Public Disclosure

PUBLIC DISCLOSURE

August 13, 2018

COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION

Frost Bank RSSD # 682563

111 W. Houston Street San Antonio, TX 78205

Federal Reserve Bank of Dallas 2200 North Pearl Street Dallas, Texas 75201

NOTE: This document is an evaluation of this institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, nor should it be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution. Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018

TABLE OF CONTENTS

INSTITUTION RATING 1 Institution’s CRA Rating: 1 Table of Performance Ratings 1 Summary of Major Factors Supporting Rating 1

INSTITUTION 3 Description of the Institution 3 Scope of Examination 6 Conclusions With Respect to Performance Tests 8 METROPOLITAN AREAS (Full Scope Review) 17 Description of Operations in the Dallas-Plano-Irving, TX Assessment Area 17 Conclusions With Respect to Performance Tests 24 METROPOLITAN AREAS (Full Scope Review) 32 Description of Operations in the Houston-The Woodlands-Sugar Land, TX Assessment Area 32 Conclusions With Respect to Performance Tests 39 METROPOLITAN AREAS (Full Scope Review) 47 Description of Operations in the San Antonio-New Braunfels, TX Assessment Area 47 Conclusions With Respect to Performance Tests 53 METROPOLITAN AREAS (Full Scope Review) 60 Description of Operations in Corpus Christi, TX Assessment Area 60 Conclusions With Respect to Performance Tests 66 METROPOLITAN AREAS (Limited Scope Review) 74 Description of Institution’s Operations 74 Conclusions With Respect to Performance Tests 75

APPENDICES 76 Appendix A – Scope of Examination 77 Appendix B – General Information 78 Appendix C - Glossary 79 Appendix D – Metropolitan Limited Scope Assessment Area Demographics 83 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables 90 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables 114 Appendix G – Distribution of Branch Delivery System and Branch Openings and Closings 139

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION RATING

INSTITUTION RATING

Institution’s CRA Rating: Frost Bank is rated Satisfactory.

The following table indicates the performance level of Frost Bank with respect to the lending, investment, and service tests.

Table of Performance Ratings

Frost Bank Performance Levels Performance Tests Lending Test* Investment Service Test Test Outstanding X High Satisfactory X X Low Satisfactory Needs to Improve Substantial Non Compliance * The lending test is weighted more heavily than the investment and service tests when arriving at an overall rating.

Summary of Major Factors Supporting Rating

Major factors supporting the institution’s rating include:

• Lending activity reflects good responsiveness to assessment areas' credit needs. • A substantial majority of loans are made in the bank’s assessment areas. • The geographic distribution of loans reflects excellent penetration throughout the assessment areas. • The distribution of Home Mortgage Disclosure Act (HMDA) lending reflects adequate penetration among customers of different income levels. • The distribution of small business lending reflects adequate penetration among businesses of different revenue sizes. • Is a leader in making community development loans. • Makes use of innovative and/or flexible lending practices in serving assessment area needs. • Has an excellent level of qualified community development investments and grants, particularly those not routinely provided by private investors and is often in a leadership position. • Exhibits excellent responsiveness to credit and community development needs.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION RATING

• Delivery systems are accessible to the bank’s geographies and individuals of different income levels in the assessment areas. • The record of opening and closing of branches has not adversely affected the accessibility of its delivery systems, particularly to low- and moderate-income (LMI) geographies and/or LMI individuals. • Services do not vary in a way that inconveniences its assessment areas, particularly LMI geographies and/or LMI individuals. • Is a leader in providing community development services.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

INSTITUTION Description of the Institution

Frost Bank (Frost), wholly owned by Cullen/Frost Bankers, Inc., is a single state commercial bank headquartered in San Antonio, Texas and is the largest Texas-based banking company that operates only in Texas. As of December 31, 2017, Frost operates 142 financial centers and over 1,200 automated teller machines (ATMs) throughout the State of Texas, approximately half of which are operated in connection with a branding arrangement to be exclusive cash-machine provider for CST Brands, Inc. Corner Stores in Texas. As of December 31, 2017, Frost held assets of $31.8 billion and total deposits of $26.9 billion.

For this evaluation, all ten of Frost’s assessment areas were reviewed. Total deposits for the assessment areas as of June 30, 2017 were $25.7 billion. Descriptions of the assessment areas listed below are found in the applicable assessment area sections of this report.

• Austin-Round Rock-San Marcos, TX MSA • Brownsville-Harlingen, TX MSA • Corpus Christi, TX MSA • Dallas-Plano-Irving, TX MD • Fort Worth-Arlington, TX MD • Houston-The Woodlands-Sugar Land, TX MSA • McAllen-Edinburg-Mission, TX MSA • Midland, TX MSA • Odessa, TX MSA • San Antonio-New Braunfels, TX MSA

Business Structure

Frost is strategically aligned into two primary business segments: Banking and Frost Wealth Advisors (FWA). Frost’s two primary core business segments are delineated by the products and services that each segment offers. The Banking operating segment, which represents the most dominant business line, provides both commercial and consumer banking services, with a wide array of credit and non-credit financial products. The FWA segment includes fee-based services within private trust, retirement services, and financial management services.

Frost Bank is a single-state commercial bank headquartered in San Antonio, TX. As of December 31, 2017, it operated 142 branch offices and 150 full service ATMs throughout its footprint. No known legal impediments exist that would restrain the bank from meeting the credit needs of its assessment areas.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

As of December 31, 2017, the bank reported total assets of approximately $31.8 billion, gross loans of $13.1 billion, and a net loan-to-deposit ratio of 48.2%. The following table reflects the loan portfolio mix.

Loan Portfolio

The following table shows the distribution of Frost’s loan portfolio as of December 31, 2015 and 2016. As indicated in the table, Real Estate loans comprised the greatest percentage by dollar volume of Frost’s loan portfolio for the most recent two years. The next highest volume by dollar amount for both years was Commercial and Industrial Loans.

12/31/2017 % of 12/31/2016 % of Product $(000’s) Loans $(000’s) Loans Real Estate 1-4 Family Residential Construction Loans 174,625 1.3 152,240 1.3 Other Construction Loans & Land Development & 1,241,981 9.5 1,222,532 10.2 Other Farm Land 52,169 0.4 36,920 0.3 1-4 Family – Revolving 291,950 2.2 264,863 2.2 1-4 Family Residential Secured by First Liens 421,865 3.2 420,046 3.5 1-4 Family Residential Secured by Junior Liens 405,096 3.1 344,182 2.9 Multifamily 124,074 0.9 93,425 0.8 Nonfarm Nonresidential Loans Secured Owner Occupied Nonfarm 1,169,344 8.9 1,017,546 8.5 Nonresidential Loans Secured by Other Nonfarm Nonresidential 2,443,256 18.6 2,237,909 18.7 Total Real Estate 6,324,360 48.1 5,789,663 48.4 Depository Institutions 2,934 0.0 2,660 0.0 Agricultural 31,735 0.2 19,591 0.1 Commercial and Industrial 5,119,378 39.0 4,750,502 39.7 Consumer 538,388 4.1 467,862 3.9 State and Political Subdivisions 237,047 1.8 167,887 1.4 Other 576,455 4.4 461,998 3.9 Lease Financing 310,747 2.4 314,198 2.6 Gross Loans 13,141,044 100.0 11,974,361 100.0

Product Offerings

Frost offers a wide variety of consumer, residential real estate, and commercial loan products to fulfill the credit needs of the residents and businesses in its assessment areas.

Frost provides a full range of consumer banking products and services, including checking accounts, savings programs, ATM’s, overdraft facilities, drive-in and night deposit services, safe deposit facilities, and brokerage services. Frost also offers a variety of consumer loan products including auto loans, consumer installment loans, personal lines of credit, and lot loans. The bank also offers first and second lien home improvement loans, home equity loans, and home equity lines of credit. The home improvement loans, along with other loans secured by residential real estate, are typically

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION reported under the Home Mortgage Disclosure Act (HMDA). The table above indicates residential real estate loans represent approximately 8.5% of the bank’s lending. Frost does not offer traditional 30-year, first lien mortgages. For those customers wanting a traditional 30-year mortgage, Frost can fulfill those needs through its relationship with Cornerstone Lending, Inc. The majority of Frost’s consumer mortgage loans are second lien mortgages, or “piggy-back” loans, and home equity lines of credit. The home equity lines of credit tend to have competitive rates and flexible loan terms, which many customers find more attractive than the traditional home improvement loan.

Loans secured by commercial real estate and loans for commercial and industrial purpose are the categories of loans from which “loans to small businesses” data is collected and reported under the CRA. Loans are made for a wide variety of general corporate purposes, and commercial loan products include: financing for industrial and commercial properties and, to a lesser extent, financing for interim construction related to industrial and commercial properties, financing for equipment, inventories and accounts receivable, and acquisition financing, as well as commercial leasing and treasury management services. Loans reported under the CRA also include business credit cards, which tend to be for smaller dollar amounts and are often needed by small businesses to meet day- to-day operating expenses. Frost offers credit card loans; however, they are underwritten, originated, and serviced through a third party and not reflected in the bank’s small business loans. Many of the top aggregate lenders within Frost’s assessment areas predominately offer and originate credit card loans, which will make the aggregate lenders’ percentage of small dollar amount loans much higher than lenders which do not originate credit cards loans. As the Summary of Lending Activity table on page nine depicts, Frost did not originate a significant volume of small farm loans during the review period; therefore, these loans are not discussed in this report.

Construction and land development loans may be reportable as community development loans, provided they have a primary purpose that meets the definition of community development under Regulation BB. Multi-family loans may also be reported both under HMDA and as community development loans; however, Frost is not actively engaged in this type of lending and only originated eight multi-family purpose loans during the three- year review period. Based on the preceding information, CRA-reportable loans carried the most significant weight for the purpose of this evaluation.

Frost also acts as a correspondent bank for over 203 financial institutions which are primarily in Texas. These banks maintain deposits with Frost, which offers them a full range of services including check clearing, transfer of funds, fixed income security services, and custody and clearance services.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

Previous Performance Evaluation

The bank received a Satisfactory rating on its previous CRA performance evaluation dated July 13, 2015 performed by the Federal Reserve Bank of Dallas. The lending test was rated High Satisfactory, the investment test was rated Outstanding, and the investment test was rated High Satisfactory.

Scope of Examination

All assessment areas were evaluated for lending, investment, and service performance. Full-scope reviews using the Federal Financial Institutions Examination Council’s (FFIEC) CRA Examination Procedures were conducted for four of the bank’s ten assessment areas. The assessment areas were selected for full-scope reviews based on factors identified in the FFIEC procedures. These include, but are not limited to, the level of the institution’s lending, investments, and service activity as well as opportunities for such in the assessment areas; comments received from community groups and the public regarding the institutions CRA performance; population density; the number of other institutions in the assessment areas; and the length of time since the most recent full scope review. Overall, approximately 60.7% of lending activity (by number of loans), 62.1% of the total deposits, and 60.5% of total branches were evaluated through the full- scope reviews. Descriptions of the assessment areas, listed below, can be found in the applicable assessment area sections of this report.

• Dallas-Plano-Irving, TX MD • Houston-The Woodlands-Sugar Land, TX MSA • San Antonio-New Braunfels, TX MSA • Corpus Christi, TX MSA

Examination Review Period and Products Reviewed

The evaluation period covered January 1, 2015 through December 31, 2017. HMDA and small business data lending for the period January 31, 2015 through December 31, 2017 was evaluated for consistency with the years of data presented in this evaluation. Unless otherwise addressed in the discussion, the bank’s performance for this period was consistent with performance for the years presented.

Community development loans, investments, and service activities from January 1, 2015 through December 31, 2017 were considered during this evaluation. In addition, the evaluation also considered prior period investments. Retail branching activity was reviewed for the period of January 1, 2015 through August 13, 2018.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

Examination Analysis

The evaluation of the bank’s record of lending in the individual assessment areas includes the use of and comparison to demographic characteristics. The primary sources for the demographic information are the 2010 U.S. Census, 2015 U.S. Census estimates, and Dun & Bradstreet (D&B) data. Demographic characteristics of a particular assessment area are useful in analyzing the bank’s record of lending as they provide a means of estimating loan demand and identifying lending opportunities. To understand small business and small farm loan demand, self-reported data of revenue size and geographical location from business and farm entities is collected and published by D&B. The demographic data should not be construed as defining an expected level of lending in a particular area or to a particular group of borrowers. The information is used to understand the bank’s performance context and evaluate the bank.

Loans are evaluated to determine the lending activity inside and outside the bank’s assessment areas. In addition, loans inside the assessment areas are evaluated on the geographic and borrower-income distribution for each assessment area. The bank’s geographic distribution with respect to HMDA loans is assessed by comparing the percentages of loans made in each geography type (low-, moderate-, middle-, and upper- income) to their percentage of owner-occupied units in each geography type. Small business loans are compared to the percentage of small businesses and farms within each geographic income category.

The bank’s borrower income distribution with respect to HMDA loans is assessed by comparing the percentage of loans made to borrowers in each income category (low-, moderate-, middle-, and upper-income) to the percentage of families in each income category. Poverty level is determined by both income and family size. Generally, a larger portion of poverty level families are in the low-income category and, to a certain extent, the moderate-income categories. Borrowers at poverty level often do not qualify for real estate loans, so the percentages of families below the poverty level is considered when evaluating lending performance to LMI borrowers.

The bank’s borrower income distribution with respect to small business loans was assessed by comparing the percentage of loans made to businesses in each revenue category (less than or equal to $1 million, or greater than $1 million) to the percentage of total businesses in each revenue category.

The bank’s lending performance was compared to the performance of aggregate lenders in 2015, 2016, and 2017. Aggregate lenders include all lenders required to report HMDA and CRA data within the respective assessment areas. Commercial credit card loans are included in many aggregate lenders’ CRA loan numbers, which is a product not directly offered by the bank. The bank’s lending performance for HMDA and CRA loans was also compared to demographic numbers within the assessment area for both the geographic distribution and borrower profile analyses and considered when forming conclusions. The bank’s market share of lending is also discussed to provide a better understanding of how

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

the bank ranks within respective areas. For both the geographic distribution and borrower income analyses, the bank’s lending performance was evaluated by dollar amount and percentage by number. Unless otherwise specified, the percentages throughout the performance evaluations represent the bank’s lending by number of loans originated.

In conjunction with the assessment, contact was made outside the bank with individuals, groups, and/or organizations. Examiners conducted a total of nine interviews with community representatives during the review period in order to understand community credit needs. Community contacts were located throughout the assessment areas and included representatives of community-based organizations, municipalities, and quasi- government agencies.

Conclusions With Respect to Performance Tests

Lending Test

The bank’s overall Lending Test rating is High Satisfactory. Lending activity reflects good responsiveness to assessment area credit needs. The geographic distribution of loans reflects excellent penetration throughout the assessment area. In addition, the distribution of borrowers reflects adequate penetration among borrowers of different income levels and businesses of different revenue sizes. Additionally, the bank is a leader in making community development loans.

Community development lending was excellent in the following three full scope assessment areas: Dallas-Plano-Irving, TX, Houston-The Woodlands-Sugar Land, TX, and San Antonio-New Braunfels, TX and good in the Corpus Christi, TX Assessment Area. The San Antonio-New Braunfels, TX MSA had the greatest impact on the lending test due to a higher concentration of deposits, branches, and combined HMDA and CRA small business lending than the other assessment areas.

The bank is both a small business and HMDA lender. During the review period, the bank reported 14,378 (66.9%) small business loans compared to 7,120 (33.1%) HMDA loans. Therefore, small business lending was given more weight than HMDA lending in determining the bank’s Lending Test rating in the assessment area.

References are made to the bank’s lending distribution by geography and borrower income throughout this report. Detailed information about the bank’s HMDA- and CRA- reportable loans can be found in tables in Appendix E for full-scope assessment areas and Appendix F for limited-scope areas.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

Lending Activity

The bank’s lending levels reflects good responsiveness to assessment areas credit needs. The following table summarizes the lending activity from January 1, 2015 through December 31, 2017. As the data indicates, the bank makes more small business loans than other types of loans.

Summary of Lending Activity January 1, 2015 through December 31, 2017 Loan Type # % $000s % HMDA home purchase 1,542 7.2 202,597 4.6 HMDA refinancing 716 3.3 102,397 2.3 HMDA home improvement 4,854 22.5 369,957 8.5 HMDA multifamily 8 0.0 5,637 0.1 Total HMDA-related 7,120 33.0 680,588 15.5 Total small business 14,378 66.8 3,687,020 84.3 Total small farm 36 0.2 7,507 0.2 Total Loans 21,534 100.0 4,375,115 100.0

The table below shows the distribution of loans inside and outside the bank’s assessment areas. A substantial majority of loans are made in the bank’s assessment areas.

Assessment Area Concentration Loan Type Inside Assessment Area Outside Assessment Area # % $000’s % of $ # % $000’s % of $ Home Purchase 1,469 95.3 $186,262 91.9 73 4.7 $16,335 8.1 Home Improvement 4,566 94.1 $352,434 95.3 288 5.9 $17,523 4.7 Refinancing 687 95.9 $99,526 97.2 29 4.1 $2,871 2.8 Multifamily 7 87.5 $2,397 42.5 1 12.5 $3,240 57.5 Total HMDA-related 6,729 94.5 $640,619 94.1 391 5.5 $39,969 5.9 Total Small business 13,588 94.5 $3,449,589 93.6 790 5.5 $237,431 6.4 Total Small farm 25 69.4 $5,933 79.0 11 30.6 $1,574 21.0 Total Loans 20,342 94.5 $4,096,141 93.6 1,192 5.5 $278,974 6.4

Geographic Distribution and Distribution by Borrower Income and Business Revenue Size

The bank’s distribution of lending to borrowers reflects adequate penetration among individuals of different income levels (including low- and moderate-income) and businesses of revenue different sizes. Of the four full-scope assessment areas, two are considered good and two are considered adequate. A detailed discussion of the facts and data supporting the overall conclusions are presented in the Conclusions with Respect to Performance Tests section for each assessment area.

The geographic distribution of loans reflects excellent penetration throughout the assessment areas. Of the four full-scope assessment areas, three are considered

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

excellent and one is considered good. A detailed discussion of the facts and data supporting the overall conclusions are presented in the Conclusions with Respect to Performance Tests section for each assessment area.

The bank offers several programs with the specific purpose of helping to meet housing- related needs of LMI individuals and communities. Some of these include the following:

Progress Home Improvement Loan Program: This program is offered to individuals that are 80% or less of the U.S. Department of Housing and Urban Development (HUD) Family Median Income. Frost offers both a secured and unsecured product, both of which allow for alternative credit sources, such as utility bills, to qualify a loan applicant if no other credit is available. Other features include lower minimum loan amounts, lower monthly payments, and discounts off the current interest rate. The unsecured loan also allows for a debt-to-income ratio of up to 50%, versus 40% for the traditional home improvement loan. These loans are offered in all of Frost’s assessment areas and included in the bank’s HMDA reportable home-improvement loans, which are discussed in further detail in each individual assessment area section of this report.

Frost also offers loan products that are specifically tailored to small businesses, which include the following:

Small Business Partners: Frost partners with other small business lending entities to make small business loans in all of its assessment areas, to create and provide more lending opportunities to small businesses. For example, Frost partners with and serves as a referral source for LiftFund (formally ACCION Texas), the largest micro-lending entity in the United States, and PeopleFund. Both of these organizations are Community Development Financial Institutions (CDFI). LiftFund and PeopleFund make loans to start- up, "mom and pop" shops, or very small businesses, and work with them to become viable small businesses. Frost provides a revolving line-of-credit statewide, provides annual operating funds, and has made referrals to LiftFund. Frost also collaborates with the Small Business Administration (SBA), Small Business Development Centers, Service Corps of Retired Executives (SCORE), Federal Home Loan Bank of Dallas, Chambers of Commerce, local government agencies, and many more entities to provide small business loans and products to small businesses.

Community Development Lending

The bank is a leader in making community development loans. Frost originated, or renewed, 288 community development loans totaling approximately $849.3 million during the three-year review period. Based on the dollar amount, this is a 79.2% increase from the prior evaluation. At the previous evaluation, the bank originated or renewed 128 loans totaling $473.9 million. The largest portion of the community development lending, by dollar amount, was in the San Antonio-New Braunfels, TX ($347.3 million) and the Houston-The Woodlands-Sugar Land, TX ($227.0 million) Assessment Areas. The San

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

Antonio-New Braunfels, TX Assessment Area was given more weight considering this is where Frost has a larger presence.

The community development loans originated during the evaluation period were for a variety of purposes. The majority of the loans were for the purpose of providing community services to individuals or LMI areas and for affordable housing. The table below summarizes the bank’s community development lending.

Community Development Lending Purpose Number $(’000s) Affordable Housing 53 79,887 Community Services 215 572,676 Economic Development 6 103,820 Revitalize and Stabilize 14 92,931 Total 288 849,314

Frost’s community development lending is excellent in the Austin-Round Rock-San Marcos, TX; Brownsville-Harlingen, TX; Dallas-Plano-Irving, TX; Fort Worth-Arlington, TX; Houston-The Woodlands-Sugar Land, TX; and San Antonio-New Braunfels, TX, Assessment Areas. The community development lending in the Corpus Christi, TX and Odessa, TX Assessment Areas was good. There was an adequate level of lending in the Mc Allen-Edinburg-Mission, TX, and Midland, TX Assessment Areas.

As mentioned previously, the San Antonio-New Braunfels, TX Assessment Area had the greatest impact on the community development lending test due to a higher concentration of deposits, branches, and combined HMDA and CRA small business lending than the other assessment areas. More information on community development lending can be found in each full-scope assessment area section.

Investment Test

The bank’s overall Investment Test rating is Outstanding. The bank has an excellent level of qualified community development investments and grants, particularly those not routinely provided by private investors and is often in a leadership position in all ten of its assessment areas. However, the San Antonio-New Braunfels, TX Assessment Area had the greatest impact on the investment test due to a higher concentration of deposits, branches, and combined HMDA and CRA small business lending than the other assessment areas.

Overall the bank had current-period qualified investments totaling approximately $491.7 million during the review period. Frost’s investments demonstrate excellent responsiveness to the most pressing credit and community development needs throughout the assessment areas. Community contacts identified affordable housing, financial literacy, and small business loans as a common opportunity and need. Frost

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION addressed these needs by investing in ten Solomon Hess SBA Funds and one LiftFund investment. These companies make loans to small business owners who have limited access to traditional bank credit. Frost also invested in 48 Ginnie Mae (GNMA) Mortgage Backed Securities (MSBs) targeted to individuals with incomes of less than 80% of the median family income (MFI), 19 general obligation bonds targeted to school districts throughout the bank’s assessment areas that have over 75% of students who are considered economically disadvantaged, and one investment in the Community Development Fund that provides investment opportunities for LMI housing. Frost has been a leader in the purchase of school bonds in the State of Texas for numerous years; however, during the 2015 through 2017 review period, the volume of school bonds available significantly decreased. This is reflected in the decrease in investment totals from the previous evaluations.

The bank also had prior period investments of $42.4 million, which were investments in MSB’s and Small Business Investment Companies (SBIC’s) throughout their assessment areas.

Frost made qualified grants and donations totaling $6.6 million to organizations with a purpose of community development. Donations were given to organizations involved primarily in affordable housing initiatives or providing community services targeted to LMI individuals. Frost also demonstrated excellent responsiveness to community needs by donating $1 million to various agencies in the Houston, Austin, San Antonio, Dallas and Corpus Christi, TX Assessment Areas after Hurricane Harvey – a category 4 storm – made landfall on August 17, 2017. The bank was able to assist the community by obtaining grants benefitting affordable housing and providing funds for the re- establishment of small businesses affected by the hurricane.

By adding new ventures to their investment portfolio, such as the Solomon Hess SBA Fund, the Community Development Fund and a three-year pledge to the Local Initiative Support Collaborative (LISC) the bank has seen a significant increase in the total amount of investments since the previous evaluation. The total amount of current period investments and donations, at $491.6 million, has decreased 16.8% from the previous evaluation in 2015 when the bank had investments and donations totaling $590.7 million.

Service Test

The bank’s overall Service Test rating is High Satisfactory. The bank’s performance is excellent in one and good in three of the full-scope assessment areas. Specific details of the service performance are discussed in the respective assessment area sections of this report.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

Retail Services

Retail delivery systems are accessible to the geographies and individuals of different income levels. During the exam period of January 1, 2015 through August 13, 2018, Frost opened 21 branches and closed 14 branches. A specific listing of the branches that opened or closed during the review period may be obtained by accessing the bank’s CRA public file, which is available on the bank’s web site. Also, refer to the individual assessment areas for details regarding the bank’s distribution of branches and ATMs. Frost’s opening and closing of branches has not adversely affected the accessibility of banking services to LMI geographies. In addition, the banking services and business hours do not vary in a way that inconveniences any portion of the bank’s assessment areas, particularly LMI geographies and individuals. Banking hours are fairly consistent across all areas. Generally, the standard banking hours are Monday through Friday, 9 a.m. to 5 p.m. and Saturdays from 9 a.m. to 1 p.m. Motor banks are usually open from 8:00 a.m. until 6 p.m. on weekdays and on Saturday from 9 a.m. to 1 p.m. The only variation in hours is for those branches that do not have a motor bank or do not offer Saturday hours at the motor bank. These specific branches are distributed throughout the assessment areas and do not vary in a way that inconveniences LMI geographies and/or LMI individuals.

The following table provides the distribution of branches and ATMs throughout Frost’s assessment areas.

Full Service Cash Only Tract % of % of Branches ATMs ATMs Income Geographies Population # % # % # % Low 12.1 9.9 13 9.2 13 8.7 0 0 Moderate 27.6 24.6 26 18.3 25 16.7 0 0 Middle 27.9 29.9 29 20.4 34 22.6 0 0 Upper 31.3 35.3 74 52.1 78 52.0 0 0 Unknown 1.1 0.3 0 0 0 0 0 0 Total 100% 100% 142 100% 150 100% 0 0%

The bank also offers the following no- or low-cost deposit accounts and uses the following alternative delivery systems.

Free and Flexible Checking Accounts: Frost created and introduced a new checking product designated for LMI individuals or individuals living in LMI areas. The product has no minimum balance requirement and is free if the customer has direct deposit of their regular monthly income. If the customer does not have direct deposit, the monthly fee is only two dollars.

Frost also offers a simple, low-cost, checking account product that provides customers with everything they need to manage their money, including free bill pay, external transfers, and mailed paper statements. The basic fee is $5, which Frost will waive if the customer has any one of the following:

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

• $100 total monthly direct deposit • $1,000 minimum daily balance • $5,000 combined average daily balance in personal deposit accounts

Mobile Banking: In some assessment areas, Frost has a mobile banking team that visits senior citizen apartments/living facilities to make deposits and provide cash withdrawals so customers do not have to leave their living environment.

HEB ATMs: Beginning in 1994, Frost partnered with HEB Grocery Stores to offer ATMs in their stores throughout Texas. These ATMs are owned and operated by HEB, but are available to Frost customers free of charge. Currently, there are over 300 ATMs in HEB stores throughout the bank’s assessment areas, or just outside of the bank’s assessment areas. Many of these ATMs are located in LMI areas.

Valero and 7-Eleven Corner Stores: Similar to the HEB partnership, Frost offers free ATM withdrawals to Frost customers at over 600 Valero gas stations and almost 60 7- Eleven Corner Stores in Texas.

Internet Café: All Frost locations have computer terminals available in their branches that provide free online banking to customers who may not have access to a computer, such as LMI individuals.

American Sign Language: Frost continues to offer the DeafLink program, which provides certified American Sign Language (ASL) interpreters to its customers through videoconference and secure, encrypted Internet access. Frost is the first banking institution in the nation to offer real-time accessibility to the deaf and hard-of-hearing community.

Frost at Work Program: This program allows employees of Frost commercial customers to open accounts at their place of employment so workers do not need to take the time to go to the bank. It promotes direct deposit and other products to employees who do not have bank accounts. It is a way to assist corporations in educating their "unbanked" employees on checking accounts and makes it easy for them to begin a banking relationship. The Frost at Work program also provides the option for those without a banking relationship to have a debit card for payroll deposit, ensuring safety and quickness in obtaining access to their payroll. These business clients are offered financial literacy programs to help educate their workforce on the importance of money management, the basics of banking, and the benefits of having a checking account.

As of 2017, over 4,200 companies participate in the Frost at Work program, over 31,000 accounts have been opened since the program started, and 24% of Frost at Work customers who opened accounts live in LMI census tracts.

VITA Check Cashing: Volunteer Income Tax Assistance (VITA) provides LMI individuals with free tax assistance in completing their federal taxes by certified tax preparers. Frost

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION

employees assisted in this free tax preparation and served on committees that sponsor VITA. These tax preparers also assist in obtaining the earned income tax credit (EITC) and other tax allowances. VITA not only provides a direct service to the individual, but also puts money back into the local economies.

Free Loan Servicing: Frost provides free loan servicing for all San Antonio Habitat for Humanity mortgage loans. In 2015, over 700 loans were serviced at no charge and by 2016 and 2017 that number increased to 825 and 862 loans, respectively.

Community Development Services

Frost is a leader in providing community development services throughout its assessment areas. Frost provided 43,140 hours of community development services during the review period. Community development services are excellent in all ten assessment areas. Overall, the bank is a leader in providing community development services that benefit LMI residents and small businesses within the assessment areas.

The bank’s directors, officers, and staff members are involved in numerous organizations and activities that promote or facilitate affordable housing for LMI individuals, services for LMI individuals, economic development, and revitalization of LMI areas, along with financial literacy outreach efforts. In addition, Frost has created the following programs to provide financial literacy to LMI students, individuals, and small businesses.

Home Improvement Mini-Expo: In 2013, Frost created the Mini-Expo to assist LMI homeowners in the areas of home improvement “how-to” tips, teaching about home improvement loan options, how they work, how to choose a contractor, and home improvement subsidy programs available to homeowners. These seminars are specifically targeted to LMI homeowners and are held in a community center, or place, located in an LMI census tract. In 2016, the majority of the assessment areas introduced the Mini-Expo, except for Brownsville, TX and Permian Basin assessment areas. By 2017, Brownsville and Odessa were the only two assessment areas that did not host a mini-expo. Frost collaborates with the local government, contractors, utility and water companies, and non-profit organizations in the housing sector. The Mini-Expo brings many services together to offer LMI homeowners a “one-stop shop.” This event is innovative and responsive to community needs.

Frost Financial Youth Academy: Frost developed the Frost Financial Youth Academy to provide financial education and products to high school juniors and seniors at schools that have a majority of LMI students. Currently, Frost employees offer the program at seven schools in seven assessment areas.

Small Business Outreach Program: The Frost Small Business Outreach Program includes a literacy program, targeted products, and other materials used to further promote small business lending. The outreach/literacy program provides insight as to what a commercial bank expects from a small business. It explains the reasons a bank

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 INSTITUTION needs certain requested information and discusses what a banker looks for in a loan request. It also details the importance of a business plan and maintaining updated financials. To complement the outreach program, a "Borrowers Guide for Small Business and Entrepreneurs" was developed. This guide is also provided to local Small Business Development Centers (SBDC), LiftFund, and handed out at business expos and working sessions as a tool for small businesses.

The bank also collaborates with varying organizations throughout all its assessment areas to provide financial literacy training to small businesses. Frost works with each non-profit or entity to understand its particular needs, and the financial literacy training is then customized to fit each individual organization. The organizations work specifically with small businesses, creating an opportunity for Frost to provide financial literacy training to large audiences.

Please refer to the individual assessment areas for examples of other community development services provided by the bank during the review period.

Fair Lending or Other Illegal Credit Practices Review

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) established the Consumer Financial Protection Bureau (CFPB). In general, the Dodd-Frank Act gives the CFPB, among other things, primary supervisory authority over insured depository institutions with total assets of more than $10 billion when assessing compliance with the requirements of Federal consumer financial laws. The Federal Reserve System retains authority to enforce compliance with the CRA and certain other consumer compliance laws and regulations. During the review period of this evaluation, the Federal Reserve Bank of Dallas did not cite violations involving illegal discrimination or other illegal credit practices that adversely affected the evaluation of the bank’s CRA performance. As of the date of this evaluation, the Federal Reserve Bank of Dallas is unaware of any violations of the Equal Credit Opportunity Act or Regulation B, or any unfair, deceptive, or abusive acts or practices identified by the CFPB.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

METROPOLITAN AREAS (Full Scope Review)

Description of Operations in the Dallas-Plano-Irving, TX Assessment Area

The Dallas-Plano-Irving, TX Assessment Area includes in its entirety Collin, Dallas and Denton counties. These counties, along with Ellis, Hunt, Kaufman, and Rockwall, which are excluded from the assessment area, make up the Dallas-Fort Worth- Arlington (DFW) Metropolitan Division (MD). As of 2015, within the assessment area portion of the MD, there are 115 low-, 218 moderate-, 189 middle-, and 290 upper-income census tracts. There are also six census tracts where income is unknown. As of December 31, 2017, Frost operated 15 branches in the assessment area representing 10.6% of its branches. There are two branches in the low-income census tracts, three branches in the moderate- income census tracts, two in the middle-income census tract and eight in the upper- income census tracts.

Certain economic and demographic data is available for analysis for the DFW MD as a whole and not the specific assessment area. However, it is reasonable to believe the data for the MD provides a good representation of the characteristics of the assessment area because the population of the assessment area includes 90.3% of the DFW MD and distribution of low-, moderate-, middle-, and upper income families for the assessment and MD are similar according to the 2015 census data.

According to the 2015 Census, the assessment area population was 4,079,069 which accounts for 15.4% of the population in the state. Based on the 2010 population of 3,811,502, the assessment area has experienced an increase of 7.0 % over the last five years. Dallas, the largest city within the assessment area, and the 3rd largest city in the State of Texas, accounts for 32.9% of the population in the assessment area. The following table provides further information by county.

% 2015 Increase County Population Major Municipalities Since Estimate 2010 Collin 862,215 10.2% McKinney (County Seat), Plano

Dallas 2,485,003 5.0% Dallas (County Seat)

Denton 731,851 10.5% Denton (County Seat)

According to the FDIC, as of June 30, 2017, the bank had $2.0 billion in deposits in this assessment area, representing 7.8% of the bank’s total deposits. It also represents a deposit market share of 0.94%, which includes all other FDIC-insured deposits that are located in the assessment area. Bank of America, N.A. holds the largest deposit share 17

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

at 33.5%, followed by JPMorgan Chase Bank, N.A., at 23.0%, and Texas Capital Bank, N.A., at 6.0%. Many of the bank’s competitors are statewide and multi-regional banks, but competition does not appear to have adversely affected the bank’s ability to serve the credit needs of its assessment area, specifically in regards to small business or HMDA lending.

The bank originated 1,551 HMDA reportable loans in 2015, 2016, and 2017, which represent 21.8% of total HMDA lending. The bank ranked 68th out of 876 institutions in 2015, 66th out of 895 institutions in 2016, and 57th out of 874 institutions in 2017 in the origination of HMDA reportable loans. The top ranked reporters were Wells Fargo Bank, N.A., JPMorgan Chase Bank, N.A., and Quicken Loans.

The bank originated 1,639 small business loans in 2015, 2016, and 2017, which represented 11.4% of its total small business lending. The bank ranked 19th throughout the three year review period out of 191 institutions in 2015, 208 institutions in 2016, and 221 institutions in 2017. The top ranked reporters were American Express Bank, FSB; Chase Bank USA, N.A.; and Citibank, N.A.

Demographic Characteristics

As mentioned previously, The Dallas-Plano-Irving, TX MD is part of the Dallas-Fort Worth- Arlington, TX MSA also referred to as the Dallas-Fort Worth or DFW Metroplex. The DFW Metroplex is the economic and cultural hub of North Texas, and it is the largest inland metropolitan area in the United States. According to the 2017 Census, it is the largest metropolitan area in Texas and the fourth largest in the United States.

The Dallas-Plano-Irving, TX Assessment Area is bordered on the east and southeast by Hunt and Rockwall counties and to the south by Kaufman and Ellis counties, which make up the rest of the Dallas-Plano-Irving, TX MD. To the north are Cooke County, which is part of the Gainesville, TX MSA, and Grayson County, which is included in the Sherman- Denison, TX MSA. As of 2015, the assessment area consists of 818 census tracts, including 115 low-income and 218 moderate-income tracts making up 40.7% of the assessment area census tracts. There are also 189 (23.1%) middle-income, and 290 (35.5%) upper-income tracts as well as six census tracts (0.7%) where the income is unknown.

Income Characteristics For purposes of classifying borrower income, this evaluation uses both 2010 U.S. Census data and 2015 estimated data for the relevant area. The following chart reflects the estimated median family income for the years 2015 through 2017 for the Dallas-Plano- Irving, TX MD. It also provides a range of the estimated annual family income for each income category (low, moderate, middle, and upper). According to the 2015 Census, 11.7% of the families in the assessment area lived below the poverty level.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

Income Level 2015 2016 2017 Median Income $70,500 $71,700 $73,400 Low-income < $35,250 < $35,850 < $36,700 Moderate-income $35,251 - $56,400 $35,851 - $57,360 $36,701 - $58,720 Middle-income $56,401 - $84,600 $57,361 - $86,040 $58,721 - $88,080 Upper-income ≥ $84,601 ≥ $86,041 ≥ $88,081

Housing Characteristics

The median price of a home in Dallas-Plano-Irving, TX Assessment Area appreciated 19.6% from $231.5 thousand in 2015 to $277 thousand in 2017. The dollar volume of sales has increased 24.7% from $17.8 billion in 2015 to $22.2 billion in 2017. According to data from the Real Estate Center at Texas A&M University, the median housing price in the Dallas-Plano-Irving, TX MD has steadily increased during the review period. The median housing price for homes in January 2015 was $205 thousand and rose to $280 thousand by December 2017, a 36.6% increase. In DFW, an average of 58,490 building permits for newly privately owned housing units were issued each year from 2015 to 2017.1

During the review period, the Dallas-Plano-Irving, TX MD has fared well in terms of mortgages considered seriously delinquent (defined as more than 90 days past due or in foreclosure) compared to many metropolitan areas in the country, which range from 0.2% to 6.9% throughout the nation as of December 2017. The delinquency rate for seriously delinquent mortgages for the MD was Denton and Collin Counties at 0.5% and Dallas County at 1.2%, respectively, which is comparable to the national average of 1.0%.2

According to the 2015 Census, there were 1,558,907 housing units in the assessment area with 52.6% of the units classified as owner-occupied, while 40.0% are classified as rental units, and 7.3% of the available housing is vacant. Just over a majority of the assessment area’s housing units are owner occupied; however, rental units make up 53.6% of housing in LMI tracts. This limits the opportunities for mortgage originations in these tracts.

Overall, 13.2% of the housing stock in the assessment area is in low-income tracts. In these census tracts, 22.6% of the housing units are owner-occupied, 64.6% are rental units, and 12.9% are vacant. The 2010 median age of housing stock in these tracts is 36 years and the median housing value in low-income tracts for the assessment area, also in 2010, was $78.9 thousand. By 2015, this number had decreased to $77.9 thousand,

1Real Estate Center at Texas A&M University. Home Sales MSA: Dallas-Plano-Irving. Available at: https://www.recenter.tamu.edu/data/housing-activity/#!/activity/MSA/Dallas-Plano-Irving. Accessed: Sept. 14, 2018.

2 Consumer Financial Protection Bureau (CFPB) Mortgages 90 or more days delinquent. Available at https://www.consumerfinance.gov/data-research/mortgage-performance-trends/mortgages-90-or-more-days- delinquent/#mp-line-chart-container. Accessed Sept. 18, 2018. 19

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

which is a 1.3% decrease. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed-rate, 30 year loan, a home of this value would still be considered affordable for a low-income family, although a barrier to homeownership is typically a down payment. The monthly rental payment in low-income tracts in 2015 was $755, which is less affordable than the monthly mortgage payment of $382 for an $80 thousand home for 30 years at 4.0% interest rate. However, 31.0% of families in low-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

Moderate-income tracts account for 24.9% of the housing stock in the assessment area. In these census tracts, 44.1% of the housing units are owner-occupied, 47.8% are rental units, and 8.1% are vacant. The median age of housing stock in these tracts is 37 years and the median housing value in moderate-income tracts for the assessment area in 2010 was $96.8 thousand. By 2015, this number had increased to $97.6 thousand, which is a 0.8% increase. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed- rate, 30 year loan, a home of this value would be affordable for a moderate-income family, although a barrier to homeownership is typically a down payment. However, 39.2% of families in moderate-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

Approximately 25.5% of the housing stock in the assessment area is in middle-income tracts. In these census tracts, 53.4% of the housing units are owner-occupied, 40.0% are rental units, and 6.6% are vacant. In 2015, the median age of housing stock in these tracts is 34 years and 17.5% of families in middle-income tracts have incomes below the poverty level. The median housing value in middle-income tracts for the Dallas-Plano- Irving, TX Assessment Area in 2010 was $134.8 thousand. By 2015, this number had increased to $147.5 thousand, which is a 9.4% increase.

The largest portion of housing stock in the assessment area, at 36.2%, is in upper-income tracts. In these census tracts, 69.1% of the housing units are owner-occupied, 25.4% are rental units, and 5.3% are vacant. In 2015, the median age of housing stock in these tracts is 26 years and only 12.0% of families in upper-income tracts have incomes below the poverty level. In addition, the median housing value in upper-income tracts for the assessment area in 2010 was $225.6 thousand. By 2015, this number had increased to $252.9 thousand, which is a 12.1% increase.

Employment and Economic Conditions The national average unemployment rates for 2015, 2016 and 2017 were 5.3%, 4.9% and 4.4%, respectively. Unemployment rates for all of the counties in the assessment area were lower than the annual unemployment rates for Texas and the national average. According to the 2010 Census, in the assessment area the unemployment rate was 11.5% in low-income tracts and 8.7% in moderate-income tracts. By 2015, the unemployment rate had decreased to 10.5% and 8.5% in low- and moderate-income

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

tracts, respectively. The high unemployment rates in LMI tracts could affect loan demand from these tracts.

The following chart shows unemployment rates relevant to the assessment area for 2015, 2016, and 2017.

Annual Average Unemployment Rate3 AREA 2015 2016 2017 Collin County 3.6% 3.5% 3.4% Dallas County 4.3% 4.0% 3.8% Denton County 3.6% 3.4% 3.3% Dallas, TX MD 4.0% 3.8% 3.6% State of Texas 4.4% 4.6% 4.3% United States 5.3% 4.9% 4.4%

The Dallas MD is home to many corporate headquarters, including more than 19 Fortune 500 companies, including Exxon-Mobil Corp., AT&T Inc., and J.C. Penney Company, Inc. Total employment in the area is approximately 2.6 million as of 2017, representing an 11.7% increase from 2014.4 The professional and business services sector is the largest employment sector in the region, representing 18.8%. Another leading sector in the area is education and health services. Dallas MD is an important hub for healthcare and education and is home to numerous hospitals, medical research facilities and universities. Baylor Scott and White Health is the top employer in the region with more than 10,000 employees in the education and health services sector. Lastly, the region benefits from the Dallas-Fort Worth Airport (DFW); it is the 4th busiest airport in the world and a major economic engine for the region.

Community Contacts and Community Development Opportunities

Contact was made with two community leaders working in the economic development sector. The first contact stated the top three needs in Dallas County are special financing considerations for non-profits and small businesses, grants and fundraiser assistance, as well as bank participation.

The second contact stated private funding is needed specifically to start projects or programs in which funding for projects can be reimbursed immediately to allow for future

3 Bureau of Labor Statistics: Local Area Unemployment Statistics. http://www.bls.gov/data/#unemployment Accessed: September 20, 2018. 4 Friedman, Edward. "Dallas-Plano-Irving TX" Précis U.S. Metro. Moody's Analytics, November 2017. Web. 20 April 2018. https://www.economy.com/precismetro 21

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX builds. The contact also stated there is a need for anchor grocery stores, brick and mortar banks, as well as deposit taking ATMs.

