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Richemont

cfr · NYSE Financial Services
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Industry Banks - Regional
Employees 1001-5000
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FY2019 Annual Report · Richemont
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F I N A N C I A L   H I G H L I G H T S
F I N A N C I A L   H I G H L I G H T S

F I N A N C I A L   H I G H L I G H T S
F I N A N C I A L   H I G H L I G H T S
F I N A N C I A L   H I G H L I G H T S

2019
2019
2019
2019
2019

D O L L A R S   I N   T H O U S A N D S ,   E X C E P T   P E R - S H A R E   A M O U N T S
D O L L A R S   I N   T H O U S A N D S ,   E X C E P T   P E R - S H A R E   A M O U N T S

D O L L A R S   I N   T H O U S A N D S ,   E X C E P T   P E R - S H A R E   A M O U N T S
D O L L A R S   I N   T H O U S A N D S ,   E X C E P T   P E R - S H A R E   A M O U N T S
D O L L A R S   I N   T H O U S A N D S ,   E X C E P T   P E R - S H A R E   A M O U N T S

N E T   I N CO M E   AVA I L A B L E 
N E T   I N CO M E   AVA I L A B L E 
N E T   I N CO M E   AVA I L A B L E 
N E T   I N CO M E   AVA I L A B L E 
N E T   I N CO M E   AVA I L A B L E 
TO   CO M M O N   S H A R E H O L D E R S
TO   CO M M O N   S H A R E H O L D E R S
TO   CO M M O N   S H A R E H O L D E R S
TO   CO M M O N   S H A R E H O L D E R S
TO   CO M M O N   S H A R E H O L D E R S

P E R   CO M M O N   S H A R E   DATA
P E R   CO M M O N   S H A R E   DATA

P E R   CO M M O N   S H A R E   DATA
P E R   CO M M O N   S H A R E   DATA
P E R   CO M M O N   S H A R E   DATA

Earnings per Common Share – Basic
Earnings per Common Share – Basic

Earnings per Common Share – Basic
Earnings per Common Share – Basic
Earnings per Common Share – Basic

Earnings per Common Share – Diluted
Earnings per Common Share – Diluted

Earnings per Common Share – Diluted
Earnings per Common Share – Diluted
Earnings per Common Share – Diluted

Cash Dividends
Cash Dividends

Cash Dividends
Cash Dividends
Cash Dividends

Book Value
Book Value

Book Value
Book Value
Book Value

P E R F O R M A N C E   R AT I O S
P E R F O R M A N C E   R AT I O S

P E R F O R M A N C E   R AT I O S
P E R F O R M A N C E   R AT I O S
P E R F O R M A N C E   R AT I O S

Return on Average Assets
Return on Average Assets

Return on Average Assets
Return on Average Assets
Return on Average Assets

Return on Average Common Equity
Return on Average Common Equity

Return on Average Common Equity
Return on Average Common Equity
Return on Average Common Equity

Net Interest Margin
Net Interest Margin

Net Interest Margin
Net Interest Margin
Net Interest Margin

Dividend Payout Ratio on Common Shares
Dividend Payout Ratio on Common Shares

Dividend Payout Ratio on Common Shares
Dividend Payout Ratio on Common Shares
Dividend Payout Ratio on Common Shares

Y E A R- E N D   B A L A N C E   S H E E T   DATA
Y E A R- E N D   B A L A N C E   S H E E T   DATA

Y E A R- E N D   B A L A N C E   S H E E T   DATA
Y E A R- E N D   B A L A N C E   S H E E T   DATA
Y E A R- E N D   B A L A N C E   S H E E T   DATA

Loans
Loans

Loans
Loans
Loans

Securities
Securities

Securities
Securities
Securities

Earning Assets
Earning Assets

Earning Assets
Earning Assets
Earning Assets

Total Assets
Total Assets

Total Assets
Total Assets
Total Assets

Non-interest-bearing Demand Deposits
Non-interest-bearing Demand Deposits

Non-interest-bearing Demand Deposits
Non-interest-bearing Demand Deposits
Non-interest-bearing Demand Deposits

