PUBLIC DISCLOSURE. February 2, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. United Bank, Inc. 514 Market Street

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1 PUBLIC DISCLOSURE February 2, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION United Bank, Inc Market Street Parkersburg, West Virginia Federal Reserve Bank of Richmond P. O. Box Richmond, Virginia 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.

2 TABLE OF CONTENTS Institution Rating Institution s CRA Rating... 1 Table of Performance Test Ratings... 1 Summary of Major Factors Supporting Rating... 1 Institution Description of Institution... 2 Scope of Examination... 3 Conclusions With Respect to Performance Tests... 4 Multistate Metropolitan Area Multistate Metropolitan Area Rating... 8 Scope of Examination... 8 Description of Operations... 8 Conclusions With Respect to Performance Tests State of West Virginia State Rating Scope of Examination Description of Operations Conclusions With Respect to Performance Tests West Virginia Metropolitan Area (Full-Scope Review) Description of Operations in Charleston MSA Conclusions With Respect to Performance Tests Description of Operations in Parkersburg-Marietta-Vienna MSA Conclusion With Respect to Performance Tests West Virginia Metropolitan Area (Limited-Scope Review) Nonmetropolitan Area (Full-Scope Review) Description of Operations in Braxton Counties NonMSA Conclusions With Respect to Performance Tests Nonmetropolitan Statewide Area (Limited-Scope Review) Appendices CRA Appendix A: Scope of Examination CRA Appendix B: Summary of State and Multistate Metropolitan Area Ratings CRA Appendix C: Limited Review Tables CRA Appendix D: Branch, Loan, and Deposit Volume by Assessment Area CRA Appendix E: Assessment Area Composition CRA Appendix F: Glossary... 53

3 INSTITUTION RATING INSTITUTION'S CRA RATING: United Bank, Inc. is rated SATISFACTORY. The following table indicates the performance level of United Bank, Inc., with respect to the lending, investment, and service tests. PERFORMACE LEVELS Outstanding Lending Test* United Bank, Inc. PERFORMANCE TESTS Investment Test Service Test High Satisfactory X X X Low Satisfactory Needs to Improve Substantial Noncompliance * The lending test is weighted more heavily than the investment and service tests in determining the overall rating. Major factors supporting the institution s rating include: Lending activity overall is consistent with the bank s capacity and market presence. A high percentage of the institution s reported Home Mortgage Disclosure Act (HMDA), small business, and consumer loans were originated within the bank s assessment areas. While the geographic and borrower distribution of loans in the markets reviewed using the examination procedures is varied, in almost all cases, the performance is considered adequate or good. Participation in qualified community development lending is responsive to community credit needs and is considered good. A significant level of participation in qualified community development investments responsive to community credit needs was noted and is considered good. Delivery systems and branch locations are accessible to all segments of the assessment area reviewed. A relatively high level of community development services throughout the institution s numerous assessment areas was identified. 1

4 DESCRIPTION OF INSTITUTION INSTITUTION Headquartered in Parkersburg, West Virginia, United Bank, Inc. (UBI) operates 51 full-service branch offices and five limited purpose facilities throughout West Virginia and southeastern Ohio. UBI is a subsidiary of United Bankshares, Incorporated, a multi-bank holding company headquartered in Charleston, West Virginia. UBI, remains the largest commercial bank headquartered in West Virginia. The bank and its holding company have a number of other affiliates and subsidiaries including one other bank subsidiary, United Bank, headquartered in Fairfax, Virginia. Notable for assisting the bank in meeting its CRA obligations is another affiliate, United Venture Fund, a licensed community development organization. As of December 31, 2008, UBI had assets exceeding $4.2 billion of which 70.5% were loans and 14.8% were securities. From December 31, 2006, through December 31, 2008, bank assets, loans, and deposits increased 9.9%, 3.3%, and 5%, respectively. The chart below illustrates the composition of the loan portfolio on December 31, Loan Type $(000s) % Secured by 1-4 Family dwellings 1,036, Multifamily 82, Construction and Development 236, Commercial & Industrial/ NonFarm NonResidential Composition of Loan Portfolio 12/31/2008 1,245, Consumer Loans and Credit Cards 312, Agricultural Loans/ Farmland 3, All Other 53, Total 2,970, Based on its financial capacity, there are no significant limitations on the bank's ability to meet credit needs within the communities it serves. The bank serves 11 assessment areas throughout West Virginia and southeastern Ohio. Currently, three of the bank s branch offices are located in Belmont County, Ohio, which is included in the Wheeling, WV-OH multistate Metropolitan Statistical Area (MSA). Appendix E contains the composition of each assessment area. Appendix D includes a table reflecting the number and percentage of branches, volume of lending, and volume of deposits by assessment area and includes subtotals for the State of West Virginia (which excludes activity within the Wheeling, West Virginia-Ohio multistate MSA). UBI received a satisfactory rating at its prior CRA evaluation conducted November 27, Since the previous CRA evaluation, the organization acquired 100% of the outstanding common stock of Premier Community Bankshares, Inc. (PCB) of Winchester, Virginia. Consequently, the merger resulted in the addition of one branch office and necessitated the creation of the Hagerstown-Martinsburg, MD-WV MSA assessment area. There have been no other branch additions or closures since the previous evaluation. 2