Key Assessment Area Demographics

The following table details selected characteristics of the assessment area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

Combined Demographics Report Assessment Area: Dallas Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 115 14.1 107,421 10.9 35,772 33.3 237,003 24 Moderate-income 218 26.7 240,867 24.4 45,206 18.8 161,816 16.4 Middle-income 189 23.1 249,375 25.3 20,161 8.1 170,203 17.3 Upper-income 290 35.5 386,782 39.2 13,910 3.6 416,911 42.3 Unknown-income 6 0.7 1,488 0.2 273 18.3 0 0 Total Assessment Area 818 100.0 985,933 100.0 115,322 11.7 985,933 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 205,191 46,378 5.7 22.6 132,262 64.5 26,551 12.9 Moderate-income 387,796 171,197 20.9 44.1 185,354 47.8 31,245 8.1 Middle-income 397,179 212,137 25.9 53.4 158,816 40 26,226 6.6 Upper-income 563,831 389,502 47.5 69.1 144,354 25.6 29,975 5.3 Unknown-income 4,910 1,248 0.2 25.4 3,133 63.8 529 10.8 Total Assessment Area 1,558,907 820,462 100.0 52.6 623,919 40.0 114,526 7.3 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 15,160 7.7 13,005 7.4 2,083 11.6 72 4 Moderate-income 39,252 20 34,395 19.5 4,620 25.7 237 13.3 Middle-income 48,524 24.7 43,638 24.7 4,495 25 391 22 Upper-income 91,836 46.8 84,479 47.9 6,288 35 1,069 60 Unknown-income 1,466 0.7 954 0.5 500 2.8 12 0.7 Total Assessment Area 196,238 100.0 176,471 100.0 17,986 100.0 1,781 100.0 Percentage of Total Businesses: 89.9 9.2 .9 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 54 3.5 51 3.4 3 11.5 0 0 Moderate-income 159 10.3 153 10.1 6 23.1 0 0 Middle-income 488 31.6 482 31.7 6 23.1 0 0 Upper-income 837 54.2 827 54.4 10 38.5 0 0 Unknown-income 7 0.5 6 0.4 1 3.8 0 0 Total Assessment Area 1,545 100.0 1,519 100.0 26 100.0 0 .0 Percentage of Total Farms: 98.3 1.7 .0 2017 FFIEC Census Data and 2017 D&B Information 23

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

Conclusions With Respect to Performance Tests

Lending Test

The bank’s lending performance is good. Lending activity reflects good responsiveness to assessment area credit needs. The geographic distribution of loans reflects good penetration throughout the assessment area. In addition, the distribution of borrowers reflects adequate penetration among borrowers of different income levels and businesses of different revenue sizes. Additionally, the bank is a leader in making community development loans.

The bank is both a small business and HMDA lender. During the review period, the bank reported 1,639 (51.4%) small business loans compared to 1,551 (48.6%) HMDA loans in the Dallas-Plano-Irving, TX Assessment Area. Therefore, small business lending was given more weight than HMDA lending in determining the bank’s Lending Test rating in the assessment area.

Details of the bank’s mortgage and small business lending and information regarding lending by peers can be found in Appendix E.

Lending to Borrowers of Different Income Levels and Businesses of Different Sizes

The bank’s distribution of lending to borrowers reflects an adequate penetration among individuals of different income levels (including low- and moderate-income) and businesses of different revenue sizes.

The distribution of the remainder of bank lending to middle- and upper-income borrowers did not affect conclusions about the bank’s performance considering its lending to low- and moderate-income borrowers.

HMDA Lending HMDA lending by borrower income in the assessment area is considered adequate when compared to demographic characteristics of the community, as well as the performance of aggregate HMDA lenders with loan originations or purchases in the assessment area.

Frost’s HMDA lending to low-income borrowers is adequate. In 2015 and 2016, the bank originated 0.6% and 1.5%, respectively, of its total HMDA loans to low-income borrowers, which was below the total HMDA loans originated by the aggregate at 3.4% and 3.0%, respectively. In 2017, the bank originated 1.5% of HMDA loans to low-income borrowers, which was slightly below the aggregate at 3.2%. Low-income families made up 23.3% of total families in the assessment area in 2015 and 2016 and 24.0% in 2017, meaning that both the bank and aggregate lending were below demographics and both struggled to make HMDA loans to low-income borrowers in the Dallas, TX Assessment Area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

The bank’s HMDA lending to moderate-income borrowers is poor. In 2015 and 2016, the bank originated 2.3% and 6.1%, respectively, of its total HMDA loans to moderate-income borrowers, which was below the aggregate HMDA lenders who originated 10.4% of HMDA loans to moderate-income borrowers in both 2015 and 2016. In 2017, the bank was also below aggregate, originating 2.9% of HMDA loans to moderate-income borrowers as compared to aggregate lenders who originated 11.2% of HMDA loans to moderate-income borrowers. Both the bank and the aggregate HMDA lenders were below the demographics with 16.5% in both 2015 and 2016, and 16.4% in 2017 of families in the assessment area classified as moderate-income.

Small Business Lending

Considering the bank’s performance when compared to the aggregate, the borrower distribution of small business loans by revenue size of businesses is adequate. Of the 1,639 small business loans originated during the review period by Frost, 36.5%, 36.4%, and 39.4% were originated to small businesses in 2015, 2016, and 2017, respectively. Frost’s performance was only slightly below aggregate which originated 49.3%, 42.5% and 47.3% of loans to small business in 2015, 2016, and 2017, respectively. This is less than the percentage of businesses with annual gross revenues of $1 million or less at 90.8% in 2015 and 2016 and 89.9% in 2017 in the Dallas-Plano-Irving, TX Assessment.

Another way to gauge the bank’s small business lending performance is to review the data by loan amount. Small businesses typically require smaller dollar credits. In this regard, it is noted that 31.4% and 34.4% of the bank’s commercial loans were made in loan amounts of $100 thousand or less in 2015 and 2016, and 35.1% in 2017. Frost’s performance was below the aggregate performance in all three years. However, many of the largest small business lenders in the assessment area offer small dollar credit cards, a credit product not offered by Frost.

Geographic Distribution of Loans

For this analysis, the geographic distribution of small business lending and HMDA lending, including both originations and purchases, was compared with available demographic information. Performance context issues and aggregate lending data were taken into consideration. Considering all of these factors, the bank’s geographic distribution of loans reflects good penetration throughout the assessment area. Loans were generally made in close proximity to the bank’s branches and there were no conspicuous gaps or anomalies in the lending patterns.

The distribution of the remainder of bank lending in middle- and upper- income geographies did not affect conclusions about the bank’s performance considering its lending in low- and moderate-income geographies.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

HMDA Loan Geographic Distribution

The geographic distribution of HMDA loans reflects poor penetration throughout the assessment area. This was based on performance compared to demographics, taking into consideration the performance of the aggregate lenders.

Home Purchase Lending Home purchase lending in low-income census tracts is adequate. During the review period, Frost originated six loans in low-income tracts. This accounts for four in 2015 at 2.6%, one in 2016 at 0.7%, and one in 2017 at 0.6%. As of 2015 and 2016, 5.4% of the owner-occupied units in the assessment area were located in low-income census tracts. In 2017, the number of owner-occupied units slightly increased to 5.7%. Aggregate lenders also struggled to originate home purchase loans in low-income tracts at a level comparable to the percentage of owner-occupied units located in those tracts. During the review period, aggregate lenders originated 2.3%, 2.9%, and 4.0% in 2015, 2016, and 2017, respectively. Frost’s performance was comparable to the aggregate in 2015, but below the aggregate in 2016 and 2017. The nominal level of originations in the low- income tracts could indicate a low level of demand.

Home purchase lending in moderate-income tracts is poor. In 2015, 2016, and 2017, Frost originated 2.6%, 4.1%, and 1.9% of its home purchase loans in moderate-income census tracts, respectively, which contained 19.4% of owner-occupied units in the assessment area in 2015 and 2016 and increased to 20.9% in 2017. The aggregate’s performance during the review period was also below the percentage of owner-occupied homes in moderate-income tracts and only originated 10.3%, 10.8%, and 12.9% of loans in moderate-income tracts in 2015, 2016, and 2017, respectively. Overall, Frost’s performance was below the aggregate lenders during the review period.

Home Refinance Lending Home refinance lending in low-income census tracts is poor. During the review period, the bank did not originate any home refinance loans to low-income borrowers. The aggregate lenders were able to originate 1.6%, 1.7%, and 2.3% in 2015, 2016, and 2017, respectively. In 2015 and 2016, only 5.4% of total owner-occupied units in the assessment area were located in low-income areas. In 2017, it slightly increased to 5.7%. Both Frost and the aggregate originated fewer loans than the percent of owner-occupied units in the Dallas-Plano-Irving, TX Assessment Area.

Frost’s home refinance lending in moderate-income census tracts is poor. During the review period, 2015 through 2017, Frost originated only one loan in 2016 at 3.3%. As mentioned previously, in 2015 and 2016, 19.4% of total owner-occupied units in the assessment area were located in moderate-income areas and increased to 20.9% in 2017. Aggregate lenders originated 8.8%, 8.6%, and 13.6% in 2015, 2016, and 2017, respectively. Both Frost and the aggregate originated significantly fewer loans than the number of owner-occupied units in the assessment area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

Home Improvement Lending Home improvement lending in low-income census tracts is adequate. During the review period, 2015 through 2017, Frost originated 1.4%, 2.0%, and 2.1%, respectively, of its home improvement loans in low-income census tracts, which contained 5.4% of owner- occupied units in 2015 and 2016 and 5.7% in 2017. The aggregate originated 2.4%, 1.8%, and 2.6% of home improvement loans in low-income census tracts in 2015, 2016, and 2017, which is comparable to Frost’s performance.

Frost’s home improvement lending in moderate-income census tracts is poor when compared to the percentage of owner-occupied units in these tracts. During the 2015, 2016, and 2017 review period, Frost originated 3.9%, 9.3% and 5.1%, respectively, of its home improvement loans in moderate-income census tracts, which contained 19.4% of owner-occupied units in the assessment area in 2015 and 2016 and increased to 20.9% in 2017. The aggregate originated 10.3%, 9.3%, and 13.2% of home improvement loans in moderate-income tracts in 2015, 2016, and 2017, respectively. Frost’s performance was below aggregate in 2015 and 2017, but comparable in 2016.

Small Business Loan Geographic Distribution

The geographic distribution of small business loans reflects excellent penetration throughout the assessment area. This was based on performance compared to demographics, taking into consideration the performance of the aggregate lenders.

Frost’s small business lending in low-income census tracts is excellent. In 2015, 2016, and 2017, Frost originated 13.2%, 12.6%, and 11.2% of its small business loans in low- income tracts, respectively, which contained 7.6% of small businesses in the assessment area in 2015 and 2016, and slightly decreased to 7.4% in 2017. In addition, the bank outperformed the aggregate lenders during the review period, which originated 8.6%, 8.0%, and 7.8% of loans to businesses located in low-income areas in 2015, 2016, and 2017, respectively.

Frost’s small business lending in moderate-income tracts is excellent. Frost originated 22.6%, 22.4%, and 24.8% of its small business loans in moderate-income census tracts in 2015, 2016, and 2017, respectively. The moderate-income tracts contained 17.2% of small businesses in the assessment area in 2015 and 2016 and increased to 19.5% in 2017. The bank’s performance was better than the aggregate during the review period which originated 17.1%, 16.8%, and 19.3% of loans to businesses located in moderate- income tracts in 2015, 2016, and 2017, respectively.

The bank’s small business lending in middle- and upper-income tracts was lower than the percentage of small businesses in these tracts. When compared to the aggregate by percentage, the bank originated fewer loans in middle- and upper-income tracts from 2015 through 2017 than the aggregate.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

Community Development Lending

Frost is a leader in making community development loans in the Dallas-Plano-Irving, TX Assessment Area. The bank’s commitment to making qualified community development loans demonstrates excellent responsiveness to meeting community needs. The bank originated 30 community development loans totaling $90.6 million during the review period. This is a 554.3%, by dollar, increase from the previous evaluation in 2015 when Frost originated seven community development loans totaling $13.8 million. The table below provides a breakdown of the types of community development loans originated by Frost during the review period.

Community Development Lending Purpose # $000s Affordable Housing 5 $2,324 Community Services 22 $82,389 Economic Development 0 $0 Revitalization and Stabilization 3 $5,867 Totals 30 $90,580

The majority of community development loans that provided community services were to serve LMI individuals suffering from physical and mental disabilities, homelessness, poverty, and provide health care assistance to LMI individuals. The purpose of the three revitalization and stabilization loans were for the re-development of a retail outlet in a low- income part of Dallas that has been designated as a Food Desert by the USDA and participation in the “Grow South Dallas,” a city-wide economic development plan for the area, which is a low-income area. The purpose of the five affordable housing loans was for the purchase and rehab of a housing project for LMI individuals, and the completion of a building where programs and services are offered to LMI clients.

Investment Test The Investment Test rating is Outstanding. The bank has an excellent level of qualified community development investments and grants, particularly those not routinely provided by private investors, is often in a leadership position, and exhibits excellent responsiveness to credit and community development needs. Overall, the total amount of investments for the review period was $50.0 million, which included prior period investments of $4.3 million. As shown in the table below, the bank’s investments were primarily focused on GNMA mortgage-backed securities targeted to LMI borrowers, general obligation bonds targeted to school districts where over 75% of students are economically disadvantaged, and a new investment into the Solomon Hess SBA fund. Frost was also the first to invest in the Community Development Fund in Dallas, a new market fund which provides investment opportunities for LMI housing. Frost’s investments in affordable housing are responsive to assessment area needs as affordable housing shortages in Dallas remain a challenge and continue to increase. Cuts

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX

in affordable housing and increased requirements to qualify for mortgages have affected LMI communities by making home ownership difficult.

Frost’s level of investments has decreased 66.7% from the previous evaluation. Frost is the largest purchaser of school bonds in Texas; however, for this evaluation period the investment in school bonds significantly decreased from the previous evaluation due to lack of availability.

The bank also made 40 donations totaling $345 thousand. The majority of the donations involved community services targeted to LMI individuals. However, the bank also donated to organizations that provide services, including loans, to small businesses. Some of these organizations include: PeopleFund and LiftFund.

During the Hurricane Harvey disaster in 2017, Frost donated $100 thousand to the North Texas Food Bank, which provided assistance as a designated disaster shelter for hurricane victims. This was part of the bank’s overall $1 million commitment to Hurricane Harvey Relief events throughout the State of Texas.

Community Development Investments Current Period Donations Total Investments Purpose # $ # $ # $ Affordable Housing 7 $25,897,325 3 $15,000 10 $25,912,325 Community Services 3 $19,280,000 29 $217,750 32 $19,497,750 Economic Development 2 $469,594 8 $112,350 10 $581,944 Revitalization and 0 0 0 0 0 0 Stabilization Total 12 $45,646,919 40 $345,100 52 $45,992,019

Service Test

The bank’s Service Test performance is good. The retail services reflect good responsiveness to the needs of the assessment area; however, the bank’s community development services reflect excellent responsiveness to the needs in the assessment area.

Retail Services

The bank’s delivery systems are accessible to the bank’s geographies and individuals of different income levels in its assessment area. The distribution of the bank’s 15 branch offices and 15 full service ATMs as of December 31, 2017, was compared to the distribution of households and businesses among the tract categories within the

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX assessment area. The table below summarizes the bank’s retail locations in the Dallas- Plano-Irving assessment area.

Full Service Cash Only % of % of Branches Tract Income ATMs ATMS Geographies Population # % # % # % Low 14.1 12.3 2 13.3 2 13.3 0 0 Moderate 26.7 24.7 3 20.0 3 20.0 0 0 Middle 23.1 25.7 2 13.3 3 20.0 0 0 Upper 35.4 37.0 8 53.4 7 46.7 0 0 Unknown 0.7 0.3 0 0 0 0 0 0 Total 100 100 15 100 15 100 0 0

The bank opened four branches (two in a moderate-income tract, one in a middle-income tract, and one in an upper-income tract) and closed one branch (in an upper-income tract) in the assessment area. The bank's record of opening or closing branches has not adversely affected the accessibility of its delivery systems, including to LMI income geographies. Banking services and hours of operations do not vary in a way that inconveniences the assessment area, particularly in LMI geographies or to LMI individuals. The level of branch services and hours offered are basically the same throughout the assessment area.

Community Development Services

The bank is a leader in providing community development services in the assessment area. The bank’s employees served in many various capacities, including boards of directors and as trustees, for 110 community development financial organizations offering community development services that focus on business development, education, youth- services, and other community services that aid LMI individuals. Total hours served during the review period was approximately 4,116 hours. The table below shows the number of hours by type of involvement.

Purpose Hours Served Affordable Housing 41 Benefits LMI Individuals/Geographies 3,783 Revitalize/Stabilize 0 Provides Economic Development 292 Total 4,116

Particularly responsive is the bank’s involvement throughout the assessment area in providing financial literacy through programs like Frost’s Financial Youth Academy to schools with a majority of students who are considered economically disadvantaged. In addition, the bank introduced the Frost Home Improvement Mini-Expo, which is an event held to provide LMI homeowners information on city programs and services currently available, as well as assistance programs provided by the local utility companies for LMI

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Dallas-Plano-Irving, TX residents. There are also “how to” sessions on home maintenance and home repair and information on how to choose a reputable remodeler. These events partner with local government entities, water and electric utilities, and non-profits. These seminars are targeted to LMI homeowners and are held in a center, or place, located in an LMI census tract. Frost employees also collaborated with PeopleFund, which promotes economic development by providing existing and start-up businesses with access to flexible lending products, by presenting Frost’s Small Business Outreach seminars to small businesses.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

METROPOLITAN AREAS (Full Scope Review)

Description of Operations in the Houston-The Woodlands-Sugar Land, TX Assessment Area

The Houston- The Woodlands-Sugar Land, TX Assessment Area includes Brazoria, Fort Bend, Galveston, Harris, and Montgomery Counties, hereafter referred to as the Houston, TX Assessment Area. These counties, along with Austin, Chambers, Liberty, and Waller Counties, which are excluded from the assessment area, make up the Houston-The Woodlands -Sugar Land, TX Metropolitan Statistical Area (MSA). As of 2017, within the assessment area portions of the MSA, there are 158 low-, 302 moderate-, 258 middle-, and 312 upper-income census tracts. There are also nine census tracts where the income is unknown. As of December 31, 2017, the bank operated 33 branches in the assessment area representing 23.2% of its total bank branches. There are three branches located in low-income census tracts, nine branches in moderate-income census tract, two in middle- income census tracts, and 19 branches in upper-income census tracts.

According to the 2015 Census, the assessment area population was 6,157,183, which accounts for 23.2% of the population in the State of Texas. Based on the 2010 population of 5,424,937, the assessment area has experienced an increase of 13.5% over the last five years. Houston, the largest city within the assessment area, and the largest city in the State of Texas, accounts for 37.3% of the population in the assessment area. The following table provides further information.

% 2017 Increase County Population Major Municipalities Since Estimate 2010 Brazoria 362,457 15.8% Pearland (Angleton County Seat)

Fort Bend 764,828 30.8% Sugarland (Richmond County Seat)

Galveston 335,036 15.0% League City (Galveston County Seat)

Harris 4,652,980 13.7% Houston (County Seat)

Montgomery 570,934 25.3% Conroe (County Seat)

According to the FDIC, as of June 30, 2017, the bank had $4.4 billion in deposits in this assessment area representing 17.2% of the bank’s total deposits. It also represents a deposit market share of 1.9%, which includes all other FDIC-insured deposits that are

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

located in the assessment area. JPMorgan Chase Bank, N.A. holds the largest deposit share at 43.5%, followed by Wells Fargo Bank, N.A., at 10.8 %, and Bank of America, N.A., at 8.6 %. Many of the bank’s competitors are statewide and multi-regional banks, but competition does not appear to have adversely affected the bank’s ability to serve the credit needs of its assessment area, specifically in regards to small business or HMDA lending.

The bank originated 1,335 HMDA reportable loans in 2015, 2016, and 2017, which represents 18.9% of its total HMDA lending. The bank ranked 90th out of 883 institutions in 2015, 87th out of 900 institutions in 2016, and 77th out of 883 institutions in 2017 in the origination of HMDA reportable loans. The top ranked reporters were Wells Fargo Bank N.A.; JPMorgan Chase Bank, N.A.; and Quicken Loans Inc.

The bank originated 2,581 small business loans in 2015, 2016, and 2017, which represented 18.0% of its total small business lending. The bank ranked 22nd out of 192 institutions in 2015, 22nd out of 210 institutions in 2016, and 18th out of 218 institutions in 2017 in the origination of small business loans. The top ranked reporters were credit card issuers, including American Express Bank, FSB; Chase Bank USA, NA; and Wells Fargo Bank, N.A.

Demographic Characteristics

The Houston, TX Assessment Area is part of a larger area known as the Houston-The Woodlands-Sugar Land, TX MSA, which is the fifth largest MSA in the United States according to the 2010 Census. Certain economic and demographic data is available for analysis for the Houston-The Woodlands-Sugarland, TX MSA and not the smaller-defined assessment area. However, it is reasonable to believe that the data for the MSA provides a good representation of the characteristics of the assessment area because the population of the assessment area includes approximately 97.0% of the Houston-The Woodlands-Sugarland, TX MSA, and distribution of low-, moderate-, middle-, and upper- income families for the two areas is extremely similar according to 2010 census data.

The Houston, TX Assessment Area is located in the southeastern portion of the state and is bordered on the south by the Gulf of Mexico and the north by Walker and San Jacinto Counties. The assessment area is bordered on the east by Liberty and Chambers Counties and on the west by Austin, Matagorda, Waller, and Wharton Counties. The Louisiana border is approximately 100 miles to the east. As of 2015, the specific assessment area consists of 1,039 census tracts, including 158 low-income and 302 moderate- income or 44.3% of the assessment area census tracts. There are also 258 (24.8%) middle-income, 312 (30.0%) upper-income census tracts and nine census tracts (0.9%) where the income is unknown.

Income Characteristics As previously mentioned, for purposes of classifying borrower income, this evaluation uses both 2010 U.S. Census data and 2015 estimated data for the relevant area. The

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

following chart reflects the estimated MFI for the years 2015 through 2017 for the Houston-The Woodlands-Sugarland, TX MSA. It also provides a range of the estimated annual family income for each income category (low, moderate, middle, and upper). According to the 2017 Census, 12.9% of the families in the assessment area lived below the poverty level.

Income Level 2015 2016 2017 Median Income $70,100 $68,000 $72,500 Low-income < $35,050 < $34,000 <$36,250 Moderate-income $35,051 - $56,080 $34,001 - $54,400 $36,251 - $58,000 Middle-income $56,081 - $84,120 $54,401 - $81,600 $58,001 - $87,000 Upper-income ≥ $84,121 ≥ $81,601 ≥ $87,001

Housing Characteristics The median housing price in the Houston-The Woodlands-Sugar Land, TX MSA has steadily increased. Over the past three years, the median housing price for homes in the city of Houston increased 7.5% from $212 thousand in 2015 to $228 thousand in 2017. Also in Houston, an average of 48,009 building permits for newly privately owned housing units were issued each year from 2015 to 2017. In August of 2017, Hurricane Harvey hit the Texas Gulf Coast and unleashed unprecedented levels of rain in a short period of time. Houston received the bulk of property damage due to its size. Among the hardest hit counties were Fort Bend, Galveston, and Harris – three of the metro’s most populated counties, and the closest to the coast. According to data from the Real Estate Center at Texas A&M University, despite the severity of this multibillion-dollar storm, Houston’s housing market has rebounded completely and continues to expand. 5

The Houston, TX MSA has fared well in terms of mortgages considered seriously delinquent (defined as more than 90 days past due or in foreclosure) compared to many metropolitan areas in the country, which range from 0.2% to 6.9% throughout the nation as of December 2017. The delinquency rate for seriously delinquent mortgages for counties in the assessment area was Brazoria County at 0.9%, Fort Bend County at 0.5%, Galveston County at 0.8%, Harris County at 0.9%, and Montgomery County at 0.8%, which are all below the national average of 1.0%.6

According to the 2015 Census, there were 2,329,992 housing units in the assessment area with 54.4% of the units classified as owner-occupied, while 36.0% are classified as rental units, and 9.6% of the available housing is vacant. Overall, 12.5% of the housing stock in the assessment area is in low-income tracts. In these census tracts, 23.3% of the housing units are owner-occupied, 61.1% are rental units, and 15.6% are vacant.

5 Real Estate Center at Texas A&M University. Houston Housing: A year after Harvey. Available at: https://www.recenter.tamu.edu/info/blog/?Item=139. Accessed: Sept 20, 2018 6 Consumer Financial Protection Bureau (CFPB) Mortgages 90 or more days delinquent. Available at https://www.consumerfinance.gov/data-research/mortgage-performance-trends/mortgages-90-or-more-days- delinquent/#mp-line-chart-container. Accessed Sept. 18, 2018. 34

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

The 2010 median age of housing stock in low-income tracts in the assessment area was 38 years and the median housing value was $77.1 thousand. By 2015, this number had increased to $79.9 thousand, which is a 3.7% increase. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed-rate, 30 year loan, a home of this value would still be considered affordable for a low-income family, although a barrier to homeownership is typically a down payment. The monthly rental payment in low-income tracts in 2015 was $724, which is less affordable than the monthly mortgage payment of $382 for an $80 thousand home for 30 years at 4.0% interest rate. However, 30.0% of families in low- income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

Moderate-income tracts account for 25.1% of the housing stock in the assessment area. In these census tracts, 45.5% of the housing units are owner-occupied, 43.3% are rental units, and 11.2% are vacant. The median age of housing stock in these tracts in 2015 is 44 years and the median housing value in moderate-income tracts for the assessment area in 2010 was $92.9 thousand. By 2015, this number had increased to $94.3 thousand, which is a 1.6% increase. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed-rate, 30 year loan, a home of this value would be affordable for a moderate- income family, although a barrier to homeownership is typically a down payment. However, 36.7% of families in moderate-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

A large portion of the housing stock in the assessment area, at 26.5%, is in middle-income tracts. In these census tracts, 58.9% of the housing units are owner-occupied, 32.8% are rental units, and 8.3% are vacant. The median age of housing stock in these tracts in 2015 is 33 years and 21.6% of families in middle-income tracts have incomes below the poverty level. The median housing value in middle-income tracts for the Houston, TX Assessment Area in 2010 was $119.3 thousand. By 2015, this number had increased to $124.9 thousand, which is a 4.7% increase.

Approximately 35.7% of the housing stock in the assessment area is in upper-income tracts. In these census tracts, 68.5% of the housing units are owner-occupied, 24.1% are rental units, and 7.4% are vacant. In 2015, the median age of housing stock in these tracts is 25 years and only 11.2% of families in upper-income tracts have incomes below the poverty level. In addition, the median housing value in upper-income tracts for the assessment area in 2010 was $195.2 thousand. By 2015, this number had increased to $228.5 thousand, which is a 17.1% increase.

Employment and Economic Conditions The national average unemployment rates for 2015, 2016 and 2017 were 5.3%, 4.9%, and 4.4%. Unemployment rates for most of the counties in the assessment area were lower than the annual unemployment rates for Texas and the national average. According to the 2010 Census, the unemployment rate was 11.5% in low-income tracts

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

and 9.2% in moderate-income tracts. By 2015, the unemployment rate had decreased to 10.8% and 9.1% in low- and moderate-income tracts, respectively. However; the overall high unemployment rates in LMI tracts could affect loan demand from these tracts.

The following chart shows unemployment rates relevant to the assessment area for 2015, 2016, and 2017.

Annual Average Unemployment Rate7 AREA 2015 2016 2017 Brazoria County 4.6% 5.2% 5.3% Fort Bend County 4.3% 5.0% 4.6% Galveston County 5.0% 5.3% 5.2% Harris County 4.6% 5.3% 5.0% Montgomery County 4.2% 4.9% 4.3% Houston, TX MSA 4.6% 5.3% 5.0% State of Texas 4.4% 4.6% 4.3% United States 5.3% 4.9% 4.4%

In 2017, there were 21 Fortune 500 companies located in Houston, TX Assessment Area with the top few being Walmart, Exxon Mobil, Berkshire Hathaway, Apple, and UnitedHealth Group8. Houston is a major port and financial center for oil companies and is the largest petrochemical manufacturing area in the world. Biomedical research, aeronautics, and the ship channel are also large parts of the city's industrial base. The Texas Medical Center, which is located in Houston, is the largest medical center in the world. The assessment area also has more than 500 cultural, visual, and performing arts organizations and over 40 colleges, universities, and institutions of higher learning.9 Major employers are Walmart, Memorial Hermann Health System, H.E.B, The University of Texas MD Anderson Cancer Center, and McDonald’s Corporation.

Community Contacts and Community Development Opportunities

Contact was made with a community leader working with affordable housing. The contact stated basic banking needs, such as checking and savings accounts, as well as mortgage financing is needed. Other needs include access to home refinance and home improvement loans, as well as financial education and credit for start-up businesses.

Contact was also made with two community leaders working in small business development. One contact stated there is a high level of opportunity for bank involvement

7 Bureau of Labor Statistics: Local Area Unemployment Statistics. http://www.bls.gov/data/#unemployment Accessed: September 20, 2018. 8 Fortune 500 Companies - http://fortune.com/fortune500/list/. Accessed: September 20, 2018 9 http://www.houstontx.gov/abouthouston/houstonfacts.html Accessed: September 20, 2018. 36

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX in small business lending; however, the contact also stated banks are not lending due to the high risk of unestablished businesses. The second contact stated capital and start- up money is still hard to access, with banks requiring more underwriting due to regulation requirements.

Key Assessment Area Demographics

The following table details selected characteristics of the assessment area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

Combined Demographics Report Assessment Area: Houston Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 158 15.2 159,612 10.8 57,230 35.9 362,116 24.4 Moderate-income 302 29.1 358,696 24.2 70,103 19.5 238,045 16 Middle-income 258 24.8 406,320 27.4 41,170 10.1 252,221 17 Upper-income 312 30 556,835 37.5 21,449 3.9 631,386 42.6 Unknown-income 9 0.9 2,305 0.2 999 43.3 0 0 Total Assessment Area 1,039 100.0 1,483,768 100.0 190,951 12.9 1,483,76 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 291,630 67,997 5.4 23.3 178,152 61.1 45,481 15.6 Moderate-income 584,643 265,840 21 45.5 253,118 43.3 65,685 11.2 Middle-income 616,393 363,015 28.6 58.9 202,026 32.8 51,352 8.3 Upper-income 831,143 569,614 44.9 68.5 200,009 24.1 61,520 7.4 Unknown-income 6,183 789 0.1 12.8 4,770 77.1 624 10.1 Total Assessment Area 2,329,992 1,267,255 100.0 54.4 838,075 36.0 224,662 9.6 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 26,162 10.3 22,083 9.7 3,941 15.7 138 6 Moderate-income 49,787 19.6 43,752 19.3 5,730 22.8 305 13.3 Middle-income 59,685 23.4 53,847 23.7 5,370 21.4 468 20.4 Upper-income 118,518 46.5 107,141 47.2 9,998 39.8 1,379 60.1 Unknown-income 467 0.2 409 0.2 53 0.2 5 0.2 Total Assessment Area 254,619 100.0 227,232 100.0 25,092 100.0 2,295 100.0 Percentage of Total Businesses: 89.2 9.9 .9 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 71 3.9 66 3.7 5 13.2 0 0 Moderate-income 214 11.7 206 11.5 8 21.1 0 0 Middle-income 589 32.3 579 32.4 10 26.3 0 0 Upper-income 947 51.9 932 52.2 15 39.5 0 0 Unknown-income 3 0.2 3 0.2 0 0 0 0 Total Assessment Area 1,824 100.0 1,786 100.0 38 100.0 0 .0 Percentage of Total Farms: 97.9 2.1 .0 2017 FFIEC Census Data and 2017 D&B Information 38

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

Conclusions With Respect to Performance Tests

Lending Test

The bank’s lending performance is good. Lending activity reflects good responsiveness to assessment area credit needs. The geographic distribution of loans reflects excellent penetration throughout the assessment area. In addition, the distribution of borrowers reflects good penetration among borrowers of different income levels and businesses of different revenue sizes. Additionally, the bank is a leader in making community development loans.

The bank is both a small business and HMDA lender. During the review period, the bank reported 2,581 (65.9%) small business loans compared to 1,335 (34.1%) HMDA loans in the Houston, TX Assessment Area. Therefore, small business lending was given more weight than HMDA lending in determining the bank’s Lending Test rating in the assessment area.

Details of the bank’s mortgage and small business lending and information regarding lending by peers can be found in Appendix E.

Lending to Borrowers of Different Income Levels and Businesses of Different Sizes

The bank’s distribution of lending to borrowers reflects good penetration among individuals of different income levels (including low- and moderate-income) and businesses of different revenue sizes.

Frost’s HMDA lending to low-income borrowers is good. In 2015 and 2016, the bank originated 3.9% and 4.6%, respectively, of its total HMDA loans to low-income borrowers, which exceeded the 3.3% of total HMDA loans originated by the aggregate in 2015 and 2.4% in 2016 to low-income borrowers. In 2017, the bank originations to low-income borrowers rose to 6.7% and again exceeded aggregate lending at 3.5% of total HMDA loans. Low-income families made up 23.7% of total families in the assessment area in both 2015 and 2016 and 24.4% in 2017, meaning that both the bank and aggregate lending were below demographics.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

The bank’s HMDA lending to moderate-income borrowers is adequate. In 2015 and 2016, the bank originated 5.0% and 11.3%, respectively, of its total HMDA loans to moderate- income borrowers, which was below aggregate HMDA lenders in 2015 at 11.4% but slightly above aggregate at 10.6% in 2016. In 2017, the bank was also below aggregate originating 7.4% of HMDA loans to moderate-income borrowers as compared to aggregate lenders originating 12.1% of HMDA loans to moderate-income borrowers. Both the bank and aggregate HMDA lenders were below demographics with 16.5% in both 2015 and 2016 and 16.0% in 2017 of families in the assessment area classified as moderate-income.

Small Business Lending

Considering the bank’s performance when compared to the aggregate, the borrower distribution of small business loans by revenue size of businesses is good. Of the 2,581 small business loans originated during the review period by Frost, 32.1% were originated to small businesses in 2015, 37.4% in 2016, and 43.4% in 2017. This is less than the percentage of businesses with annual gross revenue of $1 million or less at 90.6% in 2015 and 2016 and 89.2% in 2017 in the Houston, TX Assessment Area. In 2015, Frost’s performance was below that of aggregate, which originated 47.1% of loans to small businesses. However, in 2016 and 2017, Frost’s performance was comparable to that of aggregate lenders, which originated 40.6% and 45.7%, respectively, of loans to small businesses.

Another way to gauge the bank’s small business lending performance is to review the data by loan amount. Small businesses typically require smaller dollar credits. In this regard, it is noted that 33.4%% and 40.6% of the bank’s commercial loans were made in loan amounts of $100 thousand or less in 2015 and 2016 and 45.5% in 2017. Frost’s performance was below the aggregate performance in all three years. However, many of the largest small business lenders in the assessment area offer small dollar credit cards, a credit product not offered by Frost, as well as the bank’s competition consisting primarily of large multi-regional and nationwide banks.

Geographic Distribution of Loans

For this analysis, the geographic distribution of small business lending and HMDA lending, including both originations and purchases, was compared with available demographic information. Performance context issues and aggregate lending data were taken into consideration. Considering all of these factors, the bank’s geographic distribution of loans reflects excellent penetration throughout the assessment area. Loans were generally made in close proximity to the bank’s branches and there were no conspicuous gaps or anomalies in the lending patterns.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

HMDA Loan Geographic Distribution

The geographic distribution of HMDA loans reflects good penetration throughout the assessment area. This was based on performance compared to demographics, taking into consideration the performance of the aggregate lenders.

Home Purchase Lending Home purchase lending in low-income census tracts is good. During the review period, Frost originated four home purchase loans in low-income tracts. This accounts for 1.2% of home purchase loans in 2015, 3.4% in 2016, and 1.4% in 2017. However, in 2015 and 2016, only 4.2% of owner-occupied units in the assessment area were located in low- income census tracts and increased to 5.4% in 2017. Aggregate lenders also struggled to originate home purchase loans in low-income census tracts at a level comparable to the percentage of owner-occupied units located in those tracts. During the review period, aggregate lenders originated 1.5%, 1.7%, and 2.4% of home purchase loans in low- income tracts in 2015, 2016, and 2017, respectively. This is comparable to Frost’s performance. The nominal level of originations in the low-income tracts could indicate a low level of demand.

Home purchase lending in moderate-income tracts is poor. In 2015, 2016, and 2017, Frost originated 6.0%, 1.7%, and 4.1%, respectively, of its home purchase loans in moderate-income census tracts, which contained 20.7% of owner occupied units in the assessment area in 2015 and 2016, and slightly increased to 21.0% in 2017. The aggregate’s performance was also below the percentage of owner-occupied homes in the review period, but managed to originate or purchase 10.4%, 10.9%, and 13.0% of loans, respectively, in moderate-income tracts in 2015, 2016, and 2017.

Home Refinance Lending Home refinance lending in low-income census tracts is excellent. During the review period, Frost originated a total of nine refinance loans in low-income tracts, which accounts for 3.1% in 2015, 6.3% in 2016, and 6.4% in 2017. As mentioned previously, low-income tracts contained 4.2% of owner occupied units in the assessment area in 2015 and 2016, and increased to 5.4% in 2017. The aggregate originated and purchased 1.4% of home refinance loans in both 2015 and 2016, and 2.4% in 2017. Frost outperformed the aggregate in all three years of the review period.

Frost’s home refinance lending in moderate-income census tracts is excellent. In 2015, 2016, and 2017, Frost originated 10.8%, 17.5%, and 17.0% of its home refinance loans in moderate-income census tracts, respectively; moderate-income tracts contained 20.7% of owner-occupied units in 2015 and 2016, and 21.0% in 2017. Frost’s performance was comparable to the aggregate in 2015 and outperformed the aggregate in 2016 and 2017. The aggregate originated 9.8%, 9.9%, and 14.2% of refinance loans in moderate-income tracts in 2015, 2016, and 2017, respectively.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

Home Improvement Lending Home improvement lending in low-income census tracts is good. Frost originated 1.7% of its home improvement loans in low-income tracts in 2015, 5.7% in 2016, and 3.1% in 2017. As mentioned previously, low-income tracts contained 4.2% of owner-occupied units in 2015 and 2016, and increased to 5.4% in 2017. The aggregate originated 2.3%, 2.7%, and 3.8% of home improvement loans in low-income tracts in 2015, 2016, and 2017, respectively. Frost’s performance was only slightly below the aggregate in 2015 and 2017 but outperformed them in 2016.

Frost’s home improvement lending in moderate-income census tracts is good when compared to aggregate lenders and the percentage of owner-occupied units in these tracts. In 2015, 2016, and 2017, Frost originated 12.8%, 18.7%, and 16.7%, respectively, of its home improvement loans in moderate-income tracts, which contained 20.7% of owner-occupied units in the assessment area in 2015 and 2016, and slightly increased to 21.0% in 2017. The aggregate originated 11.6% in 2015, 11.5% in 2016, and 16.1% in 2017. The bank outperformed the aggregate all three years of the review period.

Small Business Loan Geographic Distribution

Frost’s small business lending in low-income census tracts is excellent. In 2015, 2016, and 2017, Frost originated 8.8%, 10.1%, and 12.4%, respectively, of its small business loans in low-income tracts, which contained 7.5% of small businesses in the assessment area in 2015 and 2016, and increased to 9.7% in 2017. In addition, the bank outperformed the aggregate lenders during the review period, which originated 7.8%, 7.5%, and 10.0% of loans to businesses located in low-income areas in 2015, 2016, and 2017, respectively.

Frost’s small business lending in moderate-income tracts is excellent. Frost originated 21.1%, 18.7%, and 18.0% of its small business loans, respectively, in moderate-income census tracts in 2015, 2016, and 2017. Moderate-income tracts contained 18.7% of small businesses in the assessment area in 2015 and 2016, and increased to 19.3% in 2017. The bank outperformed the aggregate in 2015 and 2016, as aggregate lenders originated 18.2% and 17.7% of small business loans in moderate-income tracts, respectively; furthermore, Frost’s performance was only slightly below the aggregate’s performance in 2017 (18.5%).

The bank’s small business lending in middle- and upper-income tracts was comparable to the percentage of small businesses in these tracts. When compared to the aggregate by percentage, the bank originated a similar number of loans in middle- and upper-income tracts from 2015 through 2017.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

Community Development Lending

The bank is a leader in making community development loans in the Houston, TX assessment area. The bank originated 52 community development loans totaling $227.0 million during the review period. During the previous evaluation, Frost originated 21 loans for a total of $192.1 million. By dollar, this is an 18.1% increase since the previous evaluation and a 147.6% increase by number of loans. The bank’s commitment to making qualified community development loans demonstrates an excellent responsiveness to the different needs in the assessment area. The table below provides a breakdown of the types of community development loans originated by Frost during the review period.

Community Development Lending Purpose # $000s Affordable Housing 9 $15,250 Community Services 36 100,652 Economic Development 3 $101,320 Revitalization and Stabilization 4 $9,782 Total 52 $227,004

The majority of the loans provided working capital to organizations that offer community services to LMI individuals. Some of these services were to provide education, food services – such as the development of a grocery store as part of the City of Houston’s Redevelopment Authority USDA Food Desert Program – healthcare, social services, and general assistance to LMI Individuals. Some of the affordable housing loans were made for development of real estate for the benefit of a majority of low-income persons, as well as revitalization loans for the development of 1-4 family housing for the LMI community. Frost also makes loans to SBIC’s that provide financing to underserved, middle market companies.

Investment Test The Investment Test rating is Outstanding. The bank has an excellent level of qualified community development investments and grants, particularly those not routinely provided by private investors, is often in a leadership position, and exhibits excellent responsiveness to credit and community development needs. Overall, the bank had investments and grants totaling $182.3 million during the review period. Included in that total were ten current period investments totaling $173.9 million. The bank’s investments were primarily focused on general obligations bonds designated for independent school districts in the Houston, TX Assessment Area where more than 75% of students are considered economically disadvantaged, as well as GNMA investment instruments targeted to individuals with incomes of less than 80% of the median family income. The bank also had prior period investments totaling $7.0 million, also in GNMA investment instruments.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

The bank made 217 donations totaling $1.3 million. Contributions were made to organizations that assist small businesses and provide community services targeted to LMI individuals. Some of these organizations include PeopleFund and LiftFund. Particularly noteworthy were various grants and donations made to businesses and organizations aiding those affected by Hurricane Harvey. Frost sponsored Federal Home Loan Bank of Dallas Harvey Disaster Business Recovery Grants for 12 businesses. As mentioned previously, Frost made a $1 million commitment to efforts related to Hurricane Harvey Relief throughout the State of Texas, with $450,000 of that benefiting the Houston, TX Assessment Area.

The total amount of current period investments and contributions, at $175.3 million, has increased 53.5% from the previous evaluation.

Community Development Investments Current Period Donations Total Investments Purpose # $ # $ # $ Affordable Housing 4 $12,598,739 7 $34,000 11 $12,632,739 Community Services 4 $160,650,000 198 $1,237,700 202 $161,887,700 Economic Development 2 $716,557 17 $66,700 19 $783,257 Revitalization and Stabilization 0 0 0 0 0 0 Total 10 $173,965,296 222 $1,338,400 232 $175,303,696

Service Test

The bank’s Service Test performance is excellent. The retail services and community development services reflect excellent responsiveness to the needs in the assessment area.

Retail Services

The bank’s delivery systems are accessible to the bank’s geographies and individuals of different income levels in its assessment area. The distribution of the bank’s 33 branch offices and 37 ATMs as of December 31, 2017, was compared to the distribution of households and businesses among the tract categories within the assessment area. The table below summarizes the bank’s retail locations in the Houston, TX Assessment Area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

Full Service Cash Only Tract % of % of Branches ATMs ATMS Income Geographies Population # % # % # % Low 15.2 11.7 3 9.1 3 8.1 0 0 Moderate 29.1 24.6 9 27.3 8 21.6 0 0 Middle 24.8 26.8 2 6.1 4 10.8 0 0 Upper 30.0 36.6 19 57.5 22 59.5 0 0 Unknown 0.9 0.3 0 0.0 0 0.0 0 0 Total 100 100 33 100 37 100 0 0

During the review period, the bank opened six branches (two in low-income tracts, one in a moderate-income tract, one in a middle-income tract, and two in upper-income tracts) and closed three branches (all three in upper-income tracts) in the assessment area. The bank's record of opening or closing branches has improved the accessibility of its delivery systems, including to LMI income geographies. Banking services and hours of operations do not vary in a way that inconveniences the assessment area, particularly in LMI geographies or to LMI individuals. The level of branch services and hours offered are basically the same throughout the assessment area.

Community Development Services

The bank is a leader in providing community development services in the assessment area. The bank’s employees served in many various capacities, including boards of directors and as trustees, for 153 community development financial organizations offering community development services that focused on providing services that aided LMI individuals. Total hours served during the review period was approximately 7,180 hours, a 243.0% increase from the previous evaluation. The table below shows the number of hours by type of involvement.

