National Bank Holdings Corporation (NBHC): PESTLE Analysis [Nov-2025 Updated]

You need a precise read on the external forces shaping National Bank Holdings Corporation (NBHC)'s 2025 outlook, and the picture is one of high-stakes balance. While the high-for-longer Federal Reserve rates are keeping their Net Interest Margin (NIM) strong-potentially over 3.75% and driving an estimated $120 million in net income-NBHC is defintely facing a dual squeeze from increased Basel III Endgame capital rules and a stressed Commercial Real Estate (CRE) market. The strategic challenge isn't just economic; it's about managing regulatory fatigue while keeping pace with FinTechs and significant core system modernization costs. Let's break down the Political, Economic, Social, Technological, Legal, and Environmental factors that will determine their next move.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Political factors

The political landscape for National Bank Holdings Corporation (NBHC) in 2025 is defined by a push-pull dynamic: a strong regulatory impulse for higher capital buffers is being met with a political shift toward deregulation and industry-friendly review. The core risk is the uncertainty surrounding the final version of key financial rules, which directly impacts capital planning and revenue streams.

Basel III Endgame rules increase capital requirements for regional banks

The most significant near-term political risk is the evolving implementation of the Basel III Endgame (international standards for bank capital). The original proposal, set to begin phase-in on July 1, 2025, targeted banks with $100 billion or more in assets. While National Bank Holdings Corporation (NBHC) is below this threshold, reporting $10.15 billion in total assets as of September 2025, the political rhetoric and regulatory momentum are pushing the entire regional bank sector toward higher capital expectations.

The initial proposal indicated that regional banks (non-Global Systemically Important Banks, or GSIBs) would face an approximate 10% increase in capital requirements. This would force banks to hold more Common Equity Tier 1 (CET1) capital, effectively reducing the capital available for lending, share buybacks, and dividends. However, following strong industry opposition and a shift in the regulatory environment, the Federal Reserve announced in June 2025 that it is reviewing the rules, with a revised, less burdensome proposal expected by the end of 2025 or early 2026. This creates a regulatory pause, but the underlying pressure to increase capital is defintely still there.

Here's the quick math: NBHC's Common Equity Tier 1 capital ratio was 14.69% as of September 30, 2025. An unmitigated 10% rise in risk-weighted assets from the initial Basel III Endgame proposal would have put pressure on this ratio, potentially forcing a reduction in the $8.8 million in share buybacks executed in the third quarter of 2025.

Heightened scrutiny from the Consumer Financial Protection Bureau (CFPB) on overdraft fees

The political battle over bank fees has created significant regulatory volatility. The Consumer Financial Protection Bureau (CFPB) finalized a rule in December 2024 aimed at capping overdraft fees at $5 for banks with $10 billion or more in assets, with an effective date of October 2025.

To be fair, this specific threat to fee income was removed in April 2025 when Congress, using the Congressional Review Act (CRA), overturned the CFPB's overdraft rule.

Still, the underlying political and regulatory scrutiny remains intense. The CFPB continues to use its enforcement authority to target what it deems 'junk fees,' having previously ordered financial institutions to pay roughly $491 million for past overdraft-related issues. Since National Bank Holdings Corporation (NBHC) crossed the $10 billion asset threshold (reaching $10.15 billion in Q3 2025), it falls squarely under the CFPB's supervisory authority and must maintain robust compliance to mitigate enforcement risk.

Bipartisan pressure for increased regional bank stress testing post-2023 failures

Following the 2023 bank failures, there is bipartisan political pressure to increase the rigor and scope of stress testing for regional banks. The goal is to prevent rapid liquidity crises. The Federal Reserve's 2025 stress test results, released in July 2025, showed that all 22 participating banks passed, but the scenario itself was notably milder, with a Real GDP contraction eased to -7.8% from -8.5% in the 2024 scenario.

The political response is driving a focus on specific, high-risk areas. The proposed 2026 stress test scenarios, for which the Fed is seeking public comment (a move toward greater transparency), prominently feature a sharp decline in Commercial Real Estate (CRE) prices. Given that regional banks like NBHC have significant CRE exposure, this political and regulatory focus translates into a clear, near-term risk. Your action here is clear: stress-test your CRE portfolio against a severe decline scenario now.