5 SCOPE OF EXAMINATION The institution was evaluated using the interagency examination procedures developed by the Federal Financial Institutions Examination Council (FFIEC). Consistent with these procedures, HMDA, small business, small farm, and qualified community development lending activity reported by the institution from January 1, 2006, through December 31, 2008, was reviewed. This includes all loans originated and purchased by UBI during the three-year time period. The analysis also included optionally collected consumer loan data provided by the bank. The consumer loan data included motor vehicle, other secured, and other unsecured loan transactions originated between January 1, 2006, and December 31, Since UBI reported only 81 small farm loans, these loans were not further considered in the more detailed analysis of specific assessment areas as doing so would not yield meaningful information relative to rating performance. Loans extended or purchased by affiliates or subsidiaries are not included or considered. Throughout the analysis of lending, loans without a reported income (in the case of borrower distribution) and loans where the reported geographic information is incomplete (in the case of geographic distribution) are excluded from both bank loan totals and comparative aggregate lending totals. Qualified community development investments and services are also considered for activities from November 27, 2006, through the evaluation date. All qualified investments outstanding as of the examination date were also considered regardless of when made. An overall institution rating and ratings for the lending, investment, and services tests are assigned to the Wheeling, West Virginia-Ohio multistate MSA (as the institution has branches in both the West Virginia and Ohio portions of the MSA) and to the State of West Virginia. The state rating is based only on the performance in the assessment areas subject to the full-scope review and excludes the Wheeling, West Virginia multistate MSA, as it is rated separately. For assessment areas that are reviewed utilizing the limited scope evaluation procedures, a determination was made as to whether performance was consistent with the assigned overall state rating. Because of relative size as determined by loan activity, proportion of bank deposits, and market population, full-scope FFIEC evaluation procedures were applied to the Wheeling, West Virginia-Ohio multistate MSA, Charleston, West Virginia MSA, Parkersburg-Marietta-Vienna, West Virginia-Ohio MSA, and the Braxton Counties assessment areas. The remaining seven assessment areas were subject to the limited review process also provided for by the FFIEC. The institution s overall rating for each test is based on the ratings assigned to the Wheeling, West Virginia-Ohio multistate MSA and the State of West Virginia and are weighted primarily according to bank activity as measured by relative lending volume, amount of deposits, and the number of branches. According to evaluation procedures, the lending test performance accounts for half of the overall rating, while the investment and service tests are equally weighted and, combined, account for the remaining half of the overall rating. When evaluating lending performance for specific loan types, primary consideration is given to the number (and corresponding percentage) of transactions. The institution s overall rating is based on the performance of each loan category and primary consideration is given to the dollar volume each category contributes to the overall activity considered in the evaluation. 3

6 CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS LENDING TEST An analysis of lending for the review period is discussed in greater detail later in this evaluation for assessment areas receiving a full-scope review. The analyses contain tables regarding the bank s performance for loans reported in Though tables are not presented for 2006 and 2008 performances, the data was analyzed and a statement as to whether that performance is consistent with 2007 is included. Additionally, the pertinent details of 2006 and/or 2008 lending performances are addressed when there is a meaningful difference in performance between the years included in the analysis. In assessing the bank s HMDA lending performance, consideration was given to all respective HMDA categories, their individual performances, and their contributions to the bank s total reported HMDA activity. Each category has been analyzed independently, and conclusions accompanying tables in this evaluation aggregate the performance of those categories. In general, greater weight was given to categories with greater associated dollar volumes of lending. The lending test is rated high satisfactory overall based on lending activity, distribution of loans, and community development lending. Area demographic data, Dun & Bradstreet (D&B) business data, and market aggregate information are used as proxies for demand when evaluating the bank s performance. Aggregate data includes UBI and all other reporting institutions that originated and/or purchased loans of the type considered within the bank s assessment areas. Demographic data are the 2000 census, D&B business data are from 2006 and 2007, and the small business and HMDA aggregate data are from calendar years 2006 and For the analysis of 2008 data, aggregate data from 2007 was used as 2008 aggregate data was not yet available. In analyzing the bank s community development lending performance, contextual information was obtained through the review of other bank s CRA performance evaluations within the respective assessment areas. Throughout the majority of the bank s market areas, a high level of small business lending activity is noted for specialized lenders, who tend to originate small business loans in the form of credit cards. These loans, however, tend to be much smaller in size than traditional small business bank loans. Not only do such loans tend to be smaller, but when included in the aggregate, these reporters often tend to depress the proportion of reported loans to businesses with revenues of $1 million or less. These factors were considered as an aspect of performance context when evaluating the level and distribution of bank lending. In any case where these factors materially affected the conclusion regarding bank performance in a particular assessment area, such information is included in the narrative discussion. Lending Activity: A bank s loan-to-deposit ratio is one measure of its lending relative to its capacity. The bank s quarterly loan-to-deposit ratio for the nine-quarter period ending December 31, 2008, averaged 106.3% and ranged from 104.8% to 110.6%. As of December 31, 2008, the average of quarterly loan-to-deposit ratio of the national peer group was 93.8% and ranged from 90.5% to 97.4%. The national peer group is defined as all insured commercial banks having assets greater than $3 billion. UBI s loan-to-deposit ratio, as of December 31, 2008, equaled 104.8%. These ratios evidence some reliance by the bank on non-deposit funding sources; thus, while no barriers to the bank s ability to lend are noted, the rate of loan growth could be affected by changes in funding strategy. Various loan products are available through the institution including consumer, residential mortgage, home equity, small business, and commercial loans. In an effort to meet the needs of its local communities, the bank offers and/or participates in various special loan programs that have flexible underwriting criteria and benefit low- and moderate-income people/areas or promote economic development. These programs include Fair Housing Administration (FHA), Veterans Administration, 4