Interest-bearing Demand Deposits
Interest-bearing Demand Deposits

Interest-bearing Demand Deposits
Interest-bearing Demand Deposits
Interest-bearing Demand Deposits

Total Deposits
Total Deposits

Total Deposits
Total Deposits
Total Deposits

Long-term Debt and Other Borrowings
Long-term Debt and Other Borrowings

Long-term Debt and Other Borrowings
Long-term Debt and Other Borrowings
Long-term Debt and Other Borrowings

Shareholders’ Equity
Shareholders’ Equity

Shareholders’ Equity
Shareholders’ Equity
Shareholders’ Equity

2019
2019

2019
2019
2019

2018
2018

2018
2018
2018

$ 435,536
$ 435,536

$ 435,536
$ 435,536
$ 435,536

$ 446,855
$ 446,855

$ 446,855
$ 446,855
$ 446,855

$ 6.89
$ 6.89

$ 6.89
$ 6.89
$ 6.89

6.84
6.84

6.84
6.84
6.84

2.80
2.80

2.80
2.80
2.80

60.11
60.11

60.11
60.11
60.11

1.36
1.36

1.36
1.36
1.36
%
%

%
%
%

12.24
12.24

12.24
12.24
12.24

3.75
3.75

3.75
3.75
3.75

40.64
40.64

40.64
40.64
40.64

$ 6.97
$ 6.97

$ 6.97
$ 6.97
$ 6.97

6.90
6.90

6.90
6.90
6.90

2.58
2.58

2.58
2.58
2.58

51.19
51.19

51.19
51.19
51.19

1.44
1.44

1.44
1.44
1.44
%
%

%
%
%

14.23
14.23

14.23
14.23
14.23

3.64
3.64

3.64
3.64
3.64

37.03
37.03

37.03
37.03
37.03

$ 14,750,332
$ 14,750,332

$ 14,750,332
$ 14,750,332
$ 14,750,332

$ 14,099,733
$ 14,099,733

$ 14,099,733
$ 14,099,733
$ 14,099,733

13,323,894
13,323,894

13,323,894
13,323,894
13,323,894

12,517,464
12,517,464

12,517,464
12,517,464
12,517,464

31,280,550
31,280,550

31,280,550
31,280,550
31,280,550

29,894,185
29,894,185

29,894,185
29,894,185
29,894,185

34,027,428
34,027,428

34,027,428
34,027,428
34,027,428

32,292,966
32,292,966

32,292,966
32,292,966
32,292,966

10,873,629
10,873,629

10,873,629
10,873,629
10,873,629

10,997,494
10,997,494

10,997,494
10,997,494
10,997,494

16,765,935
16,765,935

16,765,935
16,765,935
16,765,935

16,151,710
16,151,710

16,151,710
16,151,710
16,151,710

27,639,564
27,639,564

27,639,564
27,639,564
27,639,564

27,149,204
27,149,204

27,149,204
27,149,204
27,149,204

235,164
235,164

235,164
235,164
235,164

234,950
234,950

234,950
234,950
234,950

3,911,668
3,911,668

3,911,668
3,911,668
3,911,668

3,368,917
3,368,917

3,368,917
3,368,917
3,368,917

T O   O U R   S H A R E H O L D E R S :

A fter  three  years  of  significant  growth, 

This  decline  was  primarily  the  result  of  two 

earnings per share dropped slightly in 2019. 

factors:  long-term  investments  in  our  future  and 

by  25,  almost  doubling  our  physical  presence  in 

that market. We have communicated this strategy 

broadly  over  the  last  18  months,  and  it  was  a 

topic  of  discussion  in  my  previous  shareholder 

declining interest rates, both of which I’ll discuss in 

letter to you. It continues to be a subject of great 

this letter. At the same time, I like to keep in mind 

interest  to  the  investment  community  and  to  our 

that  earnings  per  share  are  up  60  percent  since 

shareholders.

