Occasionally, loan applications are received for loans outside designated market areas. To ensure that we are efficient in our calling and underwriting, this guide was written to clarify the expectations for where Capital City Bank (CCB) will make loans. Below is our Board approved policy on lending geography and the further limitations required by Credit Risk Oversight/Credit Committee.

Capital City Bank was established to support the communities in which it operates. The Bank will aggressively seek good loans from within the primary trade area, which will be defined as the counties in which our offices are located. We will accept loans within our secondary trade area, defined as adjacent counties to those in which we have offices.

On occasion we will have opportunities to make loans that are out of both the primary and secondary trade areas. These loans should be made only when the borrower is known to us and has an existing banking relationship with Capital City Bank. An example of such an exception would be to finance an out of area commercial property owned by one of our well-known clients. The Bank may also engage in loan participations outside of these defined trade areas. In these cases, Credit Committee approval is required.

In some cases, in order to take full advantage of business expansion opportunities, marketing initiatives may be directed to the combined Bank and Capital City Home Loan (CCHL) market areas. These initiatives, for promotional purposes, must be approved by Executive Management and will have defined parameters/limitations. All production will be monitored for Community Reinvestment Act (CRA) and Fair Lending purposes.

Acceptable loans for Capital City Lenders:

• Loans to Capital City clients within our designated trade areas.
  • Limited to counties where CCB has a physical office and adjoining counties. Note: Due to the small size of Georgia counties, Credit Risk Oversight or Credit Committee could make an exception for clients in a reasonable distance who maintain their primary banking relationship with CCB.
  • A client is a borrower whose primary deposit relationship is with CCB.
• Loans on property outside of CCB's trade area when the borrower is a relationship client (has operating deposit accounts at Capital City Bank) and is domiciled in our trade areas.
• Capital City will consider loans to out of area borrowers on property located in our trade areas. These loans may be subject to more restrictive underwriting or higher pricing.
• The relationship officer is located in the trade area where the property is located or where the borrower is domiciled (for example: loans in Atlanta will be handled by lenders located in Atlanta).

In an effort to grow our loan portfolio, achieve geographic diversification, and obtain quality loans not readily available in our markets, Capital City will:

• Participate in loans outside our markets with correspondent banks. These banks do the primary underwriting in the “foreign” markets. They also provide a resource to accommodate the borrowing needs of our clients beyond our internal lending limits.
• Purchase loans originated by other lenders in and out of our markets.
• Participate in 1-4 family construction lending in the greater Atlanta area.

These activities are subject to restrictions in underwriting, type, individual, and total amount by Credit Risk Oversight/Credit Committee and are managed by Brantley Henderson or, in the case of Atlanta 1-4 construction activity, Bill Edwards.