7 Farm Service Housing, and Rural Housing Service home purchase loans. UBI also offers FHA Title 1 home improvement loans. These loans carry a 90% guarantee against loss from the FHA and offer flexible nontraditional underwriting criteria. The bank originated 570 of these loans totaling nearly $5.6 million during the evaluation period. UBI s Affordable Housing Option (AHO) loan program is available for borrowers who do not meet the underwriting criteria necessary for the secondary market. This program offers home purchase, refinance, and rehabilitation loans with up to 97% financing and flexible underwriting criteria. The program is limited to families whose incomes generally do not exceed 80% of the HUD median family income for their county of residence. During the evaluation period, the bank originated 30 such loans totaling approximately $1.5 million. The bank has also partnered with the Federal Home Loan Bank- Pittsburgh (FHLBP) and participates in many of its affordable housing programs. The First Front Door (FFD) program is available to qualified first-time homebuyers whose incomes do not exceed 80% of the area median family income. Participants must also complete a homeownership counseling program. The FFD program contributes $3 for every dollar the participant contributes, up to a maximum of $5,000, toward down payment and closing costs of a home purchase. The bank assisted seven borrowers in obtaining FFD grants totaling $33,874 during the evaluation period. The bank also participates in the FHLBP s Affordable Housing (AHP), Banking on Business (BOB), Community Lending (CL), and the Homeowner Rehabilitation (HR) programs. The AHP, CL, and HR programs provide grants and loans for affordable housing projects including new and rehabilitated single- and multi-family housing projects. Since the previous evaluation, the bank, has participated in six projects that have received grants totaling $1,252,134 under the AHP program; the BOB program has provided one eligible small business with start-up and expansion funding totaling $200,000; the CL program has provided two borrowers with funds totaling $6.1 million for economic development and housing; and the HR program has provided a borrower, whose income is at or below 80% of the area median income, with funds totaling $156,000 to assist with housing repairs. Participation in such loan programs and partnerships demonstrates UBI s commitment to its local market areas and a willingness to participate in flexible and sometimes complex credit transactions that benefit low- and moderate-income borrowers and/or areas. Lending activity is considered good relative to the bank s capacity to lend and the economic conditions within the bank s market areas. Assessment Area Concentration: Loan data includes all reported originations and purchases of HMDA, small business, small farm, and consumer loans from January 1, 2006, through December 31, The data does not include large commercial loans (loan amounts in excess of $1 million), any other loan type not specified, or any activity by affiliates or subsidiaries. Comparison of Credit Extended Inside and Outside of Assessment Area(s) Loan Type Inside Outside # % $(000) % # % $(000) % Home Purchase 1, , , Home Improvement 1, , , Multi-Family , , Refinancing 1, , , Total HMDA related 5, , , , Small Business 5, , , , Total Small Bus. related 5, , , , Small Farm , , Total Small Farm related , , Motor Vehicle 14, , , , Other - Secured 2, , , Other - Unsecured 2, , , Total Consumer related 19, , , , TOTAL LOANS 30, ,435, , ,

8 As indicated above, a high percentage of the number and dollar amounts of loans have been provided to assessment area residents. Overall, the percentage of loans made in the bank s assessment areas is considered highly responsive to community credit needs. Geographic and Borrower Distribution: When evaluating the geographic and borrower distribution for a specific loan category (small business, HMDA, and consumer) within an assessment area, primary emphasis is placed on the number of loans originated or purchased. To arrive at an overall conclusion regarding the distribution of lending, performance in each loan category is then weighted by dollar volume of such loans made in the assessment area. Each assessment area subject to a full-scope review is weighted primarily according to its dollar volume of lending during the review period. As previously stated, UBI s lending activity from calendar years 2006, 2007, and 2008 were reviewed for this evaluation; however, tables are presented only for loans made in The bank s lending performance during each calendar year was compared directly to the most current aggregate and demographic data available for the corresponding year. This year-to-year comparison was considered when evaluating overall performance. In general, bank performance was relatively consistent between 2006, 2007, and 2008 within the markets analyzed. UBI s geographic distribution performance was better than its borrower distribution performance, and overall, reflected a good distribution while its borrower distribution, overall, demonstrated an adequate performance level. Community Development Lending: The bank had a good level of loans for a variety of community development purposes totaling approximately $36.5 million for the period reviewed. In general, the lending activities provide housing and other community services for low- and moderate-income people and/or facilitate microenterprise development. Detailed discussion of this lending activity is included in the appropriate assessment area sections. INVESTMENT TEST The institution s level of responding to community development needs through its investment activities is rated high satisfactory. Investments in equity housing funds, low-income mortgage loan pools, venture capital companies, and qualified community development bonds have been made. These investment are considered responsive to community credit needs and in some cases have some degree of complexity. As of the date of the evaluation, UBI held or had made during the review period $10.2 million in qualified investments. Currently (December 31, 2008), the bank has $4.2 billion in total assets, of which $618 million (14.8%) are securities. Qualified investments benefiting specific assessment areas, multiple assessment areas, or the statewide or regional area include the following: UBI maintains a $1.7 million equity investment in the United Venture Fund, a new markets venture capital company. The company provides venture capital to small independent businesses in the form of equity investments and subordinate debt. United Venture Fund s operations focus on businesses located throughout the State of West Virginia. A $2 million binding commitment, of which approximately $1.7 million is funded, in the Community Affordable Housing Equity Corporation (CAHEC). CAHEC invests in Low-Income Housing Tax Credits (LIHTC) projects located in the southeast and mid-atlantic regions of the United States. UBI s commitment will be used to fund projects throughout the State of West Virginia. Of the bank s funded amount, $1.3 million has funded projects in Kanawha County and approximately $351,000 has funded projects in Harrison County. 6