2015, and I’m proud of the hard work and execution 

of our Frost Bankers.

To  review,  these  locations  are  not  put  in  place 

solely  to  serve  as  traditional  retail  transaction 

Because  of  the  natural  makeup  of  our  balance 

processors,  although  some  of  that  will  certainly 

sheet  (lots  of  floating-rate  loans  and  checking 

take place there. More importantly, they serve as 

deposits) we tend to be “asset sensitive,” meaning 

projections of our strong brand and deployments 

we  make  more  money  when  interest  rates  rise 

of  our  multiple  lines  of  business  into  dynamic 

and  less  money  when  interest  rates  decline.  The 

markets where previously we had been absent, to 

Federal  Reserve  cut  interest  rates  three  times 

the benefit of our large bank competition.

in  2019,  reducing  what  we  otherwise  would  have 

made  in  our  net  interest  income.  There  was  also 

These lines of business include:

a  decline  in  LIBOR,  to  which  a  large  percentage 

• Commercial Banking

of  our  loan  rates  are  tied.  The  impact  of  these 

• Consumer Banking

reductions is largely out of our control.

• Private Banking

• Frost Wealth Advisors

An  area  we  do  control,  however,  is  the  level  of 

• Frost Insurance

investments  we  make  for  the  long-term  benefit  of 

• Consumer Real Estate Lending

our company, and 2019 was impacted by several 

significant investments in this regard:

These  locations  serve  as  a  center  for  world-class 

Houston Organic Expansion

solving. Each location is headed by a Community 

We  are  currently  in  the  middle  of  our  two-year 

Leader  responsible  for  integrating  Frost  into  the 

plan  to  increase  our  branch  locations  in  Houston 

community with a boots-on-the-ground approach. 

customer  service,  advice,  education  and  problem 

C U L L E N / F R O S T   B A N K E R S ,   I N C .  P A G E  2

The  physical  presence  represented  by  well-

should  decline  consistently  as  the  new  locations 

designed  and  well-located  branches 

is  still 

march toward profitability.

important  to  many  individuals  and  especially  to 

many  small  and  mid-sized  businesses,  an  area 

I believe the return on investment of this strategy is 

right in the middle of our competitive wheelhouse. 

very attractive and, to me, the only relevant question 

Commercial  customers  currently  make  up  53 

is  whether  we  can  execute  the  steps  necessary 

percent of our deposit base and 88 percent of our 

to  bring  these  locations  to  their  projected  profit-

lending business. As I have mentioned previously, 

ability  —  which  basically  represents  an  average 

my  experience  with  requests  for  proposals  from 

level  of  historical  performance.  As  things  stand, 

small and mid-size businesses for banking services 

early  results  are  encouraging.  We  have  been 

has shown they typically include an evaluation of 

able  to  successfully  find  attractive  locations  and 

the nearest branch location.

seasoned bankers, and we are making progress on 

our business volumes. For the 10 locations opened 

However,  to  successfully  execute  a  buildout 

as of year-end: 

strategy  like  this  takes  significant  investment 

and  consumes  operating  leverage  in  the  near 

• New relationships were 146 percent of our goal

term.  In  2019,  the  first  year  of  the  buildout,  it 

• Loans were 212 percent of our goal

cost  us  16  cents  per  share,  which  by  itself  would 

• Deposits were 56 percent of our goal

have  accounted  for  our  earnings  decline  for  the 

year.  This  was  slightly  less  than  the  expected 

These  volumes  do  not  include  business  we  have 

19 cents due to some of the locations opening later 

developed 

through  bankers  whose  branches 

W E   H A V E   B E E N   A B L E   T O   S U C C E S S F U L L Y   F I N D   A T T R A C T I V E 

L O C A T I O N S   A N D   S E A S O N E D   B A N K E R S ,   A N D   W E   A R E 

M A K I N G   P R O G R E S S   O N   O U R   B U S I N E S S   V O L U M E S .

in  the  year  than  expected.  I  expect  this  impact 

have  yet  to  open,  which  would  further  increase 

to  basically  double  in  2020  as  we  roll  out  the  15 

these  levels.  The  metric  on  which  I  am  most 

remaining branches of our program and the 2019 

focused  is  new  relationships,  because  I  believe 

branches  all  experience  a  full  year  of  operations. 

it  ultimately 

takes  care  of  all 

the  others. 