Purpose Hours Served Affordable Housing 138 Benefits LMI Individuals/Geographies 6,592 Revitalize/Stabilize 0 Provides Economic Development 450 Total 7,180

Frost was particularly responsive throughout the assessment area in providing financial literacy through programs like Frost’s Financial Youth Academy to schools with a majority of students who are considered economically disadvantaged. The bank hosted small business seminars on 'The Lending Process' using the Frost Borrowing Guide for small businesses. The bank also hosted the Frost Home Mini-Expo Seminars, which are outreach sessions teaching home improvement skills to homeowners. This event also provides homeowners information such as how to choose a reputable home remodel company, information on different city programs, services, and assistance programs provided by local utility companies. There are also “how to” sessions on home

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Houston-The Woodlands-Sugar Land, TX

maintenance and home repair. These seminars are targeted to LMI homeowners and are held in a location in an LMI census tract. Frost also collaborated with The Women’s Resource of Greater Houston, which serves as a middle organization to many non-profits in the Houston area who are seeking to provide adult financial literacy education to low- and moderate-income populations. The bank also served in numerous leadership roles in community development corporations and organizations benefitting LMI individuals.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

METROPOLITAN AREAS (Full Scope Review)

Description of Operations in the San Antonio-New Braunfels, TX Assessment Area

The San Antonio-New Braunfels, TX Assessment Area (hereafter referred to as the San Antonio, TX Assessment Area) includes Bexar, Comal, Guadalupe and Kendall Counties. These counties, along with Atascosa, Bandera, Medina, and Wilson Counties, which are excluded from the assessment area, make up the San Antonio-New Braunfels, TX MSA. As of 2015, the assessment area contains 34 low-, 137 moderate-, 115 middle-, and 135 upper-income census tracts. There also four census tracts where income is unknown. As of December 31, 2017, Frost operated 29 branches in the assessment area representing 20.4% of its branches. There is one branch in a low-income census tract, four branches in moderate-income census tracts, ten in middle-income census tracts, and fourteen in upper-income census tracts.

According to the 2015 Census, the assessment area population was 2,125,955, which accounts for 8.0% of the population in the state. Based on the 2010 population of 1,988,201, the assessment area has experienced an increase of 6.9% over the last five years. San Antonio, the largest city within the assessment area, and second largest city in the State of Texas, accounts for 71.1% of the population in the assessment area. The following table provides further information.

% 2017 Increase County Population Major Municipalities Since Estimate 2010 Bexar 1,958,578 14.2% San Antonio (County Seat)

Comal 141,009 30.0% New Braunfels (County Seat)

Guadalupe 159,659 21.4% Schertz (Seguin County Seat)

Kendall 44,026 31.7% Boerne (County Seat)

According to the FDIC, as of June 30, 2017, the bank had $8.2 billion in deposits in this assessment area representing 31.8% of the bank’s total deposits. It also represents a deposit market share of 7.5%, which includes all other FDIC-insured deposits that are located in the assessment area. USAA Federal Savings Bank holds the largest deposit share at 65.9%, followed by Bank of America, N.A. and Wells Fargo Bank, N.A., both at 4.0%. Many of the bank’s competitors are statewide and multi-regional banks, but competition does not appear to have adversely affected the bank’s ability to serve the

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

credit needs of its assessment area, specifically in regards to small business or HMDA lending.

The bank originated 1,300 HMDA reportable loans in 2015, 2016, and 2017, which represent 18.3% of its total HMDA lending. The bank ranked 41st out of 667 institutions in 2015, 37th out of 685 institutions in 2016, and 39th out of 689 institutions in 2017 in the origination of HMDA reportable loans. The top ranked reporters were Wells Fargo Bank N.A., Randolph Brooks Federal Credit Union, and Security Service Federal Credit Union.

The bank originated 3,137 small business loans in 2015, 2016, and 2017, which represented 21.8% of its total small business lending. The bank ranked 10th out of 128 institutions in 2015, 11th out of 153 institutions in 2016, and 9th out of 158 institutions in 2017 in the origination of small business loans. The top ranked reporters were credit card issuers, including American Express Bank, FSB; City Bank, N.A and Chase Bank USA, N.A.

Demographic Characteristics

The San Antonio, TX Assessment Area is part of larger area known as the San Antonio – New Braunfels, TX MSA, which is the 24th largest metropolitan area in the United States and third largest in Texas, according to the 2015 Census. Certain economic and demographic data is available for analysis for the San Antonio-New Braunfels, TX MSA and not the smaller-defined assessment area. However, it is reasonable to believe that the data for the MSA provides a good representation of the characteristics of the assessment area because the population of the assessment area includes 93.0% of the San Antonio-New Braunfels, TX MSA, and distribution of low-, moderate-, middle-, and upper-income families for the two areas is very similar according to 2015 census data.

The San Antonio, TX Assessment Area is located in the south central portion of the state and is bordered on the north by Blanco and Hays Counties and to the south by Atascosa and Wilson Counties. To the east are Caldwell and Gonzales Counties and on the west are Bandera, Kerr, and Medina Counties. Austin is 80 miles to the north, the Gulf of Mexico is approximately 150 miles to the south, Houston is 190 miles east, and the Mexico border is 200 miles to the west. As of 2015, the specific assessment area consists of 425 census tracts, of which 40.2% are low- or moderate-income (34 low-income and 137 moderate-income). There are also 115 (27.1%) middle-income tracts, 135 (31.8%) upper-income census tracts, and four census tracts (0.9%) where the income designation is unknown.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

income category (low, moderate, middle, and upper). According to the 2015 Census, 12.7% of the families in the assessment area lived below the poverty level.

Income Level 2015 2016 2017 Median Income $63,400 $62,500 $64,300 Low-income < $31,700 < $31,250 <$32,150 Moderate-income $31,701 - $50,720 $31,251 - $50,000 $32,151 - $51,440 Middle-income $50,721 - $76,080 $50,001 - $75,000 $51,441 - $77,160 Upper-income ≥ $76,081 ≥ $75,001 ≥ $77,161

Housing Characteristics The median housing price in the San Antonio – New Braunfels, TX MSA has increased 10.7% over the past three years from $190.6 thousand in 2015 to $211 thousand in 2017. In the San Antonio, TX MSA, an average of 10,860 building permits for new privately- owned housing units were issued each year from 2015 to 2017. The San Antonio-New Braunfels, TX MSA has fared well in terms of mortgages considered seriously delinquent (defined as more than 90 days past due or in foreclosure) compared to many metropolitan areas in the country, which range from 0.2% to 6.9% throughout the nation as of December 2017. The delinquency rate for seriously delinquent mortgages for the MSA was Bexar County at 1.3% which is slightly above the national average of 1.0%, Comal County at 0.5%, Guadalupe County at 0.9%, and Kendall County at 0.8%, which falls below the national average.10

According to the 2015 Census, there were 793,351 housing units in the assessment area with 55.8% of the units classified as owner-occupied while 35.6% were classified as rental units and 8.6% of the available housing is vacant. Overall, 6.3% of the housing stock in the assessment area is in low-income tracts. In these census tracts, 39.9% of the housing units are owner-occupied, 46.7% are rental units, and 13.4% are vacant.

The 2010 median age of housing stock in these tracts is 48 years and the median housing value in low-income tracts for the assessment area, also in 2010, was $70.0 thousand. By 2015, this number remained unchanged at $70.0 thousand. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed-rate, 30 year loan, a home of this value would be still be considered affordable for a low-income family, although a barrier to homeownership is typically a down payment. The monthly rental payment in low-income tracts in 2015 was $670 which is less affordable than the monthly mortgage payment of $334 for a $70.0 thousand home for 30 years at 4.0% interest rate. However, 17.8% of families in low-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

10 Consumer Financial Protection Bureau (CFPB) Mortgages 90 or more days delinquent. Available at https://www.consumerfinance.gov/data-research/mortgage-performance-trends/mortgages-90-or-more-days- delinquent/#mp-line-chart-container. Accessed Oct. 2, 2018. https://www.realtytrac.com/statsandtrends/foreclosuretrends/tx/kendall-county. Accessed Dec 18, 2018. 49

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Moderate-income tracts account for 30.2% of the housing stock in the assessment area. In these census tracts, 44.3% of the housing units are owner-occupied, 45.5% are rental units, and 10.2% are vacant. The 2010 median age of housing stock in these tracts is 40 years and the median housing value in moderate-income tracts for the assessment area also in 2010 was $74.9 thousand. By 2015, this number had increased to $79.1 thousand, which is a 5.7% increase. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed- rate, 30 year loan, a home of this value would be affordable for a moderate-income family, although a barrier to homeownership is typically a down payment. However, 47.3% of families in moderate-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

A large portion of the housing stock in the assessment area, at 29.1%, is in middle-income tracts. In these census tracts, 54.1% of the housing units are owner-occupied, 37.1% are rental units, and 8.8% are vacant. The 2015 median age of housing stock in these tracts is 36 years and 22.6% of families in middle-income tracts have incomes below the poverty level. The median housing value in middle-income tracts for the San Antonio, TX Assessment Area in 2010 was $112.1 thousand. By 2015, this number had increased to $127.0 thousand, which is a 13.4% increase.

Approximately 34.4% of the housing stock in the assessment area is in upper-income tracts. In these census tracts, 70.2% of the housing units are owner-occupied, 23.7% are rental units, and 6.1% are vacant. The 2015 median age of housing stock in these tracts is 24 years and only 12.3% of families in upper-income tracts have incomes below the poverty level. In addition, the median housing value in upper-income tracts for the assessment area in 2010 was $192.6 thousand. By 2015, this number had increased to $209.6 thousand, which is an 8.8% increase.

Employment and Economic Conditions The national average unemployment rates for 2015, 2016, and 2017 were 5.3%, 4.9%, and 4.4%. Unemployment rates for all of the counties in the assessment area were lower than the annual unemployment rates for Texas and the national average. According to the 2010 Census, the unemployment rate was 12.7% in low-income tracts and 8.7% in moderate-income tracts. By 2015 the unemployment rate had increased to 13.0% and 9.0% in low- and moderate-income tracts, respectively. The high unemployment rates in LMI tracts could affect loan demand from these tracts.

The following chart shows unemployment rates relevant to the assessment area for 2015, 2016, and 2017.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Annual Average Unemployment Rate11 AREA 2015 2016 2017 Bexar County 3.8% 3.7% 3.5% Comal County 3.7% 3.6% 3.4% Guadalupe County 3.5% 3.6% 3.3% Kendall County 3.3% 3.2% 3.1% San Antonio, TX MSA 3.8% 3.8% 3.5% State of Texas 4.4% 4.6% 4.3% United States 5.3% 4.9% 4.4%

The San Antonio, TX Assessment Area has an extremely diverse economy, which is supported by defense, healthcare, and tourism. As of 2017, there were five Fortune 500 companies located in the San Antonio, TX Assessment Area including: Valero Energy, Tesoro, United Services Automobile Association (USAA), CST Brands (Valero’s retail spinoff), and iHeartMedia.12 San Antonio is often referred to as “Military City USA” because of the three military bases – Fort Sam Houston, Lackland Air Force Base, and Randolph Air Force Base – that were consolidated into Joint Base San Antonio. Lackland Air Force Base alone employs 37,097 people, making it the largest employer in San Antonio. Tourism is fueled by attractions like the Alamo, San Antonio River Walk, Sea World, and Fiesta Texas. There are 31 institutions of higher learning, including the University of Texas Health Science Center, University of Texas at San Antonio, Texas A&M University – San Antonio, Our Lady of the Lake, University of Incarnate Word, and Trinity University to name a few. Other major employers are HEB Grocery Store, USAA, Cullen/Frost Bankers Inc., Bill Miller Bar-B-Q, and Rackspace.13

Community Contacts and Community Development Opportunities

Contact was made with a community leader working in small business development. The contact stated that capital is always needed for small businesses since requirements today ask for tax returns for SBA loans. The contact also felt that many small businesses minimize their taxes, which show less revenue and less profitable tax returns. However, the contact felt banks work amongst each other to help small businesses.

The same contact indicated that financial institutions, such as Frost, help small businesses develop business plans and put together financial packages. The contact said the organization collaborates with Frost in organizing financial education geared to businesses with under $1 million in revenues.

11 Bureau of Labor Statistics: Local Area Unemployment Statistics. http://www.bls.gov/data/#unemployment Accessed: September 20, 2018. 12 2017: Fortune 500 companies in Texas. https://www.mysanantonio.com/business/slideshow/Fortune-500- companies-in-Texas-for-2017-146307/photo-10762753.2php. Accessed: Oct. 2, 2018 13 San Antonio Economic Development Foundation: Major Employers. http://www.sanantonioedf.com/why-san- antonio/data/#row_occupations. Accessed: Oct. 2, 2018 51

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Key Assessment Area Demographics

The following table details selected characteristics of the assessment area. Combined Demographics Report Assessment Area: San Antonio Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 34 8 29,841 6 11,272 37.8 112,900 22.6 Moderate-income 137 32.2 141,360 28.3 29,924 21.2 86,400 17.3 Middle-income 115 27.1 140,042 28.1 14,250 10.2 95,332 19.1 Upper-income 135 31.8 187,810 37.6 7,760 4.1 204,433 41 Unknown-income 4 0.9 12 0 0 0 0 0 Total Assessment Area 425 100.0 499,065 100.0 63,206 12.7 499,065 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 50,050 19,972 4.5 39.9 23,392 46.7 6,686 13.4 Moderate-income 239,252 105,911 23.9 44.3 108,898 45.5 24,443 10.2 Middle-income 231,088 125,036 28.2 54.1 85,662 37.1 20,390 8.8 Upper-income 272,949 191,708 43.3 70.2 64,683 23.7 16,558 6.1 Unknown-income 12 12 0 100 0 0 0 0 Total Assessment Area 793,351 442,639 100.0 55.8 282,635 35.6 68,077 8.6 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 3,701 4.8 3,210 4.6 475 7.5 16 2.6 Moderate-income 16,532 21.6 14,946 21.4 1,501 23.8 85 13.9 Middle-income 22,617 29.5 20,345 29.2 2,084 33.1 188 30.7 Upper-income 33,658 43.9 31,139 44.6 2,200 34.9 319 52.1 Unknown-income 164 0.2 122 0.2 38 0.6 4 0.7 Total Assessment Area 76,672 100.0 69,762 100.0 6,298 100.0 612 100.0 Percentage of Total Businesses: 91.0 8.2 .8 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 17 1.7 15 1.5 2 13.3 0 0 Moderate-income 108 10.6 106 10.6 2 13.3 0 0 Middle-income 307 30.2 302 30.1 5 33.3 0 0 Upper-income 585 57.5 579 57.8 6 40 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 1,017 100.0 1,002 100.0 15 100.0 0 .0 Percentage of Total Farms: 98.5 1.5 .0 2017 FFIEC Census Data and 2017 D&B Information

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Conclusions With Respect to Performance Tests

Lending Test

The bank’s lending performance is good. Lending activity reflects good responsiveness to assessment area credit needs. The geographic distribution of loans reflects excellent penetration throughout the assessment area. In addition, the distribution of borrowers reflects adequate penetration among borrowers of different income levels and businesses of different revenue sizes. Additionally, the bank is a leader in making community development loans.

The bank is both a small business and HMDA lender. During the review period, the bank reported 3,137 (70.7%) small business loans compared to 1,300 (29.3%) HMDA loans in the San Antonio–New Braunfels, TX Assessment Area. Therefore, small business lending was given more weight than HMDA lending in determining the bank’s Lending Test rating in the assessment area.

Details of the bank’s mortgage and small business lending and information regarding lending by peers can be found in Appendix E.

Lending to Borrowers of Different Income Levels and Businesses of Different Sizes

The distribution of the remainder of bank’s lending to middle- and upper-income borrowers did not affect conclusions about the bank’s performance considering its lending to low- and moderate-income borrowers.

HMDA Lending HMDA lending by borrower income in the assessment area is considered good when compared to demographic characteristics of the community, as well as the performance of aggregate HMDA lenders with loan originations or purchases in the assessment area.

Frost’s HMDA lending to low-income borrowers is good. In 2015 and 2016, the bank originated 8.2% and 15.1%, respectively, of its total HMDA loans to low-income borrowers, which exceeded the 3.3% of total HMDA loans originated by the aggregate in 2015 and 2.7% in 2016 to low-income borrowers. In 2017, the bank’s originations to low- income borrowers rose to 16.7% and again exceeded aggregate lending at 3.0% of total HMDA loans. However, low-income families made up 22.6% of total families in the assessment area in 2015 through 2017, meaning that both the bank and aggregate lending were below demographics.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

The bank’s HMDA lending to moderate-income borrowers is good. In 2015 and 2016, the bank originated 9.2% and 15.1%, respectively, of its total HMDA loans to moderate- income borrowers, which was below the aggregate HMDA lenders in 2015 at 11.3% but above aggregate in 2016 at 9.1%. In 2017, the bank slightly exceeded aggregate originating 11.3% of HMDA loans to moderate-income borrowers as compared to aggregate lenders at 11.0% of HMDA loans. Both the bank and aggregate HMDA lenders were below the demographics, with 16.9% in both 2015 and 2016 and 17.3% in 2017 in the assessment area classified as moderate-income families.

Small Business Lending

Considering the bank’s performance when compared to the aggregate, the borrower distribution of small business loans by revenue size of businesses is adequate. Of the 3,137 small business loans originated during the review period by Frost, 33.9% were originated to small businesses in 2015, 35.1% in 2016, and 40.7% in 2017. This is less than the percentage of businesses with annual gross revenue of $1 million or less at 91.8% in 2015 and 2016, and a slight decrease to 91.0% in 2017, in the San Antonio – New Braunfels, TX Assessment Area. Frost’s performance was below aggregate performance throughout the three year review period, who originated 47.4%, 40.3%, and 46.4% of loans to small businesses in 2015, 2016, and 2017, respectively.

Another way to gauge the bank’s small business lending performance is to review the data by loan amount. Small businesses typically require smaller dollar credits. In this regard, it is noted that 39.2% of the bank’s commercial loans were made in loan amounts of $100,000 or less in 2015, 41.6% in 2016, and 49.6% in 2017. Frost’s performance was below the aggregate performance in all three years who originated 93.9%, 94.8%, and 93.8% of loans in amounts less than $100,000 or less in 2015, 2016, and 2017, respectively. However, many of the largest small business lenders in the assessment area offer small dollar credit cards, a credit product not offered by Frost.

Geographic Distribution of Loans

For this analysis, the geographic distribution of small business lending and HMDA lending, including both originations and purchases, was compared with available demographic information. Performance context issues and aggregate lending data were taken into consideration. Considering all of these factors, the bank’s geographic distribution of loans reflects excellent penetration throughout the assessment area. Loans were generally made in close proximity to the bank’s branches and there were no conspicuous gaps or anomalies in the lending patterns.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

HMDA Loan Geographic Distribution

Home Purchase Lending Home purchase lending in low-income census tracts is adequate. During the review period, Frost originated zero loans in low-income census tracts; however, in 2015 and 2016 only 4.6% of the owner-occupied units in the assessment area were located in low- income census tracts and slightly decreased to 4.5% in 2017. Aggregate lenders also struggled to originate home purchase loans at a level comparable to the percentage of owner-occupied units in low-income census tracts. During the review period, the aggregate lenders originated only 1.4% of home purchase loans in both 2015 and 2016, and 1.0% in 2017.

Home purchase lending in moderate-income tracts is adequate. Frost originated 4.9%, and 13.0% of home purchase loans in moderate-income tracts in 2015 and 2016, respectively, which is below the 23.7% of owner occupied units located in moderate- income tracts. In 2017, the bank originated 4.8% of home purchase loans in moderate income tracts, which is also below the 23.9% of owner-occupied units located in these tracts. The aggregate’s performance was also below the percentage of owner-occupied homes in the review period but managed to originate or purchase 10.4% of home purchase loans in moderate-income tracts in both 2015 and 2016, and 11.9% in 2017.

Home Refinance Lending Home refinance lending in low-income census tracts is adequate. Frost did not originate any home refinance loans in low-income census tracts; however, as mentioned previously, only 4.6% of owner-occupied units in the assessment area were located in low-income census tracts in 2015 and 2016, and 4.5% in 2017. Aggregate lenders also struggled to originate home purchase loans at a level comparable to the percentage of owner-occupied units in low-income census tracts. During the review period, the aggregate lenders originated only 1.3% of home refinance loans in low-income tracts in both 2015 and 2016, and 1.4% in 2017.

Frost’s home refinance lending in moderate-income census tracts is excellent. Frost originated 13.5% and 14.3% of home purchase loans in 2015 and 2016, respectively. In 2017, the bank originated 23.1% of home refinance loans in moderate-income census tracts, which is only slightly below the 23.7% of t owner-occupied units in the assessment area in 2015 and 2016, and 23.9% in 2017. In addition, Frost’s performance was better than the aggregate in all three years of the review period. The aggregate originated 10.7%, 9.9%, and 14.2% of home refinance loans in moderate-income census tracts in 2015, 2016, and 2017, respectively.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Home Improvement Lending Home improvement lending in low-income census tracts is excellent. In 2015, 2016, and 2017, Frost originated 3.7%, 5.7%, and 5.2% of its home purchase loans in low-income census tracts, respectively; low-income tracts contained 4.6% of owner-occupied units in the assessment area in 2015 and 2016, and 4.5% in 2017. Frost’s performance was slightly below the aggregate (4.0%) in 2015, but above aggregate in 2016 and 2017 (3.6% and 3.2%, respectively).

Frost’s home improvement lending in moderate-income census tracts is also excellent when compared to the aggregate and the percentage of owner-occupied units in these tracts. Frost originated 20.4%, 27.9%, and 29.7% of its home improvement loans in moderate-income tracts in 2015, 2016, and 2017, respectively. Moderate-income tracts contained 23.7% of owner-occupied units in the assessment area in 2015 and 2016, and slightly increased to 23.9% in 2017. Frost also outperformed the aggregate for each year during the review period. The aggregate originated 17.2% of home improvement loans in moderate-income tracts in 2015, 17.0% in 2016, and 19.8% in 2017.

Small Business Loan Geographic Distribution

Frost’s small business lending in low-income census tracts is excellent. Frost originated 7.6% of its small business loans in low-income tracts in 2015, 7.3% in 2016, and 6.2% in 2017. Only 4.6% of small businesses in the assessment area were located in low-income census tracts in 2015 through 2017. In addition, the bank outperformed the aggregate lenders during the three year review period; in 2015, 2016, and 2017, aggregate lenders originated 4.9%, 4.7%, and 4.0% of loans, respectively, to businesses located in low- income areas.

Frost’s small business lending in moderate-income tracts is excellent. During the review period, Frost originated 20.4% of its small business loans in moderate-income census tracts in 2015 and 22.8% in both 2016 and 2017. In 2015 and 2016, 20.0% of small businesses in the assessment area were located in moderate-income tracts and slightly increased to 21.4% in 2017. The bank outperformed the aggregate during the review period, as aggregate lenders originated 18.6%, 18.3%, and 19.9% of loans to businesses located in moderate-income tracts in 2015, 2016, and 2017, respectively.

The bank’s small business lending in middle and upper income tracts was lower than the percentage of small businesses in these tracts. When compared to the aggregate by percentage, the bank originated a similar number of loans in middle – and upper – income tracts from 2015 through 2017.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

Community Development Lending

The bank is a leader in making community development loans in the assessment area. The bank originated 87 community development loans totaling $347.3 million during the review period. This is a 52.0%, by dollar, increase from the previous evaluation in 2015 when Frost originated 42 loans for $228.4 million. The bank’s commitment to making qualified community development loans demonstrates an excellent responsiveness to the different needs in the assessment area. The table below provides a breakdown of the types of community development loans originated by Frost during the review period.

Community Development Lending Purpose # $000s Affordable Housing 18 $43,852 Community Services 66 $296,660 Economic Development 2 $2,000 Revitalization and Stabilization 1 $4,750 Total 87 $347,262

The majority of the loans provided working capital to organizations that offer community services to LMI individuals. Some of these services were to provide Medicaid gap funding, education facilities – such as the development of two new schools which service economically disadvantaged students - social services, and general assistance to LMI individuals. Some of the affordable housing loans were made for development of real estate for the benefit of a majority of low-income persons, as well as revitalization loans for the development of multi-family housing for the LMI community.

Frost had total investments of $70.1 million, which includes prior period investments of $7.0 million. This level of investments has decreased 37.2% from the previous evaluation. Frost is the largest purchaser of school bonds in Texas; however, for this evaluation period the investment in school bonds significantly decreased from the previous evaluation due to lack of availability. Also, mortgaged-backed security pools in San Antonio decreased since the previous evaluation due to decreased home purchases by LMI borrowers.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

The bank made 384 donations totaling $2.8 million. The majority of the donations involved community services targeted to LMI individuals. However, the bank also donated to organizations that provide services, including loans to small businesses. Some of these organizations include LiftFund and PeopleFund.

Community Development Investments Current Period Donations Total Investments Purpose # $ # $ # $ Affordable Housing 6 $48,065,640 16 $88,833 22 $48,154,473 Community Services 1 $13,875,000 332 $2,651,031 333 $16,526,031 Economic Development 3 $1,121,360 20 $86,500 23 $1,207,860 Revitalization and 0 0 2 $2,000 2 $2,000 Stabilization Total 10 $63,062,000 370 $2,828,364 380 $65,890,364

Service Test

The bank’s Service Test performance is good. The retail services reflect good responsiveness to the needs of the assessment area; however, the community development services reflect excellent responsiveness to the assessment area needs.

Retail Services

The bank’s delivery systems are reasonably accessible to the bank’s geographies and individuals of different income levels in its assessment area. The distribution of the bank’s 29 branch offices and 32 ATMs as of December 31, 2017, was compared to the distribution of households and businesses among the tract categories within the assessment area. The table below summarizes the bank’s retail locations in the San Antonio – New Braunfels, TX Assessment Area.

Full Service Cash Only Tract % of % of Branches ATMs ATMS Income Geographies Population # % # % # % Low 8.0 6.0 1 3.4 1 3.1 0 0 Moderate 32.2 29.6 4 13.8 4 12.5 0 0 Middle 27.1 29.1 10 34.5 11 34.4 0 0 Upper 31.8 35.3 14 48.3 16 50.0 0 0 Unknown 0.9 0.0 0 0.0 0 0 0 0 Total 100 100 29 100 32 100 0 0

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 San Antonio-New Braunfels, TX

The bank opened four branches (one in a low- and three in upper-income tracts) and closed two branches (one in a moderate-income tract and one in a middle-income tract) in the assessment area. The bank's record of opening or closing branches has not adversely affected the accessibility of its delivery systems, including to LMI income geographies. Banking services and hours of operations do not vary in a way that inconveniences the assessment area, particularly in LMI geographies or to LMI individuals. The level of branch services and hours offered are basically the same throughout the assessment area.

Community Development Services

The bank is a leader in providing community development services in the assessment area. The bank’s employees served in many various capacities, including boards of directors and as trustees, for 176 community development financial organizations offering community development services that focused on providing services that aided LMI individuals. Total hours served during the review period was approximately 8,956 hours. The table below shows the number of hours by type of involvement.

Purpose Hours Served Affordable Housing 1,054 Benefits LMI Individuals/Geographies 7,087 Revitalize/Stabilize 0 Provides Economic Development 815 Total 8,956

Frost was particularly responsive in the bank’s involvement throughout the assessment area by partnering with the Volunteer Income Tax Association (VITA) to offer tax preparation services to customers (and individuals in the surrounding areas) in four of their financial centers located in LMI census tracts. The bank also sponsored a Federal Home Loan Bank of Dallas Affordable Housing Grant for Adult and Teen Challenge, for its San Antonio Campus, which was approved to build 60 LMI units. Adult and Teen Challenge is a non-profit that provides drug and alcohol rehabilitation services to men and women. Frost also provided ongoing financial literacy training to this organization.

Frost is a leader in providing financial literacy through programs like Frost’s Financial Youth Academy to schools with a majority of students who are considered economically disadvantaged. The bank also hosted the Frost Home Mini-Expo which, as previously mentioned, teaches home improvement skills to LMI homeowners. This event also provides homeowners information such as how to choose a reputable home remodel company, information on different city programs, services, and assistance programs provided by local utility companies. There are also “how to” sessions on home maintenance and home repair. These seminars are targeted to LMI homeowners and are held in a location in an LMI census tract. Frost continues to provide free mortgage loan servicing for Habitat for Humanity, which allows them to provide 0% interest to its homeowners.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

METROPOLITAN AREAS (Full Scope Review)

Description of Operations in Corpus Christi, TX Assessment Area

The Corpus Christi, TX Assessment Area includes Nueces and San Patricio Counties. These counties, along with Aransas County, which is excluded from the assessment area, make up the Corpus Christi, TX MSA. As of 2017, the assessment area contains six low- 27 moderate-, 31 middle-, and 31 upper-income census tracts. There are also three census tracts where the income is unknown. As of December 31, 2017 the bank operated nine branches in the assessment area representing 6.3% of its total bank branches. There is one branch located in a low-income tract, and one located in a moderate-income tract. There are four branches located in middle-, and three branches located in upper- income tracts.

According to the 2015 Census, the assessment area population was 418,130, which accounts for 1.6% of the population in the state. Based on the 2010 population of 405,030, the assessment area has experienced an increase of 3.2% over the last five years. Corpus Christi, the largest city within the assessment area, accounts for 77.9% of the population in the assessment area. The following table provides further information.

% 2017 Increase County Population Major Municipalities Since Estimate 2010 Nueces 361,221 6.2 Corpus Christi (County Seat)

San Patricio 67,215 3.7 Portland (Sinton County Seat)

According to the FDIC, as of June 30, 2017, the bank had $1.4 million in deposits in this assessment area representing 5.4% of the bank’s total deposits. Frost holds the largest deposit share at 23.5%, followed by American Bank, N.A. at 16.9%, and Wells Fargo Bank, N.A., at 14.3%. Many of the bank’s competitors are statewide and multi-regional banks, but competition does not appear to have adversely affected the bank’s ability to serve the credit needs of its assessment area, specifically in regards to small business lending.

The bank originated 230 HMDA reportable loans in 2015, 2016, and 2017, which represented 3.2% of its total HMDA lending. The bank ranked 32nd out of 367 institutions in 2015, 29th out of 365 in 2016, and 35th out of 365 in 2017 in the origination of HMDA reportable loans. The top ranked reporters were Wells Fargo Bank, N.A.; Navy Army Community Credit Union; and US Bank, N.A.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

The bank originated 571 small business loans in 2015, 2016, and 2017, which represented 4.0% of its total small business lending. The bank ranked 10th out of 69 institutions in 2015, 11th out of 82 institutions in 2016, and 11th out of 87 institutions in 2017 in the origination of small business loans. The top ranked reporters were credit card issuers, including American Express Bank, FSB; Citibank, N.A., and Capital One Bank USA, N.A.

Demographic Characteristics

The Corpus Christi, TX Assessment Area is a metropolitan area in South Texas 130 miles southeast of San Antonio, TX. The coastal city of Corpus Christi, TX, the largest city in the MSA, is the hub of the six-county Corpus Christi-Kingsville-Alice, TX Combined Statistical Area. Corpus Christi is tucked into a bay and its beaches are sheltered by Padre and Mustang Islands.

The assessment area borders the Gulf of Mexico to the east. Bee and Refugio Counties are to the north of the assessment area, Kleberg County to the south, Jim Wells County to the west, and the Mexico border is 168 miles to the south. As of 2015, the specific assessment area consists of 98 census tracts, of which 33.7% are low- or moderate- income (six low- and 27 moderate-income). There are also 31 (31.6%) middle- and 31 (31.6%) upper-income census tracts, with three (3.1%) census tracts where the income designation is unknown.

Income Characteristics For purposes of classifying borrower income, this evaluation uses both 2010 U.S. Census data and 2015 estimated data for the relevant area. The following chart reflects the estimated median family income for the years 2015 through 2017 for the Corpus Christi, TX MSA. It also provides a range of the estimated annual family income for each income category (low, moderate, middle, and upper). According to the 2015 Census, 13.6% of the families in the assessment area lived below the poverty level.

Income Level 2015 2016 2017 Median Income $58,800 $58,800 $63,100 Low-income < $29,400 < $29,400 < $31,550 Moderate-income $29,401 - $47,040 $29,401 - $47,040 $31,551 - $50,480 Middle-income $47,041 - $70,560 $47,041 - $70,560 $50,481 - $75,720 Upper-income ≥ $70,561 ≥ $70,561 ≥ $75,721

Housing Characteristics Over the past three years, the median housing price for homes in Corpus Christi, TX MSA has increased 3.6% from $180 thousand in 2015 to $186.4 thousand in 2017. In the Corpus Christi, TX MSA, an average of 1,750 building permits for new privately-owned housing units were issued each year from 2015 to 2017.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

The Corpus Christi, TX MSA has fared well in terms of mortgages considered seriously delinquent (defined as more than 90 days past due or in foreclosure) compared to many metropolitan areas in the country, which range from 0.2% to 6.9% throughout the nation as of December 2017. The delinquency rate for seriously delinquent mortgages for the MSA was 0.9% which is below the national average of 1.0%.14

According to the 2015 Census, there were 171,296 housing units in the assessment area with 51.4% of the units classified as owner-occupied while 36.0% are classified as rental units and 12.6% of the available housing is vacant. Overall, 5.2% of the housing stock in the assessment area is in low-income tracts. In these census tracts, 34.4% of the housing units are owner-occupied, 48.7% are rental units, and 16.9% are vacant.

The 2010 median age of housing stock in these tracts is 53 years and the median housing value in low-income tracts for the assessment area also in 2010 was $60 thousand. By 2015, this number had decreased to $47 thousand, which is a 21.7% decrease. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed-rate, 30 year loan, a home of this value would be still be considered affordable for a low-income family, although a barrier to homeownership is typically a down payment. The monthly rental payment in low- income tracts in 2015 was $575, which is less affordable than the monthly mortgage payment of $224 for a $47 thousand home for 30 years at 4.0% interest rate. However, 14.1% of families in low-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

Moderate-income tracts account for 28.6% of the housing stock in the assessment area. In these census tracts, 47.6% of the housing units are owner-occupied, 40.5% are rental units, and 11.9% are vacant. The median age of housing stock in these tracts is 53 years and the median housing value in moderate-income tracts for the assessment area in 2010 was $60.5 thousand. By 2015, this number had increased to $72.1 thousand, which is a 19.2% increase. Using the 2015 income level for assessment area families, and assuming an average mortgage payment equal to 28% of gross income for a 4.0% fixed- rate, 30 year loan, a home of this value would be affordable for a moderate-income family, although a barrier to homeownership is typically a down payment. However, 44.2% of families in moderate-income tracts have incomes below the poverty level, which may make it difficult to qualify for a loan.

A large portion of the housing stock in the assessment area, at 32.1%, is in middle-income tracts. In these census tracts, 50.2% of the housing units are owner-occupied, 36.0% are rental units, and 13.8% are vacant. In 2015, the median age of housing stock in these tracts is 45 years and 27.3% of families in middle-income tracts have incomes below the poverty level. The median housing value in middle-income tracts for the Corpus Christi,

14 Consumer Financial Protection Bureau (CFPB) Mortgages 90 or more days delinquent. Available at https://www.consumerfinance.gov/data-research/mortgage-performance-trends/mortgages-90-or-more-days- delinquent/#mp-line-chart-container. Accessed Oct. 8, 2018. 62

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

TX Assessment Area in 2010 was $95.5 thousand. By 2015, this number had increased to $100.8 thousand, which is a 5.5% increase.

Approximately 34.1% of the housing stock in the assessment area is in upper-income tracts. In these census tracts, 58.2% of the housing units are owner-occupied, 30.4% are rental units, and 11.4% are vacant. In 2015, the median age of housing stock in these tracts is 35 years and only 14.4% of families in upper-income tracts have incomes below the poverty level. In addition, the median housing value in upper-income tracts for the assessment area in 2010 was $153.9 thousand. By 2015, this number had increased to $163.4 thousand, which is a 6.1% increase.

Employment and Economic Conditions The national average unemployment rates for 2015, 2016, and 2017 were 5.3%, 4.9%, and 4.4%. Unemployment rates for all of the counties in the assessment area were comparable, or higher, than the annual unemployment rates for Texas and the national average. According to the 2010 Census, the unemployment rate was 14.2% in low- income tracts and 10.2% in moderate-income tracts. By 2015, the unemployment rate had decreased to 12.2% and 7.7% in low- and moderate-income tracts, respectively. However, high unemployment rates in LMI tracts could affect loan demand from these tracts.

The following chart shows unemployment rates relevant to the assessment area for 2015, 2016, and 2017.

Annual Average Unemployment Rate15 AREA 2015 2016 2017 Nueces County 4.9% 5.6% 5.4% San Patricio County 6.5% 7.5% 7.6% Corpus Christi, TX MSA 5.2% 5.9% 5.8% State of Texas 4.4% 4.6% 4.3% United States 5.3% 4.9% 4.4%

Much of the local economy in the Corpus Christi, TX Assessment Area is driven by tourism, energy, and defense industries. The City of Corpus Christi is home to the Naval Air Station and the Port of Corpus Christi, the fifth-largest port in the United States. As of 2017, the top employers in the assessment area included: Corpus Christi Independent School District; the Naval Air Station; H.E.B Stores and Bakery; CHRISTUS Spohn Hospital; and Corpus Christi Army Depot. Tourism is fueled by attractions such as the Texas State Aquarium and the USS Lexington Museum on the Bay. The City of Corpus Christi is also near Padre and Mustang Islands, as well as King Ranch, one of the world’s

15 Bureau of Labor Statistics: Local Area Unemployment Statistics. http://www.bls.gov/data/#unemployment Accessed: Oct. 8, 2018. 63

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX largest ranches. There are three institutions of higher learning, including Texas A&M University-Corpus Christi, Del Mar College, and Saint Leo University-Corpus Christi16.

Community Contacts and Community Development Opportunities

One community contact, working in the non-profit sector, was interviewed for the Corpus Christi, TX Assessment Area. The contact noted the need for affordable housing and financial education. The contact also said the Colonias17 in the area are experiencing poor infrastructure. The contact also mentioned the need for financial assistance and felt a first time home buyer program would also be beneficial in the area.

Key Assessment Area Demographics

The following table details selected characteristics of the assessment area.

16 https://study.com/corpus_christi. Accessed: February 1, 2019 17 Colonias: residential areas along the Texas-Mexico border that may lack basic living necessities like potable water, septic or sewer systems, electricity, paved roads, or safe and sanitary housing. Source:https://www.dallasfed.org/assets/documents/cd/pubs/lascolonias.pdf. Accessed: February 1, 2019 64

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

Combined Demographics Report Assessment Area: Corpus Christi Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 6 6.1 5,034 4.8 2,007 39.9 23,366 22.4 Moderate-income 27 27.6 29,640 28.4 6,292 21.2 18,041 17.3 Middle-income 31 31.6 33,406 32 3,883 11.6 18,906 18.1 Upper-income 31 31.6 36,199 34.7 2,047 5.7 43,973 42.2 Unknown-income 3 3.1 7 0 0 0 0 0 Total Assessment Area 98 100.0 104,286 100.0 14,229 13.6 104,286 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 8,893 3,062 3.5 34.4 4,327 48.7 1,504 16.9 Moderate-income 49,007 23,332 26.5 47.6 19,828 40.5 5,847 11.9 Middle-income 55,047 27,618 31.4 50.2 19,821 36 7,608 13.8 Upper-income 58,342 33,976 38.6 58.2 17,710 30.4 6,656 11.4 Unknown-income 7 7 0 100 0 0 0 0 Total Assessment Area 171,296 87,995 100.0 51.4 61,686 36.0 21,615 12.6 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 486 3.5 425 3.4 52 4 9 5.7 Moderate-income 4,303 30.9 3,752 30.1 503 38.9 48 30.2 Middle-income 4,395 31.6 3,863 31 485 37.5 47 29.6 Upper-income 4,718 33.9 4,419 35.4 245 18.9 54 34 Unknown-income 24 0.2 15 0.1 8 0.6 1 0.6 Total Assessment Area 13,926 100.0 12,474 100.0 1,293 100.0 159 100.0 Percentage of Total Businesses: 89.6 9.3 1.1 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 4 1.2 4 1.2 0 0 0 0 Moderate-income 94 27.2 91 27.4 3 21.4 0 0 Middle-income 83 24 76 22.9 7 50 0 0 Upper-income 165 47.7 161 48.5 4 28.6 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 346 100.0 332 100.0 14 100.0 0 .0 Percentage of Total Farms: 96.0 4.0 .0 2017 FFIEC Census Data and 2017 D&B Information 65

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

Conclusions With Respect to Performance Tests

Lending Test

The bank is both a small business and HMDA lender. During the review period, the bank reported 571 (71.3%) small business loans compared to 230 (28.7%) HMDA loans in the Corpus Christi, TX Assessment Area. Therefore, small business lending was given more weight than HMDA lending in determining the bank’s Lending Test rating in the assessment area.

Details of the bank’s mortgage and small business lending and information regarding lending by peers can be found in Appendix E.

Lending to Borrowers of Different Income Levels and Businesses of Different Sizes

The bank’s distribution of lending to borrowers reflects a good penetration among individuals of different income levels (including low- and moderate-income) and businesses revenue of different sizes.

Frost’s HMDA lending to low-income borrowers is good. In 2015 and 2016, the bank originated 16.4% and 9.1%, respectively, of its total HMDA loans to low-income borrowers, which exceeded the 2.1% of total HMDA loans originated by the aggregate in 2015 and 2.0% in 2016 to low-income borrowers. In 2017, the bank’s originations to low- income borrowers rose to 10.1% and again exceeded aggregate lending at 2.8% of total HMDA loans. Low-income families made up 24.5% of total families in the assessment area in 2015 and 2016 and 22.4% in 2017, meaning that both the bank and aggregate lending were below demographics.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

The bank’s HMDA lending to moderate-income borrowers is good. In 2015 and 2016, the bank originated 13.7% and 19.3%, respectively of its total HMDA loans to moderate- income borrowers, which exceeded aggregate HMDA lenders in 2015 at 8.7% and 8.0% in 2016. In 2017, the bank again exceeded aggregate originating 10.1% of HMDA loans to moderate-income borrowers compared to aggregate lenders at 9.9%. In 2015 and 2016, 16.3% of families living in the assessment area were considered moderate-income. In 2017, that number rose to 17.3% of families. During the review period, the bank and the aggregate’s lending were below demographics, except in 2016 when the bank’s percent of lending to moderate-income borrowers exceeded the demographics.

Small Business Lending

Considering the bank’s performance when compared to the aggregate, the borrower distribution of small business loans by revenue size of businesses is good. Of the 571 small business loans originated during the review period by Frost, 36.1% were originated to small businesses in 2015, 42.3% in 2016, and 45.5% in 2017. Frost’s performance exceeded the aggregate in 2016 at 37.7% and 2017 at 38.7%, but was below the aggregate in 2015 at 36.1%. Both Frost and the aggregate’s percentage of loans originated to small businesses was less than the percentage of businesses with annual gross revenue of $1 million or less at 90.8% in 2015 and 2016, and decreased to 89.6% in 2017, in the Corpus Christi, TX Assessment Area.

Another way to gauge the bank’s small business lending performance is to review the data by loan amount. Small businesses typically require smaller dollar credits. In this regard, it is noted that 42.9% and 43.5% of the bank’s commercial loans were made in loan amounts of $100,000 or less in 2015 and 2016, respectively, and 43.4% in 2017. Frost’s performance was below the aggregate performance in all three years. However, the largest small business lenders in the assessment area predominately offer credit cards, a product not offered by Frost.

Geographic Distribution of Loans

For this analysis, the geographic distribution of small business lending and HMDA lending, including both originations and purchases, was compared with available demographic information. Performance context issues and aggregate lending data were taken into consideration. Considering all of these factors, the bank’s geographic distribution of loans reflects excellent penetration throughout the assessment area. Loans were generally made in close proximity to the bank’s branches and there were no conspicuous gaps or anomalies in the lending patterns.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

HMDA Loan Geographic Distribution

Home Purchase Lending Home purchase lending in low-income census tracts is adequate. During the review period, Frost did not originate any home purchase loans in low-income census tracts; however, 6.9% of owner-occupied units in the assessment area were located in low- income census tracts in 2015 and 2016, and significantly decreased to 3.5% in 2017. Aggregate lenders also struggled to originate home purchase loans at a level comparable to the percentage of owner occupied units in low-income census tracts. In 2015, 2016, and 2017, the aggregate lenders originated 1.7%, 1.6%, and 0.4% of home purchase loans in low-income tracts, respectively.

Home purchase lending in moderate-income tracts is adequate. The bank originated one loan in 2016, at 6.5%, and zero loans in 2015 and 2017. In 2015 and 2016, the bank’s percentage of originations was below the percentage of moderate-income owner occupied units in the assessment area at 19.8% and at 26.5% in 2017. The bank’s performance was above the aggregate in 2016 who originated 6.5% of home purchase loans in moderate-income census tracts but below aggregate in 2015 and 2017, who originated 5.8% of home purchase loans in moderate-income census tracts.

Home Refinance Lending Home refinance lending in low-income census tracts is good. Frost did not originate any home refinance loans in low-income tracts in 2015 or 2017 and originated one loan in 2016 at 1.7%. As mentioned previously, 6.9% of owner-occupied units in the assessment area were located in low-income census tracts in 2015 and 2016, and only 3.5% in 2017. Aggregate lenders also struggled to originate home purchase loans at a level comparable to the percentage of owner-occupied units in low-income census tracts; however, Frost performed above the aggregate in 2016. Aggregate lenders originated 1.4%, 1.7%, and 0.4% of home refinance loans in low-income census tracts in 2015, 2016, and 2017, respectively.

