 – RESUBMITTED AMENDMENT FEBRUARY 26, 2019 – RESUBMITTED AMENDMENT This is the Community Reinvestment Act Strategic Plan (“Strategic Plan” or “Plan”))

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