That  means  2020  should  be  the  year  most 

Deposits,  while  behind  our  early  goals,  have 

negatively impacted by the expansion. This impact 

been 

improving  as  new  relationships  mature. 

A N N U A L   R E P O R T  2 0 1 9

P A G E  3

For  example,  we  were  82  percent  of  our  monthly 

New Headquarters in San Antonio

deposit growth goal for December and 127 percent 

In  the  culmination  of  a  planning  process  which 

of  our  monthly  deposit  growth  for  January.  It’s 

began  six  years  ago,  our  company  leased  space 

important to keep in mind that we are early in this 

in  the  new  Frost  Tower  —  a  building  which  has 

long-term  process,  and  we  aren’t  planting  corn, 

transformed the San Antonio skyline. This project 

we’re planting trees. However, we are committed to 

allowed  us  to  sell  $57.5  million  of  our  downtown 

executing  the  steps  that  will  lead  to  a  successful 

real  estate.  And  while  it  would  have  been  nice  to 

implementation of this strategy.

begin incurring the new lease cost in a year when 

interest  rates  were  not  declining,  the  new  tower 

I hear fairly regularly about the need to eliminate 

has  significantly  helped  us  project  our  brand  in 

“short-termism”  from  American  public  company 

our  home  market  while  providing  great  space  for 

W H I L E   W E   H A V E   G R E A T   T E C H N O L O G Y   O F F E R I N G S , 

I   B E L I E V E   O U R   S U C C E S S   H E R E   I S   P R I M A R I L Y 

T H E   R E S U L T   O F   T H E   E M P A T H E T I C   C U S T O M E R 

S E R V I C E   E X P E R I E N C E   W E   P R O V I D E .

decision  making.  That’s  what  I  believe  we’ve  done 

our  human  capital  and  significantly  improving 

here, but it doesn’t stop the market from reacting 

our customer experience. The cost to 2019 of this 

negatively  to  the  short-term  cost  while  taking  a 

move was 11 cents per share versus last year.

“show me” stance on any future benefits. However, 

we will continue to invest with our income statement 

Technology Resources

as opposed to our balance sheet, avoiding a rollup 

A third element of our long-term investing in 2019 

strategy  in  the  markets  we  already  serve.  This 

involved  increasing  our  available  resources  for 

avoids  a  dilution  of  our  brand,  culture  and  value 

information  technology  (IT).  The  31  additional 

proposition.  It  also  allows  the  benefits  produced 

hires  brought  on  included  both  legacy  IT  and 

by our strategy to flow to our current shareholders 

cybersecurity  resources,  and  more  remains  to  be 

who  have  been  with  us  as  we  built  a  great  brand 

done. We also increased the resources in our call 

capable of generating organic growth.

center  by  30  percent  during  the  year  to  improve 

C U L L E N / F R O S T   B A N K E R S ,   I N C .  P A G E  4

the  quality  of  our  execution  for  customers.  The 

great  technology  offerings,  I  believe  our  success 

total of all these focused staff additions impacted 

here  is  primarily  the  result  of  the  empathetic 

2019 performance by 6 cents per share.

customer service experience we provide.