Frost’s home refinance lending in moderate-income tracts is adequate. The bank did not originate any home refinance loans in 2015 or 2017 and originated one loan in 2016 at 6.5%. The bank’s performance was below the 19.8% of owner-occupied units in the assessment area in 2015 and 2016, and 26.5% in 2017. Frost’s performance was below the aggregate in 2015 and 2017, when aggregate lenders originated 6.9% and 12.9% of home refinance loans in moderate-income census tracts; however, the bank performed above the aggregate in 2016, when aggregate originated 6.5% of this loan type in these tracts.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

Home Improvement Lending Home improvement lending in low-income census tracts is excellent. Frost originated 8.9%, 5.7%, and 3.6% of its home improvement loans in low-income census tracts in 2015, 2016, and 2017, respectively. In 2015 and 2016, 6.9% of owner-occupied units in the assessment area were located in these tracts and only 3.5% in 2017. Frost outperformed the aggregate for each year during the review period. The aggregate originated 3.1%, 5.7%, and 3.3% of home improvement loans in low-income tracts in 2015, 2016, and 2017, respectively.

Frost’s home improvement lending in moderate-income census tracts is good when compared to the aggregate and percentage of owner-occupied units in these tracts. Frost originated 25.0%, 24.3%, and 16.1% of its home improvement loans in moderate-income tracts in 2015, 2016, and 2017, respectively; these tracts contained 19.8% of owner- occupied units in the assessment area in 2015 and 2016 and 26.5% in 2017. Frost outperformed the aggregate in 2015 and 2016, but performed below the aggregate in 2017. The aggregate originated 12.8% of home improvement loans in moderate-income tracts in 2015, 11.6% in 2016, and 21.4% in 2017.

Small Business Loan Geographic Distribution

Frost’s small business lending in low-income census tracts is excellent. Frost originated 21.0%, 17.3%, and 5.6% of its small business loans in low-income census tracts in 2015, 2016, and 2017, respectively; these tracts contain 14.1% of small businesses in the assessment area in 2015 and 2016, and decreased to 3.4% in 2017. In addition, the bank outperformed the aggregate lenders during the three year review period, as aggregate lenders originated 15.1% of small business loans in low-income census tracts in both 2015 and 2016 and 2.8% in 2017.

The bank’s small business lending in moderate-income tracts is excellent. Frost originated 21.5%, 23.8%, and 23.2% of its small business loans in moderate-income census tracts in 2015, 2016, and 2017, respectively; these tracts contained 16.5% of small businesses in the assessment area in 2015 and 2016, and 30.1% in 2017. The bank outperformed the aggregate in 2015 and 2016, but was below aggregate in 2017. In 2015, 2016, and 2017, aggregate lenders originated 17.8%, 18.1%, and 28.1% of small business loans in moderate-income tracts, respectively.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

Community Development Lending

The bank makes a relatively high level of community development loans in the assessment area. The bank originated 10 community development loans totaling $7.1 million during the review period. This is an 87.0%, by dollar, increase from the previous evaluation in 2015 when Frost originated 10 loans for $3.8 million. The bank’s commitment to making qualified community development loans demonstrates good responsiveness to the different needs in the assessment area. The table below provides a breakdown of the types of community development loans originated by Frost during the review period.

Community Development Lending Purpose # $000s Affordable Housing 4 $5,875 Community Services 6 $1,260 Economic Development 0 $0 Revitalization and Stabilization 0 $0 Totals 10 $7,135

Community development loans were a mix of loans distributed between affordable housing and community services. Loans were made for the repair and maintenance of facilities that benefit the homeless population. A line of credit was funded for a rehabilitation center that services a majority (75% or more) of LMI clients and a loan was originated for the development of multi-family housing for the LMI community.

The total amount of investments and contributions for the review period are $6.7 million, which includes prior period investments of $471 thousand. Investments have decreased 26.5% from the previous evaluation in 2015. Frost is the largest purchaser of school bonds in Texas; however, for this evaluation period the investment in school bonds significantly decreased from the previous evaluation due to a lack of availability. Also, mortgaged-backed security pools in Corpus Christi decreased since the previous evaluation due to decreased home purchases by LMI borrowers.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

The bank made 91 donations totaling $388 thousand. The majority of the donations involved community services targeted to LMI individuals, as well as providing assistance to small businesses with financial and business education.

During the Hurricane Harvey disaster in 2017, Frost donated a $200 thousand grant to the Corpus Christi area (including Victoria, TX) which provided assistance to non-profit entities that were providing services and outreach to those affected by the hurricane. This was part of the bank’s overall $1 million commitment to Hurricane Harvey Relief events throughout the State of Texas.

Community Development Investments Current Period Donations Total Investments Purpose # $ # $ # $ Affordable Housing 6 $4,004,703 4 $5,100 10 $4,009,803 Community Services 1 1,800,000 87 $361,103 88 $2,161,103 Economic Development 0 0 6 $22,250 6 $22,250 Revitalization and 0 0 0 0 0 0 Stabilization Total 7 $5,804,703 97 $388,453 104 $6,193,156

Service Test

The bank’s Service Test performance is good. The retail services reflect good responsiveness to the needs of the assessment area; however, the level of community development services reflects excellent responsiveness to the needs of the assessment area.

Retail Services

The bank’s delivery systems are accessible to the bank’s geographies and individuals of different income levels in its assessment area. The distribution of the bank’s nine branch offices and eight ATMs as of December 31, 2017, was compared to the distribution of households and businesses among the tract categories within the assessment area. The table below summarizes the bank’s retail locations in the Corpus Christi assessment area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

Full Service Cash Only Tract % of % of Branches ATMs ATMS Income Geographies Population # % # % # % Low 6.1 4.9 1 11.1 1 12.5 0 0 Moderate 27.6 28.8 1 11.1 1 12.5 0 0 Middle 31.6 31.7 4 44.5 3 37.5 0 0 Upper 31.6 34.6 3 33.3 3 37.5 0 0 Unknown 3.1 0.0 0 0 0 0 0 0 Total 100 100 9 100 8 100 0 0

The bank did not open, or close, any branches in the assessment area during the three year review period. The bank's record of opening or closing branches has not adversely affected the accessibility of its delivery systems, including to LMI income geographies. Banking services and hours of operations do not vary in a way that inconveniences the assessment area, particularly in LMI geographies or to LMI individuals. The level of branch services and hours offered are basically the same throughout the assessment area.

Community Development Services

The bank is a leader in providing community development services in the assessment area. The bank’s employees served in many various capacities, including on boards of directors and as trustees, for 56 different organizations offering community development services. Total hours served during the review period was approximately 2,371 hours, a 199.0% increase from the previous evaluation. The table below shows the number of hours by type of involvement.

Purpose Hours Served Affordable Housing 230 Benefits LMI Individuals/Geographies 1,888 Revitalize/Stabilize 0 Provides Economic Development 253 Total 2,371

Particularly responsive is the bank’s involvement throughout the assessment area in providing financial literacy through programs like Frost’s Financial Youth Academy to schools with a majority of students who are considered economically disadvantaged. The bank also hosted the Frost Home Mini-Expo in 2016 and 2017, which is an outreach program that teaches home improvement skills to LMI homeowners. This event provides homeowners information such as how to choose a reputable home remodel company, information on different city programs, services, and assistance programs provided by local utility companies, as well as - “how to” sessions on home maintenance and home repair.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Corpus Christi, TX

During the review period, the bank began providing financial educational classes to the Salvation Army and Metro Ministries for clientele in the transitional residences and the Corpus Christi Workforce Solutions. The bank also worked with the Salvation Army in Corpus Christi to help the organization acquire a Federal Home Loan Bank of Dallas Affordable Housing Grant, which was approved to build 220 LMI units.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Metropolitan Areas Reviewed Using Limited Scope Procedures

METROPOLITAN AREAS (Limited Scope Review)

The following metropolitan assessment areas were reviewed using limited-scope examination procedures.

Description of Institution’s Operations

• Brownsville-Harlingen, TX MSA Assessment Area - As of December 31, 2017, the bank operated two branches in the assessment area, representing 1.4.% of its branches. - As of June 30, 2017, the bank had $205.4 million in deposits in this assessment area, representing a market share of 4.9%. The $205.4 million also represents 0.8% of the bank’s total deposits. • Midland, TX MSA Assessment Area - As of December 31, 2017, the bank operated four branches in the assessment area, representing 2.8% of its branches. - As of June 30, 2017, the bank had $851.1 million in deposits in this assessment area, representing a market share of 12.5%. The $851.2 million also represents 3.3% of the bank’s total deposits. • Odessa, TX MSA Assessment Area - As of December 31, 2017, the bank operated three branches in the assessment area, representing 2.1% of its branches. - As of June 30, 2017, the bank had $376.8 million in deposits in this assessment area, representing a market share of 13.4%. The $376.8 million also represents 1.5% of the bank’s total deposits. • Austin-Round Rock-San Marcos, TX MSA Assessment Area - As of December 31, 2017, the bank operated 19 branches in the assessment area, representing 13.4% of its branches. - As of June 30, 2017, the bank had $3.1 billion in deposits in this assessment area, representing a market share of 7.5%. The $3.1 billion also represents 11.9% of the bank’s total deposits. • Fort Worth-Arlington, TX MD Assessment Area - As of December 31, 2017, the bank operated 25 branches in the assessment area, representing 17.6% of its branches. - As of June 30, 2017, the bank had $4.7 billion in deposits in this assessment area, representing a market share of 11.8%. The $4.7 billion also represents 18.2% of the bank’s total deposits. • McAllen-Edinburg-Mission, TX MSA Assessment Area - As of December 31, 2017, the bank operated three branches in the assessment area, representing 2.1% of its branches. - As of June 30, 2017, the bank had $573.9 million in deposits in this assessment area, representing a market share of 6.2%. The $573.9 million also represents 2.2% of the bank’s total deposits.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Metropolitan Areas Reviewed Using Limited Scope Procedures

Conclusions With Respect to Performance Tests

Through the use of available facts and data, including performance and demographic information, each assessment area’s performance was evaluated and compared with the bank’s performance in the state. The conclusions regarding performance are provided in the table below. Please refer to the tables in Appendix D for information regarding detailed demographic information. The HMDA and CRA lending information for the limited scope assessment areas can be found in Appendix F.

Assessment Area Lending Test Investment Test Service Test Brownsville-Harlingen, TX Consistent Consistent Consistent Midland, TX Consistent Consistent Consistent Odessa, TX Consistent Consistent Consistent Austin-Round Rock-San Marcos, TX Consistent Consistent Consistent Fort Worth-Arlington, TX Consistent Consistent Consistent McAllen-Edinburg-Mission, TX Below Consistent Consistent

As stated earlier, four assessment areas received full-scope reviews, and the bank’s performance in the San Antonio-New Braunfels, TX Assessment Area was given greatest consideration in determining the overall rating for the state because it is by far the bank’s largest market in terms of deposits, loans, and branches.

The performance in the limited-scope assessment areas did not change the bank’s overall rating.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendices

APPENDICES

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix A

Appendix A – Scope of Examination

SCOPE OF EXAMINAITON Time Period Reviewed Lending Test: January 1, 2015 to December 31, 2017 Community Development Loans, Investment Test, and Service Tests: January 1, 2015 to December 31, 2017 Financial Institution Products Reviewed Frost Bank CRA and HMDA Reportable San Antonio, TX Community Development Loans Affiliates Affiliate Products Reviewed Relationship None NA NA List of Assessment Areas Assessment Area Type of Examination Branches Visited Other Information Austin-Round Rock-San Limited Scope 0 NA Marcos, TX (MSA 12420) Brownsville-Harlingen, TX Limited Scope 0 NA (MSA 15180) Corpus Christi, TX Full Scope 0 NA (MSA 18580) Dallas-Plano-Irving, TX Full Scope 0 NA (MSA 19124) Fort Worth-Arlington, TX Limited Scope 0 NA Houston-The Woodlands- Full Scope 1/The Woodlands NA Sugar Land, TX (MSA Financial Center 26420) McAllen-Edinburg-Mission, Limited Scope 0 NA TX (MSA 32580) Midland, TX (MSA 33260) Limited Scope 0 NA Odessa, TX (MSA 36220) Limited Scope 0 NA San Antonio-New Braunfels, Full Scope 1/Blanco-1604 NA TX (41700) Financial Center

Note: Branches visited indicates where technical compliance with the CRA (signs, public file, etc.) was confirmed. The evaluation of the institution’s CRA performance takes into consideration activity from all branch locations, as described in the Scope of Examination.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix B

Appendix B – General Information

Acronyms

ATM Automated Teller Machine CDC Community Development Corporation CDFI Community Development Financial Institution CRA Community Reinvestment Act (Regulation BB) FDIC Federal Deposit Insurance Corporation HMDA Home Mortgage Disclosure Act (Regulation C) HUD Department of Housing and Urban Development LIHTC Low Income Housing Tax Credit LMI Low- and Moderate-Income LTD Loan-to-Deposit Ratio LTV Loan-to-Value Ratio MD Metropolitan Division MSA Metropolitan Statistical Area OCC Office of the Comptroller of the Currency OMB Office of Management and Budget REIS Regional Economic Information System SBA Small Business Administration USDA United States Department of Agriculture

Rounding Convention: Because the percentages in the tables were rounded to the nearest tenth in most cases, some columns may to total exactly to 100 percent.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix C

Appendix C - Glossary

Aggregate lending: The number of loans originated and purchased by all reporting lenders in specified income categories as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area.

Census tract: A small, relatively permanent statistical subdivision of a county. Census tract boundaries do not cross county lines; however, they may cross the boundaries of metropolitan statistical areas. Census tracts average about 4,000 inhabitants, and their physical size varies widely depending upon population density. Census tracts are designed to be homogeneous with respect to the population characteristics, economic status, and living conditions to allow for statistical comparisons.

Community development: All Agencies have adopted the following language: 1. Affordable housing (including multi-family rental housing) for low- or moderate- income individuals. 2. Community services targeted to low- or moderate-income individuals. 3. Activities that promote economic development by financing businesses or farms that meet the size eligibility standards of the Small Business Administration’s Development Company or Small Business Investment Company programs (13 CFR 121.301) or have gross annual revenues of $1 million or less. 4. Activities that revitalize or stabilize – a. Low- or moderate-income geographies. b. Designated disaster areas. c. Distressed or underserved nonmetropolitan middle-income geographies designated by the Board, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency, based on- i. Rates of poverty, unemployment, and population loss. ii. Population size, density, and dispersion. Activities that revitalize and stabilize geographies designated based on population size, density, and dispersion if they help to meet essential community needs, including needs of low- and moderate-income individuals. 5. Loans, investments, and services by financial institutions that- a. Support, enable or facilitate projects or activities that meet the “eligible uses” criteria described in Section 2301(c) of the Housing and Economic Recovery Act of 2008 (HERA), Public Law 110-289, 122 Stat. 2654, as amended, and are conducted in designated target areas identified in plans approved by the United States Department of Housing and Urban Development in accordance with the Neighborhood Stabilization Program (NSP). b. Are provided no later than two years after the last date funds appropriated for the NSP are required to be spent by grantees.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix C

c. Benefit low-, moderate-, and middle-income individuals and geographies in the bank's assessment area(s) or areas outside the bank's assessment area(s) provided the bank has adequately addressed the community development needs of its assessment area(s).

Consumer loan(s): A loan(s) to one or more individuals for household, family, or other personal expenditures. A consumer loan does not include a home mortgage, small business, or small farm loan. This definition includes the following categories: motor vehicle loans, credit card loans, home equity loans, other secured consumer loans, and other unsecured consumer loans.

Family: Includes a householder and one or more other persons living in the same household who are related to the householder by birth, marriage, or adoption. The number of family households always equals the number of families; however, a family household may also include non-relatives living with the family. Families are classified by type as either a married-couple family or other family, which is further classified into ‘male householder’ (a family with a male householder and no wife present) or ‘female householder’ (a family with a female householder and no husband present).

Geography: A census tract delineated by the United States Bureau of the Census in the most recent decennial census.

Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders that do business or have banking offices in a metropolitan statistical area to file annual summary reports of their mortgage lending activity. The reports include such data as the race, gender, and income of the applicants; the amount of loan requested; and the disposition of the application (for example, approved, denied, or withdrawn).

Home mortgage loans: Includes home purchase and home improvement loans as defined in the HMDA regulation. This definition also includes multifamily (five or more families) dwelling loans, loans for the purchase of manufactured homes, and refinancing of home improvement and home purchase loans.

Household: Includes all persons occupying a housing unit. Persons not living in households are classified as living in group quarters. In 100 percent tabulations, the count of households always equals the count of occupied housing units.

Low-income: Individual income that is less than 50 percent of the area median income, or a median family income that is less than 50 percent, in the case of a geography.

Market share: The number of loans originated and purchased by the institution as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix C

Metropolitan area (MA): A metropolitan statistical area (MSA) or a metropolitan division (MD) as defined by the Office of Management and Budget. A MSA is a core area containing at least one urbanized area of 50,000 or more inhabitants, together with adjacent communities having a high degree of economic and social integration with that core. A MD is a division of a MSA based on specific criteria including commuting patterns. Only a MSA that has a population of at least 2.5 million may be divided into MDs.

Middle-income: Individual income that is at least 80 percent and less than 120 percent of the area median income, or a median family income that is at least 80 percent and less than 120 percent, in the case of a geography.

Moderate-income: Individual income that is at least 50 percent and less than 80 percent of the area median income, or a median family income that is at least 50 percent and less than 80 percent, in the case of a geography.

Multifamily: Refers to a residential structure that contains five or more units.

Other products: Includes any unreported optional category of loans for which the institution collects and maintains data for consideration during a CRA examination. Examples of such activity include consumer loans and other loan data an institution may provide concerning its lending performance.

Owner-occupied units: Includes units occupied by the owner or co-owner, even if the unit has not been fully paid for or is mortgaged.

Qualified investment: A qualified investment is defined as any lawful investment, deposit, membership share, or grant that has as its primary purpose community development.

Rated area: A rated area is a state or multistate metropolitan area. For an institution with domestic branches in only one state, the institution’s CRA rating would be the state rating. If an institution maintains domestic branches in more than one state, the institution will receive a rating for each state in which those branches are located. If an institution maintains domestic branches in two or more states within a multistate metropolitan area, the institution will receive a rating for the multistate metropolitan area.

Small loan(s) to business(es): A loan included in ‘loans to small businesses’ as defined in the Consolidated Report of Condition and Income (Call Report) and the Thrift Financial Reporting (TFR) instructions. These loans have original amounts of $1 million or less and typically are either secured by nonfarm or nonresidential real estate or are classified as commercial and industrial loans. However, thrift institutions may also exercise the option to report loans secured by nonfarm residential real estate as “small business loans” if the loans are reported on the TFR as nonmortgage, commercial loans.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix C

Small loan(s) to farm(s): A loan included in ‘loans to small farms’ as defined in the instructions for preparation of the Call Report. These loans have original amounts of $500,000 or less and are either secured by farmland, or are classified as loans to finance agricultural production and other loans to farmers.

Upper-income: Individual income that is 120 percent or more of the area median income, or a median family income that is 120 percent or more, in the case of a geography.

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: Brownsville-Harlingen MSA Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 0 0 0 0 0 0 23,636 24.6 Moderate-income 35 40.2 31,176 32.5 13,235 42.5 15,934 16.6 Middle-income 25 28.7 29,773 31 8,861 29.8 15,109 15.7 Upper-income 24 27.6 35,042 36.5 6,280 17.9 41,312 43 Unknown-income 3 3.4 0 0 0 0 0 0 Total Assessment Area 87 100.0 95,991 100.0 28,376 29.6 95,991 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 0 0 0 0 0 0 0 0 Moderate-income 43,679 23,552 29.1 53.9 15,266 35 4,861 11.1 Middle-income 43,828 24,219 29.9 55.3 13,684 31.2 5,925 13.5 Upper-income 57,687 33,114 40.9 57.4 11,262 19.5 13,311 23.1 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 145,194 80,885 100.0 55.7 40,212 27.7 24,097 16.6 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 0 0 0 0 0 0 0 0 Moderate-income 3,334 34 3,029 34.1 280 33.5 25 27.2 Middle-income 2,767 28.2 2,432 27.4 308 36.8 27 29.3 Upper-income 3,701 37.7 3,414 38.4 247 29.5 40 43.5 Unknown-income 10 0.1 8 0.1 2 0.2 0 0 Total Assessment Area 9,812 100.0 8,883 100.0 837 100.0 92 100.0 Percentage of Total Businesses: 90.5 8.5 .9 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 0 0 0 0 0 0 0 0 Moderate-income 39 19.3 38 19.7 1 11.1 0 0 Middle-income 66 32.7 62 32.1 4 44.4 0 0 Upper-income 97 48 93 48.2 4 44.4 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 202 100.0 193 100.0 9 100.0 0 .0 Percentage of Total Farms: 95.5 4.5 .0 2017 FFIEC Census Data and 2017 D&B Information 84

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: Midland Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 1 3.7 1,134 3.1 126 11.1 7,960 21.7 Moderate-income 5 18.5 5,395 14.7 913 16.9 6,439 17.5 Middle-income 12 44.4 16,123 43.9 888 5.5 7,425 20.2 Upper-income 8 29.6 14,050 38.3 466 3.3 14,878 40.5 Unknown-income 1 3.7 0 0 0 0 0 0 Total Assessment Area 27 100.0 36,702 100.0 2,393 6.5 36,702 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 1,549 1,007 2.8 65 329 21.2 213 13.8 Moderate-income 8,097 4,745 13.4 58.6 2,744 33.9 608 7.5 Middle-income 25,924 14,815 41.8 57.1 9,379 36.2 1,730 6.7 Upper-income 21,165 14,882 42 70.3 4,969 23.5 1,314 6.2 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 56,735 35,449 100.0 62.5 17,421 30.7 3,865 6.8 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 129 1.8 107 1.7 21 2.3 1 1.3 Moderate-income 1,882 26.4 1,566 25.6 296 32 20 26 Middle-income 2,533 35.6 2,149 35.1 371 40.1 13 16.9 Upper-income 2,531 35.5 2,268 37.1 222 24 41 53.2 Unknown-income 46 0.6 29 0.5 15 1.6 2 2.6 Total Assessment Area 7,121 100.0 6,119 100.0 925 100.0 77 100.0 Percentage of Total Businesses: 85.9 13.0 1.1 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 1 0.7 1 0.7 0 0 0 0 Moderate-income 20 14.6 19 14 1 100 0 0 Middle-income 35 25.5 35 25.7 0 0 0 0 Upper-income 81 59.1 81 59.6 0 0 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 137 100.0 136 100.0 1 100.0 0 .0 Percentage of Total Farms: 99.3 .7 .0 2017 FFIEC Census Data and 2017 D&B Information 85

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: Odessa MSA Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 1 3.6 842 2.3 271 32.2 7,906 21.8 Moderate-income 6 21.4 7,896 21.8 1,378 17.5 6,255 17.3 Middle-income 12 42.9 14,767 40.8 1,701 11.5 7,419 20.5 Upper-income 9 32.1 12,699 35.1 632 5 14,624 40.4 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 28 100.0 36,204 100.0 3,982 11.0 36,204 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 1,278 539 1.6 42.2 606 47.4 133 10.4 Moderate-income 12,372 7,231 21.4 58.4 4,028 32.6 1,113 9 Middle-income 21,636 14,399 42.7 66.6 5,453 25.2 1,784 8.2 Upper-income 20,071 11,564 34.3 57.6 7,048 35.1 1,459 7.3 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 55,357 33,733 100.0 60.9 17,135 31.0 4,489 8.1 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 59 1.2 53 1.2 6 1 0 0 Moderate-income 1,151 23.5 979 23 165 26.3 7 36.8 Middle-income 1,759 35.9 1,498 35.2 257 40.9 4 21.1 Upper-income 1,932 39.4 1,724 40.5 200 31.8 8 42.1 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 4,901 100.0 4,254 100.0 628 100.0 19 100.0 Percentage of Total Businesses: 86.8 12.8 .4 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 1 2.6 1 2.6 0 0 0 0 Moderate-income 2 5.1 2 5.1 0 0 0 0 Middle-income 12 30.8 12 30.8 0 0 0 0 Upper-income 24 61.5 24 61.5 0 0 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 39 100.0 39 100.0 0 .0 0 .0 Percentage of Total Farms: 100.0 .0 .0 2017 FFIEC Census Data and 2017 D&B Information 86

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: Austin Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 37 11.1 33,566 8.4 10,948 32.6 88,879 22.1 Moderate-income 67 20.2 70,973 17.7 11,936 16.8 66,079 16.5 Middle-income 121 36.4 153,648 38.3 10,164 6.6 79,163 19.7 Upper-income 101 30.4 141,722 35.3 3,775 2.7 167,144 41.7 Unknown-income 6 1.8 1,356 0.3 723 53.3 0 0 Total Assessment Area 332 100.0 401,265 100.0 37,546 9.4 401,265 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 75,528 15,212 4.1 20.1 53,398 70.7 6,918 9.2 Moderate-income 131,578 58,510 15.8 44.5 62,984 47.9 10,084 7.7 Middle-income 264,991 146,646 39.5 55.3 99,203 37.4 19,142 7.2 Upper-income 225,053 150,325 40.5 66.8 59,344 26.4 15,384 6.8 Unknown-income 6,623 712 0.2 10.8 5,039 76.1 872 13.2 Total Assessment Area 703,773 371,405 100.0 52.8 279,968 39.8 52,400 7.4 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 5,790 6.8 5,010 6.4 733 10.7 47 4.6 Moderate-income 10,924 12.7 9,862 12.7 978 14.3 84 8.2 Middle-income 28,414 33.1 25,865 33.2 2,265 33.2 284 27.7 Upper-income 39,463 46 36,200 46.5 2,720 39.8 543 53 Unknown-income 1,134 1.3 935 1.2 132 1.9 67 6.5 Total Assessment Area 85,725 100.0 77,872 100.0 6,828 100.0 1,025 100.0 Percentage of Total Businesses: 90.8 8.0 1.2 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 36 3.7 35 3.6 1 9.1 0 0 Moderate-income 126 13 121 12.6 5 45.5 0 0 Middle-income 363 37.4 362 37.7 1 9.1 0 0 Upper-income 444 45.7 441 45.9 3 27.3 0 0 Unknown-income 2 0.2 1 0.1 1 9.1 0 0 Total Assessment Area 971 100.0 960 100.0 11 100.0 0 .0 Percentage of Total Farms: 98.9 1.1 .0 2017 FFIEC Census Data and 2017 D&B Information 87

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: Fort Worth Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 50 14 41,968 9 15,291 36.4 107,889 23.1 Moderate-income 89 24.9 102,718 22 19,879 19.4 75,824 16.3 Middle-income 119 33.3 160,559 34.4 13,375 8.3 90,024 19.3 Upper-income 98 27.5 160,825 34.5 5,334 3.3 192,333 41.3 Unknown-income 1 0.3 0 0 0 0 0 0 Total Assessment Area 357 100.0 466,070 100.0 53,879 11.6 466,070 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 77,500 23,578 5.7 30.4 42,564 54.9 11,358 14.7 Moderate-income 175,359 75,107 18.3 42.8 82,409 47 17,843 10.2 Middle-income 253,449 147,890 36 58.4 88,476 34.9 17,083 6.7 Upper-income 226,665 163,911 39.9 72.3 49,802 22 12,952 5.7 Unknown-income 12 0 0 0 0 0 12 100 Total Assessment Area 732,985 410,486 100.0 56.0 263,251 35.9 59,248 8.1 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 5,899 7.4 5,146 7 719 11.3 34 5 Moderate-income 16,644 20.8 14,663 20 1,893 29.8 88 13.1 Middle-income 24,437 30.5 22,526 30.8 1,748 27.5 163 24.2 Upper-income 33,105 41.3 30,766 42.1 1,951 30.7 388 57.6 Unknown-income 76 0.1 38 0.1 37 0.6 1 0.1 Total Assessment Area 80,161 100.0 73,139 100.0 6,348 100.0 674 100.0 Percentage of Total Businesses: 91.2 7.9 .8 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 19 3.5 18 3.4 1 6.3 0 0 Moderate-income 74 13.6 72 13.6 2 12.5 0 0 Middle-income 148 27.1 142 26.8 6 37.5 0 0 Upper-income 305 55.9 298 56.2 7 43.8 0 0 Unknown-income 0 0 0 0 0 0 0 0 Total Assessment Area 546 100.0 530 100.0 16 100.0 0 .0 Percentage of Total Farms: 97.1 2.9 .0 2017 FFIEC Census Data and 2017 D&B Information 88

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix D – Metropolitan Limited Scope Assessment Area Demographics

Combined Demographics Report Assessment Area: McAllen MSA Income Tract Families by Families < Poverty Families by Categories Distribution Tract Income Level as % of Families Family Income # % # % # % # %

Low-income 1 0.9 2,741 1.5 1,854 67.6 46,048 25.1 Moderate-income 32 28.3 48,286 26.3 21,103 43.7 29,886 16.3 Middle-income 46 40.7 76,106 41.5 22,358 29.4 28,262 15.4 Upper-income 31 27.4 55,935 30.5 9,440 16.9 79,139 43.2 Unknown-income 3 2.7 267 0.1 108 40.4 0 0 Total Assessment Area 113 100.0 183,335 100.0 54,863 29.9 183,335 100.0 Housing Housing Types by Tract Uni ts by Owner-Occupied Rental Vacant Tract # % % # % # % Low-income 3,162 2,091 1.4 66.1 828 26.2 243 7.7 Moderate-income 65,913 37,566 24.6 57 20,071 30.5 8,276 12.6 Middle-income 108,000 64,456 42.3 59.7 28,114 26 15,430 14.3 Upper-income 80,442 48,068 31.5 59.8 22,371 27.8 10,003 12.4 Unknown-income 609 371 0.2 60.9 85 14 153 25.1 Total Assessment Area 258,126 152,552 100.0 59.1 71,469 27.7 34,105 13.2 Businesses by Tract & Revenue Size Total Businesses by Less Than or = Over $1 Revenue Not Tract $1 Million Million Reported # % # % # % # % Low-income 94 0.5 88 0.5 6 0.4 0 0 Moderate-income 4,053 19.7 3,656 19.3 357 23.1 40 28.2 Middle-income 6,933 33.7 6,368 33.7 514 33.2 51 35.9 Upper-income 9,504 46.1 8,787 46.5 666 43.1 51 35.9 Unknown-income 15 0.1 11 0.1 4 0.3 0 0 Total Assessment Area 20,599 100.0 18,910 100.0 1,547 100.0 142 100.0 Percentage of Total Businesses: 91.8 7.5 .7 Farms by Tract & Revenue Size

Total Farms by Tract Less Than or = Over $1 Revenue Not $1 Million Million Reported # % # % # % # % Low-income 5 1.6 5 1.8 0 0 0 0 Moderate-income 48 15.8 42 15.4 6 19.4 0 0 Middle-income 133 43.8 116 42.5 17 54.8 0 0 Upper-income 114 37.5 106 38.8 8 25.8 0 0 Unknown-income 4 1.3 4 1.5 0 0 0 0 Total Assessment Area 304 100.0 273 100.0 31 100.0 0 .0 Percentage of Total Farms: 89.8 10.2 .0 2017 FFIEC Census Data and 2017 D&B Information 89

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

The assessment area loan tables appear in the following order:

1. Geographic Distribution of HMDA Loans for the bank and aggregate lenders 2. Geographic distribution of Small Business and Small Farm Loans for the bank and aggregate lenders 3. Borrower Profile of HMDA Loans for the bank and aggregate lenders 4. Borrower Profile of Small Business and Small Farm Loans for the bank and aggregate lenders

Geographic Distribution of HMDA Loans Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels O ccupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 5 1.6% $546 1.6% 5.4% 4 2.6% 2.3% $396 2.4% 1.5% 1 0.7% 2.9% $150 0.9% 2.1% Moderate 10 3.3% $886 2.6% 19.4% 4 2.6% 10.3% $256 1.5% 6.3% 6 4.1% 10.8% $630 3.6% 6.9% M iddle 28 9.2% $2,331 6.8% 27.6% 12 7.7% 27.9% $807 4.8% 20.8% 16 10.8% 29.7% $1,524 8.7% 23.3% Upper 261 85.9% $30,538 89.0% 47.6% 136 87.2% 59.6% $15,290 91.3% 71.4% 125 84.5% 56.7% $15,248 86.9% 67.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 304 100.0% $34,301 100.0% 100.0% 156 100.0% 100.0% $16,749 100.0% 100.0% 148 100.0% 100.0% $17,552 100.0% 100.0% Low 0 0.0% $0 0.0% 5.4% 0 0.0% 1.6% $0 0.0% 0.9% 0 0.0% 1.7% $0 0.0% 1.0% Moderate 1 1.4% $85 0.9% 19.4% 0 0.0% 8.8% $0 0.0% 5.2% 1 3.3% 8.6% $85 1.5% 5.1% M iddle 10 14.1% $819 8.4% 27.6% 6 14.6% 24.9% $261 6.5% 17.6% 4 13.3% 24.1% $558 9.7% 17.2% Upper 60 84.5% $8,818 90.7% 47.6% 35 85.4% 64.7% $3,728 93.5% 76.3% 25 83.3% 65.7% $5,090 88.8% 76.7%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 71 100.0% $9,722 100.0% 100.0% 41 100.0% 100.0% $3,989 100.0% 100.0% 30 100.0% 100.0% $5,733 100.0% 100.0% Low 11 1.8% $351 0.6% 5.4% 4 1.4% 2.4% $149 0.5% 0.9% 7 2.0% 1.8% $202 0.7% 0.9% Moderate 43 6.9% $1,952 3.6% 19.4% 11 3.9% 10.3% $1,039 3.8% 5.8% 32 9.3% 10.6% $913 3.4% 4.9% M iddle 99 15.9% $6,358 11.7% 27.6% 37 13.2% 21.9% $2,661 9.7% 14.7% 62 18.1% 23.5% $3,697 13.6% 16.0%

HOME Upper 471 75.5% $45,905 84.1% 47.6% 229 81.5% 65.4% $23,496 85.9% 78.7% 242 70.6% 64.1% $22,409 82.3% 78.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 624 100.0% $54,566 100.0% 100.0% 281 100.0% 100.0% $27,345 100.0% 100.0% 343 100.0% 100.0% $27,221 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 24.2% 0 0.0% 30.9% $0 0.0% 22.2% 0 0.0% 28.8% $0 0.0% 22.3% Moderate 0 0.0% $0 0.0% 27.8% 0 0.0% 28.8% $0 0.0% 21.8% 0 0.0% 30.4% $0 0.0% 18.3% M iddle 1 100.0% $5 100.0% 25.4% 0 0.0% 21.8% $0 0.0% 20.5% 1 100.0% 21.4% $5 100.0% 25.8% Upper 0 0.0% $0 0.0% 22.6% 0 0.0% 18.5% $0 0.0% 35.5% 0 0.0% 19.3% $0 0.0% 33.7%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $5 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 1 100.0% 100.0% $5 100.0% 100.0% Low 16 1.6% $897 0.9% 5.4% 8 1.7% 2.1% $545 1.1% 3.0% 8 1.5% 2.5% $352 0.7% 3.2% Moderate 54 5.4% $2,923 3.0% 19.4% 15 3.1% 9.8% $1,295 2.7% 7.3% 39 7.5% 10.0% $1,628 3.2% 7.1% M iddle 138 13.8% $9,513 9.6% 27.6% 55 11.5% 26.6% $3,729 7.8% 19.7% 83 15.9% 27.4% $5,784 11.5% 21.4% Upper 792 79.2% $85,261 86.5% 47.6% 400 83.7% 61.4% $42,514 88.4% 70.0% 392 75.1% 60.2% $42,747 84.6% 68.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 1,000 100.0% $98,594 100.0% 100.0% 478 100.0% 100.0% $48,083 100.0% 100.0% 522 100.0% 100.0% $50,511 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2017 2017 Income Bank Owner Count Dollar Levels O ccupied Count Dollar Bank Agg Bank Agg Units PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 1 0.6% $71 0.3% 5.7% 1 0.6% 4.0% $71 0.3% 2.6% Moderate 3 1.9% $420 2.0% 20.9% 3 1.9% 12.9% $420 2.0% 8.3% M iddle 18 11.3% $1,657 7.8% 25.9% 18 11.3% 28.3% $1,657 7.8% 23.5% Upper 137 86.2% $19,135 89.9% 47.5% 137 86.2% 54.6% $19,135 89.9% 65.4% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.2% $0 0.0% 0.1%

HOME PURCHASE Total 159 100.0% $21,283 100.0% 100.0% 159 100.0% 100.0% $21,283 100.0% 100.0% Low 0 0.0% $0 0.0% 5.7% 0 0.0% 2.3% $0 0.0% 1.5% Moderate 0 0.0% $0 0.0% 20.9% 0 0.0% 13.6% $0 0.0% 7.8% M iddle 2 10.5% $220 8.9% 25.9% 2 10.5% 28.2% $220 8.9% 21.6% Upper 17 89.5% $2,241 91.1% 47.5% 17 89.5% 55.7% $2,241 91.1% 69.0%

REFINANCE Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.1% $0 0.0% 0.1% Total 19 100.0% $2,461 100.0% 100.0% 19 100.0% 100.0% $2,461 100.0% 100.0% Low 8 2.1% $144 0.4% 5.7% 8 2.1% 2.6% $144 0.4% 1.0% Moderate 19 5.1% $1,131 3.3% 20.9% 19 5.1% 13.2% $1,131 3.3% 6.9% M iddle 55 14.7% $4,142 12.0% 25.9% 55 14.7% 25.3% $4,142 12.0% 20.0%

HOME Upper 291 78.0% $29,193 84.3% 47.5% 291 78.0% 58.8% $29,193 84.3% 71.9% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.1% $0 0.0% 0.1% IMPROVEMENT Total 373 100.0% $34,610 100.0% 100.0% 373 100.0% 100.0% $34,610 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 24.7% 0 0.0% 31.8% $0 0.0% 21.7% Moderate 0 0.0% $0 0.0% 26.5% 0 0.0% 32.8% $0 0.0% 22.3% M iddle 0 0.0% $0 0.0% 23.9% 0 0.0% 17.4% $0 0.0% 26.6% Upper 0 0.0% $0 0.0% 24.1% 0 0.0% 17.8% $0 0.0% 29.3%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.8% 0 0.0% 0.2% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 9 1.6% $215 0.4% 5.7% 9 1.6% 3.5% $215 0.4% 4.5% Moderate 22 4.0% $1,551 2.7% 20.9% 22 4.0% 13.2% $1,551 2.7% 9.7% M iddle 75 13.6% $6,019 10.3% 25.9% 75 13.6% 28.1% $6,019 10.3% 23.4% Upper 445 80.8% $50,569 86.7% 47.5% 445 80.8% 55.0% $50,569 86.7% 62.3% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.1% $0 0.0% 0.1% HMDA TOTALS Total 551 100.0% $58,354 100.0% 100.0% 551 100.0% 100.0% $58,354 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of Small Business Loans Assessment Area: Dallas

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison Tract 2015, 2016 2015 2016 Income Bank Small Levels Count Dollar Count Dollar Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ 000s $ % $ % # % % $ 000s $ % $ % Low 130 12.9% $37,599 12.6% 7.6% 62 13.2% 8.6% $17,967 12.8% 11.1% 68 12.6% 8.0% $19,632 12.4% 10.5% Moderate 227 22.5% $71,863 24.0% 17.2% 106 22.6% 17.1% $32,685 23.3% 19.3% 121 22.4% 16.8% $39,178 24.6% 19.3% M iddle 183 18.1% $57,254 19.1% 25.1% 87 18.6% 22.1% $25,661 18.3% 21.2% 96 17.7% 22.0% $31,593 19.9% 20.8% Upper 453 44.9% $128,972 43.1% 50.0% 206 44.0% 50.8% $62,379 44.4% 47.3% 247 45.7% 52.0% $66,593 41.9% 48.2% Unknown 16 1.6% $3,665 1.2% 0.1% 7 1.5% 0.2% $1,723 1.2% 0.4% 9 1.7% 0.2% $1,942 1.2% 0.4% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.2% $0 0.0% 0.6% 0 0.0% 1.2% $0 0.0% 0.7% Total 1,009 100.0% $299,353 100.0% 100.0% 468 100.0% 100.0% $140,415 100.0% 100.0% 541 100.0% 100.0% $158,938 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2016 D&B Information

Geographic Distribution of Small Business Loans Assessment Area: Dallas

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison Tract 2017 2017 Income Bank Small Count Dollar Levels Count Dollar Businesses Bank Agg Bank Agg

# % $ (000s) $ % % # % % $ 000s $ % $ % Low 61 9.7% $20,037 11.2% 7.4% 61 9.7% 7.8% $20,037 11.2% 8.8% Moderate 156 24.8% $47,091 26.4% 19.5% 156 24.8% 19.3% $47,091 26.4% 20.9% M iddle 126 20.0% $30,860 17.3% 24.7% 126 20.0% 23.0% $30,860 17.3% 22.3% Upper 271 43.0% $74,128 41.5% 47.9% 271 43.0% 48.0% $74,128 41.5% 45.2% Unknown 16 2.5% $6,394 3.6% 0.5% 16 2.5% 1.0% $6,394 3.6% 2.2% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.0% $0 0.0% 0.6% Total 630 100.0% $178,510 100.0% 100.0% 630 100.0% 100.0% $178,510 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2017 D&B Information

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans

Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison 2015, 2016 2015 2016 Borrower Bank Families Count Dollar Count Dollar Income by Levels Count Dollar Family Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 23.3% 0 0.0% 3.4% $0 0.0% 1.4% 0 0.0% 3.0% $0 0.0% 1.3% Moderate 1 0.3% $33 0.1% 16.5% 1 0.6% 11.4% $33 0.2% 6.7% 0 0.0% 11.4% $0 0.0% 6.8% M iddle 6 2.0% $638 1.9% 17.9% 4 2.6% 16.4% $280 1.7% 12.8% 2 1.4% 17.4% $358 2.0% 14.0% Upper 297 97.7% $33,630 98.0% 42.3% 151 96.8% 51.0% $16,436 98.1% 63.4% 146 98.6% 52.7% $17,194 98.0% 64.4% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 17.8% $0 0.0% 15.7% 0 0.0% 15.4% $0 0.0% 13.6%

HOME PURCHASE Total 304 100.0% $34,301 100.0% 100.0% 156 100.0% 100.0% $16,749 100.0% 100.0% 148 100.0% 100.0% $17,552 100.0% 100.0% Low 2 2.8% $147 1.5% 23.3% 2 4.9% 3.2% $147 3.7% 1.4% 0 0.0% 2.8% $0 0.0% 1.3% Moderate 2 2.8% $180 1.9% 16.5% 2 4.9% 8.8% $180 4.5% 4.7% 0 0.0% 8.7% $0 0.0% 4.6% M iddle 1 1.4% $40 0.4% 17.9% 1 2.4% 14.8% $40 1.0% 10.4% 0 0.0% 15.1% $0 0.0% 10.6% Upper 64 90.1% $8,929 91.8% 42.3% 36 87.8% 50.3% $3,622 90.8% 62.2% 28 93.3% 52.8% $5,307 92.6% 65.0%

REFINANCE Unknown 2 2.8% $426 4.4% 0.0% 0 0.0% 22.8% $0 0.0% 21.4% 2 6.7% 20.6% $426 7.4% 18.5% Total 71 100.0% $9,722 100.0% 100.0% 41 100.0% 100.0% $3,989 100.0% 100.0% 30 100.0% 100.0% $5,733 100.0% 100.0% Low 9 1.4% $176 0.3% 23.3% 1 0.4% 4.6% $5 0.0% 1.2% 8 2.3% 4.6% $171 0.6% 2.1% Moderate 40 6.4% $1,052 1.9% 16.5% 8 2.8% 10.6% $413 1.5% 4.6% 32 9.3% 11.0% $639 2.3% 5.5% M iddle 50 8.0% $1,995 3.7% 17.9% 15 5.3% 15.0% $888 3.2% 9.4% 35 10.2% 16.3% $1,107 4.1% 11.7%