9 A $685,000 investment in West Virginia Infrastructure General Obligation bonds. The proceeds of the bonds are utilized to fund economic development and infrastructure improvement projects, as well as facilitate job creation throughout the State of West Virginia. An investment totaling $2.5 million in the CRA Fund. The Fund invests in community development projects that typically provide for the development of low- and moderate-income areas, microenterprise development, and otherwise improve the quality of life for low- and moderate-income people. While the Fund's individual investments are throughout the country, the bank's investment was allocated by the Fund for affordable housing projects in the Charleston, Hagerstown-Martinsburg, and Wierton-Steubenville MSAs, as well as Webster and Logan Counties. The bank maintains a $3 million investment in Qualified Zone Academy Bonds (QZAB). For schools serving low-income students, QZABs reduce the burden of interest payments by giving financial institutions holding the bonds a tax credit in lieu of interest. A qualified school is one that is located in an Empowerment Zone or Enterprise Community or has at least 35% of its students eligible for free or reduced price school lunch. The bank has three bonds of $1 million each. Two of the bonds serve Logan County and the third serves Harrison County. A $20,000 equity investment in the Ohio Valley Community Development Corporation (CDC). The CDC s primary focus is to facilitate small business development and increase employment opportunities in the Wheeling multistate MSA. A $205,000 investment in a privately issued mortgage-backed security. All of the underlying loans within the pool are to low- or moderate-income borrowers residing in Berkeley County, West Virginia. The institution also actively supports numerous community development organizations through grants and/or donations. From July 1, 2006, to September 30, 2008, donations in excess of $383,513 were made to community development organizations whose operations assist low- and moderate-income people and/or areas or support microenterprise development. SERVICE TEST The bank s overall performance under the service test is rated high satisfactory. Delivery systems, branch locations, and hours of operation are considered accessible and convenient to all portions of the assessment areas. Of the 56 branch offices, two (3.6%) are located within a low-income area and 13 (23.2%) are located in moderate-income areas. As previously stated, one branch office was added to the network since the previous evaluation, while during this same time period, the bank has not closed any offices. UBI also actively supports community development organizations that provide community development services throughout its various assessment areas. Discussion of specific activities is included for each assessment area, as applicable. FAIR LENDING OR OTHER ILLEGAL CREDIT PRACTICES REVIEW No evidence of discriminatory or other illegal credit practices inconsistent with helping to meet community credit needs was identified. Adequate policies, procedures, and training programs have been developed to support nondiscrimination in lending activities. 7

10 MULTISTATE METROPOLITAN AREA CRA RATING FOR WHEELING, WEST VIRGINIA-OHIO ASSESSMENT AREA 1 : Satisfactory The lending test is rated: High Satisfactory The investment test is rated: Low Satisfactory The service test is rated: Outstanding Major factors supporting the rating include: Lending activity is consistent with the bank s capacity and helps meet identified credit needs. While varying slightly by product, the geographic distribution of loans is considered good overall. Overall, the bank s distribution by borrower income and business revenue is considered adequate. The bank maintains an adequate level of qualified investments. Delivery systems and branch locations are readily accessible to all segments of the assessment area. A relatively high level of participation in qualified community development services was noted. SCOPE OF EXAMINATION The institution s lending test review includes all reported HMDA, small business, and optionally collected consumer loan data for loans either originated or purchased during calendar years 2006, 2007, and Community development loans made during this period and qualified community development services provided through the evaluation date were considered. All qualified investments made during the review period or outstanding as of the examination date, regardless of when made, were considered. DESCRIPTION OF INSTITUTION S OPERATIONS IN THE WHEELING, WEST VIRGINIA- OHIO ASSESSMENT AREA The Wheeling multistate MSA assessment area includes all of Marshall and Ohio Counties, West Virginia, and all of Belmont County, Ohio. This market area constitutes the entire Wheeling multistate MSA. According to 2000 census data, the assessment area has a population of 153,172. Housing is generally considered affordable when comparing the 2000 assessment area median housing value ($64,438) to the 2000 assessment area median family income ($38,856). The 2008 median family income equaled $45,800. The overall family poverty rate of the assessment area (11.8%) is less than the West Virginia statewide rate (13.9%) but greater than the Ohio statewide rate (7.8%). The following table provides demographic data for the assessment area by the income level of families and households and distribution of local businesses. 1 This rating reflects performance within the multistate metropolitan area. The statewide evaluations are adjusted and do not reflect performance in the parts of those states contained in the multistate metropolitan area. 8