As we enter 2020, rest assured we are focusing on 

I  want  to  recognize  our  outstanding  team  of 

efficiencies in our regular operations to provide us 

employees who are 100 percent responsible for all 

some breathing room for carrying these necessary 

the  excellent  service  experiences  our  customers 

long-term  investments  and  their  impact  on  our 

receive  and  for  the  awards  they  generate.  They 

income statement.

deliver  our  value  proposition  consistent  with  our 

core values of integrity, caring and excellence, and 

In 2019 we continued to be focused on our world- 

I thank them.

class  customer  service  levels,  winning  third-party 

recognition in several areas including:

I also want to thank our directors for their support 

and  counsel.  I  want  to  especially  recognize  the 

• Highest ranking in retail banking customer 

service  of  two  of  our  directors  who  will  be  retiring 

satisfaction in Texas from J.D. Power and 

from  the  board  this  year.  Richard  M.  Kleberg,  III 

Associates 10 years in a row

and  Horace  Wilkins,  Jr.  provided  their  insight  and 

support  to  our  company  for  27  and  23  years, 

• 29 Greenwich Associates Excellence Awards 

respectively. I sincerely thank them for their hard 

for superior service, advice and performance 

work and dedication.

to small business and middle market banking 

clients —more than any other bank nationwide

Finally,  thanks  to  you,  our  shareholders,  for  your 

continued support of this great company.

• Named “Best Bank in Texas” by Money 

magazine

• Named a “better choice” by Consumer Reports 

for people in Texas when compared to three 

big competitors

• Named one of the “Best Banks in Texas” 

by Forbes magazine

We  also  continued  to  maintain  an  outstanding 

Net  Promoter  Score,  which  increased  to  over  80 

percent  with  a  score  of  81.8.  That  score  exceeds 

many well-regarded technology brands and all our 

major banking competitors, and helps explain our 

success  with  organic  growth.  And  while  we  have 

A N N U A L   R E P O R T  2 0 1 9

P A G E  5

S I N C E R E L Y ,

P H I L L I P D.  G R E E N

Chairman and Chief Executive Officer

T H E   B O A R D   O F   D I R E C T O R S

O F   C U L L E N / F R O S T   B A N K E R S ,   I N C .   A N D   F R O S T   B A N K

Carlos Alvarez 
Chairman and Chief Executive Officer

The Gambrinus Company

Patrick B. Frost 
President

Frost Bank

Chris M. Avery
Chairman 

James Avery Craftsman, Inc.

Phillip D. Green2,3
Chairman and Chief Executive Officer

Cullen/Frost Bankers, Inc.

Cynthia J. Comparin1
Founder and Former Chief Executive Officer

David J. Haemisegger 
President

Animato Technologies Corp.

NorthPark Management Company

Charles W. Matthews4
Former General Counsel

Exxon Mobil Corporation

Ida Clement Steen5
Investments

Graham Weston6
Co-Founder and Former CEO 

and Chairman, Rackspace

Co-Founder, Weston Urban

Samuel G. Dawson
Chief Executive Officer

Pape-Dawson Engineers, Inc.

Crawford H. Edwards
General Manager, Edwards Geren, Limited

President, Cassco Land Company and 

Cassco Development Company

Karen E. Jennings 
Former Senior Executive Vice President,

Horace Wilkins, Jr.7,8
Former President Special Markets,

Advertising and Corporate Communications

Regional President

AT&T Inc.

AT&T Inc.

Richard M. Kleberg, III8
Investments

S E N I O R   O F F I C E R S

Phillip D. Green · Chairman and Chief Executive Officer, Cullen/Frost Bankers, Inc.

Annette Alonzo
Group Executive Vice President

Chief Human Resources Officer, Frost Bank

William L. Perotti
Group Executive Vice President 

Chief Credit Officer, Frost Bank

Robert A. Berman
Group Executive Vice President

Jerry Salinas
Group Executive Vice President

Research and Strategy, Frost Bank 

Chief Financial Officer, Cullen/Frost Bankers, Inc.

James L. Waters
Group Executive Vice President

General Counsel and Corporate Secretary,

Cullen/Frost Bankers, Inc.

Candace Wolfshohl
Group Executive Vice President

Culture and People Development, Frost Bank

Paul H. Bracher
President

Cullen/Frost Bankers, Inc.