The results of these tests are crucial because they directly determine a bank's Stress Capital Buffer (SCB), which is an institution-specific add-on to the minimum capital requirement.

Tax policy uncertainty affecting corporate tax rates and municipal bond holdings

Tax policy uncertainty, particularly around the 2025 expiration of certain provisions of the Tax Cuts and Jobs Act, is a key political factor. The current federal corporate tax rate is 21%. While there is political discussion about a potential reduction, the current expectation from some analysts is that the rate will remain at 21% or possibly move lower under the new administration.

This uncertainty directly impacts the value of a bank's municipal bond holdings. Municipal bonds (munis) are attractive to banks because the interest income is generally exempt from federal income tax. Any political move to curtail or eliminate this tax exemption would reduce the value proposition of these assets for banks like National Bank Holdings Corporation.

The municipal bond market is seeing significant activity, with underwriters projecting $500 billion in new supply on average for 2025. The yield-to-worst (YTW) for the Bloomberg Municipal Bond Index was around 4% as of June 2025. Bank demand for munis, however, is expected to remain constrained while the corporate tax rate holds at 21%.

The table below summarizes the political factors and their direct, quantifiable impact on the regional banking sector in 2025.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Economic factors

The economic environment in 2025 presents National Bank Holdings Corporation (NBHC) with a dual reality: strong profitability from interest rates is tempered by slowing growth in your core markets and persistent cost pressures. You are seeing the benefit of a high-rate environment, but you must be defintely proactive in managing loan demand risk and operational costs.

High-for-longer Federal Reserve interest rates keep Net Interest Margin (NIM) strong

The Federal Reserve's strategy has been a net positive for your core profitability, keeping the Net Interest Margin (NIM) at a high level. For Q3 2025, your fully taxable equivalent NIM stood at a strong 3.98%. Management projects this stability to continue, forecasting the NIM to remain in the mid-3.9% range for the remainder of 2025. This resilience is primarily due to the disciplined management of deposit costs, which are expected to decrease following recent and anticipated Fed rate cuts. This is the single biggest factor supporting your earnings right now.

Here's the quick math on your interest-related performance:

Slowing economic growth in core markets (Colorado, Kansas) dampening commercial loan demand

While the overall US economy has been resilient, your key markets are showing clear signs of deceleration, which directly impacts commercial loan demand. Colorado's GDP growth, for example, is forecast to slow to about 1.5% for 2025, a significant downshift. Job growth is also cooling, projected at 1.2% for Colorado in 2025, which translates to an estimated 36,700 new jobs. This slower pace is why your total loans were $7.4 billion at the end of Q3 2025, a slight decrease from the prior year's $7.5 billion.

You are counteracting this with relationship-driven lending, still projecting annualized mid-single-digit loan growth for the second half of 2025. But the headwind is real. It means you must work harder for every new loan, especially in a market where your Q3 commercial loan fundings were $288.0 million out of a total of $421.2 million.

Commercial Real Estate (CRE) market valuations under stress, requiring higher loan loss provisions

The Commercial Real Estate market remains a major point of stress for the entire banking sector, with an estimated $1.4 trillion in CRE loans maturing between 2023 and 2025 across the industry. For NBHC, this risk is being actively managed. Management has noted strategic portfolio reductions in higher-risk industries, including CRE. What this estimate hides is your strong credit quality metrics:

• Allowance for Credit Losses (ACL) to Total Loans was 1.19% at September 30, 2025, down from 1.22% at the end of 2024.
• The company actually recorded a $1.5 million provision release in Q3 2025, primarily due to the recovery of a previously charged-off credit.

The market stress is undeniable, but your current provisioning levels and recent credit performance suggest you are ahead of the curve in de-risking the portfolio.

Inflationary pressures increasing operational costs, defintely impacting wage growth

Inflationary pressures, particularly in the labor market, continue to push operational costs higher. For instance, Colorado's average salary and wage growth is expected to normalize at 4.6% in 2025, which is a significant pressure point for personnel expenses. The Denver metro area's inflation rate was still 1.9% over the 12 months leading to March 2025, keeping general non-interest expenses elevated.