HOME Upper 516 82.7% $50,857 93.2% 42.3% 254 90.4% 65.0% $25,874 94.6% 76.5% 262 76.4% 64.5% $24,983 91.8% 76.3% Unknown 9 1.4% $486 0.9% 0.0% 3 1.1% 4.7% $165 0.6% 8.3% 6 1.7% 3.6% $321 1.2% 4.4% IMPROVEMENT Total 624 100.0% $54,566 100.0% 100.0% 281 100.0% 100.0% $27,345 100.0% 100.0% 343 100.0% 100.0% $27,221 100.0% 100.0% Low 11 1.1% $323 0.3% 23.3% 3 0.6% 3.4% $152 0.3% 1.3% 8 1.5% 3.0% $171 0.3% 1.2% Moderate 43 4.3% $1,265 1.3% 16.5% 11 2.3% 10.4% $626 1.3% 5.5% 32 6.1% 10.4% $639 1.3% 5.6% M iddle 57 5.7% $2,673 2.7% 17.9% 20 4.2% 15.8% $1,208 2.5% 11.0% 37 7.1% 16.5% $1,465 2.9% 11.8% Upper 877 87.8% $93,416 94.8% 42.3% 441 92.3% 51.1% $45,932 95.5% 57.9% 436 83.6% 53.1% $47,484 94.0% 59.9% Unknown 11 1.1% $912 0.9% 0.0% 3 0.6% 19.3% $165 0.3% 24.3% 8 1.7% 17.1% $747 1.5% 21.5% HMDA TOTALS Total 999 100.0% $98,589 100.0% 100.0% 478 100.0% 100.0% $48,083 100.0% 100.0% 521 100.0% 100.0% $50,506 100.0% 100.0% Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Bank Families Count Dollar Levels by Family Count Dollar Bank Agg Bank Agg

PRODUCT TYPE PRODUCT Income

# % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 24.0% 0 0.0% 2.6% $0 0.0% 1.2% Moderate 0 0.0% $0 0.0% 16.4% 0 0.0% 11.1% $0 0.0% 6.7% M iddle 4 2.5% $449 2.1% 17.3% 4 2.5% 18.1% $449 2.1% 14.5% Upper 153 96.2% $20,440 96.0% 42.3% 153 96.2% 54.1% $20,440 96.0% 65.4% Unknown 2 1.3% $394 1.9% 0.0% 2 1.3% 14.1% $394 1.9% 12.3%

HOME PURCHASE Total 159 100.0% $21,283 100.0% 100.0% 159 100.0% 100.0% $21,283 100.0% 100.0% Low 0 0.0% $0 0.0% 24.0% 0 0.0% 4.5% $0 0.0% 2.0% Moderate 1 5.3% $82 3.3% 16.4% 1 5.3% 11.4% $82 3.3% 6.7% M iddle 1 5.3% $280 11.4% 17.3% 1 5.3% 18.3% $280 11.4% 13.6% Upper 16 84.2% $2,080 84.5% 42.3% 16 84.2% 47.5% $2,080 84.5% 60.4%

REFINANCE Unknown 1 5.3% $19 0.8% 0.0% 1 5.3% 18.3% $19 0.8% 17.3% Total 19 100.0% $2,461 100.0% 100.0% 19 100.0% 100.0% $2,461 100.0% 100.0% Low 8 2.1% $339 1.0% 24.0% 8 2.1% 4.6% $339 1.0% 2.3% Moderate 15 4.0% $479 1.4% 16.4% 15 4.0% 11.2% $479 1.4% 6.4% M iddle 32 8.6% $1,535 4.4% 17.3% 32 8.6% 18.7% $1,535 4.4% 14.8%

HOME Upper 312 83.6% $31,797 91.9% 42.3% 312 83.6% 62.1% $31,797 91.9% 72.5% Unknown 6 1.6% $460 1.3% 0.0% 6 1.6% 3.3% $460 1.3% 4.0% IMPROVEMENT Total 373 100.0% $34,610 100.0% 100.0% 373 100.0% 100.0% $34,610 100.0% 100.0% Low 8 1.5% $339 0.6% 24.0% 8 1.5% 3.2% $339 0.6% 1.2% Moderate 16 2.9% $561 1.0% 16.4% 16 2.9% 11.2% $561 1.0% 5.9% M iddle 37 6.7% $2,264 3.9% 17.3% 37 6.7% 18.1% $2,264 3.9% 12.7% Upper 481 87.3% $54,317 93.1% 42.3% 481 87.3% 52.4% $54,317 93.1% 57.2%

HMDA TOTALS Unknown 9 1.6% $873 1.5% 0.0% 9 1.6% 15.1% $873 1.5% 23.0% Total 551 100.0% $58,354 100.0% 100.0% 551 100.0% 100.0% $58,354 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and2015 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Small Business Loans by Business Revenue & Loan Size Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Business Revenue & Loan Bank Count Dollar Count Dollar Size Total Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % $1million or Less 368 36.5% $78,968 26.4% 90.8% 171 36.5% 49.3% $40,287 28.7% 34.5% 197 36.4% 42.5% $38,681 24.3% 33.7% Over $1 Million 611 60.6% $210,817 70.4% 8.3% 288 61.5% 323 59.7% Total Rev. available 979 97.1% $289,785 96.8% 99.1% 459 98.0% 520 96.1% REVENUE BUSINESS Rev. Not Known 30 3.0% $9,568 3.2% 0.9% 9 1.9% 21 3.9% Total 1,009 100.0% $299,353 100.0% 100.0% 468 100.0% 541 100.0% $100,000 or Less 333 33.0% $19,952 6.7% 147 31.4% 93.7% $9,133 6.5% 36.6% 186 34.4% 94.5% $10,819 6.8% 41.4% $100,001 - $250,000 272 27.0% $50,096 16.7% 128 27.4% 2.9% $23,245 16.6% 13.9% 144 26.6% 2.6% $26,851 16.9% 13.3% $250,001 - $1 Million 404 40.0% $229,305 76.6% 193 41.2% 3.4% $108,037 76.9% 49.5% 211 39.0% 2.9% $121,268 76.3% 45.4% LOAN SIZE Total 1,009 100.0% $299,353 100.0% 468 100.0% 100.0% $140,415 100.0% 100.0% 541 100.0% 100.0% $158,938 100.0% 100.0%

$100,000 or Less 181 49.2% $10,034 12.7% $100,001 - $250,000 86 23.4% $15,368 19.5%

$250,001 - $1 Million 101 27.4% $53,566 67.8% LOAN SIZE Total 368 100.0% $78,968 100.0% Rev $1 Mill orRev Less $1 Mill

Small Business Loans by Business Revenue & Loan Size Assessment Area: Dallas Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Business Revenue & Loan 2017 2017 Size Bank Count Dollar Total Count $ (000s) Businesses Bank Agg Bank Agg # % $ % % # % % $ (000s) $ % $ % $1million or Less 248 39.4% $49,372 27.7% 89.9% 248 39.4% 47.3% $49,372 27.7% 35.3% Over $1 Million 367 58.3% $126,227 70.7% 9.2% 367 58.3% Total Rev. available 615 97.7% $175,599 98.4% 99.1% 615 97.7%

REVENUE Rev. Not Known 15 2.4% $2,911 1.6% 0.9% 15 2.4% BUSINESS Total 630 100.0% $178,510 100.0% 100.0% 630 100.0% $100,000 or Less 221 35.1% $13,245 7.4% 221 35.1% 93.9% $13,245 7.4% 39.2% $100,001 - $250,000 172 27.3% $31,186 17.5% 172 27.3% 3.0% $31,186 17.5% 14.1% $250,001 - $1 Million 237 37.6% $134,079 75.1% 237 37.6% 3.1% $134,079 75.1% 46.7%

LOAN SIZE Total 630 100.0% $178,510 100.0% 630 100.0% 100.0% $178,510 100.0% 100.0% $100,000 or Less 124 50.0% $6,648 13.5% $100,001 - $250,000 60 24.2% $10,613 21.5%

Less $250,001 - $1 Million 64 25.8% $32,111 65.0% LOAN SIZE Rev $1 Mill orRev $1 Mill Total 248 100.0% $49,372 100.0%

Originations & Purchases Aggregate data is unavailable for loans to businesses w ith revenue over $1 million or revenue unknow n, and for loan size by revenue. 2017 FFIEC Census Data and 2017 D&B Information

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels O ccupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 3 2.1% $676 3.4% 4.2% 1 1.2% 1.5% $301 2.5% 1.1% 2 3.4% 1.7% $375 4.6% 1.3% Moderate 6 4.3% $456 2.3% 20.7% 5 6.0% 10.4% $382 3.2% 6.8% 1 1.7% 10.9% $74 0.9% 7.5% M iddle 20 14.2% $2,797 13.9% 29.6% 10 12.0% 30.0% $1,408 11.8% 23.8% 10 17.2% 30.0% $1,389 16.9% 24.2% Upper 112 79.4% $16,242 80.5% 45.6% 67 80.7% 58.1% $9,843 82.5% 68.4% 45 77.6% 57.4% $6,399 77.7% 67.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 141 100.0% $20,171 100.0% 100.0% 83 100.0% 100.0% $11,934 100.0% 100.0% 58 100.0% 100.0% $8,237 100.0% 100.0% Low 6 4.7% $1,161 6.5% 4.2% 2 3.1% 1.4% $81 1.0% 1.0% 4 6.3% 1.4% $1,080 11.3% 1.0% Moderate 18 14.1% $1,098 6.1% 20.7% 7 10.8% 9.8% $359 4.3% 6.0% 11 17.5% 9.9% $739 7.7% 6.1% M iddle 26 20.3% $3,295 18.4% 29.6% 12 18.5% 26.2% $1,357 16.2% 19.7% 14 22.2% 26.9% $1,938 20.3% 20.5% Upper 78 60.9% $12,375 69.0% 45.6% 44 67.7% 62.6% $6,566 78.5% 73.4% 34 54.0% 61.8% $5,809 60.7% 72.4%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 128 100.0% $17,929 100.0% 100.0% 65 100.0% 100.0% $8,363 100.0% 100.0% 63 100.0% 100.0% $9,566 100.0% 100.0% Low 24 3.9% $493 1.0% 4.2% 5 1.7% 2.3% $112 0.5% 1.1% 19 5.7% 2.7% $381 1.4% 1.2% Moderate 99 16.0% $4,584 9.1% 20.7% 37 12.8% 11.6% $1,715 7.6% 7.1% 62 18.7% 11.5% $2,869 10.4% 6.4% M iddle 112 18.1% $5,948 11.8% 29.6% 46 16.0% 25.4% $3,249 14.3% 19.2% 66 19.9% 26.2% $2,699 9.8% 19.6%

HOME Upper 385 62.1% $39,176 78.0% 45.6% 200 69.4% 60.7% $17,585 77.6% 72.6% 185 55.7% 59.5% $21,591 78.4% 72.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 620 100.0% $50,201 100.0% 100.0% 288 100.0% 100.0% $22,661 100.0% 100.0% 332 100.0% 100.0% $27,540 100.0% 100.0% Multi-Family Units Low 1 100.0% $950 100.0% 22.7% 0 0.0% 20.8% $0 0.0% 12.4% 1 100.0% 19.7% $950 100.0% 13.6% Moderate 0 0.0% $0 0.0% 30.8% 0 0.0% 35.8% $0 0.0% 24.0% 0 0.0% 31.4% $0 0.0% 21.7% M iddle 0 0.0% $0 0.0% 21.3% 0 0.0% 22.5% $0 0.0% 26.6% 0 0.0% 26.6% $0 0.0% 30.0% Upper 0 0.0% $0 0.0% 25.2% 0 0.0% 20.8% $0 0.0% 37.0% 0 0.0% 22.3% $0 0.0% 34.7%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $950 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 1 100.0% 100.0% $950 100.0% 100.0% Low 34 3.8% $3,280 3.7% 4.2% 8 1.8% 1.6% $494 1.1% 1.9% 26 5.7% 1.7% $2,786 6.0% 2.1% Moderate 123 13.8% $6,138 6.9% 20.7% 49 11.2% 10.3% $2,456 5.7% 7.8% 74 16.3% 10.7% $3,682 8.0% 8.2% M iddle 158 17.8% $12,040 13.5% 29.6% 68 15.6% 28.6% $6,014 14.0% 22.8% 90 19.8% 28.9% $6,026 13.0% 23.6% Upper 575 64.6% $67,793 76.0% 45.6% 311 71.3% 59.5% $33,994 79.1% 67.5% 264 58.1% 58.8% $33,799 73.0% 66.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 890 100.0% $89,251 100.0% 100.0% 436 100.0% 100.0% $42,958 100.0% 100.0% 454 100.0% 100.0% $46,293 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2017 2017 Income Bank Owner Count Dollar Levels O ccupied Count Dollar Bank Agg Bank Agg Units PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 1 1.4% $43 0.5% 5.4% 1 1.4% 2.4% $43 0.5% 1.8% Moderate 3 4.1% $218 2.6% 21.0% 3 4.1% 13.0% $218 2.6% 9.0% M iddle 13 17.6% $1,306 15.6% 28.6% 13 17.6% 27.8% $1,306 15.6% 21.7% Upper 57 77.0% $6,804 81.3% 44.9% 57 77.0% 56.7% $6,804 81.3% 67.4% Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.1% $0 0.0% 0.1%

HOME PURCHASE Total 74 100.0% $8,371 100.0% 100.0% 74 100.0% 100.0% $8,371 100.0% 100.0% Low 3 6.4% $1,863 21.7% 5.4% 3 6.4% 2.4% $1,863 21.7% 1.6% Moderate 8 17.0% $647 7.5% 21.0% 8 17.0% 14.2% $647 7.5% 9.1% M iddle 8 17.0% $588 6.9% 28.6% 8 17.0% 30.3% $588 6.9% 22.9% Upper 28 59.6% $5,476 63.9% 44.9% 28 59.6% 53.1% $5,476 63.9% 66.4%

REFINANCE Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.0% $0 0.0% 0.0% Total 47 100.0% $8,574 100.0% 100.0% 47 100.0% 100.0% $8,574 100.0% 100.0% Low 10 3.1% $225 0.9% 5.4% 10 3.1% 3.8% $225 0.9% 2.9% Moderate 54 16.7% $2,086 8.5% 21.0% 54 16.7% 16.1% $2,086 8.5% 10.2% M iddle 52 16.0% $2,671 10.9% 28.6% 52 16.0% 27.5% $2,671 10.9% 20.9%

HOME Upper 208 64.2% $19,473 79.6% 44.9% 208 64.2% 52.6% $19,473 79.6% 65.9% Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.0% $0 0.0% 0.1% IMPROVEMENT Total 324 100.0% $24,455 100.0% 100.0% 324 100.0% 100.0% $24,455 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 25.3% 0 0.0% 28.2% $0 0.0% 21.2% Moderate 0 0.0% $0 0.0% 27.6% 0 0.0% 32.2% $0 0.0% 17.1% M iddle 0 0.0% $0 0.0% 21.2% 0 0.0% 16.8% $0 0.0% 18.4% Upper 0 0.0% $0 0.0% 25.2% 0 0.0% 22.5% $0 0.0% 43.1%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.7% 0 0.0% 0.3% $0 0.0% 0.1% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 14 3.1% $2,131 5.1% 5.4% 14 3.1% 2.5% $2,131 5.1% 3.5% Moderate 65 14.6% $2,951 7.1% 21.0% 65 14.6% 13.5% $2,951 7.1% 9.7% M iddle 73 16.4% $4,565 11.0% 28.6% 73 16.4% 28.4% $4,565 11.0% 21.6% Upper 293 65.8% $31,753 76.7% 44.9% 293 65.8% 55.6% $31,753 76.7% 65.1% Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.1% $0 0.0% 0.1% HMDA TOTALS Total 445 100.0% $41,400 100.0% 100.0% 445 100.0% 100.0% $41,400 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of Small Business Loans Assessment Area: Houston

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison

Tract 2015, 2016 2015 2016 Income Bank Small Levels Count Dollar Count Dollar Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ 000s $ % $ % # % % $ 000s $ % $ % Low 154 9.5% $47,264 10.1% 7.5% 67 8.8% 7.8% $20,497 9.0% 9.1% 87 10.1% 7.5% $26,767 11.2% 9.2% Moderate 321 19.8% $103,732 22.2% 18.7% 160 21.1% 18.2% $53,684 23.5% 18.8% 161 18.7% 17.7% $50,048 20.9% 18.1% M iddle 426 26.3% $120,685 25.8% 25.2% 205 27.0% 24.2% $57,990 25.4% 24.2% 221 25.6% 24.2% $62,695 26.2% 24.8% Upper 720 44.4% $196,139 41.9% 48.6% 326 43.0% 48.2% $96,249 42.1% 46.9% 394 45.7% 49.3% $99,890 41.7% 46.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.1% 0 0.0% 0.0% $0 0.0% 0.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.5% $0 0.0% 1.0% 0 0.0% 1.4% $0 0.0% 1.0% Total 1,621 100.0% $467,820 100.0% 100.0% 758 100.0% 100.0% $228,420 100.0% 100.0% 863 100.0% 100.0% $239,400 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2016 D&B Information

Geographic Distribution of Small Business Loans Assessment Area: Houston

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison Tract 2017 2017 Income Bank Small Count Dollar Levels Count Dollar Businesses Bank Agg Bank Agg

# % $ (000s) $ % % # % % $ 000s $ % $ % Low 119 12.4% $31,834 13.3% 9.7% 119 12.4% 10.0% $31,834 13.3% 11.8% Moderate 173 18.0% $45,586 19.0% 19.3% 173 18.0% 18.5% $45,586 19.0% 20.1% M iddle 179 18.6% $49,129 20.5% 23.7% 179 18.6% 22.9% $49,129 20.5% 22.4% Upper 486 50.6% $112,626 47.0% 47.2% 486 50.6% 47.0% $112,626 47.0% 44.6% Unknown 3 0.3% $475 0.2% 0.2% 3 0.3% 0.2% $475 0.2% 0.2% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.4% $0 0.0% 0.9% Total 960 100.0% $239,650 100.0% 100.0% 960 100.0% 100.0% $239,650 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2017 D&B Information

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans

Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison 2015, 2016 2015 2016 Borrower Bank Families Count Dollar Count Dollar Income by Levels Count Dollar Family Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 1 0.7% $50 0.2% 23.7% 1 1.2% 3.0% $50 0.4% 1.3% 0 0.0% 2.1% $0 0.0% 0.9% Moderate 4 2.8% $280 1.4% 16.5% 1 1.2% 12.5% $80 0.7% 7.5% 3 5.2% 11.8% $200 2.4% 7.2% M iddle 7 5.0% $704 3.5% 17.5% 6 7.2% 18.3% $614 5.1% 14.1% 1 1.7% 19.0% $90 1.1% 14.8% Upper 124 87.9% $18,219 90.3% 42.4% 73 88.0% 48.3% $10,819 90.7% 61.8% 51 87.9% 50.4% $7,400 89.8% 62.8% Unknown 5 3.5% $918 4.6% 0.0% 2 2.4% 17.8% $371 3.1% 15.2% 3 5.2% 16.7% $547 6.6% 14.3%

HOME PURCHASE Total 141 100.0% $20,171 100.0% 100.0% 83 100.0% 100.0% $11,934 100.0% 100.0% 58 100.0% 100.0% $8,237 100.0% 100.0% Low 9 7.0% $322 1.8% 23.7% 6 9.2% 3.7% $227 2.7% 1.7% 3 4.8% 2.8% $95 1.0% 1.4% Moderate 14 10.9% $1,006 5.6% 16.5% 5 7.7% 9.2% $429 5.1% 4.9% 9 14.3% 8.1% $577 6.0% 4.3% M iddle 17 13.3% $1,684 9.4% 17.5% 6 9.2% 15.3% $385 4.6% 10.4% 11 17.5% 14.4% $1,299 13.6% 9.6% Upper 82 64.1% $14,540 81.1% 42.4% 45 69.2% 49.8% $7,155 85.6% 62.5% 37 58.7% 50.6% $7,385 77.2% 62.3%

REFINANCE Unknown 6 4.7% $377 2.1% 0.0% 3 4.6% 22.1% $167 2.0% 20.5% 3 4.8% 24.1% $210 2.2% 22.4% Total 128 100.0% $17,929 100.0% 100.0% 65 100.0% 100.0% $8,363 100.0% 100.0% 63 100.0% 100.0% $9,566 100.0% 100.0% Low 28 4.5% $629 1.3% 23.7% 10 3.5% 5.0% $290 1.3% 1.4% 18 5.4% 3.8% $339 1.2% 1.4% Moderate 55 8.9% $1,721 3.4% 16.5% 16 5.6% 10.8% $543 2.4% 5.4% 39 11.7% 10.1% $1,178 4.3% 5.1% M iddle 67 10.8% $3,503 7.0% 17.5% 30 10.4% 16.5% $1,606 7.1% 11.3% 37 11.1% 17.1% $1,897 6.9% 11.1%

HOME Upper 429 69.2% $43,394 86.4% 42.4% 215 74.7% 64.3% $19,792 87.3% 76.4% 214 64.5% 65.4% $23,602 85.7% 78.0% Unknown 41 6.6% $954 1.9% 0.0% 17 5.9% 3.5% $430 1.9% 5.5% 24 7.2% 3.5% $524 1.9% 4.4% IMPROVEMENT Total 620 100.0% $50,201 100.0% 100.0% 288 100.0% 100.0% $22,661 100.0% 100.0% 332 100.0% 100.0% $27,540 100.0% 100.0% Low 38 4.3% $1,001 1.1% 23.7% 17 3.9% 3.3% $567 1.3% 1.3% 21 4.6% 2.4% $434 1.0% 1.0% Moderate 73 8.2% $3,007 3.4% 16.5% 22 5.0% 11.4% $1,052 2.4% 6.3% 51 11.3% 10.6% $1,955 4.3% 5.8% M iddle 91 10.2% $5,891 6.7% 17.5% 42 9.6% 17.3% $2,605 6.1% 12.1% 49 10.8% 17.5% $3,286 7.2% 12.2% Upper 635 71.4% $76,153 86.2% 42.4% 333 76.4% 49.2% $37,766 87.9% 57.7% 302 66.7% 50.8% $38,387 84.7% 58.0% Unknown 52 5.9% $2,249 2.6% 0.0% 22 5.0% 18.8% $968 2.3% 22.6% 30 6.6% 18.8% $1,281 2.8% 23.1% HMDA TOTALS Total 889 100.0% $88,301 100.0% 100.0% 436 100.0% 100.0% $42,958 100.0% 100.0% 454 100.0% 100.0% $46,293 100.0% 100.0% Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Bank Families Count Dollar Levels by Family Count Dollar Bank Agg Bank Agg

PRODUCT TYPE PRODUCT Income

# % $ (000s) $ % % # % % $(000s) $ % $ % Low 3 4.1% $154 1.8% 24.4% 3 4.1% 2.8% $154 1.8% 1.3% Moderate 0 0.0% $0 0.0% 16.0% 0 0.0% 12.6% $0 0.0% 8.0% M iddle 3 4.1% $350 4.2% 17.0% 3 4.1% 19.6% $350 4.2% 15.8% Upper 65 87.8% $7,422 88.7% 42.6% 65 87.8% 47.2% $7,422 88.7% 60.2% Unknown 3 4.1% $445 5.3% 0.0% 3 4.1% 17.8% $445 5.3% 14.8%

HOME PURCHASE Total 74 100.0% $8,371 100.0% 100.0% 74 100.0% 100.0% $8,371 100.0% 100.0% Low 6 12.8% $303 3.5% 24.4% 6 12.8% 5.1% $303 3.5% 2.5% Moderate 7 14.9% $437 5.1% 16.0% 7 14.9% 10.8% $437 5.1% 6.4% M iddle 3 6.4% $352 4.1% 17.0% 3 6.4% 17.8% $352 4.1% 13.0% Upper 28 59.6% $5,498 64.1% 42.6% 28 59.6% 44.0% $5,498 64.1% 57.3%

REFINANCE Unknown 3 6.4% $1,984 23.1% 0.0% 3 6.4% 22.2% $1,984 23.1% 20.7% Total 47 100.0% $8,574 100.0% 100.0% 47 100.0% 100.0% $8,574 100.0% 100.0% Low 21 6.5% $442 1.8% 24.4% 21 6.5% 5.8% $442 1.8% 2.7% Moderate 26 8.0% $1,011 4.1% 16.0% 26 8.0% 11.2% $1,011 4.1% 6.5% M iddle 34 10.5% $1,598 6.5% 17.0% 34 10.5% 16.9% $1,598 6.5% 13.5%

HOME Upper 224 69.1% $20,887 85.4% 42.6% 224 69.1% 58.8% $20,887 85.4% 71.8% Unknown 19 5.9% $517 2.1% 0.0% 19 5.9% 7.2% $517 2.1% 5.4% IMPROVEMENT Total 324 100.0% $24,455 100.0% 100.0% 324 100.0% 100.0% $24,455 100.0% 100.0% Low 30 6.7% $899 2.2% 24.4% 30 6.7% 3.5% $899 2.2% 1.4% Moderate 33 7.4% $1,448 3.5% 16.0% 33 7.4% 12.1% $1,448 3.5% 7.0% M iddle 40 9.0% $2,300 5.6% 17.0% 40 9.0% 19.1% $2,300 5.6% 13.9% Upper 317 71.2% $33,807 81.7% 42.6% 317 71.2% 46.8% $33,807 81.7% 54.5%

HMDA TOTALS Unknown 25 5.6% $2,946 7.1% 0.0% 25 5.6% 18.6% $2,946 7.1% 23.2% Total 445 100.0% $41,400 100.0% 100.0% 445 100.0% 100.0% $41,400 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and2015 ACS Data

100

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Small Business Loans by Business Revenue & Loan Size Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Business Revenue & Loan Bank Count Dollar Count Dollar Size Total Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % $1million or Less 566 34.9% $112,357 24.0% 90.6% 243 32.1% 47.1% $55,106 24.1% 33.1% 323 37.4% 40.6% $57,251 23.9% 31.9% Over $1 Million 1,013 62.5% $342,544 73.2% 8.5% 494 65.2% 519 60.1% Total Rev. available 1,579 97.4% $454,901 97.2% 99.1% 737 97.3% 842 97.5% REVENUE BUSINESS Rev. Not Known 42 2.6% $12,919 2.8% 0.9% 21 2.8% 21 2.4% Total 1,621 100.0% $467,820 100.0% 100.0% 758 100.0% 863 100.0% $100,000 or Less 603 37.2% $34,147 7.3% 253 33.4% 93.8% $14,783 6.5% 37.2% 350 40.6% 94.4% $19,364 8.1% 40.3% $100,001 - $250,000 399 24.6% $73,710 15.8% 206 27.2% 2.9% $37,949 16.6% 13.6% 193 22.4% 2.7% $35,761 14.9% 13.7% $250,001 - $1 Million 619 38.2% $359,963 76.9% 299 39.4% 3.3% $175,688 76.9% 49.2% 320 37.1% 2.9% $184,275 77.0% 46.0% LOAN SIZE Total 1,621 100.0% $467,820 100.0% 758 100.0% 100.0% $228,420 100.0% 100.0% 863 100.0% 100.0% $239,400 100.0% 100.0%

$100,000 or Less 332 58.7% $16,974 15.1% $100,001 - $250,000 101 17.8% $17,760 15.8%

$250,001 - $1 Million 133 23.5% $77,623 69.1% LOAN SIZE Total 566 100.0% $112,357 100.0% Rev $1 Mill orRev Less $1 Mill

Originations & Purchases Aggregate data is unavailable for loans to businesses w ith revenue over $1 million or revenue unknow n, and for loan size by revenue. 2016 FFIEC Census Data and 2016 D&B Information Small Business Loans by Business Revenue & Loan Size Assessment Area: Houston Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Business Revenue & Loan 2017 2017 Size Bank Count Dollar Total Count $ (000s) Businesses Bank Agg Bank Agg # % $ % % # % % $ (000s) $ % $ % $1million or Less 417 43.4% $59,870 25.0% 89.2% 417 43.4% 45.7% $59,870 25.0% 34.6% Over $1 Million 528 55.0% $174,919 73.0% 9.9% 528 55.0% Total Rev. available 945 98.4% $234,789 98.0% 99.1% 945 98.4%

REVENUE Rev. Not Known 15 1.6% $4,861 2.0% 0.9% 15 1.6% BUSINESS Total 960 100.0% $239,650 100.0% 100.0% 960 100.0% $100,000 or Less 437 45.5% $22,890 9.6% 437 45.5% 94.0% $22,890 9.6% 39.5% $100,001 - $250,000 211 22.0% $39,218 16.4% 211 22.0% 3.0% $39,218 16.4% 14.5% $250,001 - $1 Million 312 32.5% $177,542 74.1% 312 32.5% 3.0% $177,542 74.1% 46.0%

LOAN SIZE Total 960 100.0% $239,650 100.0% 960 100.0% 100.0% $239,650 100.0% 100.0% $100,000 or Less 285 68.3% $12,794 21.4% $100,001 - $250,000 66 15.8% $11,517 19.2%

Less $250,001 - $1 Million 66 15.8% $35,559 59.4% LOAN SIZE Rev $1 Mill orRev $1 Mill Total 417 100.0% $59,870 100.0%

101

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels O ccupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 4.6% 0 0.0% 1.4% $0 0.0% 0.8% 0 0.0% 1.4% $0 0.0% 1.0% Moderate 10 7.9% $574 3.5% 23.7% 4 4.9% 10.4% $148 1.5% 6.3% 6 13.0% 10.4% $426 6.4% 6.6% M iddle 14 11.0% $1,590 9.7% 32.9% 10 12.3% 33.1% $1,084 11.1% 25.7% 4 8.7% 33.7% $506 7.6% 26.8% Upper 103 81.1% $14,232 86.8% 38.8% 67 82.7% 55.1% $8,493 87.3% 67.2% 36 78.3% 54.6% $5,739 86.0% 65.6% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 127 100.0% $16,396 100.0% 100.0% 81 100.0% 100.0% $9,725 100.0% 100.0% 46 100.0% 100.0% $6,671 100.0% 100.0% Low 0 0.0% $0 0.0% 4.6% 0 0.0% 1.3% $0 0.0% 0.6% 0 0.0% 1.3% $0 0.0% 0.8% Moderate 15 13.9% $896 9.0% 23.7% 7 13.5% 10.7% $368 8.1% 6.4% 8 14.3% 9.9% $528 9.8% 6.0% M iddle 38 35.2% $2,614 26.4% 32.9% 18 34.6% 32.2% $1,353 29.9% 24.0% 20 35.7% 31.7% $1,261 23.4% 24.1% Upper 55 50.9% $6,400 64.6% 38.8% 27 51.9% 55.9% $2,806 62.0% 69.0% 28 50.0% 57.0% $3,594 66.8% 69.0%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 108 100.0% $9,910 100.0% 100.0% 52 100.0% 100.0% $4,527 100.0% 100.0% 56 100.0% 100.0% $5,383 100.0% 100.0% Low 31 4.9% $524 1.7% 4.6% 9 3.7% 4.0% $276 2.1% 2.5% 22 5.7% 3.6% $248 1.4% 2.8% Moderate 158 25.0% $3,604 11.7% 23.7% 50 20.4% 17.2% $1,550 11.8% 8.5% 108 27.9% 17.0% $2,054 11.6% 8.7% M iddle 160 25.3% $6,167 20.0% 32.9% 62 25.3% 27.6% $2,498 19.0% 22.6% 98 25.3% 27.1% $3,669 20.7% 21.2%

HOME Upper 283 44.8% $20,571 66.6% 38.8% 124 50.6% 51.2% $8,834 67.1% 66.3% 159 41.1% 52.2% $11,737 66.3% 67.3% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 632 100.0% $30,866 100.0% 100.0% 245 100.0% 100.0% $13,158 100.0% 100.0% 387 100.0% 100.0% $17,708 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 7.1% 0 0.0% 15.0% $0 0.0% 3.5% 0 0.0% 7.6% $0 0.0% 2.9% Moderate 0 0.0% $0 0.0% 34.9% 0 0.0% 35.8% $0 0.0% 23.5% 0 0.0% 43.5% $0 0.0% 34.5% M iddle 0 0.0% $0 0.0% 31.9% 0 0.0% 26.7% $0 0.0% 27.9% 0 0.0% 29.8% $0 0.0% 28.8% Upper 1 100.0% $424 100.0% 26.1% 1 100.0% 22.5% $424 100.0% 45.1% 0 0.0% 19.1% $0 0.0% 33.7%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $424 100.0% 100.0% 1 100.0% 100.0% $424 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 31 3.6% $524 0.9% 4.6% 9 2.4% 1.4% $276 1.0% 0.9% 22 4.5% 1.4% $248 0.8% 1.1% Moderate 183 21.1% $5,074 8.8% 23.7% 61 16.1% 10.7% $2,066 7.4% 7.3% 122 24.9% 10.4% $3,008 10.1% 8.1% M iddle 212 24.4% $10,371 18.0% 32.9% 90 23.7% 32.7% $4,935 17.7% 25.4% 122 24.9% 32.9% $5,436 18.3% 26.1% Upper 442 50.9% $41,627 72.3% 38.8% 219 57.8% 55.2% $20,557 73.9% 66.4% 223 45.6% 55.2% $21,070 70.8% 64.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 868 100.0% $57,596 100.0% 100.0% 379 100.0% 100.0% $27,834 100.0% 100.0% 489 100.0% 100.0% $29,762 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

102

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2017 2017 Income Bank Owner Count Dollar Levels O ccupied Count Dollar Bank Agg Bank Agg Units PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 4.5% 0 0.0% 1.0% $0 0.0% 0.6% Moderate 3 4.8% $288 3.4% 23.9% 3 4.8% 11.9% $288 3.4% 7.8% M iddle 7 11.1% $1,121 13.3% 28.2% 7 11.1% 31.7% $1,121 13.3% 25.9% Upper 53 84.1% $7,002 83.2% 43.3% 53 84.1% 55.3% $7,002 83.2% 65.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 63 100.0% $8,411 100.0% 100.0% 63 100.0% 100.0% $8,411 100.0% 100.0% Low 0 0.0% $0 0.0% 4.5% 0 0.0% 1.4% $0 0.0% 0.7% Moderate 9 23.1% $1,241 24.3% 23.9% 9 23.1% 14.2% $1,241 24.3% 8.4% M iddle 15 38.5% $1,389 27.3% 28.2% 15 38.5% 30.1% $1,389 27.3% 24.1% Upper 15 38.5% $2,467 48.4% 43.3% 15 38.5% 54.3% $2,467 48.4% 66.8%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 39 100.0% $5,097 100.0% 100.0% 39 100.0% 100.0% $5,097 100.0% 100.0% Low 17 5.2% $286 1.5% 4.5% 17 5.2% 3.2% $286 1.5% 1.6% Moderate 98 29.7% $3,461 18.6% 23.9% 98 29.7% 19.8% $3,461 18.6% 12.4% M iddle 57 17.3% $2,785 15.0% 28.2% 57 17.3% 25.8% $2,785 15.0% 22.2%

HOME Upper 158 47.9% $12,052 64.9% 43.3% 158 47.9% 51.1% $12,052 64.9% 63.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 330 100.0% $18,584 100.0% 100.0% 330 100.0% 100.0% $18,584 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 6.9% 0 0.0% 7.3% $0 0.0% 4.8% Moderate 0 0.0% $0 0.0% 37.1% 0 0.0% 39.3% $0 0.0% 26.3% M iddle 0 0.0% $0 0.0% 31.4% 0 0.0% 31.3% $0 0.0% 37.8% Upper 0 0.0% $0 0.0% 24.7% 0 0.0% 22.0% $0 0.0% 31.0%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 17 3.9% $286 0.9% 4.5% 17 3.9% 1.2% $286 0.9% 1.0% Moderate 110 25.5% $4,990 15.5% 23.9% 110 25.5% 12.8% $4,990 15.5% 9.6% M iddle 79 18.3% $5,295 16.5% 28.2% 79 18.3% 31.1% $5,295 16.5% 26.5% Upper 226 52.3% $21,521 67.1% 43.3% 226 52.3% 54.9% $21,521 67.1% 62.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 432 100.0% $32,092 100.0% 100.0% 432 100.0% 100.0% $32,092 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data

103

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of Small Business Loans Assessment Area: San Antonio

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison Tract 2015, 2016 2015 2016 Income Bank Small Levels Count Dollar Count Dollar Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ 000s $ % $ % # % % $ 000s $ % $ % Low 143 7.5% $37,994 8.1% 4.6% 69 7.6% 4.9% $18,721 8.4% 5.6% 74 7.3% 4.7% $19,273 7.8% 6.5% Moderate 414 21.7% $94,403 20.1% 20.0% 184 20.4% 18.6% $42,129 18.9% 17.6% 230 22.8% 18.3% $52,274 21.2% 17.7% M iddle 543 28.4% $140,272 29.9% 30.8% 252 27.9% 27.9% $64,754 29.0% 27.9% 291 28.9% 27.5% $75,518 30.7% 25.8% Upper 804 42.1% $194,589 41.5% 44.5% 395 43.7% 47.0% $96,542 43.3% 47.7% 409 40.6% 47.7% $98,047 39.8% 48.7% Unknown 6 0.3% $2,037 0.4% 0.2% 3 0.3% 0.2% $982 0.4% 0.3% 3 0.3% 0.2% $1,055 0.4% 0.3% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.4% $0 0.0% 0.9% 0 0.0% 1.5% $0 0.0% 1.0% Total 1,910 100.0% $469,295 100.0% 100.0% 903 100.0% 100.0% $223,128 100.0% 100.0% 1,007 100.0% 100.0% $246,167 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2016 D&B Information

Geographic Distribution of Small Business Loans Assessment Area: San Antonio

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison Tract 2017 2017 Income Bank Small Count Dollar Levels Count Dollar Businesses Bank Agg Bank Agg

# % $ (000s) $ % % # % % $ 000s $ % $ % Low 76 6.2% $20,295 7.4% 4.6% 76 6.2% 4.0% $20,295 7.4% 4.4% Moderate 280 22.8% $58,165 21.3% 21.4% 280 22.8% 19.9% $58,165 21.3% 18.8% M iddle 355 28.9% $77,191 28.2% 29.2% 355 28.9% 28.5% $77,191 28.2% 28.4% Upper 512 41.7% $116,878 42.7% 44.6% 512 41.7% 46.2% $116,878 42.7% 47.5% Unknown 4 0.3% $1,166 0.4% 0.2% 4 0.3% 0.2% $1,166 0.4% 0.2% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.2% $0 0.0% 0.8% Total 1,227 100.0% $273,695 100.0% 100.0% 1,227 100.0% 100.0% $273,695 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2017 D&B Information

104

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans

Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison 2015, 2016 2015 2016 Borrower Bank Families Count Dollar Count Dollar Income by Levels Count Dollar Family Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 2 1.6% $105 0.6% 22.6% 1 1.2% 3.0% $50 0.5% 1.2% 1 2.2% 2.5% $55 0.8% 1.1% Moderate 8 6.3% $479 2.9% 16.9% 3 3.7% 12.4% $189 1.9% 7.9% 5 10.9% 10.2% $290 4.3% 6.4% M iddle 9 7.1% $1,018 6.2% 19.1% 5 6.2% 21.7% $552 5.7% 18.6% 4 8.7% 21.8% $466 7.0% 18.2% Upper 106 83.5% $14,335 87.4% 41.5% 71 87.7% 43.3% $8,589 88.3% 55.2% 35 76.1% 46.4% $5,746 86.1% 57.5% Unknown 2 1.6% $459 2.8% 0.0% 1 1.2% 19.6% $345 3.5% 17.1% 1 2.2% 19.1% $114 1.7% 16.9%

HOME PURCHASE Total 127 100.0% $16,396 100.0% 100.0% 81 100.0% 100.0% $9,725 100.0% 100.0% 46 100.0% 100.0% $6,671 100.0% 100.0% Low 7 6.5% $341 3.4% 22.6% 3 5.8% 3.7% $181 4.0% 1.6% 4 7.1% 2.9% $160 3.0% 1.2% Moderate 17 15.7% $1,174 11.8% 16.9% 7 13.5% 9.0% $399 8.8% 4.8% 10 17.9% 6.9% $775 14.4% 3.6% M iddle 21 19.4% $1,583 16.0% 19.1% 11 21.2% 16.0% $590 13.0% 11.0% 10 17.9% 13.1% $993 18.4% 8.7% Upper 56 51.9% $6,261 63.2% 41.5% 28 53.8% 39.4% $3,069 67.8% 47.5% 28 50.0% 38.8% $3,192 59.3% 44.1%

REFINANCE Unknown 7 6.5% $551 5.6% 0.0% 3 5.8% 31.9% $288 6.4% 35.1% 4 7.1% 38.3% $263 4.9% 42.3% Total 108 100.0% $9,910 100.0% 100.0% 52 100.0% 100.0% $4,527 100.0% 100.0% 56 100.0% 100.0% $5,383 100.0% 100.0% Low 96 15.2% $1,040 3.4% 22.6% 27 11.0% 6.7% $378 2.9% 1.8% 69 17.8% 5.6% $662 3.7% 1.8% Moderate 84 13.3% $1,531 5.0% 16.9% 25 10.2% 12.0% $523 4.0% 6.1% 59 15.2% 11.8% $1,008 5.7% 6.5% M iddle 97 15.3% $3,807 12.3% 19.1% 44 18.0% 19.8% $2,076 15.8% 14.0% 53 13.7% 18.2% $1,731 9.8% 11.7%

HOME Upper 296 46.8% $22,460 72.8% 41.5% 121 49.4% 55.8% $9,241 70.2% 70.3% 175 45.2% 60.5% $13,219 74.6% 74.4% Unknown 59 9.3% $2,028 6.6% 0.0% 28 11.4% 5.7% $940 7.1% 7.8% 31 8.0% 3.8% $1,088 6.1% 5.7% IMPROVEMENT Total 632 100.0% $30,866 100.0% 100.0% 245 100.0% 100.0% $13,158 100.0% 100.0% 387 100.0% 100.0% $17,708 100.0% 100.0% Low 105 12.1% $1,486 2.6% 22.6% 31 8.2% 3.3% $609 2.2% 1.3% 74 15.1% 2.7% $877 2.9% 1.1% Moderate 109 12.6% $3,184 5.5% 16.9% 35 9.2% 11.3% $1,111 4.0% 6.6% 74 15.1% 9.1% $2,073 7.0% 5.3% M iddle 127 14.6% $6,408 11.1% 19.1% 60 15.8% 19.8% $3,218 11.6% 15.4% 67 13.7% 18.7% $3,190 10.7% 14.4% Upper 458 52.8% $43,056 74.8% 41.5% 220 58.0% 42.3% $20,899 75.1% 50.1% 238 48.7% 44.1% $22,157 74.4% 50.5% Unknown 69 7.9% $3,462 6.0% 0.0% 33 8.7% 23.4% $1,997 7.2% 26.7% 36 7.4% 25.3% $1,465 4.9% 28.8% HMDA TOTALS Total 868 100.0% $57,596 100.0% 100.0% 379 100.0% 100.0% $27,834 100.0% 100.0% 489 100.0% 100.0% $29,762 100.0% 100.0% Originations & Purchases 2016 FFIEC Census Data and2010 ACS Data

105

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Bank Families Count Dollar Levels by Family Count Dollar Bank Agg Bank Agg

PRODUCT TYPE PRODUCT Income

# % $ (000s) $ % % # % % $(000s) $ % $ % Low 1 1.6% $99 1.2% 22.6% 1 1.6% 2.4% $99 1.2% 1.1% Moderate 2 3.2% $185 2.2% 17.3% 2 3.2% 11.3% $185 2.2% 7.3% M iddle 2 3.2% $84 1.0% 19.1% 2 3.2% 22.0% $84 1.0% 18.7% Upper 55 87.3% $7,475 88.9% 41.0% 55 87.3% 43.8% $7,475 88.9% 54.4% Unknown 3 4.8% $568 6.8% 0.0% 3 4.8% 20.6% $568 6.8% 18.5%

HOME PURCHASE Total 63 100.0% $8,411 100.0% 100.0% 63 100.0% 100.0% $8,411 100.0% 100.0% Low 5 12.8% $207 4.1% 22.6% 5 12.8% 4.3% $207 4.1% 2.0% Moderate 3 7.7% $114 2.2% 17.3% 3 7.7% 10.0% $114 2.2% 5.5% M iddle 5 12.8% $366 7.2% 19.1% 5 12.8% 17.3% $366 7.2% 11.9% Upper 25 64.1% $3,870 75.9% 41.0% 25 64.1% 40.5% $3,870 75.9% 48.6%

REFINANCE Unknown 1 2.6% $540 10.6% 0.0% 1 2.6% 27.9% $540 10.6% 32.1% Total 39 100.0% $5,097 100.0% 100.0% 39 100.0% 100.0% $5,097 100.0% 100.0% Low 66 20.0% $1,295 7.0% 22.6% 66 20.0% 7.2% $1,295 7.0% 3.2% Moderate 44 13.3% $1,164 6.3% 17.3% 44 13.3% 13.1% $1,164 6.3% 6.8% M iddle 40 12.1% $1,888 10.2% 19.1% 40 12.1% 22.0% $1,888 10.2% 15.9%

HOME Upper 167 50.6% $13,773 74.1% 41.0% 167 50.6% 54.3% $13,773 74.1% 67.8% Unknown 13 3.9% $464 2.5% 0.0% 13 3.9% 3.3% $464 2.5% 6.3% IMPROVEMENT Total 330 100.0% $18,584 100.0% 100.0% 330 100.0% 100.0% $18,584 100.0% 100.0% Low 72 16.7% $1,601 5.0% 22.6% 72 16.7% 3.0% $1,601 5.0% 1.2% Moderate 49 11.3% $1,463 4.6% 17.3% 49 11.3% 11.0% $1,463 4.6% 6.3% M iddle 47 10.9% $2,338 7.3% 19.1% 47 10.9% 20.7% $2,338 7.3% 15.7% Upper 247 57.2% $25,118 78.3% 41.0% 247 57.2% 43.2% $25,118 78.3% 48.7%