11 Assessment Area Demographics Wheeling, WV-OH MSA Income Categories* Tract Distribution Families by Tract Families < Poverty as a Families by Tract % of Families by Family Income Low Moderate Middle Upper NA Total Low Moderate Middle Upper NA Total # % # % # % # % , , , , , , , , , , , Owner Occupied Units by Households Tract HHs by Tract HHs < Poverty by Tract HHs by HH Income # % # % # % # % , , , , , , , , , , , , , , , , , Businesses by Tract and Revenue Size Total Businesses by Tract Less than or = $1 Million Over $1 Million Revenue not Reported Low Moderate Middle Upper NA Total # % # % # % # % , , , , , , Percentage of Total Businesses: *NA Tracts are tracts without household or family income as applicable. Three top area employers include Wheeling-Pittsburgh Steel Corporation, Wheeling Hospital, and Consolidated Coal Company. The area s industrial strength continues to rely heavily on the steel and coal industries. Area unemployment rates, as of December 2008, are as follows: Marshall County, WV 5.3% Wheeling MSA 5.9% Ohio County, WV 4.5% West Virginia State 4.4% Belmont County, OH 7.1% Ohio State 7.7% The bank operates nine full-service branches and one drive-in facility within this market area. As of June 2008, UBI ranked second in deposit market share having 13.4% of the assessment area s available Federal Deposit Insurance Corporation (FDIC) insured deposits (credit union deposits are not included). According to 2007 aggregate data, the institution ranked eighth in reported mortgage lending with a 3.7% market share and ranked ninth in reported small business loans with a 4.1% market share. Two representatives from economic development organizations were contacted during the evaluation to discuss local economic conditions and community credit needs. The contacts indicated that local credit needs are being met by area financial institutions. Overall, local opportunities for community development loans and investments are reasonably available when considering the bank s strategy, size, competition, and other area relevant factors. Additionally, the institution faces no significant constraints relative to its size and business strategy in making community development loans or investments. 9

12 CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN THE WHEELING, WEST VIRGINIA-OHIO ASSESSMENT AREA LENDING TEST The institution's overall lending performance within this assessment area is considered high satisfactory. This conclusion is based on the evaluation of geographic and borrower distribution and the level of community development lending while taking into account the bank s market strategy, area demographic data, and aggregate CRA small business and HMDA loan data. Lending Activity: Although bank lending activity within the market, as measured by both number (8.4%) and dollar volume (7.1%), is less than the percentage of branches in the area (17.9%), the activity is more closely aligned with the percentage of the bank s deposits within the area (12.5%) and is considered adequate. During the review period, no small farm loans were originated. The following tables present data about the bank's 2007 lending distribution by geography and by borrower income or revenue. Discussion of the performance follows each table, including evaluative statements regarding 2006 and 2008 performance. Geographic Distribution: Distribution of HMDA Loans by Income Level of Census Tract Wheeling, WV-OH MSA Income Bank Aggregate Categories # % $(000s) % $ # % $(000s) % $ (62) Home Purchase (1,759) Low Moderate , (45) Refinance (1,876) Low Moderate , (55) Home Improvement (812) Low Moderate , (2) Multi-Family (10) Low Moderate HMDA Totals Low Moderate , Middle , , , Upper , , , Unknown* Total , , , *Unknown are tracts where no income was reported ( ) represents the total number of bank loans for the specific Loan Purpose Within this market, HMDA lending, by number of loans, was divided relatively evenly between purchases, refinances, and home improvement loans in 2006, 2007, and In each year, the dollar volume of purchases and refinances was generally comparable to each other and greater than the home improvement dollar volume. As reflected in the preceding table, overall, the bank s performance in lowincome tracts, by number of loans, equals the 2007 aggregate lending level. This level of performance is also comparable to the percentage of owner-occupied housing units (.8%) within the market. Within moderate-income tracts, UBI s performance exceeds both the aggregate lending level and the percentage 10