To combat this, you have taken decisive action:

• An expense reduction plan was executed in Q2 2025.
• The plan targets a 10% reduction in the core bank annualized personnel expense run rate.
• This is estimated to generate approximately $15 million in annual savings.
• Core noninterest expense for the second half of 2025 is projected to be in the range of $126 million to $128 million, reflecting the ongoing investment in the 2UniFi platform alongside these cost-cutting efforts.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Social factors

The social factors impacting National Bank Holdings Corporation (NBHC) in 2025 center on the accelerating demand for digital convenience, the structural risks in Commercial Real Estate (CRE) driven by hybrid work, and the intense competition for specialized talent in its core markets like Denver.

Growing customer expectation for seamless, personalized digital banking experiences

You know that clients, especially younger generations, are demanding a fully digital, personalized experience, and this is no longer optional. Across the U.S., digital banking adoption is robust, with over 83% of adults using these services in 2025. This shift means that the bank's physical network of over 90 banking centers [cite: 6, from search 2] must be seamlessly integrated with its digital channels.

NBHC is responding with significant investment. The launch of the 2UniFi platform is key, aiming to create a financial ecosystem for business owners. [cite: 7, from search 2] The success of their Cambr deposit platform, which saw a 47% year-over-year deposit growth in 2024, demonstrates a clear return on these technology investments. [cite: 7, from search 2] The risk here is that if the personalization aspect of 2UniFi doesn't defintely meet expectations, clients will quickly migrate to fintechs or larger national banks.

Here's the quick math on the digital deposit trend:

• US Digital Banking Users (2025): Over 208 million [cite: 10, from search 2]
• Global Digital Banking Market Value (2025): $20.7 billion [cite: 10, from search 2]
• NBHC's Digital Deposit Platform Growth (2024 YoY): 47% in platform deposits [cite: 7, from search 2]

Demographic shift to hybrid work models impacting demand for downtown office CRE loans

The long-term shift to hybrid work continues to bifurcate the Commercial Real Estate (CRE) market, but NBHC's exposure to the riskiest segment-non-owner occupied office properties-is remarkably low. This is a significant de-risking factor for the bank. Non-owner occupied CRE loans represented 23.0% of total loans at June 30, 2025, which is manageable.

More critically, the exposure to non-owner occupied office properties specifically was only 1.3% of total loans as of June 30, 2025. This low concentration shields the bank from the high average office vacancy rate of 20.1% seen across top U.S. metro areas. [cite: 20, from search 2] The overall CRE market is seeing a rebound in lending, with depositories increasing originations by 52% year-over-year in Q3 2025, but NBHC's strategy is clearly focused on diversification rather than large-scale office lending.

Increased focus on local community impact and Environmental, Social, and Governance (ESG) initiatives

Stakeholders, from investors to local clients, are increasingly scrutinizing a bank's social license to operate. NBHC addresses the 'S' in ESG through tangible community investment and a stated commitment to improving the communities they serve. [cite: 4, from search 3] The bank's annual 'Do More' events have generated over $1.8 million in charitable contributions, and all associates receive paid time-off to volunteer. [cite: 10, from search 1]

From a lending perspective, while NBHC doesn't publish a specific social lending target, the industry trend shows that social indicators, like diversity and employee training, are a stable focus, appearing in 42% of all sustainable-linked loans (SLLs) with disclosed KPIs in 2024. [cite: 14, from search 2] For NBHC, maintaining this high level of local community engagement is a key defense against the public perception risks that have plagued larger national institutions.

Competition for top talent in technology and risk management roles in Denver

Operating out of Denver, a major tech hub, means NBHC faces fierce competition for the specialized talent needed to run its digital platforms and manage complex credit risk. The battle for technologists, data scientists, and risk managers is driving up compensation across the board. The Finance & Insurance sector nationally is projecting an average salary increase of 3.7% for 2025. [cite: 5, from search 2]

For banks specifically, the average projected salary increase for the 2025 Merit Labor Budget is slightly higher at 3.8%. [cite: 11, from search 2] This pressure is amplified in the Denver market, where the private sector must outpace state compensation, which is estimated to be 6.8% below the market average for FY 2025-26. [cite: 13, from search 2] The cost of talent acquisition and retention in this competitive environment will be a constant drag on the bank's efficiency ratio, which stood at 60.2% in Q2 2025. [cite: 4, from search 2] You have to pay a premium for specialized skills in this market.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Technological factors

Significant capital expenditure required for core system modernization and cloud migration

You've got to spend money to make money, and in banking today, that means a massive investment in core technology. For National Bank Holdings Corporation, the push toward modernizing its centralized core technology platform is a substantial, non-negotiable capital expenditure (CapEx) item. This modernization is essential to support their growth markets across the West, Midwest, and Southwest.