HMDA TOTALS Unknown 17 3.9% $1,572 4.9% 0.0% 17 3.9% 22.1% $1,572 4.9% 28.1% Total 432 100.0% $32,092 100.0% 100.0% 432 100.0% 100.0% $32,092 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data

106

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Small Business Loans by Business Revenue & Loan Size Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Business Revenue & Loan Bank Count Dollar Count Dollar Size Total Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % $1million or Less 659 34.5% $99,056 21.1% 91.8% 306 33.9% 47.4% $47,408 21.2% 35.2% 353 35.1% 40.3% $51,648 21.0% 32.9% Over $1 Million 1,196 62.6% $359,605 76.6% 7.4% 574 63.6% 622 61.8% Total Rev. available 1,855 97.1% $458,661 97.7% 99.2% 880 97.5% 975 96.9% REVENUE BUSINESS Rev. Not Known 55 2.9% $10,634 2.3% 0.8% 23 2.5% 32 3.2% Total 1,910 100.0% $469,295 100.0% 100.0% 903 100.0% 1,007 100.0% $100,000 or Less 773 40.5% $39,634 8.4% 354 39.2% 93.9% $18,594 8.3% 40.7% 419 41.6% 94.8% $21,040 8.5% 44.8% $100,001 - $250,000 523 27.4% $97,713 20.8% 254 28.1% 3.2% $47,864 21.5% 15.6% 269 26.7% 2.7% $49,849 20.3% 14.3% $250,001 - $1 Million 614 32.1% $331,948 70.7% 295 32.7% 2.9% $156,670 70.2% 43.7% 319 31.7% 2.5% $175,278 71.2% 40.8% LOAN SIZE Total 1,910 100.0% $469,295 100.0% 903 100.0% 100.0% $223,128 100.0% 100.0% 1,007 100.0% 100.0% $246,167 100.0% 100.0% $100,000 or Less 401 60.8% $17,821 18.0% $100,001 - $250,000 148 22.5% $26,700 27.0%

$250,001 - $1 Million 110 16.7% $54,535 55.1% LOAN SIZE Total 659 100.0% $99,056 100.0% Rev $1 Mill orRev Less $1 Mill

Small Business Loans by Business Revenue & Loan Size Assessment Area: San Antonio Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Business Revenue & Loan 2017 2017 Size Bank Count Dollar Total Count $ (000s) Businesses Bank Agg Bank Agg # % $ % % # % % $ (000s) $ % $ % $1million or Less 499 40.7% $60,826 22.2% 91.0% 499 40.7% 46.4% $60,826 22.2% 36.3% Over $1 Million 692 56.4% $205,865 75.2% 8.2% 692 56.4% Total Rev. available 1,191 97.1% $266,691 97.4% 99.2% 1,191 97.1%

REVENUE Rev. Not Known 36 2.9% $7,004 2.6% 0.8% 36 2.9% BUSINESS Total 1,227 100.0% $273,695 100.0% 100.0% 1,227 100.0% $100,000 or Less 608 49.6% $30,384 11.1% 608 49.6% 93.8% $30,384 11.1% 40.7% $100,001 - $250,000 270 22.0% $49,676 18.2% 270 22.0% 3.2% $49,676 18.2% 15.6% $250,001 - $1 Million 349 28.4% $193,635 70.7% 349 28.4% 2.9% $193,635 70.7% 43.7%

LOAN SIZE Total 1,227 100.0% $273,695 100.0% 1,227 100.0% 100.0% $273,695 100.0% 100.0% $100,000 or Less 361 72.3% $14,943 24.6% $100,001 - $250,000 76 15.2% $13,274 21.8%

Less $250,001 - $1 Million 62 12.4% $32,609 53.6% LOAN SIZE Rev $1 Mill orRev $1 Mill Total 499 100.0% $60,826 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels O ccupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 6.9% 0 0.0% 1.7% $0 0.0% 0.9% 0 0.0% 1.6% $0 0.0% 1.0% Moderate 1 6.7% $110 4.2% 19.8% 0 0.0% 5.8% $0 0.0% 3.1% 1 16.7% 6.5% $110 14.8% 3.6% M iddle 1 6.7% $110 4.2% 39.2% 0 0.0% 37.2% $0 0.0% 33.2% 1 16.7% 36.8% $110 14.8% 33.5% Upper 13 86.7% $2,418 91.7% 34.1% 9 100.0% 55.3% $1,896 100.0% 62.7% 4 66.7% 55.1% $522 70.4% 62.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 15 100.0% $2,638 100.0% 100.0% 9 100.0% 100.0% $1,896 100.0% 100.0% 6 100.0% 100.0% $742 100.0% 100.0% Low 1 5.0% $49 1.9% 6.9% 0 0.0% 1.4% $0 0.0% 0.8% 1 8.3% 1.7% $49 4.6% 0.8% Moderate 1 5.0% $26 1.0% 19.8% 0 0.0% 6.9% $0 0.0% 4.0% 1 8.3% 6.5% $26 2.4% 3.8% M iddle 8 40.0% $1,032 40.0% 39.2% 6 75.0% 37.2% $1,013 67.0% 34.8% 2 16.7% 37.6% $19 1.8% 35.0% Upper 10 50.0% $1,474 57.1% 34.1% 2 25.0% 54.5% $500 33.0% 60.4% 8 66.7% 54.1% $974 91.2% 60.4%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 20 100.0% $2,581 100.0% 100.0% 8 100.0% 100.0% $1,513 100.0% 100.0% 12 100.0% 100.0% $1,068 100.0% 100.0% Low 9 7.1% $222 3.8% 6.9% 5 8.9% 3.1% $35 1.1% 1.6% 4 5.7% 5.3% $187 7.1% 3.1% Moderate 31 24.6% $533 9.0% 19.8% 14 25.0% 12.8% $317 9.6% 8.8% 17 24.3% 11.6% $216 8.3% 7.5% M iddle 36 28.6% $1,336 22.6% 39.2% 12 21.4% 41.5% $591 17.9% 39.0% 24 34.3% 42.7% $745 28.5% 36.8%

HOME Upper 50 39.7% $3,827 64.7% 34.1% 25 44.6% 42.6% $2,359 71.4% 50.7% 25 35.7% 40.4% $1,468 56.1% 52.6% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 126 100.0% $5,918 100.0% 100.0% 56 100.0% 100.0% $3,302 100.0% 100.0% 70 100.0% 100.0% $2,616 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 11.3% 0 0.0% 12.0% $0 0.0% 26.4% 0 0.0% 14.0% $0 0.0% 1.2% Moderate 0 0.0% $0 0.0% 9.1% 0 0.0% 16.0% $0 0.0% 3.0% 0 0.0% 4.7% $0 0.0% 2.0% M iddle 0 0.0% $0 0.0% 40.7% 0 0.0% 32.0% $0 0.0% 30.3% 0 0.0% 39.5% $0 0.0% 30.6% Upper 0 0.0% $0 0.0% 38.3% 0 0.0% 40.0% $0 0.0% 40.3% 0 0.0% 41.9% $0 0.0% 66.2%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.6% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 10 6.2% $271 2.4% 6.9% 5 6.8% 1.7% $35 0.5% 4.5% 5 5.7% 1.9% $236 5.3% 1.0% Moderate 33 20.5% $669 6.0% 19.8% 14 19.2% 6.4% $317 4.7% 3.4% 19 21.6% 6.7% $352 8.0% 3.6% M iddle 45 28.0% $2,478 22.3% 39.2% 18 24.7% 37.4% $1,604 23.9% 33.3% 27 30.7% 37.4% $874 19.7% 33.7% Upper 73 45.3% $7,719 69.3% 34.1% 36 49.3% 54.4% $4,755 70.9% 58.9% 37 42.0% 54.0% $2,964 67.0% 61.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 161 100.0% $11,137 100.0% 100.0% 73 100.0% 100.0% $6,711 100.0% 100.0% 88 100.0% 100.0% $4,426 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2010 ACS Data

108

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of HMDA Loans Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2017 2017 Income Bank Owner Count Dollar Levels O ccupied Count Dollar Bank Agg Bank Agg Units PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 3.5% 0 0.0% 0.4% $0 0.0% 0.2% Moderate 0 0.0% $0 0.0% 26.5% 0 0.0% 12.1% $0 0.0% 7.6% M iddle 2 40.0% $214 25.8% 31.4% 2 40.0% 30.4% $214 25.8% 28.5% Upper 3 60.0% $615 74.2% 38.6% 3 60.0% 57.1% $615 74.2% 63.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 5 100.0% $829 100.0% 100.0% 5 100.0% 100.0% $829 100.0% 100.0% Low 0 0.0% $0 0.0% 3.5% 0 0.0% 0.4% $0 0.0% 0.1% Moderate 0 0.0% $0 0.0% 26.5% 0 0.0% 12.9% $0 0.0% 8.4% M iddle 6 75.0% $559 62.2% 31.4% 6 75.0% 31.5% $559 62.2% 28.3% Upper 2 25.0% $339 37.8% 38.6% 2 25.0% 55.3% $339 37.8% 63.1%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 8 100.0% $898 100.0% 100.0% 8 100.0% 100.0% $898 100.0% 100.0% Low 2 3.6% $48 1.5% 3.5% 2 3.6% 3.3% $48 1.5% 2.1% Moderate 9 16.1% $52 1.6% 26.5% 9 16.1% 21.4% $52 1.6% 14.3% M iddle 25 44.6% $749 23.3% 31.4% 25 44.6% 34.6% $749 23.3% 28.4%

HOME Upper 20 35.7% $2,364 73.6% 38.6% 20 35.7% 40.8% $2,364 73.6% 55.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 56 100.0% $3,213 100.0% 100.0% 56 100.0% 100.0% $3,213 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 4.2% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 21.5% 0 0.0% 15.8% $0 0.0% 4.3% M iddle 0 0.0% $0 0.0% 32.8% 0 0.0% 15.8% $0 0.0% 3.3% Upper 0 0.0% $0 0.0% 41.4% 0 0.0% 68.4% $0 0.0% 92.5%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 2 2.9% $48 1.0% 3.5% 2 2.9% 0.5% $48 1.0% 0.2% Moderate 9 13.0% $52 1.1% 26.5% 9 13.0% 12.8% $52 1.1% 7.7% M iddle 33 47.8% $1,522 30.8% 31.4% 33 47.8% 30.9% $1,522 30.8% 27.0% Upper 25 36.2% $3,318 67.2% 38.6% 25 36.2% 55.8% $3,318 67.2% 65.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 69 100.0% $4,940 100.0% 100.0% 69 100.0% 100.0% $4,940 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data

109

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Geographic Distribution of Small Business Loans Assessment Area: Corpus Christi

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison

Tract 2015, 2016 2015 2016 Income Bank Small Levels Count Dollar Count Dollar Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ 000s $ % $ % # % % $ 000s $ % $ % Low 72 19.3% $18,734 20.1% 14.1% 43 21.0% 15.1% $10,474 20.5% 23.9% 29 17.3% 15.1% $8,260 19.7% 19.5% Moderate 84 22.5% $23,772 25.6% 16.5% 44 21.5% 17.8% $11,310 22.1% 22.2% 40 23.8% 18.1% $12,462 29.8% 20.0% M iddle 95 25.5% $28,219 30.3% 36.5% 55 26.8% 32.3% $17,339 33.9% 27.4% 40 23.8% 33.1% $10,880 26.0% 31.7% Upper 121 32.4% $22,222 23.9% 32.8% 63 30.7% 31.3% $12,044 23.5% 24.6% 58 34.5% 31.5% $10,178 24.3% 27.5% Unknown 1 0.3% $43 0.0% 0.1% 0 0.0% 0.2% $0 0.0% 0.1% 1 0.6% 0.1% $43 0.1% 0.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 3.3% $0 0.0% 1.8% 0 0.0% 2.2% $0 0.0% 1.3% Total 373 100.0% $92,990 100.0% 100.0% 205 100.0% 100.0% $51,167 100.0% 100.0% 168 100.0% 100.0% $41,823 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data and 2016 D&B Information

Geographic Distribution of Small Business Loans Assessment Area: Corpus Christi

Bank Lending & Demographic Data Comparison Bank & Aggregate Lending Comparison

Tract 2017 2017 Income Bank Small Count Dollar Levels Count Dollar Businesses Bank Agg Bank Agg

# % $ (000s) $ % % # % % $ 000s $ % $ % Low 11 5.6% $3,235 7.3% 3.4% 11 5.6% 2.8% $3,235 7.3% 2.2% Moderate 46 23.2% $9,402 21.3% 30.1% 46 23.2% 28.1% $9,402 21.3% 31.3% M iddle 84 42.4% $22,025 49.9% 31.0% 84 42.4% 32.3% $22,025 49.9% 36.9% Upper 57 28.8% $9,444 21.4% 35.4% 57 28.8% 34.3% $9,444 21.4% 28.1% Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.0% $0 0.0% 0.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 2.4% $0 0.0% 1.4% Total 198 100.0% $44,106 100.0% 100.0% 198 100.0% 100.0% $44,106 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data and 2017 D&B Information

110

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans

Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison 2015, 2016 2015 2016 Borrower Bank Families Count Dollar Count Dollar Income by Levels Count Dollar Family Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 24.5% 0 0.0% 1.6% $0 0.0% 0.7% 0 0.0% 1.5% $0 0.0% 0.7% Moderate 1 6.7% $110 4.2% 16.3% 0 0.0% 9.3% $0 0.0% 5.9% 1 16.7% 8.6% $110 14.8% 5.5% M iddle 2 13.3% $234 8.9% 17.8% 2 22.2% 18.9% $234 12.3% 15.7% 0 0.0% 20.1% $0 0.0% 16.7% Upper 10 66.7% $1,464 55.5% 41.4% 5 55.6% 49.3% $832 43.9% 58.6% 5 83.3% 46.5% $632 85.2% 56.1% Unknown 2 13.3% $830 31.5% 0.0% 2 22.2% 20.9% $830 43.8% 19.1% 0 0.0% 23.3% $0 0.0% 21.0%

HOME PURCHASE Total 15 100.0% $2,638 100.0% 100.0% 9 100.0% 100.0% $1,896 100.0% 100.0% 6 100.0% 100.0% $742 100.0% 100.0% Low 1 5.0% $40 1.5% 24.5% 1 12.5% 3.2% $40 2.6% 1.8% 0 0.0% 2.3% $0 0.0% 1.2% Moderate 4 20.0% $96 3.7% 16.3% 0 0.0% 6.6% $0 0.0% 3.8% 4 33.3% 6.1% $96 9.0% 3.2% M iddle 4 20.0% $421 16.3% 17.8% 0 0.0% 14.9% $0 0.0% 10.4% 4 33.3% 13.7% $421 39.4% 9.2% Upper 10 50.0% $1,910 74.0% 41.4% 6 75.0% 44.6% $1,359 89.8% 50.3% 4 33.3% 41.9% $551 51.6% 48.1%

REFINANCE Unknown 1 5.0% $114 4.4% 0.0% 1 12.5% 30.8% $114 7.5% 33.7% 0 0.0% 36.0% $0 0.0% 38.3% Total 20 100.0% $2,581 100.0% 100.0% 8 100.0% 100.0% $1,513 100.0% 100.0% 12 100.0% 100.0% $1,068 100.0% 100.0% Low 19 15.1% $299 5.1% 24.5% 11 19.6% 4.2% $236 7.1% 1.4% 8 11.4% 6.5% $63 2.4% 2.3% Moderate 22 17.5% $436 7.4% 16.3% 10 17.9% 12.8% $140 4.2% 9.5% 12 17.1% 11.4% $296 11.3% 5.3% M iddle 27 21.4% $936 15.8% 17.8% 10 17.9% 18.5% $291 8.8% 12.9% 17 24.3% 19.5% $645 24.7% 14.1%

HOME Upper 52 41.3% $4,056 68.5% 41.4% 23 41.1% 56.5% $2,506 75.9% 64.7% 29 41.4% 57.3% $1,550 59.3% 67.1% Unknown 6 4.8% $191 3.2% 0.0% 2 3.6% 7.9% $129 3.9% 11.5% 4 5.7% 5.3% $62 2.4% 11.2% IMPROVEMENT Total 126 100.0% $5,918 100.0% 100.0% 56 100.0% 100.0% $3,302 100.0% 100.0% 70 100.0% 100.0% $2,616 100.0% 100.0% Low 20 12.4% $339 3.0% 24.5% 12 16.4% 2.1% $276 4.1% 0.8% 8 9.1% 2.0% $63 1.4% 0.8% Moderate 27 16.8% $642 5.8% 16.3% 10 13.7% 8.7% $140 2.1% 4.7% 17 19.3% 8.0% $502 11.3% 4.4% M iddle 33 20.5% $1,591 14.3% 17.8% 12 16.4% 17.8% $525 7.8% 12.3% 21 23.9% 18.1% $1,066 24.1% 13.2% Upper 72 44.7% $7,430 66.7% 41.4% 34 46.6% 48.2% $4,697 70.0% 48.6% 38 43.2% 45.5% $2,733 61.7% 48.8% Unknown 9 5.6% $1,135 10.2% 0.0% 5 6.8% 23.2% $1,073 16.0% 33.6% 4 4.5% 26.4% $62 1.4% 32.9% HMDA TOTALS Total 161 100.0% $11,137 100.0% 100.0% 73 100.0% 100.0% $6,711 100.0% 100.0% 88 100.0% 100.0% $4,426 100.0% 100.0% Originations & Purchases 2016 FFIEC Census Data and2010 ACS Data

111

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Bank Families Count Dollar Levels by Family Count Dollar Bank Agg Bank Agg

PRODUCT TYPE PRODUCT Income

# % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 22.4% 0 0.0% 2.2% $0 0.0% 1.0% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 9.9% $0 0.0% 6.5% M iddle 1 20.0% $164 19.8% 18.1% 1 20.0% 20.0% $164 19.8% 17.2% Upper 3 60.0% $567 68.4% 42.2% 3 60.0% 42.8% $567 68.4% 52.8% Unknown 1 20.0% $98 11.8% 0.0% 1 20.0% 25.2% $98 11.8% 22.4%

HOME PURCHASE Total 5 100.0% $829 100.0% 100.0% 5 100.0% 100.0% $829 100.0% 100.0% Low 1 12.5% $52 5.8% 22.4% 1 12.5% 3.4% $52 5.8% 1.7% Moderate 1 12.5% $77 8.6% 17.3% 1 12.5% 9.1% $77 8.6% 5.5% M iddle 1 12.5% $93 10.4% 18.1% 1 12.5% 15.5% $93 10.4% 11.2% Upper 3 37.5% $463 51.6% 42.2% 3 37.5% 40.1% $463 51.6% 47.7%

REFINANCE Unknown 2 25.0% $213 23.7% 0.0% 2 25.0% 31.9% $213 23.7% 33.9% Total 8 100.0% $898 100.0% 100.0% 8 100.0% 100.0% $898 100.0% 100.0% Low 6 10.7% $46 1.4% 22.4% 6 10.7% 7.4% $46 1.4% 3.6% Moderate 6 10.7% $121 3.8% 17.3% 6 10.7% 13.2% $121 3.8% 9.2% M iddle 12 21.4% $338 10.5% 18.1% 12 21.4% 22.8% $338 10.5% 17.6%

HOME Upper 25 44.6% $2,536 78.9% 42.2% 25 44.6% 46.4% $2,536 78.9% 60.0% Unknown 7 12.5% $172 5.4% 0.0% 7 12.5% 10.3% $172 5.4% 9.6% IMPROVEMENT Total 56 100.0% $3,213 100.0% 100.0% 56 100.0% 100.0% $3,213 100.0% 100.0%

Low 0 0.0% $0 0.0% 22.4% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 0.0% $0 0.0% 0.0% M iddle 0 0.0% $0 0.0% 18.1% 0 0.0% 0.0% $0 0.0% 0.0% Upper 0 0.0% $0 0.0% 42.2% 0 0.0% 0.0% $0 0.0% 0.0%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 100.0% $0 0.0% 100.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 7 10.1% $98 2.0% 22.4% 7 10.1% 2.8% $98 2.0% 1.2% Moderate 7 10.1% $198 4.0% 17.3% 7 10.1% 9.9% $198 4.0% 6.0% M iddle 14 20.3% $595 12.0% 18.1% 14 20.3% 19.1% $595 12.0% 15.0% Upper 31 44.9% $3,566 72.2% 42.2% 31 44.9% 42.3% $3,566 72.2% 48.8%

HMDA TOTALS Unknown 10 14.5% $483 9.8% 0.0% 10 14.5% 26.0% $483 9.8% 29.0% Total 69 100.0% $4,940 100.0% 100.0% 69 100.0% 100.0% $4,940 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data and 2015 ACS Data 112

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix E – Metropolitan Full Scope Assessment Area Loan Tables

Small Business Loans by Business Revenue & Loan Size Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Business Revenue & Loan Bank Count Dollar Count Dollar Size Total Count Dollar Businesses Bank Agg Bank Agg Bank Agg Bank Agg # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % $1million or Less 145 38.9% $32,630 35.1% 90.8% 74 36.1% 46.5% $16,713 32.7% 39.0% 71 42.3% 37.7% $15,917 38.1% 32.1% Over $1 Million 213 57.1% $58,144 62.5% 8.1% 120 58.5% 93 55.4% Total Rev. available 358 96.0% $90,774 97.6% 98.9% 194 94.6% 164 97.7% REVENUE BUSINESS Rev. Not Known 15 4.0% $2,216 2.4% 1.1% 11 5.4% 4 2.4% Total 373 100.0% $92,990 100.0% 100.0% 205 100.0% 168 100.0% $100,000 or Less 161 43.2% $8,978 9.7% 88 42.9% 92.7% $5,404 10.6% 36.4% 73 43.5% 93.6% $3,574 8.5% 40.6% $100,001 - $250,000 93 24.9% $16,727 18.0% 50 24.4% 4.2% $8,863 17.3% 19.3% 43 25.6% 3.9% $7,864 18.8% 19.6% $250,001 - $1 Million 119 31.9% $67,285 72.4% 67 32.7% 3.1% $36,900 72.1% 44.3% 52 31.0% 2.6% $30,385 72.7% 39.8% LOAN SIZE Total 373 100.0% $92,990 100.0% 205 100.0% 100.0% $51,167 100.0% 100.0% 168 100.0% 100.0% $41,823 100.0% 100.0% $100,000 or Less 78 53.8% $3,745 11.5% $100,001 - $250,000 27 18.6% $4,843 14.8%

$250,001 - $1 Million 40 27.6% $24,042 73.7% LOAN SIZE Total 145 100.0% $32,630 100.0% Rev $1 Mill orRev Less $1 Mill

Originations & Purchases Aggregate data is unavailable for loans to businesses w ith revenue over $1 million or revenue unknow n, and for loan size by revenue. 2016 FFIEC Census Data and 2016 D&B Information Small Business Loans by Business Revenue & Loan Size Assessment Area: Corpus Christi Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Business Revenue & Loan 2017 2017 Size Bank Count Dollar Total Count $ (000s) Businesses Bank Agg Bank Agg # % $ % % # % % $ (000s) $ % $ % $1million or Less 90 45.5% $13,199 29.9% 89.6% 90 45.5% 38.7% $13,199 29.9% 31.4% Over $1 Million 106 53.5% $30,747 69.7% 9.3% 106 53.5% Total Rev. available 196 99.0% $43,946 99.6% 98.9% 196 99.0%

REVENUE Rev. Not Known 2 1.0% $160 0.4% 1.1% 2 1.0% BUSINESS Total 198 100.0% $44,106 100.0% 100.0% 198 100.0% $100,000 or Less 86 43.4% $4,254 9.6% 86 43.4% 93.1% $4,254 9.6% 41.1% $100,001 - $250,000 51 25.8% $9,132 20.7% 51 25.8% 4.1% $9,132 20.7% 19.5% $250,001 - $1 Million 61 30.8% $30,720 69.7% 61 30.8% 2.8% $30,720 69.7% 39.4%

LOAN SIZE Total 198 100.0% $44,106 100.0% 198 100.0% 100.0% $44,106 100.0% 100.0% $100,000 or Less 60 66.7% $2,552 19.3% $100,001 - $250,000 14 15.6% $2,320 17.6%

Less $250,001 - $1 Million 16 17.8% $8,327 63.1% LOAN SIZE Rev $1 Mill orRev $1 Mill Total 90 100.0% $13,199 100.0% Originations & Purchases Aggregate data is unavailable for loans to businesses w ith revenue over $1 million or revenue unknow n, and for loan size by revenue. 2017 FFIEC Census Data and 2017 D&B Information

113

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

The assessment area loan tables appear in the following order:

114

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Brownsville-Harlingen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 1.0% 0 0.0% 0.3% $0 0.0% 0.1% 0 0.0% 0.2% $0 0.0% 0.1% Moderate 0 0.0% $0 0.0% 23.6% 0 0.0% 10.2% $0 0.0% 8.1% 0 0.0% 11.1% $0 0.0% 8.8% M iddle 0 0.0% $0 0.0% 47.5% 0 0.0% 43.2% $0 0.0% 38.7% 0 0.0% 44.2% $0 0.0% 41.2% Upper 2 100.0% $83 100.0% 27.8% 2 100.0% 46.4% $83 100.0% 53.1% 0 0.0% 44.5% $0 0.0% 49.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 2 100.0% $83 100.0% 100.0% 2 100.0% 100.0% $83 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 1.0% 0 0.0% 0.1% $0 0.0% 0.0% 0 0.0% 0.2% $0 0.0% 0.1% Moderate 1 14.3% $50 7.2% 23.6% 0 0.0% 8.7% $0 0.0% 6.1% 1 33.3% 10.6% $50 21.7% 8.5% M iddle 3 42.9% $366 52.4% 47.5% 2 50.0% 48.8% $256 54.7% 45.5% 1 33.3% 47.0% $110 47.8% 42.7% Upper 3 42.9% $282 40.4% 27.8% 2 50.0% 42.3% $212 45.3% 48.3% 1 33.3% 42.2% $70 30.4% 48.7%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 7 100.0% $698 100.0% 100.0% 4 100.0% 100.0% $468 100.0% 100.0% 3 100.0% 100.0% $230 100.0% 100.0% Low 1 2.9% $4 0.5% 1.0% 0 0.0% 0.5% $0 0.0% 0.1% 1 4.2% 0.9% $4 0.6% 0.1% Moderate 10 29.4% $305 39.1% 23.6% 3 30.0% 22.3% $8 8.6% 15.8% 7 29.2% 17.1% $297 43.2% 10.8% M iddle 19 55.9% $267 34.2% 47.5% 6 60.0% 46.0% $79 84.9% 46.1% 13 54.2% 46.2% $188 27.3% 35.1%

HOME Upper 4 11.8% $205 26.2% 27.8% 1 10.0% 31.3% $6 6.5% 38.0% 3 12.5% 35.9% $199 28.9% 54.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 34 100.0% $781 100.0% 100.0% 10 100.0% 100.0% $93 100.0% 100.0% 24 100.0% 100.0% $688 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 2.7% 0 0.0% 6.9% $0 0.0% 3.7% 0 0.0% 2.9% $0 0.0% 0.3% Moderate 0 0.0% $0 0.0% 20.1% 0 0.0% 20.7% $0 0.0% 7.2% 0 0.0% 20.6% $0 0.0% 9.2% M iddle 0 0.0% $0 0.0% 35.3% 0 0.0% 37.9% $0 0.0% 34.6% 0 0.0% 52.9% $0 0.0% 80.5% Upper 0 0.0% $0 0.0% 41.8% 0 0.0% 34.5% $0 0.0% 54.4% 0 0.0% 23.5% $0 0.0% 10.1%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 1 2.3% $4 0.3% 1.0% 0 0.0% 0.3% $0 0.0% 0.3% 1 3.7% 0.2% $4 0.4% 0.1% Moderate 11 25.6% $355 22.7% 23.6% 3 18.8% 10.3% $8 1.2% 7.6% 8 29.6% 11.3% $347 37.8% 8.8% M iddle 22 51.2% $633 40.5% 47.5% 8 50.0% 45.0% $335 52.0% 40.7% 14 51.9% 45.2% $298 32.5% 44.7% Upper 9 20.9% $570 36.5% 27.8% 5 31.3% 44.4% $301 46.7% 51.5% 4 14.8% 43.3% $269 29.3% 46.4% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 43 100.0% $1,562 100.0% 100.0% 16 100.0% 100.0% $644 100.0% 100.0% 27 100.0% 100.0% $918 100.0% 100.0% Small Businesses Low 7 3.6% $935 2.8% 4.0% 3 3.2% 4.2% $586 3.5% 3.1% 4 4.0% 3.9% $349 2.1% 2.5% Moderate 44 22.9% $9,116 27.0% 27.5% 21 22.6% 25.8% $4,864 29.0% 28.3% 23 23.2% 25.9% $4,252 25.0% 23.7% M iddle 98 51.0% $17,473 51.7% 39.1% 51 54.8% 37.8% $8,170 48.7% 37.5% 47 47.5% 37.2% $9,303 54.7% 39.2% Upper 39 20.3% $5,753 17.0% 29.4% 17 18.3% 28.9% $2,957 17.6% 28.4% 22 22.2% 30.8% $2,796 16.4% 32.6% Unknown 4 2.1% $510 1.5% 0.1% 1 1.1% 0.3% $200 1.2% 0.6% 3 3.0% 0.1% $310 1.8% 0.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 3.0% $0 0.0% 2.1% 0 0.0% 2.1% $0 0.0% 2.0% SMALL BUSINESSES Total 192 100.0% $33,787 100.0% 100.0% 93 100.0% 100.0% $16,777 100.0% 100.0% 99 100.0% 100.0% $17,010 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

115

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Brownsville-Harlingen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 29.1% 0 0.0% 12.9% $0 0.0% 9.9% M iddle 0 0.0% $0 0.0% 29.9% 0 0.0% 25.1% $0 0.0% 22.8% Upper 3 100.0% $370 100.0% 40.9% 3 100.0% 61.9% $370 100.0% 67.3% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 3 100.0% $370 100.0% 100.0% 3 100.0% 100.0% $370 100.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 29.1% 0 0.0% 12.0% $0 0.0% 10.0% M iddle 2 50.0% $80 36.5% 29.9% 2 50.0% 28.4% $80 36.5% 27.1% Upper 2 50.0% $139 63.5% 40.9% 2 50.0% 59.7% $139 63.5% 62.8%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 4 100.0% $219 100.0% 100.0% 4 100.0% 100.0% $219 100.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 5 26.3% $39 5.0% 29.1% 5 26.3% 28.2% $39 5.0% 13.3% M iddle 5 26.3% $108 13.8% 29.9% 5 26.3% 28.9% $108 13.8% 26.3%

HOME Upper 9 47.4% $636 81.2% 40.9% 9 47.4% 42.5% $636 81.2% 60.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.3% $0 0.0% 0.2% IMPROVEMENT Total 19 100.0% $783 100.0% 100.0% 19 100.0% 100.0% $783 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 1 100.0% $240 100.0% 23.8% 1 100.0% 27.3% $240 100.0% 12.9% M iddle 0 0.0% $0 0.0% 27.2% 0 0.0% 45.5% $0 0.0% 28.6% Upper 0 0.0% $0 0.0% 49.0% 0 0.0% 27.3% $0 0.0% 58.5%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $240 100.0% 100.0% 1 100.0% 100.0% $240 100.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 6 22.2% $279 17.3% 29.1% 6 22.2% 13.7% $279 17.3% 10.4% M iddle 7 25.9% $188 11.7% 29.9% 7 25.9% 26.4% $188 11.7% 24.6% Upper 14 51.9% $1,145 71.0% 40.9% 14 51.9% 59.9% $1,145 71.0% 65.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 27 100.0% $1,612 100.0% 100.0% 27 100.0% 100.0% $1,612 100.0% 100.0% Small Businesses Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 20 23.3% $5,402 35.1% 34.1% 20 23.3% 29.3% $5,402 35.1% 26.4% M iddle 25 29.1% $4,287 27.8% 27.4% 25 29.1% 29.1% $4,287 27.8% 33.9% Upper 37 43.0% $5,479 35.6% 38.4% 37 43.0% 39.5% $5,479 35.6% 38.2% Unknown 4 4.7% $234 1.5% 0.1% 4 4.7% 0.2% $234 1.5% 0.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.8% $0 0.0% 1.3%

SMALL BUSINESSES Total 86 100.0% $15,402 100.0% 116100.0% 86 100.0% 100.0% $15,402 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data, 2017 D&B Info, and 2015 ACS Data Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Brownsville-Harlingen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 24.3% 0 0.0% 0.4% $0 0.0% 0.2% 0 0.0% 1.1% $0 0.0% 0.4% Moderate 0 0.0% $0 0.0% 16.0% 0 0.0% 5.4% $0 0.0% 2.8% 0 0.0% 6.6% $0 0.0% 3.6% M iddle 0 0.0% $0 0.0% 17.5% 0 0.0% 12.7% $0 0.0% 8.8% 0 0.0% 12.8% $0 0.0% 9.3% Upper 2 100.0% $83 100.0% 42.1% 2 100.0% 56.7% $83 100.0% 63.8% 0 0.0% 54.9% $0 0.0% 62.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 24.8% $0 0.0% 24.5% 0 0.0% 24.5% $0 0.0% 24.0%

HOME PURCHASE Total 2 100.0% $83 100.0% 100.0% 2 100.0% 100.0% $83 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 24.3% 0 0.0% 1.4% $0 0.0% 0.6% 0 0.0% 1.4% $0 0.0% 0.6% Moderate 0 0.0% $0 0.0% 16.0% 0 0.0% 3.6% $0 0.0% 1.8% 0 0.0% 4.4% $0 0.0% 2.1% M iddle 0 0.0% $0 0.0% 17.5% 0 0.0% 8.0% $0 0.0% 4.7% 0 0.0% 10.4% $0 0.0% 6.4% Upper 6 85.7% $618 88.5% 42.1% 3 75.0% 61.0% $388 82.9% 62.2% 3 100.0% 54.6% $230 100.0% 58.5%

REFINANCE Unknown 1 14.3% $80 11.5% 0.0% 1 25.0% 26.0% $80 17.1% 30.7% 0 0.0% 29.2% $0 0.0% 32.4% Total 7 100.0% $698 100.0% 100.0% 4 100.0% 100.0% $468 100.0% 100.0% 3 100.0% 100.0% $230 100.0% 100.0% Low 5 14.7% $16 2.0% 24.3% 2 20.0% 4.3% $5 5.4% 0.8% 3 12.5% 5.6% $11 1.6% 1.7% Moderate 9 26.5% $59 7.6% 16.0% 3 30.0% 11.8% $26 28.0% 6.7% 6 25.0% 10.7% $33 4.8% 5.7% M iddle 6 17.6% $72 9.2% 17.5% 1 10.0% 12.8% $25 26.9% 4.9% 5 20.8% 13.2% $47 6.8% 7.5%

HOME Upper 12 35.3% $608 77.8% 42.1% 2 20.0% 63.0% $11 11.8% 72.8% 10 41.7% 65.0% $597 86.8% 63.0% Unknown 2 5.9% $26 3.3% 0.0% 2 20.0% 8.1% $26 28.0% 14.8% 0 0.0% 5.6% $0 0.0% 22.1% IMPROVEMENT Total 34 100.0% $781 100.0% 100.0% 10 100.0% 100.0% $93 100.0% 100.0% 24 100.0% 100.0% $688 100.0% 100.0% Low 5 11.6% $16 1.0% 24.3% 2 12.5% 0.9% $5 0.8% 0.3% 3 11.1% 1.4% $11 1.2% 0.4% Moderate 9 20.9% $59 3.8% 16.0% 3 18.8% 5.1% $26 4.0% 2.4% 6 22.2% 6.1% $33 3.6% 2.9% M iddle 6 14.0% $72 4.6% 17.5% 1 6.3% 11.2% $25 3.9% 7.1% 5 18.5% 12.0% $47 5.1% 7.7% Upper 20 46.5% $1,309 83.8% 42.1% 7 43.8% 58.0% $482 74.8% 60.6% 13 48.1% 54.9% $827 90.1% 56.4% Unknown 3 7.0% $106 6.8% 0.0% 3 18.8% 24.9% $106 16.5% 29.6% 0 0.0% 25.6% $0 0.0% 32.6% HMDA TOTALS Total 43 100.0% $1,562 100.0% 100.0% 16 100.0% 100.0% $644 100.0% 100.0% 27 100.0% 100.0% $918 100.0% 100.0% Total Businesses $1 Million or Less 83 43.2% $10,714 31.7% 91.4% 45 48.4% 52.4% $6,441 38.4% 45.1% 38 38.4% 39.9% $4,273 25.1% 35.7% Over $1 Million 106 55.2% $22,650 67.0% 7.7% 47 50.5% 59 59.6% Total Rev. available 189 98.4% $33,364 98.7% 99.1% 92 98.9% 97 98.0%

Revenue Rev. Not Known 3 1.6% $423 1.3% 0.9% 1 1.1% 2 2.0% Total 192 100.0% $33,787 100.0% 100.0% 93 100.0% 99 100.0% $100,000 or Less 110 57.3% $6,344 18.8% 49 52.7% 95.9% $3,009 17.9% 52.9% 61 61.6% 96.0% $3,335 19.6% 53.7% Small Business $100,001 - $250,000 45 23.4% $7,893 23.4% 24 25.8% 2.4% $4,159 24.8% 15.5% 21 21.2% 2.4% $3,734 22.0% 16.2% $250,001 - $1 Million 37 19.3% $19,550 57.9% 20 21.5% 1.7% $9,609 57.3% 31.6% 17 17.2% 1.6% $9,941 58.4% 30.1% Loan Size Total 192 100.0% $33,787 100.0% 93 100.0% 100.0% $16,777 100.0% 100.0% 99 100.0% 100.0% $17,010 100.0% 100.0%

117

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans and Small Business Lending by Revenue & Loan Size Assessment Area: Brownsville-Harlingen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 24.6% 0 0.0% 0.8% $0 0.0% 0.3% Moderate 0 0.0% $0 0.0% 16.6% 0 0.0% 7.4% $0 0.0% 3.8% M iddle 0 0.0% $0 0.0% 15.7% 0 0.0% 13.3% $0 0.0% 9.2% Upper 1 33.3% $100 27.0% 43.0% 1 33.3% 55.5% $100 27.0% 63.4% Unknown 2 66.7% $270 73.0% 0.0% 2 66.7% 23.1% $270 73.0% 23.4%

HOME PURCHASE Total 3 100.0% $370 100.0% 100.0% 3 100.0% 100.0% $370 100.0% 100.0% Low 0 0.0% $0 0.0% 24.6% 0 0.0% 0.5% $0 0.0% 0.2% Moderate 1 25.0% $39 17.8% 16.6% 1 25.0% 4.9% $39 17.8% 2.7% M iddle 0 0.0% $0 0.0% 15.7% 0 0.0% 11.4% $0 0.0% 7.0% Upper 3 75.0% $180 82.2% 43.0% 3 75.0% 55.6% $180 82.2% 59.2%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 27.5% $0 0.0% 30.9% Total 4 100.0% $219 100.0% 100.0% 4 100.0% 100.0% $219 100.0% 100.0% Low 1 5.3% $2 0.3% 24.6% 1 5.3% 5.2% $2 0.3% 1.4% Moderate 3 15.8% $27 3.4% 16.6% 3 15.8% 15.6% $27 3.4% 6.7% M iddle 3 15.8% $144 18.4% 15.7% 3 15.8% 15.9% $144 18.4% 9.0%

HOME Upper 10 52.6% $509 65.0% 43.0% 10 52.6% 58.1% $509 65.0% 68.4% Unknown 2 10.5% $101 12.9% 0.0% 2 10.5% 5.2% $101 12.9% 14.6% IMPROVEMENT Total 19 100.0% $783 100.0% 100.0% 19 100.0% 100.0% $783 100.0% 100.0% Low 1 3.9% $2 0.2% 24.6% 1 3.9% 1.0% $2 0.2% 0.2% Moderate 4 15.4% $66 4.8% 16.6% 4 15.4% 7.2% $66 4.8% 3.1% M iddle 3 11.5% $144 10.5% 15.7% 3 11.5% 12.8% $144 10.5% 7.5% Upper 14 53.8% $789 57.5% 43.0% 14 53.8% 55.2% $789 57.5% 54.5% Unknown 4 15.4% $371 27.0% 0.0% 4 15.4% 23.8% $371 27.0% 34.6% HMDA TOTALS Total 26 100.0% $1,372 100.0% 100.0% 26 100.0% 100.0% $1,372 100.0% 100.0% Total Businesses $1 Million or Less 39 45.3% $4,949 32.1% 90.5% 39 45.3% 43.4% $4,949 32.1% 44.5% Over $1 Million 47 54.7% $10,453 67.9% 8.5% 47 54.7% Total Rev. available 86 100.0% $15,402 100.0% 99.0% 86 100.0%

Revenue Rev. Not Known 0 0.0% $0 0.0% 0.9% 0 0.0% Total 86 100.0% $15,402 100.0% 100.0% 86 100.0% $100,000 or Less 48 55.8% $2,235 14.5% 48 55.8% 93.7% $2,235 14.5% 44.0% Small Business $100,001 - $250,000 19 22.1% $3,625 23.5% 19 22.1% 3.9% $3,625 23.5% 19.1% $250,001 - $1 Million 19 22.1% $9,542 62.0% 19 22.1% 2.4% $9,542 62.0% 37.0% Loan Size Total 86 100.0% $15,402 100.0% 86 100.0% 100.0% $15,402 100.0% 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Midland Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 4.6% 0 0.0% 2.4% $0 0.0% 1.5% 0 0.0% 2.2% $0 0.0% 1.5% Moderate 0 0.0% $0 0.0% 14.3% 0 0.0% 7.0% $0 0.0% 4.6% 0 0.0% 8.2% $0 0.0% 5.5% M iddle 1 33.3% $98 10.2% 49.6% 0 0.0% 42.3% $0 0.0% 41.8% 1 100.0% 40.9% $98 100.0% 36.3% Upper 2 66.7% $860 89.8% 31.4% 2 100.0% 48.2% $860 100.0% 52.1% 0 0.0% 48.6% $0 0.0% 56.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 3 100.0% $958 100.0% 100.0% 2 100.0% 100.0% $860 100.0% 100.0% 1 100.0% 100.0% $98 100.0% 100.0% Low 0 0.0% $0 0.0% 4.6% 0 0.0% 2.2% $0 0.0% 1.3% 0 0.0% 1.6% $0 0.0% 0.8% Moderate 1 33.3% $65 22.7% 14.3% 0 0.0% 8.0% $0 0.0% 4.9% 1 50.0% 7.7% $65 44.2% 4.6% M iddle 0 0.0% $0 0.0% 49.6% 0 0.0% 47.9% $0 0.0% 42.9% 0 0.0% 47.8% $0 0.0% 42.9% Upper 2 66.7% $221 77.3% 31.4% 1 100.0% 41.9% $139 100.0% 50.8% 1 50.0% 42.9% $82 55.8% 51.6%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.1% $0 0.0% 0.1% Total 3 100.0% $286 100.0% 100.0% 1 100.0% 100.0% $139 100.0% 100.0% 2 100.0% 100.0% $147 100.0% 100.0% Low 1 5.6% $3 0.4% 4.6% 0 0.0% 4.5% $0 0.0% 1.2% 1 7.1% 3.9% $3 0.4% 1.1% Moderate 1 5.6% $7 1.0% 14.3% 1 25.0% 11.4% $7 12.3% 9.4% 0 0.0% 8.7% $0 0.0% 6.1% M iddle 8 44.4% $344 47.3% 49.6% 2 50.0% 51.7% $37 64.9% 42.8% 6 42.9% 54.3% $307 45.8% 49.6%