13 of owner-occupied housing units in the assessment area (9.9%). The bank s performance in 2006 is substantially similar to its 2007 performance and is also considered good. In 2008, UBI s lending in moderate-income areas declined to 7.6% and its lending in low-income areas to 0%. This level of lending is considered adequate. Overall, given the dollar volumes of lending in the years analyzed, the bank s performance is considered good. Distribution of Small Business Loans by Income Level of Census Tract Wheeling, WV-OH MSA Bank Aggregate Income Categories # % $(000s) % $ # % $(000s) % $ Low , Moderate , , Middle , , , Upper , , Unknown* Total , , , *Unknown are tracts where no income was reported D&B data from 2007 indicates that 2.8% and 24.5% of all area businesses are located in low- and moderate-income census tracts, respectively. As shown in the preceding table, in 2007, bank lending to businesses in both low- and moderate-income tracts exceeded both the 2007 aggregate lending level and D&B demographic demand proxies. The bank s 2008 performance was substantially similar, and though 2006 performance was slightly less, it was still considered good. Overall, the penetration of lowand moderate-income areas reflects an excellent distribution of small business loans. Distribution of Consumer Loans by Income Level of Census Tract Wheeling, WV-OH MSA Consumer Loans Income Categories # % $(000s) % $ Low Moderate Middle , Upper , Unknown* Total , *Unknown are tracts where no income was reported According to demographic data for the assessment area, 1.5% and 13.8% of all area households are located in low- and moderate-income census tracts, respectively. Within these respective tracts, 41.7% and 28.5% of households have incomes that place them below the poverty level. Such high concentrations of impoverished residents may reduce the viable demand for credit from such areas, particularly in low-income tracts. As presented in the preceding table, considering the high percentage of impoverished households in the market, UBI s performance is considered excellent. The bank s distribution of consumer loans during 2006 and 2008 was very similar, and overall, is considered excellent. The overall geographic loan distribution within this assessment area is considered excellent given the institution s size, branch locations, effective demand for credit, and lending performance levels of the bank s HMDA, small business, and consumer loan products. 11

14 Distribution by Borrower Income and Revenue Size of the Business: Distribution of HMDA Loans by Income Level of Borrower Wheeling, WV-OH MSA Bank Income Aggregate Categories # % $(000s) % $ # % $(000s) % $ (62) Home Purchase (1,575) Low , Moderate , (41) Refinance (1,639) Low , Moderate , (54) Home Improvement (788) Low , Moderate , (0) Multi-Family (0) Low Moderate HMDA Totals Low , Moderate , Middle , , , Upper , , , Unknown ,750 Total , , , ( ) represents the total number of bank loans for the specific Loan Purpose where income is known Percentage's (%) are calculated on all loans where incomes are known Demographic data from the 2000 census indicates that within the assessment area, 19.8% and 18.6% of families are low- and moderate-income, respectively. Overall, as reflected in the preceding table, although UBI s lending to both low- and moderate-income borrowers is less than the percentages of such families in the market, its performance level is consistent with the 2007 aggregate lending levels for both low- and moderate-income borrowers. This level of lending is considered good, as is the bank s 2006 performance which was substantially similar. UBI s 2008 HMDA performance, however, represented a poor lending performance and a decline from both preceding years as only 4.4% and 13.3%, respectively, of the bank s lending was to low- and moderate-income borrowers. Overall, given the greater dollar volume of HMDA lending present in 2006 and 2007, the bank s performance is considered adequate. Wheeling, WV-OH MSA Bank Aggregate* by Revenue # % $(000s) % $ # % $(000s) % $ $1 Million or Less , , , Over $1 Million , NA NA NA NA Unknown , NA NA NA NA by Loan Size Distribution of Lending by Loan Amount and Size of Business $100,000 or less , , , $100,001-$250, , , $250,001-$1 Million , , Total , , , * No data is available for Aggregate loans with Revenues over $1 million and those with Unknown revenues 12

15 According to aggregate small business data, of all loans reported in 2007, 37.4% were to businesses with annual revenues of $1 million or less. Because the aggregate data includes significant lending by credit card lenders that typically extend credit in very small amounts, data for a peer group of the five largest traditional bank reporters was also considered in addition to the overall aggregate. According to the 2007 data, 70.9% of the selected peer group s reported small business loans were to businesses having revenues of $1 million or less. Revenues were either unknown or in excess of $1 million for the remaining portion of loans. D&B data indicates that 86.9% of all local businesses have revenues that do not exceed $1 million per year. Compared to these proxies for demand the bank s level of lending is considered adequate. Bank performance during both 2006 and 2008 was substantially similar. The 2000 census data indicates that 24.9% and 15.8% of area households are in low- and moderateincome, respectively. Although the bank s level of lending to low-income borrowers lags the demographic proxy, the level of lending to moderate-income borrowers exceeds the demographic proxy. Bank performance in both 2006 and 2008 was substantially similar, and overall, the bank s level of lending is considered good. The overall distribution by borrower income and business revenue within this assessment area is considered adequate given the institution s size, branch locations, and the effective demand for credit. Community Development Loans: During the evaluation period, the bank extended a relatively high level of community development loans by originating four such loans totaling approximately $3.1 million in the assessment area. The loans provided funding for organizations whose purposes were primarily for economic development or providing services and opportunities for low- or moderate-income individuals. INVESTMENT TEST The institution has two investments totaling approximately $2.4 million which benefit the West Virginia statewide area, including this assessment area. UBI also has equity investments totaling $20,000 in a local CDC fund whose operations benefit the Wheeling MSA. Charitable donations in excess of $18,277 qualifying as community development investments have been made in this market. These donations support organizations whose operations primarily benefit low- and moderate-income people and/or areas or provide for microenterprise development. Overall, the investment test is rated low satisfactory. SERVICE TEST Distribution of Consumer Loans by Income Level of Borrower Wheeling, WV-OH MSA Consumer Loans Income Categories # % $(000s) % $ Low Moderate , Middle , Upper , Unknown 9 80 Total , Percentage's (%) are calculated on all loans where incomes are known Within the Wheeling multistate MSA, UBI s performance under the service test is rated outstanding. Systems for delivering retail banking services are readily accessible to all portions of the assessment area, including low- and moderate-income areas. Also, a relatively high level of services is provided by UBI actively participating in several community development organizations. 13