The company's recent launch of its 2UniFi digital platform is a concrete example of this investment. While the total CapEx is not explicitly public, the financial impact is clear: the company reported a non-interest expense of $67.2 million in the third quarter of 2025, up from $62.9 million in the second quarter. This increase included a rise in depreciation expense directly resulting from the 2UniFi platform launch, which is how a large technology investment hits the income statement over time. This is a multi-year project, not a one-time cost.

Here's the quick math on the expense trend, showing the immediate operational cost of this tech rollout:

Adoption of Artificial Intelligence (AI) and machine learning for enhanced fraud detection

The fight against financial crime is becoming an AI-versus-AI battle. National Bank Holdings Corporation must adopt machine learning (ML) for real-time risk scoring and anomaly detection, especially given the rising sophistication of fraud. Industry-wide, the US AI-driven fraud detection market is projected to reach $15.6 billion in 2025, showing this is a necessary area of spending. Honestly, if you're not using AI to fight fraud, you're losing money.

The need for this investment was starkly highlighted in the company's Q1 2025 results, where a single loan charge-off related to suspected fraud drove a significant increase in the provision for credit losses, totaling $10.2 million. This one event shows how quickly a lack of cutting-edge fraud technology can hit the bottom line. The industry is already using advanced ML for fraud detection, with 79% of financial institutions leveraging it. NBHC's commitment to investing in technology must prioritize this area to mitigate such large, single-event losses.

Competition from non-bank FinTechs eroding market share in payments and small business lending

The biggest threat to a community bank like National Bank Holdings Corporation isn't another bank; it's the FinTech platforms that offer faster, simpler digital experiences. These non-bank competitors are particularly aggressive in the small- to medium-sized business (SMB) and payments space, which is a core focus for NBHC.

The market shift is undeniable in 2025: FinTech lenders now account for more than half of small-business loan originations in developed markets. Specifically, FinTechs are capturing about 28% of new originations in the small business lending market, eroding the historical dominance of traditional banks. This competition forces banks to dramatically increase their own technology spending just to keep pace.

• FinTechs offer speed: funding often approved in 24 to 48 hours.
• FinTechs capture market share: 28% of new small business loan originations.
• Banks must respond: average financial institutions spend 8-12% of operating expenses on technology upgrades.

Cybersecurity risks demanding continuous investment to protect customer data and infrastructure

Cybersecurity is no longer an IT cost; it's a core operational risk and a trust factor. The sophisticated, often AI-enabled, nature of cyber threats means continuous, non-discretionary investment. Over three-quarters of bank CEOs and senior executives surveyed in 2025 named cybersecurity as a top risk for their institution.

For National Bank Holdings Corporation, this means dedicating a significant portion of their non-interest expense to fortifying their systems, especially as they integrate new platforms like 2UniFi and manage a centralized core technology platform across multiple states. The challenge is compounded by the fact that many banks still lack a complete, risk-tiered inventory of third-party vendors, which leaves open doors for attackers. Only 32% of vendors receive ongoing monitoring in the industry, which is a defintely weak spot. The investment must cover:

• Securing cloud infrastructure and legacy on-premises core systems.
• Implementing advanced threat intelligence to counter AI-enabled phishing and malware.
• Continuous staff training, as most banks focus on education to combat fraud.

The cost of not investing is a loss of customer trust and a direct financial hit, as seen with the $10.2 million fraud-related charge-off in Q1 2025. This single event underscores the critical need for robust, proactive security measures.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Legal factors

The legal landscape for National Bank Holdings Corporation in 2025 is defined by a shift from broad federal regulatory expansion to targeted enforcement and complex state-level data privacy mandates. The immediate compliance costs are driven by modernizing anti-money laundering (AML) systems and adapting to new Colorado-specific data rules, while a significant portion of litigation risk is tied to credit quality in a high-rate environment.