Group Executive Vice President

Chief Banking Officer, Frost Bank

Patrick B. Frost
President

Frost Bank

Group Executive Vice President

Frost Wealth Advisors

President

Frost Insurance

Carol J. Severyn
Group Executive Vice President

Chief Risk Officer, Frost Bank

Jimmy Stead
Group Executive Vice President

Chief Consumer Banking and Technology Officer, 

Frost Bank

1 .   C h a i r,   A u d i t   C o m m i t t e e   —   2 .   C h a i r,   S t r a t e g i c   C o m m i t t e e   —   3 .   C h a i r,   E x e c u t i v e   C o m m i t t e e

4 .   C h a i r,   C o m p e n s a t i o n   &   B e n e f i t s   C o m m i t t e e   &   C o r p o r a t e   G o v e r n a n c e   &   N o m i n a t i n g   C o m m i t t e e

5 .   C h a i r,   We a l t h   A d v i s o r s   C o m m i t t e e   —   6 .   C h a i r,   Te c h n o l o g y   C o m m i t t e e   —   7.   C h a i r,   R i s k   C o m m i t t e e 

8 .   Te r m   e x p i r e s   a t   t h e   A p r i l   2 9 ,   2 0 2 0   m e e t i n g   a n d   w i l l   n o t   s t a n d   f o r   r e e l e c t i o n

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(cid:58)(cid:68)(cid:86)(cid:75)(cid:76)(cid:81)(cid:74)(cid:87)(cid:82)(cid:81)(cid:15)(cid:3)(cid:39)(cid:17)(cid:38)(cid:17)(cid:3)(cid:21)(cid:19)(cid:24)(cid:23)(cid:28)(cid:3)

(cid:41)(cid:50)(cid:53)(cid:48)(cid:3)(cid:20)(cid:19)(cid:16)(cid:46)(cid:3)

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DOCUMENTS INCORPORATED BY REFERENCE

Portions of the Proxy Statement for the 2020 Annual Meeting of Shareholders of Cullen/Frost Bankers, Inc. to be held on April 29, 
2020 are incorporated by reference in this Form 10-K in response to Part III, Items 10, 11, 12, 13 and 14.

CULLEN/FROST BANKERS, INC.
ANNUAL REPORT ON FORM 10-K

TABLE OF CONTENTS

PART I

Item 1.

Business

Item 1A.

Risk Factors

Item 1B.

Unresolved Staff Comments

Item 2.

Item 3.

Item 4.

PART II

Properties

Legal Proceedings

Mine Safety Disclosures

Item 5.

Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of

Item 6.

Item 7.

Equity Securities

Selected Financial Data

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Item 7A.

Quantitative and Qualitative Disclosures About Market Risk

Item 8.

Item 9.

Financial Statements and Supplementary Data

Changes in and Disagreements With Accountants on Accounting and Financial Disclosure

Item 9A.

Controls and Procedures

Item 9B.

Other Information

PART III

Item 10.

Directors, Executive Officers and Corporate Governance

Item 11.

Executive Compensation

Item 12.

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder

Matters

Item 13.

Certain Relationships and Related Transactions, and Director Independence

Item 14.

Principal Accounting Fees and Services

PART IV

Item 15.

Exhibits, Financial Statement Schedules

Item 16.

10-K Summary

SIGNATURES

Page

4

18

31

31

31

31

32

34

37

67

69

132

132

133

134

134

134

134

134

135

136

137  

3

 
 
 
 
 
 
 
 
 
 
 
ITEM 1. BUSINESS

PART I

The disclosures set forth in this item are qualified by Item 1A. Risk Factors and the section captioned “Forward-
Looking Statements and Factors that Could Affect Future Results” in Item 7. Management’s Discussion and Analysis 
of Financial Condition and Results of Operations of this report and other cautionary statements set forth elsewhere in 
this report.