16 Retail Services: Delivery systems are readily accessible to all portions of the assessment area. Automated teller machines (ATMs) are available and, through a network, provide customers with 24-hour nationwide access. Bank-by-mail and bank-by-computer services are also offered by the institution. In addition, the institution provides customers with 24-hour telephone access to their accounts through an automated system. The institution has ten branch offices within this assessment area, of which five (50%) are located in moderate-income census tracts. The distribution of branches is excellent when considering that 1.1% and 11.4% of the assessment area s families reside in low- and moderate-income areas, respectively. Branch locations and business hours are considered convenient and meet the needs of the assessment area. No branches have been opened or closed since the previous evaluation. Community Development Services: UBI and its employees provide a relatively high level of support to various local organizations and activities whose operations directly benefit low- and moderate-income residents or encourage microenterprise development. These activities include, but are not limited to the following: Housing Authority of Wheeling, Moundsville, and Benwood Various bank employees serve on committees and as advisors to this organization that provides affordable housing programs for low-income individuals. Ohio Valley Industry and Business Development Corporation (OVIBDC) - Multibank entity that focuses on small business development initiatives. An employee is a board member. Council for Rural Housing and Development of Ohio (CRHDO) An employee is a member of this organization, which makes loans and grants to low-income households. Community Homebuyer Investment Program (CHIP) - The program facilitates the provision of housing for low- and moderate-income people. Bank employees serve this organization in many capacities, including board member, financial counselor, treasurer, education committee member, and homebuyer education instructors. YMCA of Wheeling An executive officer serves on the endowment committee, the board of directors, and treasurer of this nonprofit organization that provides free community youth programs to many low- and moderate-income children who live within the assessment area. America Saves and Ohio Valley Saves Various bank employees serve these organizations as active members. These programs are comprised of a coalition of local and national nonprofit, corporate, and government groups that are designed to assist individuals, many whom are lowand moderate-income residents, to build wealth, reduce debt, and save for goals such as home ownership and retirement. 14

17 STATE CRA RATING FOR WEST VIRGINIA 2 : Satisfactory The lending test is rated: High Satisfactory The investment test is rated: High Satisfactory The service test is rated: High Satisfactory Major factors supporting the rating include: Lending activity is consistent with available capacity, and the bank offers a broad spectrum of loan products in an effort to meet local credit needs. While performance varies by product and market area, the geographic distribution is considered good overall and the borrower distribution is considered adequate overall. Qualified investment opportunities within individual MSAs and other regional nonmetropolitan areas are somewhat limited. Opportunities that do exist tend to benefit statewide or larger regional areas. When considering available opportunities, the bank maintains a significant level of qualified investments. Delivery systems and branch locations are accessible to all segments of the assessment areas. Participation in qualified community development services promotes housing and other services to low- and moderate-income residents, as well as facilitating microenterprise development and is considered good. SCOPE OF EXAMINATION Reported HMDA and small business as well as consumer loans were analyzed to determine the geographic and borrower distribution of the bank s lending. The reported loan data are from calendar years 2006, 2007, and Farm lending was not included because of limited volume. The institution s efforts to serve its markets through qualified community development investments and services were also reviewed. A description of each of the bank s assessment areas is provided in the description of the institution presented earlier in this evaluation. When excluding activity in the Wheeling Multistate MSA, the West Virginia assessment areas account for 91.6%, 92.9%, and 87.5% of the institution s overall lending, branches, and deposit volume, respectively. Within the State of West Virginia, the Charleston MSA, Parkersburg-Marietta-Vienna MSA, and Braxton Counties assessment areas contain 66.6% of lending, 48.2% of branches, and 60.2% of deposits. Therefore, performance in the state was evaluated by applying the full-scope interagency examination procedures to those three markets. In arriving at an overall state rating, assessment areas were generally weighted based on the dollar volume of lending as well as the percentage of loans originated within the market. Hence the greatest weight was given to the Braxton Counties assessment area as it contained 21.9% of loans by dollar volume and also 38.1% of the bank s lending activity during the review period. For the remaining assessment areas subject to limited review procedures, a determination was made as to whether performance was consistent with the assigned state rating. 2 For institutions with branches in two or more states in a multistate metropolitan area, this statewide evaluation is adjusted and does not reflect performance in the parts of those states contained within the multistate metropolitan area. Refer to the multistate metropolitan area rating and discussion for the rating and evaluation of the institution s performance in that area. 15