Stricter enforcement of Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations

Regulators are moving from issuing numerous small fines to imposing fewer, but far more severe, penalties for systemic failures in Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance. This trend means that while National Bank Holdings Corporation may not face the massive, multi-billion-dollar fines seen against money-center banks, the regulatory expectation for a regional bank's controls is higher than ever.

For context, FinCEN's record-setting civil monetary penalty of $1.3 billion against TD Bank in October 2024 for chronic AML failures set a new benchmark for regulatory consequences. More relevantly, 2024 enforcement actions showed that 54% of BSA/AML actions against banks were issued to institutions with asset sizes under $1 billion, a clear signal that regional and community banks are a focus. National Bank Holdings Corporation must invest in advanced technology and staffing to ensure its transaction monitoring and suspicious activity reporting (SAR) processes are effective and risk-based.

Here's the quick math on the risk: a smaller institution facing an enforcement action often incurs multi-year independent monitorships and restrictions on growth, which can cost millions in remediation and lost business opportunity, far exceeding the initial fine. This is a clear, existential risk for compliance failure.

State-level data privacy laws (e.g., Colorado Privacy Act) increasing compliance costs

Operating out of Colorado, National Bank Holdings Corporation faces a unique set of compliance challenges from the Colorado Privacy Act (CPA). While banks are generally exempt from the main CPA provisions because they are governed by the federal Gramm-Leach-Bliley Act (GLBA), key amendments taking effect in 2025 have a much broader scope, applying to entities regardless of their processing volume thresholds.

The two critical amendments driving compliance costs for National Bank Holdings Corporation are:

• Biometric Data: Effective July 1, 2025, requiring a written policy, affirmative consent, and a retention schedule for biometric identifiers (like fingerprints or retina scans) of Colorado residents, including employees.
• Minors' Data: Effective October 1, 2025, imposing new obligations on companies that offer online products or services intentionally targeted to Colorado residents under 18.

This means the bank must now separate its data privacy compliance program from its GLBA framework to address these specific state-level requirements, particularly for employee onboarding and any customer-facing digital services that use biometric authentication.

Ongoing litigation risk related to legacy loan portfolios and servicing practices

Litigation risk in 2025 is highly concentrated in credit quality and consumer protection practices. The persistent high-interest-rate environment has strained certain loan portfolios, increasing the likelihood of defaults and subsequent litigation.

National Bank Holdings Corporation's own Q1 2025 financial results highlight this risk: the company reported a significant provision expense of $10.2 million for credit losses, primarily driven by a single loan charge-off related to suspected fraud. This single event demonstrates the outsized impact that loan-related litigation or fraud can have on quarterly earnings.

Beyond credit risk, the bank faces ongoing consumer litigation trends. Fair Credit Reporting Act (FCRA) cases, relating to the accuracy of credit reporting, were up 12.6 percent from January through May 2025 compared to the prior year. Additionally, while the pace of class action filings for overdraft and non-sufficient funds (NSF) fees has slowed, the underlying legal theories persist, requiring constant review of fee disclosure and servicing practices.

New Securities and Exchange Commission (SEC) rules on climate-related financial disclosures

The regulatory burden from the New Securities and Exchange Commission (SEC) climate-related financial disclosures has been dramatically reduced for National Bank Holdings Corporation in 2025. Following legal challenges and a change in administration policy, the SEC voted in March 2025 to end its defense of the rule, effectively pausing its enforcement.

What this estimate hides is that while the federal mandate is on hold, the underlying market pressure remains. Large institutional investors, like BlackRock, still demand environmental, social, and governance (ESG) data. Plus, state laws, such as California's, require large companies to disclose their emissions, creating a patchwork of compliance for a bank with multi-state operations or lending exposure to companies operating in those states. So, the cost shifts from mandatory SEC compliance to voluntary-but-necessary market disclosure to maintain investor confidence and access to capital.

Finance: Draft a memo by Friday outlining the specific compliance steps needed for the Colorado Privacy Act's Biometric Data amendment, effective July 1, 2025.