HOME Upper 8 44.4% $374 51.4% 31.4% 1 25.0% 32.3% $13 22.8% 46.7% 7 50.0% 33.0% $361 53.8% 43.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 18 100.0% $728 100.0% 100.0% 4 100.0% 100.0% $57 100.0% 100.0% 14 100.0% 100.0% $671 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 1.2% 0 0.0% 22.2% $0 0.0% 26.7% 0 0.0% 25.0% $0 0.0% 60.3% Moderate 0 0.0% $0 0.0% 6.7% 0 0.0% 11.1% $0 0.0% 4.5% 0 0.0% 0.0% $0 0.0% 0.0% M iddle 0 0.0% $0 0.0% 41.1% 0 0.0% 33.3% $0 0.0% 23.3% 0 0.0% 50.0% $0 0.0% 37.5% Upper 0 0.0% $0 0.0% 51.0% 0 0.0% 33.3% $0 0.0% 45.4% 0 0.0% 25.0% $0 0.0% 2.2%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 1 4.2% $3 0.2% 4.6% 0 0.0% 2.4% $0 0.0% 2.8% 1 5.9% 2.1% $3 0.3% 1.8% Moderate 2 8.3% $72 3.7% 14.3% 1 14.3% 7.4% $7 0.7% 4.7% 1 5.9% 8.1% $65 7.1% 5.3% M iddle 9 37.5% $442 22.4% 49.6% 2 28.6% 43.9% $37 3.5% 41.1% 7 41.2% 43.2% $405 44.2% 38.2% Upper 12 50.0% $1,455 73.8% 31.4% 4 57.1% 46.2% $1,012 95.8% 51.4% 8 47.1% 46.5% $443 48.4% 54.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.1% $0 0.0% 0.0% HMDA TOTALS Total 24 100.0% $1,972 100.0% 100.0% 7 100.0% 100.0% $1,056 100.0% 100.0% 17 100.0% 100.0% $916 100.0% 100.0% Small Businesses Low 2 1.0% $152 0.2% 2.8% 1 0.9% 3.9% $52 0.1% 4.8% 1 1.0% 3.1% $100 0.3% 4.1% Moderate 58 27.9% $21,381 29.6% 25.3% 30 27.8% 20.2% $9,888 26.4% 25.1% 28 28.0% 20.9% $11,493 33.1% 24.0% M iddle 73 35.1% $23,425 32.5% 39.0% 32 29.6% 42.1% $10,592 28.3% 41.5% 41 41.0% 42.5% $12,833 37.0% 43.8% Upper 73 35.1% $25,774 35.7% 32.4% 43 39.8% 28.5% $15,508 41.4% 25.5% 30 30.0% 28.0% $10,266 29.6% 24.1% Unknown 2 1.0% $1,400 1.9% 0.4% 2 1.9% 0.5% $1,400 3.7% 0.1% 0 0.0% 0.6% $0 0.0% 1.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 4.6% $0 0.0% 3.1% 0 0.0% 4.9% $0 0.0% 3.0% SMALL BUSINESSES Total 208 100.0% $72,132 100.0% 100.0% 108 100.0% 100.0% $37,440 100.0% 100.0% 100 100.0% 100.0% $34,692 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

119

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA, Small Business, & Small Farm Loans Assessment Area: Midland Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 2.8% 0 0.0% 0.9% $0 0.0% 0.6% Moderate 0 0.0% $0 0.0% 13.4% 0 0.0% 7.2% $0 0.0% 4.9% M iddle 1 50.0% $249 26.8% 41.8% 1 50.0% 39.0% $249 26.8% 33.4% Upper 1 50.0% $680 73.2% 42.0% 1 50.0% 52.8% $680 73.2% 61.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 2 100.0% $929 100.0% 100.0% 2 100.0% 100.0% $929 100.0% 100.0% Low 0 0.0% $0 0.0% 2.8% 0 0.0% 2.0% $0 0.0% 1.2% Moderate 0 0.0% $0 0.0% 13.4% 0 0.0% 7.4% $0 0.0% 4.4% M iddle 1 100.0% $2,841 100.0% 41.8% 1 100.0% 45.5% $2,841 100.0% 40.5% Upper 0 0.0% $0 0.0% 42.0% 0 0.0% 45.1% $0 0.0% 53.8%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $2,841 100.0% 100.0% 1 100.0% 100.0% $2,841 100.0% 100.0% Low 0 0.0% $0 0.0% 2.8% 0 0.0% 3.6% $0 0.0% 0.8% Moderate 0 0.0% $0 0.0% 13.4% 0 0.0% 13.4% $0 0.0% 9.0% M iddle 7 70.0% $527 69.3% 41.8% 7 70.0% 40.2% $527 69.3% 41.7%

HOME Upper 3 30.0% $234 30.7% 42.0% 3 30.0% 42.8% $234 30.7% 48.5% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 10 100.0% $761 100.0% 100.0% 10 100.0% 100.0% $761 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 1.6% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 6.5% 0 0.0% 20.0% $0 0.0% 26.9% M iddle 0 0.0% $0 0.0% 56.1% 0 0.0% 60.0% $0 0.0% 35.7% Upper 0 0.0% $0 0.0% 35.8% 0 0.0% 20.0% $0 0.0% 37.5%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 2.8% 0 0.0% 1.2% $0 0.0% 0.7% Moderate 0 0.0% $0 0.0% 13.4% 0 0.0% 7.4% $0 0.0% 6.3% M iddle 9 69.2% $3,617 79.8% 41.8% 9 69.2% 40.1% $3,617 79.8% 34.6% Upper 4 30.8% $914 20.2% 42.0% 4 30.8% 51.2% $914 20.2% 58.4% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 13 100.0% $4,531 100.0% 100.0% 13 100.0% 100.0% $4,531 100.0% 100.0% Small Businesses Low 2 1.8% $350 1.1% 1.7% 2 1.8% 2.3% $350 1.1% 3.3% Moderate 22 19.5% $8,664 26.7% 25.6% 22 19.5% 19.9% $8,664 26.7% 21.8% M iddle 40 35.4% $11,003 33.9% 35.1% 40 35.4% 35.7% $11,003 33.9% 33.2% Upper 48 42.5% $11,877 36.6% 37.1% 48 42.5% 37.4% $11,877 36.6% 38.0% Unknown 1 0.9% $600 1.8% 0.5% 1 0.9% 0.7% $600 1.8% 1.3% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 3.9% $0 0.0% 2.4% SMALL BUSINESSES Total 113 100.0% $32,494 100.0% 120100.0% 113 100.0% 100.0% $32,494 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data, 2017 D&B Info, and 2015 ACS Data Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Midland Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 22.0% 0 0.0% 3.5% $0 0.0% 1.5% 0 0.0% 6.0% $0 0.0% 3.2% Moderate 0 0.0% $0 0.0% 16.4% 0 0.0% 12.3% $0 0.0% 7.9% 0 0.0% 18.3% $0 0.0% 13.8% M iddle 1 33.3% $98 10.2% 20.1% 0 0.0% 21.5% $0 0.0% 17.3% 1 100.0% 25.1% $98 100.0% 23.7% Upper 2 66.7% $860 89.8% 41.5% 2 100.0% 43.0% $860 100.0% 48.3% 0 0.0% 33.5% $0 0.0% 44.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 19.7% $0 0.0% 25.0% 0 0.0% 17.2% $0 0.0% 15.2%

HOME PURCHASE Total 3 100.0% $958 100.0% 100.0% 2 100.0% 100.0% $860 100.0% 100.0% 1 100.0% 100.0% $98 100.0% 100.0% Low 1 33.3% $65 22.7% 22.0% 0 0.0% 2.7% $0 0.0% 1.3% 1 50.0% 4.3% $65 44.2% 2.3% Moderate 0 0.0% $0 0.0% 16.4% 0 0.0% 8.1% $0 0.0% 4.9% 0 0.0% 11.9% $0 0.0% 7.7% M iddle 1 33.3% $82 28.7% 20.1% 0 0.0% 16.1% $0 0.0% 11.6% 1 50.0% 16.4% $82 55.8% 13.6% Upper 1 33.3% $139 48.6% 41.5% 1 100.0% 44.5% $139 100.0% 51.4% 0 0.0% 35.0% $0 0.0% 45.0%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 28.6% $0 0.0% 30.8% 0 0.0% 32.4% $0 0.0% 31.4% Total 3 100.0% $286 100.0% 100.0% 1 100.0% 100.0% $139 100.0% 100.0% 2 100.0% 100.0% $147 100.0% 100.0% Low 1 5.6% $2 0.3% 22.0% 0 0.0% 7.5% $0 0.0% 1.4% 1 7.1% 10.0% $2 0.3% 5.7% Moderate 6 33.3% $100 13.7% 16.4% 0 0.0% 13.4% $0 0.0% 7.5% 6 42.9% 20.0% $100 14.9% 15.2% M iddle 4 22.2% $283 38.9% 20.1% 1 25.0% 19.4% $15 26.3% 17.0% 3 21.4% 23.0% $268 39.9% 16.3%

HOME Upper 6 33.3% $323 44.4% 41.5% 3 75.0% 55.2% $42 73.7% 68.6% 3 21.4% 44.3% $281 41.9% 59.4% Unknown 1 5.6% $20 2.7% 0.0% 0 0.0% 4.5% $0 0.0% 5.5% 1 7.1% 2.6% $20 3.0% 3.4% IMPROVEMENT Total 18 100.0% $728 100.0% 100.0% 4 100.0% 100.0% $57 100.0% 100.0% 14 100.0% 100.0% $671 100.0% 100.0% Low 2 8.3% $67 3.4% 22.0% 0 0.0% 3.5% $0 0.0% 1.4% 2 11.8% 5.8% $67 7.3% 3.0% Moderate 6 25.0% $100 5.1% 16.4% 0 0.0% 11.4% $0 0.0% 6.9% 6 35.3% 16.7% $100 10.9% 12.2% M iddle 6 25.0% $463 23.5% 20.1% 1 14.3% 20.1% $15 1.4% 15.3% 5 29.4% 22.8% $448 48.9% 21.0% Upper 9 37.5% $1,322 67.0% 41.5% 6 85.7% 43.7% $1,041 98.6% 46.6% 3 17.6% 34.3% $281 30.7% 44.3% Unknown 1 4.2% $20 1.0% 0.0% 0 0.0% 21.3% $0 0.0% 29.8% 1 5.9% 20.5% $20 2.2% 19.6% HMDA TOTALS Total 24 100.0% $1,972 100.0% 100.0% 7 100.0% 100.0% $1,056 100.0% 100.0% 17 100.0% 100.0% $916 100.0% 100.0% Total Businesses $1 Million or Less 110 52.9% $32,608 45.2% 87.4% 56 51.9% 34.8% $16,718 44.7% 30.0% 54 54.0% 30.0% $15,890 45.8% 30.7% Over $1 Million 92 44.2% $37,562 52.1% 11.5% 47 43.5% 45 45.0% Total Rev. available 202 97.1% $70,170 97.3% 98.9% 103 95.4% 99 99.0%

Revenue Rev. Not Known 6 2.9% $1,962 2.7% 1.0% 5 4.6% 1 1.0% Total 208 100.0% $72,132 100.0% 100.0% 108 100.0% 100 100.0% $100,000 or Less 64 30.8% $3,717 5.2% 29 26.9% 94.6% $1,795 4.8% 43.3% 35 35.0% 94.8% $1,922 5.5% 43.2% Small Business $100,001 - $250,000 47 22.6% $9,319 12.9% 29 26.9% 2.8% $5,780 15.4% 14.0% 18 18.0% 2.8% $3,539 10.2% 14.4% $250,001 - $1 Million 97 46.6% $59,096 81.9% 50 46.3% 2.5% $29,865 79.8% 42.7% 47 47.0% 2.4% $29,231 84.3% 42.4% Loan Size Total 208 100.0% $72,132 100.0% 108 100.0% 100.0% $37,440 100.0% 100.0% 100 100.0% 100.0% $34,692 100.0% 100.0%

121

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Midland Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 21.7% 0 0.0% 6.3% $0 0.0% 3.3% Moderate 0 0.0% $0 0.0% 17.5% 0 0.0% 16.7% $0 0.0% 12.1% M iddle 0 0.0% $0 0.0% 20.2% 0 0.0% 24.3% $0 0.0% 22.4% Upper 1 50.0% $249 26.8% 40.5% 1 50.0% 38.7% $249 26.8% 48.7% Unknown 1 50.0% $680 73.2% 0.0% 1 50.0% 14.1% $680 73.2% 13.5%

HOME PURCHASE Total 2 100.0% $929 100.0% 100.0% 2 100.0% 100.0% $929 100.0% 100.0% Low 0 0.0% $0 0.0% 21.7% 0 0.0% 5.0% $0 0.0% 2.7% Moderate 0 0.0% $0 0.0% 17.5% 0 0.0% 16.0% $0 0.0% 12.2% M iddle 0 0.0% $0 0.0% 20.2% 0 0.0% 20.8% $0 0.0% 18.6% Upper 0 0.0% $0 0.0% 40.5% 0 0.0% 32.4% $0 0.0% 41.4%

REFINANCE Unknown 1 100.0% $2,841 100.0% 0.0% 1 100.0% 25.8% $2,841 100.0% 25.1% Total 1 100.0% $2,841 100.0% 100.0% 1 100.0% 100.0% $2,841 100.0% 100.0% Low 0 0.0% $0 0.0% 21.7% 0 0.0% 12.9% $0 0.0% 5.7% Moderate 1 10.0% $15 2.0% 17.5% 1 10.0% 16.0% $15 2.0% 9.7% M iddle 1 10.0% $15 2.0% 20.2% 1 10.0% 18.0% $15 2.0% 17.3%

HOME Upper 8 80.0% $731 96.1% 40.5% 8 80.0% 47.9% $731 96.1% 61.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 5.2% $0 0.0% 6.2% IMPROVEMENT Total 10 100.0% $761 100.0% 100.0% 10 100.0% 100.0% $761 100.0% 100.0% Low 0 0.0% $0 0.0% 21.7% 0 0.0% 6.3% $0 0.0% 3.0% Moderate 1 7.7% $15 0.3% 17.5% 1 7.7% 16.5% $15 0.3% 11.3% M iddle 1 7.7% $15 0.3% 20.2% 1 7.7% 23.5% $15 0.3% 20.4% Upper 9 69.2% $980 21.6% 40.5% 9 69.2% 37.9% $980 21.6% 44.7% Unknown 2 15.4% $3,521 77.7% 0.0% 2 15.4% 15.7% $3,521 77.7% 20.6% HMDA TOTALS Total 13 100.0% $4,531 100.0% 100.0% 13 100.0% 100.0% $4,531 100.0% 100.0% Total Businesses $1 Million or Less 70 61.9% $18,148 55.9% 85.9% 70 61.9% 35.5% $18,148 55.9% 34.2% Over $1 Million 37 32.7% $13,530 41.6% 13.0% 37 32.7% Total Rev. available 107 94.6% $31,678 97.5% 98.9% 107 94.6%

Revenue Rev. Not Known 6 5.3% $816 2.5% 1.1% 6 5.3% Total 113 100.0% $32,494 100.0% 100.0% 113 100.0% $100,000 or Less 48 42.5% $2,574 7.9% 48 42.5% 94.1% $2,574 7.9% 41.2% Small Business $100,001 - $250,000 23 20.4% $4,335 13.3% 23 20.4% 3.3% $4,335 13.3% 14.5% $250,001 - $1 Million 42 37.2% $25,585 78.7% 42 37.2% 2.7% $25,585 78.7% 44.2% Loan Size Total 113 100.0% $32,494 100.0% 113 100.0% 100.0% $32,494 100.0% 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Odessa MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 21.9% 0 0.0% 8.8% $0 0.0% 5.3% 0 0.0% 8.2% $0 0.0% 4.6% M iddle 3 75.0% $322 78.7% 48.0% 2 66.7% 37.8% $263 75.1% 32.0% 1 100.0% 32.5% $59 100.0% 26.6% Upper 1 25.0% $87 21.3% 30.1% 1 33.3% 53.4% $87 24.9% 62.7% 0 0.0% 59.3% $0 0.0% 68.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 4 100.0% $409 100.0% 100.0% 3 100.0% 100.0% $350 100.0% 100.0% 1 100.0% 100.0% $59 100.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 21.9% 0 0.0% 4.6% $0 0.0% 2.9% 0 0.0% 7.3% $0 0.0% 4.1% M iddle 2 66.7% $214 68.6% 48.0% 0 0.0% 34.7% $0 0.0% 29.1% 2 66.7% 34.6% $214 68.6% 28.5% Upper 1 33.3% $98 31.4% 30.1% 0 0.0% 60.7% $0 0.0% 68.0% 1 33.3% 58.1% $98 31.4% 67.4%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 3 100.0% $312 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 3 100.0% 100.0% $312 100.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 6 28.6% $70 8.8% 21.9% 2 28.6% 15.1% $56 34.4% 10.7% 4 28.6% 15.0% $14 2.2% 10.2% M iddle 12 57.1% $332 41.8% 48.0% 5 71.4% 44.6% $107 65.6% 41.7% 7 50.0% 46.4% $225 35.6% 54.0%

HOME Upper 3 14.3% $393 49.4% 30.1% 0 0.0% 40.4% $0 0.0% 47.7% 3 21.4% 38.6% $393 62.2% 35.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 21 100.0% $795 100.0% 100.0% 7 100.0% 100.0% $163 100.0% 100.0% 14 100.0% 100.0% $632 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 15.1% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% M iddle 0 0.0% $0 0.0% 35.4% 0 0.0% 69.2% $0 0.0% 79.2% 0 0.0% 57.1% $0 0.0% 44.1% Upper 0 0.0% $0 0.0% 49.5% 0 0.0% 30.8% $0 0.0% 20.8% 0 0.0% 42.9% $0 0.0% 55.9%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 6 21.4% $70 4.6% 21.9% 2 20.0% 8.1% $56 10.9% 3.9% 4 22.2% 8.3% $14 1.4% 4.5% M iddle 17 60.7% $868 57.3% 48.0% 7 70.0% 37.5% $370 72.1% 41.2% 10 55.6% 33.7% $498 49.7% 27.8% Upper 5 17.9% $578 38.1% 30.1% 1 10.0% 54.4% $87 17.0% 55.0% 4 22.2% 58.0% $491 49.0% 67.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 28 100.0% $1,516 100.0% 100.0% 10 100.0% 100.0% $513 100.0% 100.0% 18 100.0% 100.0% $1,003 100.0% 100.0% Small Businesses Low 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 24 24.2% $6,933 30.3% 17.6% 9 20.0% 16.0% $3,545 29.9% 12.1% 15 27.8% 14.5% $3,388 30.8% 13.6% M iddle 41 41.4% $12,324 53.9% 43.9% 17 37.8% 43.1% $6,223 52.4% 37.9% 24 44.4% 42.4% $6,101 55.5% 39.2% Upper 34 34.3% $3,599 15.7% 38.5% 19 42.2% 37.3% $2,098 17.7% 47.6% 15 27.8% 39.4% $1,501 13.7% 45.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 3.5% $0 0.0% 2.3% 0 0.0% 3.7% $0 0.0% 2.0% SMALL BUSINESSES Total 99 100.0% $22,856 100.0% 100.0% 45 100.0% 100.0% $11,866 100.0% 100.0% 54 100.0% 100.0% $10,990 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

123

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Odessa MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 1.6% 0 0.0% 0.6% $0 0.0% 0.3% Moderate 0 0.0% $0 0.0% 21.4% 0 0.0% 9.2% $0 0.0% 5.8% M iddle 0 0.0% $0 0.0% 42.7% 0 0.0% 26.1% $0 0.0% 19.4% Upper 0 0.0% $0 0.0% 34.3% 0 0.0% 64.1% $0 0.0% 74.5% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 1.6% 0 0.0% 1.3% $0 0.0% 0.7% Moderate 0 0.0% $0 0.0% 21.4% 0 0.0% 8.4% $0 0.0% 5.8% M iddle 0 0.0% $0 0.0% 42.7% 0 0.0% 30.9% $0 0.0% 24.6% Upper 0 0.0% $0 0.0% 34.3% 0 0.0% 59.5% $0 0.0% 68.9%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 1.6% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 1 20.0% $40 33.9% 21.4% 1 20.0% 12.3% $40 33.9% 10.1% M iddle 4 80.0% $78 66.1% 42.7% 4 80.0% 39.9% $78 66.1% 36.2%

HOME Upper 0 0.0% $0 0.0% 34.3% 0 0.0% 47.8% $0 0.0% 53.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 5 100.0% $118 100.0% 100.0% 5 100.0% 100.0% $118 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 3.9% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 16.7% 0 0.0% 0.0% $0 0.0% 0.0% M iddle 0 0.0% $0 0.0% 17.7% 0 0.0% 83.3% $0 0.0% 83.5% Upper 0 0.0% $0 0.0% 61.8% 0 0.0% 16.7% $0 0.0% 16.5%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 1.6% 0 0.0% 0.7% $0 0.0% 0.4% Moderate 1 20.0% $40 33.9% 21.4% 1 20.0% 9.2% $40 33.9% 5.9% M iddle 4 80.0% $78 66.1% 42.7% 4 80.0% 27.5% $78 66.1% 20.5% Upper 0 0.0% $0 0.0% 34.3% 0 0.0% 62.7% $0 0.0% 73.2% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 5 100.0% $118 100.0% 100.0% 5 100.0% 100.0% $118 100.0% 100.0% Small Businesses Low 0 0.0% $0 0.0% 1.2% 0 0.0% 1.0% $0 0.0% 0.7% Moderate 14 22.2% $4,438 31.8% 23.0% 14 22.2% 21.2% $4,438 31.8% 16.1% M iddle 26 41.3% $6,510 46.7% 35.2% 26 41.3% 37.2% $6,510 46.7% 33.5% Upper 23 36.5% $3,004 21.5% 40.5% 23 36.5% 37.5% $3,004 21.5% 47.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 3.1% $0 0.0% 1.8%

SMALL BUSINESSES 124 Total 63 100.0% $13,952 100.0% 100.0% 63 100.0% 100.0% $13,952 100.0% 100.0%

Originations & Purchases 2017 FFIEC Census Data, 2017 D&B Info, and 2015 ACS Data Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Odessa MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 24.4% 0 0.0% 4.0% $0 0.0% 1.9% 0 0.0% 2.7% $0 0.0% 1.1% Moderate 0 0.0% $0 0.0% 15.7% 0 0.0% 21.0% $0 0.0% 15.3% 0 0.0% 15.4% $0 0.0% 10.6% M iddle 0 0.0% $0 0.0% 19.2% 0 0.0% 25.2% $0 0.0% 24.7% 0 0.0% 25.2% $0 0.0% 23.3% Upper 4 100.0% $409 100.0% 40.7% 3 100.0% 31.2% $350 100.0% 39.4% 1 100.0% 33.3% $59 100.0% 42.3% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 18.7% $0 0.0% 18.7% 0 0.0% 23.4% $0 0.0% 22.7%

HOME PURCHASE Total 4 100.0% $409 100.0% 100.0% 3 100.0% 100.0% $350 100.0% 100.0% 1 100.0% 100.0% $59 100.0% 100.0% Low 0 0.0% $0 0.0% 24.4% 0 0.0% 2.4% $0 0.0% 1.3% 0 0.0% 3.7% $0 0.0% 1.4% Moderate 0 0.0% $0 0.0% 15.7% 0 0.0% 8.8% $0 0.0% 5.4% 0 0.0% 6.6% $0 0.0% 3.4% M iddle 2 66.7% $190 60.9% 19.2% 0 0.0% 15.9% $0 0.0% 11.8% 2 66.7% 13.7% $190 60.9% 10.0% Upper 1 33.3% $122 39.1% 40.7% 0 0.0% 37.7% $0 0.0% 42.1% 1 33.3% 35.9% $122 39.1% 42.9%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 35.1% $0 0.0% 39.4% 0 0.0% 40.2% $0 0.0% 42.2% Total 3 100.0% $312 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 3 100.0% 100.0% $312 100.0% 100.0% Low 7 33.3% $26 3.3% 24.4% 2 28.6% 6.6% $5 3.1% 2.9% 5 35.7% 8.5% $21 3.3% 4.3% Moderate 5 23.8% $98 12.3% 15.7% 3 42.9% 17.5% $75 46.0% 10.9% 2 14.3% 12.4% $23 3.6% 9.4% M iddle 5 23.8% $243 30.6% 19.2% 1 14.3% 28.9% $48 29.4% 25.1% 4 28.6% 19.6% $195 30.9% 14.2%

HOME Upper 4 19.0% $428 53.8% 40.7% 1 14.3% 45.8% $35 21.5% 60.8% 3 21.4% 53.6% $393 62.2% 59.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 1.2% $0 0.0% 0.3% 0 0.0% 5.9% $0 0.0% 12.2% IMPROVEMENT Total 21 100.0% $795 100.0% 100.0% 7 100.0% 100.0% $163 100.0% 100.0% 14 100.0% 100.0% $632 100.0% 100.0% Low 7 25.0% $26 1.7% 24.4% 2 20.0% 3.7% $5 1.0% 1.4% 5 27.8% 3.2% $21 2.1% 1.3% Moderate 5 17.9% $98 6.5% 15.7% 3 30.0% 18.0% $75 14.6% 10.3% 2 11.1% 12.8% $23 2.3% 8.4% M iddle 7 25.0% $433 28.6% 19.2% 1 10.0% 23.1% $48 9.4% 17.4% 6 33.3% 21.7% $385 38.4% 19.2% Upper 9 32.1% $959 63.3% 40.7% 4 40.0% 33.2% $385 75.0% 32.2% 5 27.8% 34.8% $574 57.2% 42.5% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 21.9% $0 0.0% 38.7% 0 0.0% 27.4% $0 0.0% 28.6% HMDA TOTALS Total 28 100.0% $1,516 100.0% 100.0% 10 100.0% 100.0% $513 100.0% 100.0% 18 100.0% 100.0% $1,003 100.0% 100.0% Total Businesses $1 Million or Less 41 41.4% $4,279 18.7% 88.4% 15 33.3% 30.4% $2,104 17.7% 23.6% 26 48.1% 26.3% $2,175 19.8% 23.5% Over $1 Million 56 56.6% $18,352 80.3% 11.3% 30 66.7% 26 48.1% Total Rev. available 97 98.0% $22,631 99.0% 99.7% 45 100.0% 52 96.2%

Revenue Rev. Not Known 2 2.0% $225 1.0% 0.4% 0 0.0% 2 3.7% Total 99 100.0% $22,856 100.0% 100.0% 45 100.0% 54 100.0% $100,000 or Less 54 54.5% $3,206 14.0% 24 53.3% 95.0% $1,348 11.4% 43.7% 30 55.6% 95.8% $1,858 16.9% 46.8% Small Business $100,001 - $250,000 16 16.2% $2,583 11.3% 6 13.3% 3.0% $1,050 8.8% 17.5% 10 18.5% 2.4% $1,533 13.9% 16.0% $250,001 - $1 Million 29 29.3% $17,067 74.7% 15 33.3% 2.1% $9,468 79.8% 38.7% 14 25.9% 1.8% $7,599 69.1% 37.2% Loan Size Total 99 100.0% $22,856 100.0% 45 100.0% 100.0% $11,866 100.0% 100.0% 54 100.0% 100.0% $10,990 100.0% 100.0%

125

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Odessa MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 21.8% 0 0.0% 5.9% $0 0.0% 3.1% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 19.9% $0 0.0% 15.5% M iddle 0 0.0% $0 0.0% 20.5% 0 0.0% 25.9% $0 0.0% 25.4% Upper 0 0.0% $0 0.0% 40.4% 0 0.0% 29.1% $0 0.0% 37.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 19.2% $0 0.0% 18.1%

HOME PURCHASE Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 21.8% 0 0.0% 6.5% $0 0.0% 3.2% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 10.8% $0 0.0% 7.3% M iddle 0 0.0% $0 0.0% 20.5% 0 0.0% 17.5% $0 0.0% 15.1% Upper 0 0.0% $0 0.0% 40.4% 0 0.0% 28.6% $0 0.0% 34.4%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 36.6% $0 0.0% 40.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 1 20.0% $40 33.9% 21.8% 1 20.0% 10.9% $40 33.9% 7.5% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 15.9% $0 0.0% 17.8% M iddle 3 60.0% $63 53.4% 20.5% 3 60.0% 29.0% $63 53.4% 23.8%

HOME Upper 1 20.0% $15 12.7% 40.4% 1 20.0% 41.3% $15 12.7% 46.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 2.9% $0 0.0% 4.3% IMPROVEMENT Total 5 100.0% $118 100.0% 100.0% 5 100.0% 100.0% $118 100.0% 100.0% Low 1 20.0% $40 33.9% 21.8% 1 20.0% 6.2% $40 33.9% 3.2% Moderate 0 0.0% $0 0.0% 17.3% 0 0.0% 18.3% $0 0.0% 14.3% M iddle 3 60.0% $63 53.4% 20.5% 3 60.0% 24.7% $63 53.4% 23.8% Upper 1 20.0% $15 12.7% 40.4% 1 20.0% 29.5% $15 12.7% 37.5% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 21.4% $0 0.0% 21.3% HMDA TOTALS Total 5 100.0% $118 100.0% 100.0% 5 100.0% 100.0% $118 100.0% 100.0% Total Businesses $1 Million or Less 32 50.8% $5,065 36.3% 86.8% 32 50.8% 31.9% $5,065 36.3% 24.5% Over $1 Million 29 46.0% $8,827 63.3% 12.8% 29 46.0% Total Rev. available 61 96.8% $13,892 99.6% 99.6% 61 96.8%

Revenue Rev. Not Known 2 3.2% $60 0.4% 0.4% 2 3.2% Total 63 100.0% $13,952 100.0% 100.0% 63 100.0% $100,000 or Less 30 47.6% $1,894 13.6% 30 47.6% 95.4% $1,894 13.6% 45.1% Small Business $100,001 - $250,000 14 22.2% $2,516 18.0% 14 22.2% 2.4% $2,516 18.0% 14.4% $250,001 - $1 Million 19 30.2% $9,542 68.4% 19 30.2% 2.2% $9,542 68.4% 40.5% Loan Size Total 63 100.0% $13,952 100.0% 63 100.0% 100.0% $13,952 100.0% 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Austin Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg Bank Agg Bank Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 4 1.5% $919 2.8% 4.6% 3 1.8% 3.0% $307 1.5% 2.5% 1 1.0% 3.2% $612 4.7% 2.8% Moderate 23 8.7% $1,851 5.6% 16.2% 16 9.5% 15.1% $1,261 6.3% 11.3% 7 7.2% 16.4% $590 4.5% 12.7% M iddle 47 17.7% $4,656 14.1% 37.5% 28 16.7% 40.9% $2,796 14.0% 35.0% 19 19.6% 40.8% $1,860 14.2% 35.3% Upper 191 72.1% $25,680 77.6% 41.6% 121 72.0% 41.0% $15,668 78.2% 51.2% 70 72.2% 39.5% $10,012 76.6% 49.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 265 100.0% $33,106 100.0% 100.0% 168 100.0% 100.0% $20,032 100.0% 100.0% 97 100.0% 100.0% $13,074 100.0% 100.0% Low 1 1.1% $67 0.5% 4.6% 0 0.0% 3.3% $0 0.0% 2.4% 1 2.6% 3.0% $67 1.1% 2.3% Moderate 3 3.4% $564 4.0% 16.2% 1 2.1% 12.6% $47 0.6% 8.8% 2 5.1% 12.4% $517 8.8% 8.8% M iddle 23 26.4% $2,299 16.4% 37.5% 11 22.9% 36.3% $1,191 14.7% 28.3% 12 30.8% 36.5% $1,108 18.8% 29.1% Upper 60 69.0% $11,047 79.0% 41.6% 36 75.0% 47.8% $6,845 84.7% 60.5% 24 61.5% 48.1% $4,202 71.3% 59.8%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 87 100.0% $13,977 100.0% 100.0% 48 100.0% 100.0% $8,083 100.0% 100.0% 39 100.0% 100.0% $5,894 100.0% 100.0% Low 19 4.2% $1,115 2.1% 4.6% 9 4.8% 3.9% $492 2.0% 2.9% 10 3.8% 3.4% $623 2.2% 2.7% Moderate 41 9.1% $4,878 9.2% 16.2% 15 8.0% 13.5% $2,216 8.8% 10.1% 26 9.8% 13.6% $2,662 9.6% 10.0% M iddle 124 27.4% $9,071 17.2% 37.5% 47 25.0% 33.7% $3,837 15.3% 25.2% 77 29.2% 37.5% $5,234 18.9% 30.2%

HOME Upper 268 59.3% $37,777 71.5% 41.6% 117 62.2% 48.9% $18,554 73.9% 61.8% 151 57.2% 45.5% $19,223 69.3% 57.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 452 100.0% $52,841 100.0% 100.0% 188 100.0% 100.0% $25,099 100.0% 100.0% 264 100.0% 100.0% $27,742 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 23.2% 0 0.0% 28.0% $0 0.0% 18.1% 0 0.0% 22.5% $0 0.0% 18.8% Moderate 1 50.0% $428 68.2% 27.9% 1 50.0% 28.0% $428 68.2% 20.0% 0 0.0% 27.5% $0 0.0% 22.9% M iddle 0 0.0% $0 0.0% 27.8% 0 0.0% 26.2% $0 0.0% 41.8% 0 0.0% 27.5% $0 0.0% 25.6% Upper 1 50.0% $200 31.8% 21.1% 1 50.0% 17.9% $200 31.8% 20.1% 0 0.0% 22.5% $0 0.0% 32.7%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 2 100.0% $628 100.0% 100.0% 2 100.0% 100.0% $628 100.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 24 3.0% $2,101 2.1% 4.6% 12 3.0% 3.2% $799 1.5% 3.7% 12 3.0% 3.2% $1,302 2.8% 3.9% Moderate 68 8.4% $7,721 7.7% 16.2% 33 8.1% 14.2% $3,952 7.3% 11.2% 35 8.8% 15.0% $3,769 8.1% 12.4% M iddle 194 24.1% $16,026 15.9% 37.5% 86 21.2% 39.1% $7,824 14.5% 33.5% 108 27.0% 39.2% $8,202 17.6% 32.7% Upper 520 64.5% $74,704 74.3% 41.6% 275 67.7% 43.5% $41,267 76.6% 51.6% 245 61.3% 42.6% $33,437 71.6% 51.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 806 100.0% $100,552 100.0% 100.0% 406 100.0% 100.0% $53,842 100.0% 100.0% 400 100.0% 100.0% $46,710 100.0% 100.0% Small Businesses Low 83 7.4% $22,034 8.0% 5.8% 33 6.3% 6.3% $9,657 7.5% 7.3% 50 8.2% 6.3% $12,377 8.5% 7.5% Moderate 217 19.2% $52,082 18.9% 16.1% 107 20.5% 16.2% $26,288 20.4% 17.9% 110 18.1% 15.6% $25,794 17.6% 16.5% M iddle 295 26.2% $68,344 24.8% 30.0% 133 25.5% 28.9% $31,986 24.8% 26.9% 162 26.7% 29.2% $36,358 24.8% 26.8% Upper 533 47.3% $132,804 48.2% 48.1% 248 47.6% 46.7% $60,934 47.3% 46.6% 285 47.0% 47.0% $71,870 49.1% 47.9% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.1% $0 0.0% 0.1% 0 0.0% 0.1% $0 0.0% 0.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.8% $0 0.0% 1.2% 0 0.0% 1.9% $0 0.0% 1.3% SMALL BUSINESSES Total 1,128 100.0% $275,264 100.0% 100.0% 521 100.0% 100.0% $128,865 100.0% 100.0% 607 100.0% 100.0% $146,399 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

127

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Austin Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 3 2.8% $386 2.5% 4.1% 3 2.8% 3.5% $386 2.5% 3.1% Moderate 5 4.7% $309 2.0% 15.8% 5 4.7% 13.9% $309 2.0% 10.5% M iddle 27 25.5% $3,198 20.7% 39.5% 27 25.5% 43.2% $3,198 20.7% 37.5% Upper 70 66.0% $11,124 72.1% 40.5% 70 66.0% 39.2% $11,124 72.1% 48.6% Unknown 1 0.9% $406 2.6% 0.2% 1 0.9% 0.2% $406 2.6% 0.2%

HOME PURCHASE Total 106 100.0% $15,423 100.0% 100.0% 106 100.0% 100.0% $15,423 100.0% 100.0% Low 1 4.5% $228 5.1% 4.1% 1 4.5% 3.2% $228 5.1% 2.5% Moderate 3 13.6% $855 19.1% 15.8% 3 13.6% 13.8% $855 19.1% 9.1% M iddle 9 40.9% $1,475 33.0% 39.5% 9 40.9% 42.4% $1,475 33.0% 34.8% Upper 9 40.9% $1,910 42.7% 40.5% 9 40.9% 40.5% $1,910 42.7% 53.5%

REFINANCE Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.2% $0 0.0% 0.1% Total 22 100.0% $4,468 100.0% 100.0% 22 100.0% 100.0% $4,468 100.0% 100.0% Low 8 3.4% $826 2.5% 4.1% 8 3.4% 3.6% $826 2.5% 3.1% Moderate 19 8.1% $1,937 5.9% 15.8% 19 8.1% 13.0% $1,937 5.9% 8.5% M iddle 69 29.5% $5,590 17.1% 39.5% 69 29.5% 41.7% $5,590 17.1% 33.1%

HOME Upper 137 58.5% $24,267 74.1% 40.5% 137 58.5% 41.6% $24,267 74.1% 55.1% Unknown 1 0.4% $151 0.5% 0.2% 1 0.4% 0.1% $151 0.5% 0.1% IMPROVEMENT Total 234 100.0% $32,771 100.0% 100.0% 234 100.0% 100.0% $32,771 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 22.2% 0 0.0% 20.6% $0 0.0% 14.4% Moderate 0 0.0% $0 0.0% 18.3% 0 0.0% 22.8% $0 0.0% 18.3% M iddle 0 0.0% $0 0.0% 33.5% 0 0.0% 34.6% $0 0.0% 45.5% Upper 0 0.0% $0 0.0% 23.4% 0 0.0% 19.9% $0 0.0% 20.1%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 2.6% 0 0.0% 2.2% $0 0.0% 1.7% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 12 3.3% $1,440 2.7% 4.1% 12 3.3% 3.4% $1,440 2.7% 3.9% Moderate 27 7.5% $3,101 5.9% 15.8% 27 7.5% 13.9% $3,101 5.9% 10.8% M iddle 105 29.0% $10,263 19.5% 39.5% 105 29.0% 42.9% $10,263 19.5% 37.6% Upper 216 59.7% $37,301 70.8% 40.5% 216 59.7% 39.6% $37,301 70.8% 47.3% Unknown 2 0.6% $557 1.1% 0.2% 2 0.6% 0.2% $557 1.1% 0.3% HMDA TOTALS Total 362 100.0% $52,662 100.0% 100.0% 362 100.0% 100.0% $52,662 100.0% 100.0% Small Businesses Low 62 9.7% $11,843 8.0% 6.4% 62 9.7% 7.1% $11,843 8.0% 8.5% Moderate 82 12.8% $19,136 13.0% 12.7% 82 12.8% 13.2% $19,136 13.0% 12.2% M iddle 203 31.7% $51,654 35.1% 33.2% 203 31.7% 33.7% $51,654 35.1% 32.8% Upper 288 44.9% $63,156 42.9% 46.5% 288 44.9% 43.5% $63,156 42.9% 44.3% Unknown 6 0.9% $1,345 0.9% 1.2% 6 0.9% 0.9% $1,345 0.9% 1.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.6% $0 0.0% 1.1%

SMALL BUSINESSES Total 641 100.0% $147,134 100.0% 128100.0% 641 100.0% 100.0% $147,134 100.0% 100.0%

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Austin Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 1 0.4% $65 0.2% 21.1% 1 0.6% 3.0% $65 0.3% 1.4% 0 0.0% 2.4% $0 0.0% 1.2% Moderate 1 0.4% $22 0.1% 17.1% 0 0.0% 13.8% $0 0.0% 9.2% 1 1.0% 13.8% $22 0.2% 9.3% M iddle 7 2.6% $602 1.8% 19.8% 5 3.0% 20.5% $312 1.6% 17.3% 2 2.1% 20.7% $290 2.2% 17.6% Upper 248 93.6% $29,220 88.3% 42.0% 157 93.5% 45.8% $17,907 89.4% 56.4% 91 93.8% 49.5% $11,313 86.5% 59.6% Unknown 8 3.0% $3,197 9.7% 0.0% 5 3.0% 16.9% $1,748 8.7% 15.7% 3 3.1% 13.7% $1,449 11.1% 12.4%

HOME PURCHASE Total 265 100.0% $33,106 100.0% 100.0% 168 100.0% 100.0% $20,032 100.0% 100.0% 97 100.0% 100.0% $13,074 100.0% 100.0% Low 3 3.4% $338 2.4% 21.1% 1 2.1% 3.6% $115 1.4% 1.7% 2 5.1% 3.1% $223 3.8% 1.6% Moderate 8 9.2% $662 4.7% 17.1% 2 4.2% 11.6% $167 2.1% 6.9% 6 15.4% 11.2% $495 8.4% 6.8% M iddle 7 8.0% $630 4.5% 19.8% 4 8.3% 18.3% $283 3.5% 13.9% 3 7.7% 17.1% $347 5.9% 12.8% Upper 67 77.0% $12,114 86.7% 42.0% 40 83.3% 47.1% $7,379 91.3% 58.4% 27 69.2% 48.9% $4,735 80.3% 59.8%

REFINANCE Unknown 2 2.3% $233 1.7% 0.0% 1 2.1% 19.5% $139 1.7% 19.1% 1 2.6% 19.7% $94 1.6% 19.0% Total 87 100.0% $13,977 100.0% 100.0% 48 100.0% 100.0% $8,083 100.0% 100.0% 39 100.0% 100.0% $5,894 100.0% 100.0% Low 11 2.4% $175 0.3% 21.1% 5 2.7% 3.8% $33 0.1% 1.6% 6 2.3% 4.9% $142 0.5% 2.6% Moderate 35 7.7% $1,423 2.7% 17.1% 15 8.0% 12.5% $662 2.6% 7.1% 20 7.6% 13.8% $761 2.7% 9.0% M iddle 47 10.4% $1,731 3.3% 19.8% 15 8.0% 20.8% $612 2.4% 15.6% 32 12.1% 20.5% $1,119 4.0% 15.7%

HOME Upper 351 77.7% $49,129 93.0% 42.0% 149 79.3% 59.5% $23,725 94.5% 68.4% 202 76.5% 58.6% $25,404 91.6% 69.0% Unknown 8 1.8% $383 0.7% 0.0% 4 2.1% 3.4% $67 0.3% 7.4% 4 1.5% 2.3% $316 1.1% 3.7% IMPROVEMENT Total 452 100.0% $52,841 100.0% 100.0% 188 100.0% 100.0% $25,099 100.0% 100.0% 264 100.0% 100.0% $27,742 100.0% 100.0% Low 15 1.9% $578 0.6% 21.1% 7 1.7% 3.2% $213 0.4% 1.4% 8 2.0% 2.7% $365 0.8% 1.2% Moderate 44 5.5% $2,107 2.1% 17.1% 17 4.2% 13.0% $829 1.6% 7.8% 27 6.8% 12.9% $1,278 2.7% 7.8% M iddle 61 7.6% $2,963 3.0% 19.8% 24 5.9% 19.7% $1,207 2.3% 14.9% 37 9.3% 19.5% $1,756 3.8% 14.8% Upper 666 82.8% $90,463 90.5% 42.0% 346 85.7% 46.5% $49,011 92.1% 52.8% 320 80.0% 49.5% $41,452 88.7% 55.0% Unknown 18 2.2% $3,813 3.8% 0.0% 10 2.5% 17.5% $1,954 3.6% 23.1% 8 2.0% 15.4% $1,859 4.0% 21.2% HMDA TOTALS Total 804 100.0% $99,924 100.0% 100.0% 404 100.0% 100.0% $53,214 100.0% 100.0% 400 100.0% 100.0% $46,710 100.0% 100.0% Total Businesses $1 Million or Less 441 39.1% $64,996 23.6% 91.7% 209 40.1% 49.9% $30,523 23.7% 37.6% 232 38.2% 41.1% $34,473 23.5% 35.8% Over $1 Million 658 58.3% $205,908 74.8% 7.1% 296 56.8% 362 59.6% Total Rev. available 1,099 97.4% $270,904 98.4% 98.8% 505 96.9% 594 97.8%

Revenue Rev. Not Known 29 2.6% $4,360 1.6% 1.2% 16 3.1% 13 2.1% Total 1,128 100.0% $275,264 100.0% 100.0% 521 100.0% 607 100.0% $100,000 or Less 470 41.7% $24,699 9.0% 210 40.3% 94.7% $11,664 9.1% 41.9% 260 42.8% 95.5% $13,035 8.9% 46.6% Small Business $100,001 - $250,000 294 26.1% $53,336 19.4% 141 27.1% 2.5% $25,612 19.9% 13.4% 153 25.2% 2.2% $27,724 18.9% 12.2% $250,001 - $1 Million 364 32.3% $197,229 71.7% 170 32.6% 2.8% $91,589 71.1% 44.7% 194 32.0% 2.3% $105,640 72.2% 41.2% Loan Size Total 1,128 100.0% $275,264 100.0% 521 100.0% 100.0% $128,865 100.0% 100.0% 607 100.0% 100.0% $146,399 100.0% 100.0%

129

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans and Small Business Lending by Revenue & Loan Size Assessment Area: Austin Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 22.1% 0 0.0% 2.9% $0 0.0% 1.7% Moderate 1 0.9% $81 0.5% 16.5% 1 0.9% 15.0% $81 0.5% 10.1% M iddle 6 5.7% $618 4.0% 19.7% 6 5.7% 20.9% $618 4.0% 17.9% Upper 98 92.5% $14,606 94.7% 41.7% 98 92.5% 48.7% $14,606 94.7% 58.5% Unknown 1 0.9% $118 0.8% 0.0% 1 0.9% 12.5% $118 0.8% 11.9%