The Corporation

Cullen/Frost Bankers, Inc., a Texas business corporation incorporated in 1977, is a financial holding company and 
a bank holding company headquartered in San Antonio, Texas that provides, through its subsidiaries, a broad array of 
products and services throughout numerous Texas markets. The terms “Cullen/Frost,” “the Corporation,” “we,” “us” 
and “our” mean Cullen/Frost Bankers, Inc. and its subsidiaries, when appropriate. We offer commercial and consumer 
banking services, as well as trust and investment management, insurance, brokerage, mutual funds, leasing, treasury 
management,  capital  markets  advisory  and  item  processing  services.  At  December 31,  2019,  Cullen/Frost  had 
consolidated total assets of $34.0 billion and was one of the largest independent bank holding companies headquartered 
in the State of Texas.

Our philosophy is to grow and prosper, building long-term relationships based on top quality service, high ethical 
standards, and safe, sound assets. We operate as a locally-oriented, community-based financial services organization, 
augmented by experienced, centralized support in select critical areas. Our local market orientation is reflected in our 
regional management and regional advisory boards, which are comprised of local business persons, professionals and 
other community representatives that assist our regional management in responding to local banking needs. Despite 
this local market, community-based focus, we offer many of the products available at much larger money-center financial 
institutions.

We serve a wide variety of industries including, among others, energy, manufacturing, services, construction, retail, 
telecommunications, healthcare, military and transportation. Our customer base is similarly diverse. While our loan 
portfolio  has  a  significant  concentration  of  energy-related  loans  totaling  approximately  11.2%  of  total  loans  at 
December 31, 2019, we are not dependent upon any single industry or customer.

Our operating objectives include expansion, diversification within our markets, growth of our fee-based income, 
and growth internally and through acquisitions of financial institutions, branches and financial services businesses. We 
generally seek merger or acquisition partners that are culturally similar and have experienced management and possess 
either significant market presence or have potential for improved profitability through financial management, economies 
of scale and expanded services. From time to time, we evaluate merger and acquisition opportunities and conduct due 
diligence activities related to possible transactions with other financial institutions and financial services companies. 
As a result, merger or acquisition discussions and, in some cases, negotiations may take place and future mergers or 
acquisitions involving cash, debt or equity securities may occur. Acquisitions typically involve the payment of a premium 
over book and market values, and, therefore, some dilution of our tangible book value and net income per common 
share  may  occur  in  connection  with  any  future  transaction.  Our  ability  to  engage  in  certain  merger  or  acquisition 
transactions, whether or not any regulatory approval is required, will be dependent upon our bank regulators’ views at 
the time as to the capital levels, quality of management and our overall condition and their assessment of a variety of 
other  factors.  Certain  merger  or  acquisition  transactions,  including  those  involving  the  acquisition  of  a  depository 
institution or the assumption of the deposits of any depository institution, require formal approval from various bank 
regulatory authorities, which will be subject to a variety of factors and considerations.

Although Cullen/Frost is a corporate entity, legally separate and distinct from its affiliates, bank holding companies 
such as Cullen/Frost are required to act as a source of financial strength for their subsidiary banks. The principal source 
of Cullen/Frost’s income is dividends from its subsidiaries. There are certain regulatory restrictions on the extent to 
which  these  subsidiaries  can  pay  dividends  or  otherwise  supply  funds  to  Cullen/Frost.  See  the  section  captioned 
“Supervision and Regulation” elsewhere in this item for further discussion of these matters.

Cullen/Frost’s executive offices are located at 111 W. Houston Street, San Antonio, Texas 78205, and its telephone 

number is (210) 220-4011.

4

Subsidiaries of Cullen/Frost

Frost Bank

Frost Bank, the principal operating subsidiary and sole banking subsidiary of Cullen/Frost, is a Texas-chartered bank 
primarily engaged in the business of commercial and consumer banking through approximately 142 financial centers 
across Texas in the Austin, Corpus Christi, Dallas, Fort Worth, Houston, Permian Basin, Rio Grande Valley and San 
Antonio regions. Frost Bank also operates 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 the exclusive cash-
machine provider for a convenience store chain in Texas. Frost Bank was originally chartered as a national banking 
association in 1899, but its origin can be traced to a mercantile partnership organized in 1868. At December 31, 2019, 
Frost Bank had consolidated total assets of $34.1 billion and total deposits of $27.7 billion and was one of the largest 
commercial banks headquartered in the State of Texas.