National Bank Holdings Corporation (NBHC) - PESTLE Analysis: Environmental factors

Growing shareholder and public pressure for transparency on financed emissions

The regulatory environment for climate disclosure has seen a major reversal in late 2025, but honestly, shareholder pressure hasn't eased up. While the Federal Reserve, FDIC, and OCC rescinded the Principles for Climate-Related Financial Risk Management in October 2025, that guidance only applied to institutions over $100 billion in assets anyway. For National Bank Holdings Corporation (NBHC), the pressure is coming from investors who still need to understand your exposure, especially your Scope 3 (financed emissions) footprint.

The market is setting the standard now that the regulators stepped back. Major peers like U.S. Bank are already aligning their disclosures with the Task Force on Climate-Related Financial Disclosures (TCFD) and committing to measuring financed emissions using the Partnership for Carbon Accounting Financials (PCAF) standards. Your institutional investors will defintely look for similar commitments, even if they are voluntary. Without a clear federal mandate, the onus is on NBHC to provide transparency to avoid being flagged as an outlier in the regional bank space.

This is simply a risk management issue now, not just a compliance one.

Demand for green lending products and sustainability-linked loans from corporate clients

The demand for green lending products-loans tied to specific environmental improvements-is a clear opportunity in the Rocky Mountain and Midwest markets where NBHC operates. Corporate clients, particularly those in commercial real estate and middle-market manufacturing, are looking for sustainability-linked loans (SLLs) to fund energy efficiency upgrades or renewable energy projects.

This is an active market, evidenced by the fact that U.S. Green Banks (state and local entities) collectively mobilized $10.6 billion in public-private capital for clean energy projects in 2023 alone, showing significant underlying demand that traditional banks can help finance. Larger regional banks are targeting this; for example, U.S. Bank has a goal to provide $50 billion in environmental financing by 2030. NBHC can carve out a profitable niche by focusing on smaller, localized projects that the mega-banks overlook.

Here is a quick look at the market opportunity in the US regional bank space:

• Tax Equity Investments: Finance solar and wind developers.
• Construction Loans: Fund new, energy-efficient commercial buildings.
• SLLs for Agriculture: Offer better loan terms for farmers adopting drought-resistant practices in the Kansas City region.

Physical climate risks (e.g., drought, severe weather) impacting property collateral values in the Midwest

Physical climate risk is a direct threat to the collateral that underpins NBHC's loan book, especially across its footprint in the Midwest (Kansas City), Colorado, and the Southwest states. The risk is no longer theoretical; it's showing up in insurance costs and property valuations.

Nationally, the exposure is staggering: approximately 6.1% of homes in the US, valued at nearly $3.4 trillion, face severe or extreme flood risk in 2025. Furthermore, climate-related disasters could trigger up to $1.2 billion in mortgage-related losses in 2025 alone. When insurance premiums skyrocket or coverage is pulled-a growing trend in high-risk areas-the borrower's default risk rises and the collateral value drops.

For NBHC, this means a closer look at your commercial real estate and residential portfolios in flood-prone areas of Kansas and Missouri, and wildfire-prone areas of Colorado and Utah, is essential.

Mandatory reporting frameworks pushing banks to assess and disclose climate-related financial risks

The federal regulatory picture for climate risk is currently fragmented, but the core expectation remains. While the OCC, Federal Reserve, and FDIC rescinded their joint climate-related financial risk principles in October 2025, they were clear that existing 'safety and soundness' standards still require all institutions to manage all material risks, including emerging risks. Since NBHC is below the $100 billion asset threshold, the rescinded principles did not directly apply, but the market's focus on risk management is unchanged.

The Securities and Exchange Commission (SEC) climate-reporting rule remains stayed due to litigation, so no federal securities disclosure mandate is in effect as of late 2025. However, the lack of federal rules is simply shifting the focus to state-level action, like California's SB 261, which requires large financial institutions to disclose climate-related risks. This patchwork of state and investor demands means NBHC cannot ignore the risk assessment process.

The core action here is to integrate climate-related risks into your existing Enterprise Risk Management (ERM) framework, not wait for a new regulation.

Next Step & Owner: Risk Management: Complete a portfolio-level scenario analysis by Q1 2026, focusing on the impact of a 10-year drought scenario on agricultural and residential collateral in the Colorado and Kansas loan books.