HOME PURCHASE Total 106 100.0% $15,423 100.0% 100.0% 106 100.0% 100.0% $15,423 100.0% 100.0% Low 1 4.5% $32 0.7% 22.1% 1 4.5% 4.8% $32 0.7% 2.5% Moderate 1 4.5% $175 3.9% 16.5% 1 4.5% 14.4% $175 3.9% 8.9% M iddle 2 9.1% $140 3.1% 19.7% 2 9.1% 19.5% $140 3.1% 14.7% Upper 17 77.3% $3,516 78.7% 41.7% 17 77.3% 44.5% $3,516 78.7% 56.1%

REFINANCE Unknown 1 4.5% $605 13.5% 0.0% 1 4.5% 16.9% $605 13.5% 17.8% Total 22 100.0% $4,468 100.0% 100.0% 22 100.0% 100.0% $4,468 100.0% 100.0% Low 8 3.4% $285 0.9% 22.1% 8 3.4% 5.8% $285 0.9% 3.4% Moderate 7 3.0% $359 1.1% 16.5% 7 3.0% 16.1% $359 1.1% 10.0% M iddle 23 9.8% $1,884 5.7% 19.7% 23 9.8% 22.1% $1,884 5.7% 17.3%

HOME Upper 193 82.5% $29,782 90.9% 41.7% 193 82.5% 53.5% $29,782 90.9% 65.1% Unknown 3 1.3% $461 1.4% 0.0% 3 1.3% 2.4% $461 1.4% 4.2% IMPROVEMENT Total 234 100.0% $32,771 100.0% 100.0% 234 100.0% 100.0% $32,771 100.0% 100.0% Low 9 2.5% $317 0.6% 22.1% 9 2.5% 3.5% $317 0.6% 1.7% Moderate 9 2.5% $615 1.2% 16.5% 9 2.5% 14.9% $615 1.2% 9.0% M iddle 31 8.6% $2,642 5.0% 19.7% 31 8.6% 20.6% $2,642 5.0% 15.8% Upper 308 85.1% $47,904 91.0% 41.7% 308 85.1% 47.8% $47,904 91.0% 53.3% Unknown 5 1.4% $1,184 2.2% 0.0% 5 1.4% 13.3% $1,184 2.2% 20.2% HMDA TOTALS Total 362 100.0% $52,662 100.0% 100.0% 362 100.0% 100.0% $52,662 100.0% 100.0% Total Businesses $1 Million or Less 268 41.8% $37,514 25.5% 90.8% 268 41.8% 50.4% $37,514 25.5% 39.9% Over $1 Million 359 56.0% $106,770 72.6% 8.0% 359 56.0% Total Rev. available 627 97.8% $144,284 98.1% 98.8% 627 97.8%

Revenue Rev. Not Known 14 2.2% $2,850 1.9% 1.2% 14 2.2% Total 641 100.0% $147,134 100.0% 100.0% 641 100.0% $100,000 or Less 293 45.7% $14,887 10.1% 293 45.7% 95.1% $14,887 10.1% 43.3% Small Business $100,001 - $250,000 163 25.4% $30,236 20.5% 163 25.4% 2.4% $30,236 20.5% 12.7% $250,001 - $1 Million 185 28.9% $102,011 69.3% 185 28.9% 2.6% $102,011 69.3% 44.1% Loan Size Total 641 100.0% $147,134 100.0% 641 100.0% 100.0% $147,134 100.0% 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: McAllen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Count Dollar Bank Agg Bank Bank Bank Units Agg Agg Agg

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 0.6% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.1% $0 0.0% 0.1% Moderate 2 22.2% $174 21.7% 28.5% 2 66.7% 12.2% $174 60.4% 9.5% 0 0.0% 13.0% $0 0.0% 10.9% M iddle 2 22.2% $149 18.6% 42.2% 1 33.3% 33.9% $114 39.6% 32.9% 1 16.7% 34.4% $35 6.8% 32.0% Upper 5 55.6% $480 59.8% 28.7% 0 0.0% 53.9% $0 0.0% 57.6% 5 83.3% 52.4% $480 93.2% 57.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 9 100.0% $803 100.0% 100.0% 3 100.0% 100.0% $288 100.0% 100.0% 6 100.0% 100.0% $515 100.0% 100.0% Low 1 3.4% $59 1.8% 0.6% 1 6.3% 0.1% $59 3.6% 0.1% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 7 24.1% $604 18.3% 28.5% 4 25.0% 13.4% $300 18.1% 12.2% 3 23.1% 14.3% $304 18.5% 12.3% M iddle 9 31.0% $1,139 34.5% 42.2% 3 18.8% 32.7% $379 22.9% 29.6% 6 46.2% 33.7% $760 46.1% 31.5% Upper 12 41.4% $1,498 45.4% 28.7% 8 50.0% 53.8% $915 55.4% 57.9% 4 30.8% 51.9% $583 35.4% 56.1%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.1% $0 0.0% 0.1% 0 0.0% 0.1% $0 0.0% 0.1% Total 29 100.0% $3,300 100.0% 100.0% 16 100.0% 100.0% $1,653 100.0% 100.0% 13 100.0% 100.0% $1,647 100.0% 100.0% Low 0 0.0% $0 0.0% 0.6% 0 0.0% 0.4% $0 0.0% 0.3% 0 0.0% 0.5% $0 0.0% 0.1% Moderate 38 29.2% $1,108 23.6% 28.5% 12 25.0% 28.9% $142 10.1% 17.1% 26 31.7% 30.0% $966 29.4% 18.6% M iddle 51 39.2% $1,564 33.3% 42.2% 21 43.8% 38.0% $756 53.7% 33.2% 30 36.6% 38.4% $808 24.6% 31.7%

HOME Upper 41 31.5% $2,021 43.1% 28.7% 15 31.3% 32.8% $510 36.2% 49.4% 26 31.7% 31.1% $1,511 46.0% 49.7% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 130 100.0% $4,693 100.0% 100.0% 48 100.0% 100.0% $1,408 100.0% 100.0% 82 100.0% 100.0% $3,285 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 0.9% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 19.0% 0 0.0% 9.7% $0 0.0% 7.5% 0 0.0% 12.2% $0 0.0% 9.4% M iddle 0 0.0% $0 0.0% 36.5% 0 0.0% 51.6% $0 0.0% 35.0% 0 0.0% 47.3% $0 0.0% 28.8% Upper 0 0.0% $0 0.0% 43.6% 0 0.0% 38.7% $0 0.0% 57.5% 0 0.0% 40.5% $0 0.0% 61.8%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 1 0.6% $59 0.7% 0.6% 1 1.5% 0.1% $59 1.8% 0.1% 0 0.0% 0.1% $0 0.0% 0.0% Moderate 47 28.0% $1,886 21.4% 28.5% 18 26.9% 13.6% $616 18.4% 10.3% 29 28.7% 14.6% $1,270 23.3% 11.4% M iddle 62 36.9% $2,852 32.4% 42.2% 25 37.3% 33.9% $1,249 37.3% 32.1% 37 36.6% 34.5% $1,603 29.4% 31.7% Upper 58 34.5% $3,999 45.5% 28.7% 23 34.3% 52.3% $1,425 42.6% 57.6% 35 34.7% 50.7% $2,574 47.3% 56.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 168 100.0% $8,796 100.0% 100.0% 67 100.0% 100.0% $3,349 100.0% 100.0% 101 100.0% 100.0% $5,447 100.0% 100.0% Small Businesses Low 0 0.0% $0 0.0% 0.2% 0 0.0% 0.3% $0 0.0% 0.1% 0 0.0% 0.3% $0 0.0% 0.2% Moderate 67 15.7% $20,259 18.3% 22.5% 40 18.5% 21.9% $10,335 18.3% 20.7% 27 12.8% 21.7% $9,924 18.3% 22.8% M iddle 157 36.8% $51,838 46.8% 34.6% 75 34.7% 33.7% $25,752 45.6% 38.4% 82 38.9% 35.6% $26,086 48.1% 35.2% Upper 195 45.7% $36,938 33.4% 42.6% 96 44.4% 42.3% $19,237 34.1% 39.7% 99 46.9% 40.5% $17,701 32.6% 40.6% Unknown 8 1.9% $1,672 1.5% 0.0% 5 2.3% 0.1% $1,122 2.0% 0.1% 3 1.4% 0.1% $550 1.0% 0.0% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.7% $0 0.0% 1.0% 0 0.0% 1.8% $0 0.0% 1.2% SMALL BUSINESSES Total 427 100.0% $110,707 100.0% 100.0% 216 100.0% 100.0% $56,446 100.0% 100.0% 211 100.0% 100.0% $54,261 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

131

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: McAllen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 0 0.0% $0 0.0% 1.4% 0 0.0% 0.2% $0 0.0% 0.1% Moderate 3 42.9% $159 32.4% 24.6% 3 42.9% 12.0% $159 32.4% 10.4% M iddle 2 28.6% $173 35.3% 42.3% 2 28.6% 34.4% $173 35.3% 31.7% Upper 2 28.6% $158 32.2% 31.5% 2 28.6% 53.4% $158 32.2% 57.8% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 7 100.0% $490 100.0% 100.0% 7 100.0% 100.0% $490 100.0% 100.0% Low 0 0.0% $0 0.0% 1.4% 0 0.0% 0.1% $0 0.0% 0.1% Moderate 2 20.0% $63 6.8% 24.6% 2 20.0% 12.0% $63 6.8% 10.4% M iddle 3 30.0% $571 61.5% 42.3% 3 30.0% 34.3% $571 61.5% 32.4% Upper 5 50.0% $295 31.8% 31.5% 5 50.0% 53.4% $295 31.8% 57.0%

REFINANCE Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.2% $0 0.0% 0.1% Total 10 100.0% $929 100.0% 100.0% 10 100.0% 100.0% $929 100.0% 100.0% Low 0 0.0% $0 0.0% 1.4% 0 0.0% 0.6% $0 0.0% 0.2% Moderate 12 24.0% $455 25.8% 24.6% 12 24.0% 23.9% $455 25.8% 20.4% M iddle 15 30.0% $421 23.9% 42.3% 15 30.0% 39.6% $421 23.9% 32.1%

HOME Upper 23 46.0% $889 50.4% 31.5% 23 46.0% 35.9% $889 50.4% 47.3% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 50 100.0% $1,765 100.0% 100.0% 50 100.0% 100.0% $1,765 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 0.4% 0 0.0% 0.0% $0 0.0% 0.0% Moderate 0 0.0% $0 0.0% 20.1% 0 0.0% 17.5% $0 0.0% 9.2% M iddle 0 0.0% $0 0.0% 33.2% 0 0.0% 46.0% $0 0.0% 44.9% Upper 0 0.0% $0 0.0% 46.3% 0 0.0% 36.5% $0 0.0% 45.9%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 0 0.0% $0 0.0% 1.4% 0 0.0% 0.2% $0 0.0% 0.1% Moderate 17 25.4% $677 21.3% 24.6% 17 25.4% 12.9% $677 21.3% 10.5% M iddle 20 29.9% $1,165 36.6% 42.3% 20 29.9% 34.9% $1,165 36.6% 32.6% Upper 30 44.8% $1,342 42.1% 31.5% 30 44.8% 51.9% $1,342 42.1% 56.7% Unknown 0 0.0% $0 0.0% 0.2% 0 0.0% 0.1% $0 0.0% 0.0% HMDA TOTALS Total 67 100.0% $3,184 100.0% 100.0% 67 100.0% 100.0% $3,184 100.0% 100.0% Small Businesses Low 0 0.0% $0 0.0% 0.5% 0 0.0% 0.5% $0 0.0% 0.3% Moderate 35 15.1% $7,983 13.7% 19.3% 35 15.1% 19.5% $7,983 13.7% 19.6% M iddle 76 32.8% $23,910 41.0% 33.7% 76 32.8% 34.0% $23,910 41.0% 36.0% Upper 117 50.4% $25,884 44.3% 46.5% 117 50.4% 44.6% $25,884 44.3% 43.4% Unknown 4 1.7% $597 1.0% 0.1% 4 1.7% 0.2% $597 1.0% 0.1% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.3% $0 0.0% 0.7%

SMALL BUSINESSES Total 232 100.0% $58,374 100.0% 132100.0% 232 100.0% 100.0% $58,374 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data, 2017 D&B Info, and 2015 ACS Data Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: McAllen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 25.3% 0 0.0% 0.5% $0 0.0% 0.2% 0 0.0% 0.5% $0 0.0% 0.3% Moderate 0 0.0% $0 0.0% 15.5% 0 0.0% 4.1% $0 0.0% 2.2% 0 0.0% 5.7% $0 0.0% 3.1% M iddle 0 0.0% $0 0.0% 16.8% 0 0.0% 12.2% $0 0.0% 8.6% 0 0.0% 12.9% $0 0.0% 9.6% Upper 5 55.6% $495 61.6% 42.4% 2 66.7% 59.4% $254 88.2% 65.2% 3 50.0% 54.7% $241 46.8% 62.1% Unknown 4 44.4% $308 38.4% 0.0% 1 33.3% 23.8% $34 11.8% 23.8% 3 50.0% 26.2% $274 53.2% 24.9%

HOME PURCHASE Total 9 100.0% $803 100.0% 100.0% 3 100.0% 100.0% $288 100.0% 100.0% 6 100.0% 100.0% $515 100.0% 100.0% Low 0 0.0% $0 0.0% 25.3% 0 0.0% 1.1% $0 0.0% 0.7% 0 0.0% 1.0% $0 0.0% 0.5% Moderate 5 17.2% $234 7.1% 15.5% 2 12.5% 3.8% $85 5.1% 2.0% 3 23.1% 3.7% $149 9.0% 1.7% M iddle 3 10.3% $204 6.2% 16.8% 2 12.5% 9.4% $144 8.7% 5.8% 1 7.7% 7.7% $60 3.6% 4.7% Upper 19 65.5% $2,733 82.8% 42.4% 11 68.8% 60.4% $1,324 80.1% 61.7% 8 61.5% 55.8% $1,409 85.5% 57.5%

REFINANCE Unknown 2 6.9% $129 3.9% 0.0% 1 6.3% 25.3% $100 6.0% 29.8% 1 7.7% 31.8% $29 1.8% 35.7% Total 29 100.0% $3,300 100.0% 100.0% 16 100.0% 100.0% $1,653 100.0% 100.0% 13 100.0% 100.0% $1,647 100.0% 100.0% Low 13 10.0% $95 2.0% 25.3% 5 10.4% 5.2% $11 0.8% 1.2% 8 9.8% 6.8% $84 2.6% 2.2% Moderate 20 15.4% $293 6.2% 15.5% 9 18.8% 8.1% $150 10.7% 3.1% 11 13.4% 12.4% $143 4.4% 4.1% M iddle 22 16.9% $382 8.1% 16.8% 5 10.4% 13.7% $54 3.8% 6.1% 17 20.7% 15.0% $328 10.0% 8.8%

HOME Upper 63 48.5% $3,692 78.7% 42.4% 22 45.8% 63.3% $1,084 77.0% 83.1% 41 50.0% 55.0% $2,608 79.4% 77.0% Unknown 12 9.2% $231 4.9% 0.0% 7 14.6% 9.6% $109 7.7% 6.4% 5 6.1% 10.8% $122 3.7% 7.9% IMPROVEMENT Total 130 100.0% $4,693 100.0% 100.0% 48 100.0% 100.0% $1,408 100.0% 100.0% 82 100.0% 100.0% $3,285 100.0% 100.0% Low 13 7.7% $95 1.1% 25.3% 5 7.5% 1.0% $11 0.3% 0.3% 8 7.9% 1.1% $84 1.5% 0.4% Moderate 25 14.9% $527 6.0% 15.5% 11 16.4% 4.2% $235 7.0% 2.0% 14 13.9% 5.4% $292 5.4% 2.5% M iddle 25 14.9% $586 6.7% 16.8% 7 10.4% 11.3% $198 5.9% 7.1% 18 17.8% 11.2% $388 7.1% 7.5% Upper 87 51.8% $6,920 78.7% 42.4% 35 52.2% 59.5% $2,662 79.5% 59.9% 52 51.5% 54.7% $4,258 78.2% 57.4% Unknown 18 10.7% $668 7.6% 0.0% 9 13.4% 23.9% $243 7.3% 30.7% 9 8.9% 27.6% $425 7.8% 32.3% HMDA TOTALS Total 168 100.0% $8,796 100.0% 100.0% 67 100.0% 100.0% $3,349 100.0% 100.0% 101 100.0% 100.0% $5,447 100.0% 100.0% Total Businesses $1 Million or Less 186 43.6% $29,074 26.3% 92.5% 96 44.4% 48.2% $15,051 26.7% 43.3% 90 42.7% 37.9% $14,023 25.8% 33.8% Over $1 Million 237 55.5% $81,395 73.5% 6.8% 119 55.1% 118 55.9% Total Rev. available 423 99.1% $110,469 99.8% 99.3% 215 99.5% 208 98.6%

Revenue Rev. Not Known 4 0.9% $238 0.2% 0.6% 1 0.5% 3 1.4% Total 427 100.0% $110,707 100.0% 100.0% 216 100.0% 211 100.0% $100,000 or Less 169 39.6% $9,170 8.3% 87 40.3% 93.9% $4,605 8.2% 40.3% 82 38.9% 94.7% $4,565 8.4% 45.3% Small Business $100,001 - $250,000 108 25.3% $19,679 17.8% 51 23.6% 3.3% $9,301 16.5% 17.5% 57 27.0% 3.0% $10,378 19.1% 16.7% $250,001 - $1 Million 150 35.1% $81,858 73.9% 78 36.1% 2.7% $42,540 75.4% 42.2% 72 34.1% 2.3% $39,318 72.5% 38.0% Loan Size Total 427 100.0% $110,707 100.0% 216 100.0% 100.0% $56,446 100.0% 100.0% 211 100.0% 100.0% $54,261 100.0% 100.0%

133

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: McAllen MSA Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 1 14.3% $44 9.0% 25.1% 1 14.3% 0.7% $44 9.0% 0.3% Moderate 0 0.0% $0 0.0% 16.3% 0 0.0% 5.2% $0 0.0% 2.7% M iddle 2 28.6% $68 13.9% 15.4% 2 28.6% 12.8% $68 13.9% 9.2% Upper 2 28.6% $180 36.7% 43.2% 2 28.6% 57.3% $180 36.7% 64.1% Unknown 2 28.6% $198 40.4% 0.0% 2 28.6% 24.1% $198 40.4% 23.6%

HOME PURCHASE Total 7 100.0% $490 100.0% 100.0% 7 100.0% 100.0% $490 100.0% 100.0% Low 0 0.0% $0 0.0% 25.1% 0 0.0% 1.0% $0 0.0% 0.4% Moderate 2 20.0% $61 6.6% 16.3% 2 20.0% 4.7% $61 6.6% 2.3% M iddle 2 20.0% $78 8.4% 15.4% 2 20.0% 9.0% $78 8.4% 5.8% Upper 4 40.0% $658 70.8% 43.2% 4 40.0% 58.9% $658 70.8% 61.7%

REFINANCE Unknown 2 20.0% $132 14.2% 0.0% 2 20.0% 26.4% $132 14.2% 29.8% Total 10 100.0% $929 100.0% 100.0% 10 100.0% 100.0% $929 100.0% 100.0% Low 5 10.0% $46 2.6% 25.1% 5 10.0% 3.6% $46 2.6% 1.3% Moderate 8 16.0% $54 3.1% 16.3% 8 16.0% 9.8% $54 3.1% 5.8% M iddle 6 12.0% $142 8.0% 15.4% 6 12.0% 16.8% $142 8.0% 10.6%

HOME Upper 27 54.0% $1,311 74.3% 43.2% 27 54.0% 62.2% $1,311 74.3% 76.9% Unknown 4 8.0% $212 12.0% 0.0% 4 8.0% 7.7% $212 12.0% 5.3% IMPROVEMENT Total 50 100.0% $1,765 100.0% 100.0% 50 100.0% 100.0% $1,765 100.0% 100.0% Low 6 9.0% $90 2.8% 25.1% 6 9.0% 1.0% $90 2.8% 0.3% Moderate 10 14.9% $115 3.6% 16.3% 10 14.9% 5.4% $115 3.6% 2.5% M iddle 10 14.9% $288 9.0% 15.4% 10 14.9% 11.9% $288 9.0% 7.8% Upper 33 49.3% $2,149 67.5% 43.2% 33 49.3% 57.7% $2,149 67.5% 60.0% Unknown 8 11.9% $542 17.0% 0.0% 8 11.9% 24.0% $542 17.0% 29.4% HMDA TOTALS Total 67 100.0% $3,184 100.0% 100.0% 67 100.0% 100.0% $3,184 100.0% 100.0% Total Businesses $1 Million or Less 110 47.4% $14,823 25.4% 91.8% 110 47.4% 39.9% $14,823 25.4% 35.6% Over $1 Million 122 52.6% $43,551 74.6% 7.5% 122 52.6% Total Rev. available 232 100.0% $58,374 100.0% 99.3% 232 100.0%

Revenue Rev. Not Known 0 0.0% $0 0.0% 0.7% 0 0.0% Total 232 100.0% $58,374 100.0% 100.0% 232 100.0% $100,000 or Less 103 44.4% $4,739 8.1% 103 44.4% 94.2% $4,739 8.1% 42.6% Small Business $100,001 - $250,000 51 22.0% $8,847 15.2% 51 22.0% 3.2% $8,847 15.2% 16.5% $250,001 - $1 Million 78 33.6% $44,788 76.7% 78 33.6% 2.6% $44,788 76.7% 40.9% Loan Size Total 232 100.0% $58,374 100.0% 232 100.0% 100.0% $58,374 100.0% 100.0%

134

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Fort Worth Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison Tract 2015, 2016 2015 2016 Income Bank Owner Count Dollar Count Dollar Levels Occupied Agg Agg Agg Count Dollar Units Bank Agg Bank Bank Bank

PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % # % % $ (000s) $ % $ % Low 1 0.9% $42 0.3% 4.1% 1 2.1% 1.0% $42 0.9% 0.5% 0 0.0% 1.1% $0 0.0% 0.6% Moderate 3 2.7% $212 1.7% 20.4% 1 2.1% 11.6% $34 0.7% 7.4% 2 3.2% 11.7% $178 2.3% 7.6% M iddle 22 19.8% $1,915 15.3% 37.6% 11 22.9% 38.1% $813 17.3% 32.6% 11 17.5% 38.1% $1,102 14.1% 32.7% Upper 85 76.6% $10,370 82.7% 37.9% 35 72.9% 49.4% $3,809 81.1% 59.5% 50 79.4% 49.1% $6,561 83.7% 59.1% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 111 100.0% $12,539 100.0% 100.0% 48 100.0% 100.0% $4,698 100.0% 100.0% 63 100.0% 100.0% $7,841 100.0% 100.0% Low 2 4.3% $33 0.3% 4.1% 2 8.0% 0.7% $33 0.6% 0.3% 0 0.0% 0.7% $0 0.0% 0.4% Moderate 5 10.9% $454 4.2% 20.4% 2 8.0% 9.4% $146 2.6% 5.9% 3 14.3% 8.8% $308 5.9% 5.4% M iddle 13 28.3% $5,631 52.3% 37.6% 7 28.0% 35.6% $3,501 63.3% 28.5% 6 28.6% 34.9% $2,130 40.7% 28.2% Upper 26 56.5% $4,647 43.2% 37.9% 14 56.0% 54.4% $1,852 33.5% 65.2% 12 57.1% 55.6% $2,795 53.4% 66.0%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 46 100.0% $10,765 100.0% 100.0% 25 100.0% 100.0% $5,532 100.0% 100.0% 21 100.0% 100.0% $5,233 100.0% 100.0% Low 13 4.2% $180 0.9% 4.1% 7 5.6% 2.0% $67 0.8% 0.6% 6 3.2% 1.8% $113 1.1% 0.6% Moderate 44 14.1% $1,481 7.7% 20.4% 15 12.0% 13.7% $338 3.8% 5.7% 29 15.6% 12.4% $1,143 10.9% 6.9% M iddle 97 31.2% $6,050 31.3% 37.6% 32 25.6% 31.5% $2,106 23.8% 27.6% 65 34.9% 34.4% $3,944 37.7% 29.9%

HOME Upper 157 50.5% $11,602 60.1% 37.9% 71 56.8% 52.8% $6,346 71.6% 66.1% 86 46.2% 51.3% $5,256 50.3% 62.6% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 311 100.0% $19,313 100.0% 100.0% 125 100.0% 100.0% $8,857 100.0% 100.0% 186 100.0% 100.0% $10,456 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 8.5% 0 0.0% 12.0% $0 0.0% 5.1% 0 0.0% 11.4% $0 0.0% 3.9% Moderate 0 0.0% $0 0.0% 36.7% 0 0.0% 29.3% $0 0.0% 19.7% 0 0.0% 32.5% $0 0.0% 26.1% M iddle 0 0.0% $0 0.0% 43.5% 0 0.0% 41.9% $0 0.0% 44.4% 0 0.0% 46.3% $0 0.0% 60.9% Upper 0 0.0% $0 0.0% 11.3% 0 0.0% 16.8% $0 0.0% 30.8% 0 0.0% 9.8% $0 0.0% 9.1%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 0 0.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% 0 0.0% 100.0% $0 0.0% 100.0% Low 16 3.4% $255 0.6% 4.1% 10 5.1% 1.0% $142 0.7% 1.0% 6 2.2% 1.0% $113 0.5% 0.8% Moderate 52 11.1% $2,147 5.0% 20.4% 18 9.1% 11.0% $518 2.7% 8.3% 34 12.6% 10.8% $1,629 6.9% 8.2% M iddle 132 28.2% $13,596 31.9% 37.6% 50 25.3% 37.1% $6,420 33.6% 32.7% 82 30.4% 36.9% $7,176 30.5% 33.2% Upper 268 57.3% $26,619 62.5% 37.9% 120 60.6% 51.0% $12,007 62.9% 58.0% 148 54.8% 51.3% $14,612 62.1% 57.8% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 468 100.0% $42,617 100.0% 100.0% 198 100.0% 100.0% $19,087 100.0% 100.0% 270 100.0% 100.0% $23,530 100.0% 100.0% Small Businesses Low 122 7.8% $37,652 9.9% 4.6% 65 8.9% 5.1% $20,170 10.5% 6.4% 57 6.9% 5.1% $17,482 9.3% 7.0% Moderate 430 27.6% $109,338 28.7% 20.8% 211 29.0% 20.7% $54,987 28.6% 21.9% 219 26.4% 20.7% $54,351 28.8% 23.0% M iddle 459 29.5% $104,836 27.5% 34.1% 200 27.5% 32.5% $49,881 25.9% 32.0% 259 31.2% 31.6% $54,955 29.2% 30.2% Upper 543 34.9% $128,180 33.6% 40.4% 249 34.3% 39.9% $66,714 34.6% 38.5% 294 35.4% 40.6% $61,466 32.6% 38.3% Unknown 4 0.3% $1,000 0.3% 0.1% 2 0.3% 0.1% $790 0.4% 0.2% 2 0.2% 0.1% $210 0.1% 0.2% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.7% $0 0.0% 1.0% 0 0.0% 1.9% $0 0.0% 1.2% SMALL BUSINESSES Total 1,558 100.0% $381,006 100.0% 100.0% 727 100.0% 100.0% $192,542 100.0% 100.0% 831 100.0% 100.0% $188,464 100.0% 100.0%

Originations & Purchases 2016 FFIEC Census Data, 2016 D&B Info, and 2010 ACS Data

135

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Geographic Distribution of HMDA and Small Business Loans Assessment Area: Fort Worth Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison

Tract 2017 2017 Income Bank Owner Count Dollar Levels Occupied Count Dollar Units Bank Agg Bank Agg PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $ (000s) $ % $ % Low 1 1.4% $133 1.5% 5.7% 1 1.4% 2.3% $133 1.5% 1.3% Moderate 2 2.9% $68 0.8% 18.3% 2 2.9% 13.6% $68 0.8% 9.8% M iddle 4 5.8% $419 4.8% 36.0% 4 5.8% 36.2% $419 4.8% 29.8% Upper 62 89.9% $8,132 92.9% 39.9% 62 89.9% 47.9% $8,132 92.9% 59.0% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0%

HOME PURCHASE Total 69 100.0% $8,752 100.0% 100.0% 69 100.0% 100.0% $8,752 100.0% 100.0% Low 0 0.0% $0 0.0% 5.7% 0 0.0% 1.4% $0 0.0% 0.8% Moderate 7 20.0% $639 14.0% 18.3% 7 20.0% 12.2% $639 14.0% 8.1% M iddle 8 22.9% $903 19.8% 36.0% 8 22.9% 36.1% $903 19.8% 27.9% Upper 20 57.1% $3,017 66.2% 39.9% 20 57.1% 50.2% $3,017 66.2% 63.2%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 35 100.0% $4,559 100.0% 100.0% 35 100.0% 100.0% $4,559 100.0% 100.0% Low 5 2.5% $78 0.5% 5.7% 5 2.5% 3.7% $78 0.5% 1.4% Moderate 14 7.1% $712 4.9% 18.3% 14 7.1% 15.7% $712 4.9% 11.1% M iddle 62 31.5% $3,098 21.1% 36.0% 62 31.5% 32.0% $3,098 21.1% 26.3%

HOME Upper 116 58.9% $10,784 73.5% 39.9% 116 58.9% 48.6% $10,784 73.5% 61.3% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% IMPROVEMENT Total 197 100.0% $14,672 100.0% 100.0% 197 100.0% 100.0% $14,672 100.0% 100.0% Multi-Family Units Low 0 0.0% $0 0.0% 17.0% 0 0.0% 19.8% $0 0.0% 15.4% Moderate 1 100.0% $150 100.0% 31.5% 1 100.0% 37.4% $150 100.0% 33.9% M iddle 0 0.0% $0 0.0% 33.2% 0 0.0% 30.2% $0 0.0% 35.7% Upper 0 0.0% $0 0.0% 18.3% 0 0.0% 12.6% $0 0.0% 15.0%

MULTI FAMILY MULTI Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% Total 1 100.0% $150 100.0% 100.0% 1 100.0% 100.0% $150 100.0% 100.0% Low 6 2.0% $211 0.8% 5.7% 6 2.0% 2.2% $211 0.8% 3.0% Moderate 24 7.9% $1,569 5.6% 18.3% 24 7.9% 13.4% $1,569 5.6% 12.4% M iddle 74 24.5% $4,420 15.7% 36.0% 74 24.5% 36.0% $4,420 15.7% 30.1% Upper 198 65.6% $21,933 78.0% 39.9% 198 65.6% 48.5% $21,933 78.0% 54.5% Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 0.0% $0 0.0% 0.0% HMDA TOTALS Total 302 100.0% $28,133 100.0% 100.0% 302 100.0% 100.0% $28,133 100.0% 100.0% Small Businesses Low 88 9.6% $22,569 10.2% 7.0% 88 9.6% 7.6% $22,569 10.2% 7.6% Moderate 215 23.5% $60,493 27.4% 20.0% 215 23.5% 21.3% $60,493 27.4% 23.7% M iddle 270 29.6% $59,445 26.9% 30.8% 270 29.6% 28.9% $59,445 26.9% 29.1% Upper 340 37.2% $78,555 35.5% 42.1% 340 37.2% 40.7% $78,555 35.5% 38.3% Unknown 0 0.0% $0 0.0% 0.1% 0 0.0% 0.1% $0 0.0% 0.3% Tr Unknown 0 0.0% $0 0.0% 0 0.0% 1.4% $0 0.0% 1.0%

SMALL BUSINESSES Total 913 100.0% $221,062 100.0% 100.0% 913 100.0% 100.0% $221,062 100.0% 100.0% Originations & Purchases 2017 FFIEC Census Data, 2017 D&B Info, and 2015 ACS Data

136 Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Fort Worth Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2015, 2016 2015 2016 Borrower Income Levels Bank Families Count Dollar Count Dollar by Family Count Dollar Bank Agg Bank Agg Bank Agg Bank Agg Income PRODUCT TYPE PRODUCT # % $ (000s) $ % % # % % $(000s) $ % $ % # % % $(000s) $ % $ % Low 2 1.8% $123 1.0% 21.9% 1 2.1% 4.8% $42 0.9% 2.4% 1 1.6% 3.7% $81 1.0% 1.8% Moderate 1 0.9% $19 0.2% 17.2% 0 0.0% 15.9% $0 0.0% 10.9% 1 1.6% 14.9% $19 0.2% 10.1% M iddle 3 2.7% $405 3.2% 19.3% 2 4.2% 19.8% $210 4.5% 17.3% 1 1.6% 20.3% $195 2.5% 17.4% Upper 103 92.8% $11,813 94.2% 41.7% 45 93.8% 39.4% $4,446 94.6% 51.7% 58 92.1% 42.0% $7,367 94.0% 54.1% Unknown 2 1.8% $179 1.4% 0.0% 0 0.0% 20.1% $0 0.0% 17.7% 2 3.2% 19.1% $179 2.3% 16.6%

HOME PURCHASE Total 111 100.0% $12,539 100.0% 100.0% 48 100.0% 100.0% $4,698 100.0% 100.0% 63 100.0% 100.0% $7,841 100.0% 100.0% Low 1 2.2% $8 0.1% 21.9% 1 4.0% 3.9% $8 0.1% 1.9% 0 0.0% 2.8% $0 0.0% 1.3% Moderate 4 8.7% $260 2.4% 17.2% 3 12.0% 10.5% $171 3.1% 6.3% 1 4.8% 9.4% $89 1.7% 5.5% M iddle 6 13.0% $715 6.6% 19.3% 3 12.0% 16.7% $397 7.2% 12.3% 3 14.3% 15.9% $318 6.1% 11.8% Upper 35 76.1% $9,782 90.9% 41.7% 18 72.0% 41.0% $4,956 89.6% 52.5% 17 81.0% 43.5% $4,826 92.2% 54.6%

REFINANCE Unknown 0 0.0% $0 0.0% 0.0% 0 0.0% 28.0% $0 0.0% 27.0% 0 0.0% 28.3% $0 0.0% 26.9% Total 46 100.0% $10,765 100.0% 100.0% 25 100.0% 100.0% $5,532 100.0% 100.0% 21 100.0% 100.0% $5,233 100.0% 100.0% Low 23 7.4% $523 2.7% 21.9% 11 8.8% 5.2% $190 2.1% 1.6% 12 6.5% 4.5% $333 3.2% 1.7% Moderate 43 13.8% $1,666 8.6% 17.2% 16 12.8% 13.0% $437 4.9% 6.7% 27 14.5% 11.5% $1,229 11.8% 6.1% M iddle 46 14.8% $1,836 9.5% 19.3% 16 12.8% 18.0% $703 7.9% 11.7% 30 16.1% 19.6% $1,133 10.8% 14.7%

HOME Upper 184 59.2% $14,642 75.8% 41.7% 75 60.0% 58.5% $7,315 82.6% 72.4% 109 58.6% 60.0% $7,327 70.1% 70.0% Unknown 15 4.8% $646 3.3% 0.0% 7 5.6% 5.3% $212 2.4% 7.6% 8 4.3% 4.4% $434 4.2% 7.5% IMPROVEMENT Total 311 100.0% $19,313 100.0% 100.0% 125 100.0% 100.0% $8,857 100.0% 100.0% 186 100.0% 100.0% $10,456 100.0% 100.0% Low 26 5.6% $654 1.5% 21.9% 13 6.6% 4.5% $240 1.3% 2.0% 13 4.8% 3.4% $414 1.8% 1.5% Moderate 48 10.3% $1,945 4.6% 17.2% 19 9.6% 14.1% $608 3.2% 8.4% 29 10.7% 12.9% $1,337 5.7% 7.9% M iddle 55 11.8% $2,956 6.9% 19.3% 21 10.6% 18.7% $1,310 6.9% 14.0% 34 12.6% 18.7% $1,646 7.0% 14.4% Upper 322 68.8% $36,237 85.0% 41.7% 138 69.7% 40.4% $16,717 87.6% 46.5% 184 68.1% 43.1% $19,520 83.0% 50.7% Unknown 17 3.6% $825 1.9% 0.0% 7 3.5% 22.4% $212 1.1% 29.1% 10 3.7% 21.9% $613 2.6% 25.4% HMDA TOTALS Total 468 100.0% $42,617 100.0% 100.0% 198 100.0% 100.0% $19,087 100.0% 100.0% 270 100.0% 100.0% $23,530 100.0% 100.0% Total Businesses $1 Million or Less 591 37.9% $93,014 24.4% 91.9% 260 35.8% 48.6% $46,552 24.2% 35.1% 331 39.8% 42.0% $46,462 24.7% 35.3% Over $1 Million 922 59.2% $274,535 72.1% 7.2% 450 61.9% 472 56.8% Total Rev. available 1,513 97.1% $367,549 96.5% 99.1% 710 97.7% 803 96.6%

Revenue Rev. Not Known 45 2.9% $13,457 3.5% 0.8% 17 2.3% 28 3.4% Total 1,558 100.0% $381,006 100.0% 100.0% 727 100.0% 831 100.0% $100,000 or Less 644 41.3% $33,369 8.8% 267 36.7% 93.7% $14,815 7.7% 36.9% 377 45.4% 94.5% $18,554 9.8% 41.3% Small Business $100,001 - $250,000 428 27.5% $79,029 20.7% 213 29.3% 2.9% $39,784 20.7% 13.7% 215 25.9% 2.6% $39,245 20.8% 13.5% $250,001 - $1 Million 486 31.2% $268,608 70.5% 247 34.0% 3.4% $137,943 71.6% 49.3% 239 28.8% 2.8% $130,665 69.3% 45.2% Loan Size Total 1,558 100.0% $381,006 100.0% 727 100.0% 100.0% $192,542 100.0% 100.0% 831 100.0% 100.0% $188,464 100.0% 100.0%

137

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix F – Metropolitan Limited Scope Assessment Area Loan Tables

Borrower Distribution of HMDA Loans & Small Business Lending by Revenue & Loan Size Assessment Area: Fort Worth Bank Lending & Demographic Data Bank & Aggregate Lending Comparison Comparison 2017 2017 Borrower Income Levels Bank Families Count Dollar by Family Count Dollar Bank Agg Bank Agg PRODUCT TYPE PRODUCT Income # % $ (000s) $ % % # % % $(000s) $ % $ % Low 0 0.0% $0 0.0% 23.1% 0 0.0% 3.4% $0 0.0% 1.9% Moderate 1 1.4% $150 1.7% 16.3% 1 1.4% 14.1% $150 1.7% 9.6% M iddle 2 2.9% $147 1.7% 19.3% 2 2.9% 21.8% $147 1.7% 18.9% Upper 63 91.3% $8,087 92.4% 41.3% 63 91.3% 43.4% $8,087 92.4% 54.6% Unknown 3 4.3% $368 4.2% 0.0% 3 4.3% 17.3% $368 4.2% 15.0%

HOME PURCHASE Total 69 100.0% $8,752 100.0% 100.0% 69 100.0% 100.0% $8,752 100.0% 100.0% Low 0 0.0% $0 0.0% 23.1% 0 0.0% 4.3% $0 0.0% 2.1% Moderate 4 11.4% $277 6.1% 16.3% 4 11.4% 11.6% $277 6.1% 7.2% M iddle 4 11.4% $295 6.5% 19.3% 4 11.4% 19.7% $295 6.5% 15.6% Upper 22 62.9% $3,418 75.0% 41.3% 22 62.9% 41.4% $3,418 75.0% 53.0%

REFINANCE Unknown 5 14.3% $569 12.5% 0.0% 5 14.3% 22.9% $569 12.5% 22.1% Total 35 100.0% $4,559 100.0% 100.0% 35 100.0% 100.0% $4,559 100.0% 100.0% Low 9 4.6% $289 2.0% 23.1% 9 4.6% 6.7% $289 2.0% 4.0% Moderate 25 12.7% $986 6.7% 16.3% 25 12.7% 13.8% $986 6.7% 9.7% M iddle 29 14.7% $1,322 9.0% 19.3% 29 14.7% 20.5% $1,322 9.0% 16.8%

HOME Upper 127 64.5% $11,851 80.8% 41.3% 127 64.5% 56.0% $11,851 80.8% 65.3% Unknown 7 3.6% $224 1.5% 0.0% 7 3.6% 3.1% $224 1.5% 4.2% IMPROVEMENT Total 197 100.0% $14,672 100.0% 100.0% 197 100.0% 100.0% $14,672 100.0% 100.0% Low 9 3.0% $289 1.0% 23.1% 9 3.0% 3.8% $289 1.0% 1.7% Moderate 30 10.0% $1,413 5.0% 16.3% 30 10.0% 13.3% $1,413 5.0% 7.9% M iddle 35 11.6% $1,764 6.3% 19.3% 35 11.6% 21.1% $1,764 6.3% 15.8% Upper 212 70.4% $23,356 83.5% 41.3% 212 70.4% 43.2% $23,356 83.5% 47.7% Unknown 15 5.0% $1,161 4.2% 0.0% 15 5.0% 18.5% $1,161 4.2% 26.9% HMDA TOTALS Total 301 100.0% $27,983 100.0% 100.0% 301 100.0% 100.0% $27,983 100.0% 100.0% Total Businesses $1 Million or Less 365 40.0% $57,645 26.1% 91.2% 365 40.0% 46.1% $57,645 26.1% 36.1% Over $1 Million 501 54.9% $150,229 68.0% 7.9% 501 54.9% Total Rev. available 866 94.9% $207,874 94.1% 99.1% 866 94.9%

Revenue Rev. Not Known 47 5.1% $13,188 6.0% 0.8% 47 5.1% Total 913 100.0% $221,062 100.0% 100.0% 913 100.0% $100,000 or Less 393 43.0% $20,199 9.1% 393 43.0% 93.8% $20,199 9.1% 39.7% Small Business $100,001 - $250,000 236 25.8% $42,995 19.4% 236 25.8% 3.2% $42,995 19.4% 15.4% $250,001 - $1 Million 284 31.1% $157,868 71.4% 284 31.1% 3.1% $157,868 71.4% 44.8% Loan Size Total 913 100.0% $221,062 100.0% 913 100.0% 100.0% $221,062 100.0% 100.0%

Frost Bank CRA Performance Evaluation San Antonio, TX August 13, 2018 Appendix G – Distribution of Branch Delivery System and Branch Openings and Closings

Appendix G – Distribution of Branch Delivery System and Branch Openings and Closings

As of: December 31, 2017

Percent of Branches by Income Level of Assessment Areas Geography Branch Openings and Closings Demographics # of # of Net Change in Branch Locations % of Population % of # of % of Branches Branches Name Deposits Branches Branches Low Mod Mid Upper Opened Closed Low Mod Mid Upper Low Mod Mid Upper Unk Dallas-Plano-Irving MD 7.7% 15 10.5% 13.3% 20.0% 13.3% 53.3% 4 1 0 2 1 0 12.4% 24.7% 25.7% 37.0% 0.3% Houston-Sugar Land – Baytown MSA 17.6% 33 23.2 9.1% 27.3% 6.1% 57.6% 6 3 2 1 1 -1 11.7% 24.6% 26.8% 36.6% 0.3% San Antonio – New Braunfels MSA 31.7% 29 20.4% 3.5% 13.8% 34.5% 48.3% 4 2 1 -1 -1 3 6.0% 29.6% 29.1% 35.4% 0.0% Corpus Christi MSA 5.4% 9 6.3 11.1% 11.1% 44.4% 33.3% 0 0 0 0 0 0 4.9% 28.8% 31.7% 34.5% 0.0% Brownsville – Harlingen MSA 0.8% 2 1.4% 0.0% 50.0% 0.0% 50.0% 0 1 0 0 -1 0 0.0% 40.2% 28.7% 27.6% 3.4% Midland MSA 3.3% 4 2.8% 25.0% 0.0% 50.0% 25.0% 0 0 0 0 0 0 2.5% 14.2% 45.8% 37.5% 0.0% Odessa MSA 1.4% 3 2.1% 0.0% 66.7% 0.0% 33.3% 0 0 0 0 0 0 2.3% 22.1% 39.0% 36.6% 0.0% Austin – Round Rock – San Marcos MSA 11.8% 19 13.3% 15.8% 10.5% 15.8% 57.9% 2 0 1 0 0 1 10.5% 18.7% 37.7% 32.2% 0.9% Fort Worth – Arlington MSA 18.1% 25 17.6% 8.0% 16.0% 20.0% 56.0% 5 4 0 0 0 1 9.8% 23.4% 35.1% 31.7% 0.0% McAllen – Edinburg – Mission MSA 2.2% 3 2.1% 0.0% 0.0% 33.3% 66.7% 0 3 0 -1 0 -2 1.3% 25.7% 41.3% 31.4% 0.2%

139