18 DESCRIPTION OF INSTITUTION S OPERATIONS IN WEST VIRGINIA The institution operates 46 branches throughout the statewide area. Two (4.3%) offices are located in low-income geographies and eight (17.4%) are located in moderate-income areas. These 46 branch offices account for nearly $2.5 billion of the bank s total deposit base. Based on 2000 census data, the West Virginia assessment areas served by the bank have a total population of approximately 1.2 million, including 325,676 families. A majority of the families are middle- and upper-income (60.2%), while low- and moderate-income families each comprise 24.2% and 15.6% of the total, respectively. Within these assessment areas, the owner-occupancy rate is 65.7%, and 12.8% of West Virginia families live below the poverty level. The 2008 median family incomes within the MSAs range from $46,900 (Wierton-Strubenville MSA) to $97,200 (Washington MSA), while the median family income for nonmetropolitan areas equals $41,100. CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN WEST VIRGINIA LENDING TEST Overall, the statewide lending test is rated high satisfactory. As previously mentioned, of the three markets reviewed with full-scope procedures, the greatest weight was given to the performance within the Braxton Counties assessment area. Lending activity is considered good and is measured primarily by market share. Though the borrower distribution of loans is considered adequate, the geographic distribution of loans and provision of community development loans are considered good. Lending Activity: Overall, lending activity is considered good and consistent with the bank s capacity. According to both 2007 and 2006 market share data, the bank ranked fifth in HMDA lending with 4.7% and 5.3% of the market share, respectively. UBI ranked sixth in market share for small business loans with 5.6% and 6.6%, respectively, in both 2007 and Geographic and Borrower Distribution: UBI s distribution of lending is considered good. While varying by product, the geographic distribution performance was better than the borrower distribution. Performance relative to the three products evaluated was generally consistent among the full-scope market areas. When making overall conclusions, regarding performance in each assessment area, weight was given to the products primarily according to dollar volume. Within the markets reviewed, small business loans were the largest product by dollar volume, followed by HMDA and consumer loans, and, therefore, received the greatest weight. Community Development Loans: The bank has been active in originating loans that qualify as community development loans. During the evaluation period, UBI funded or renewed 91 community development loans totaling $33.4 million. The loans provided for a variety of projects including job creation, services targeted and provided to low- and moderate-income residents, and housing for low- and moderate-income people. Local opportunities are reasonably available when considering the bank s competition, bank size, bank conditions, and other area relevant factors. The institution faces no lending constraints relative to its size and business strategy. 16

19 INVESTMENT TEST The institution s level of qualified investments benefiting West Virginia is rated high satisfactory. The institution has eight investments totaling $10.2 million throughout the state. Charitable donations of $365,236 were made during the review period to organizations providing community development programs throughout West Virginia. These organizations operate within multiple geographic regions in the statewide area, including the bank s assessment areas. SERVICE TEST The statewide rating for the institution under the service test is high satisfactory. Delivery systems are accessible to all portions of the bank s market areas and to people of varying income levels. Products and services offered within the West Virginia markets evaluated using the full-scope procedures are representative of those offered by the institution overall. Additionally, the institution and its employees participate in a relatively high level of community development services. Activities include participation in numerous organizations that provide housing and other services to low- and moderateincome people and microenterprise development. Examples of these organizations include, but are not limited to the West Virginia State Habitat for Humanity, West Virginia Interagency Housing Council, West Virginia Housing Development Fund, West Virginia Roundtable, West Virginia Jobs Investment Trust, and West Virginia Affordable Housing Partnership. In addition, bank staff demonstrates a good level of responsiveness to community development needs by actively assisting area organizations in completing applications for various grant programs provided by the FHLBP. These programs provide funding for affordable housing projects and microenterprise development, such as small business incubators, throughout several states, including West Virginia. During the evaluation period, 23 such applications were completed and submitted with bank assistance. 17

20 METROPOLITAN AREAS (For metropolitan areas with some or all assessment areas reviewed using full-scope review) DESCRIPTION OF INSTITUTION S OPERATIONS IN THE CHARLESTON, WEST VIRGINIA MSA The Charleston MSA assessment area includes all of Boone, Kanawha, and Putnam Counties, West Virginia. According to 2000 census data, the assessment area has a population of 277,197. Housing is generally considered affordable when comparing the 2000 assessment area median housing value ($76,200) to the 2000 assessment area median family income of $42,728. The 2008 median family income is $48,500. The overall family poverty rate of the assessment area (11.1%) is less than the West Virginia statewide rate (13.9%). The following table provides demographic data for the assessment area by the income level of families and households, and distribution of local businesses. Assessment Area Demographics Charleston, WV MSA Income Categories* Tract Distribution Families by Tract Families < Poverty as a Families by Tract % of Families by Family Income Low Moderate Middle Upper NA Total Low Moderate Middle Upper NA Total # % # % # % # % , , , , , , , , , , , , Owner Occupied Units by Households Tract HHs by Tract HHs < Poverty by Tract HHs by HH Income # % # % # % # % , , , , , , , , , , , , , , , , , Businesses by Tract and Revenue Size Total Businesses by Tract Less than or = $1 Million Over $1 Million Revenue not Reported Low Moderate Middle Upper NA Total # % # % # % # % 1, , , , , , , , , Percentage of Total Businesses: *NA Tracts are tracts without household or family income as applicable. 18