Significant services offered by Frost Bank include:

•  Commercial Banking. Frost Bank provides commercial banking services to corporations and other business clients. 
Loans are made for a wide variety of general corporate purposes, including 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.  We  also  originate 
commercial leases and offer treasury management services.

•  Consumer Services. Frost Bank provides a full range of consumer banking services, including checking accounts, 
savings programs, ATMs, overdraft facilities, installment and real estate loans, home equity loans and lines of credit, 
drive-in and night deposit services, safe deposit facilities and brokerage services.

• 

International Banking. Frost Bank provides international banking services to customers residing in or dealing with 
businesses located in Mexico. These services consist of accepting deposits (generally only in U.S. dollars), making 
loans (generally only in U.S. dollars), issuing letters of credit, handling foreign collections, transmitting funds, and 
to a limited extent, dealing in foreign exchange.

•  Correspondent Banking. Frost Bank acts as correspondent for approximately 184 financial institutions, which are 
primarily banks in Texas. These banks maintain deposits with Frost Bank, which offers them a full range of services 
including check clearing, transfer of funds, fixed income security services, and securities custody and clearance 
services.

•  Trust Services. Frost Bank provides a wide range of trust, investment, agency and custodial services for individual 
and  corporate  clients.  These  services  include  the  administration  of  estates  and  personal  trusts,  as  well  as  the 
management  of  investment  accounts  for  individuals,  employee  benefit  plans  and  charitable  foundations.  At 
December 31, 2019, the estimated fair value of trust assets was $37.8 billion, including managed assets of $16.4 
billion and custody assets of $21.4 billion.

•  Capital Markets - Fixed-Income Services. Frost Bank’s Capital Markets Division supports the transaction needs of 
fixed-income institutional investors. Services include sales and trading, new issue underwriting, money market 
trading, advisory services and securities safekeeping and clearance.

•  Global  Trade  Services.  Frost  Bank's  Global  Trade  Services  Division  supports  international  business  activities 

including foreign exchange, international letters of credit and export-import financing, among other things.

Frost Insurance Agency, Inc.

Frost Insurance Agency, Inc. is a wholly-owned subsidiary of Frost Bank that provides insurance brokerage services 
to individuals and businesses covering corporate and personal property and casualty insurance products, as well as 
group health and life insurance products.

Frost Brokerage Services, Inc.

Frost Brokerage Services, Inc. (“FBS”) is a wholly-owned subsidiary of Frost Bank that provides brokerage services 
and performs other transactions or operations related to the sale and purchase of securities of all types. FBS is registered 
as a fully disclosed introducing broker-dealer under the Securities Exchange Act of 1934 and, as such, does not hold 
any customer accounts.

5

Frost Investment Advisors, LLC

Frost Investment Advisors, LLC is a registered investment advisor and a wholly-owned subsidiary of Frost Bank 

that provides investment management services to Frost-managed mutual funds, institutions and individuals.

Frost Investment Services, LLC

Frost Investment Services, LLC is a registered investment advisor and a wholly-owned subsidiary of Frost Bank 

that provides investment management services to individuals.

Tri–Frost Corporation

Tri-Frost Corporation is a wholly-owned subsidiary of Frost Bank that primarily holds securities for investment 
purposes and the receipt of cash flows related to principal and interest on the securities until such time that the securities 
mature.

Main Plaza Corporation

Main Plaza Corporation is a wholly-owned subsidiary of Cullen/Frost that occasionally makes loans to qualified 
borrowers. Loans are funded with current cash or borrowings against internal credit lines. Main Plaza also holds severed 
mineral interests on certain oil producing properties. We receive royalties on these interests based upon production.

Cullen/Frost Capital Trust II and WNB Capital Trust I

Cullen/Frost Capital Trust II (“Trust II”) is a Delaware statutory business trust formed in 2004 for the purpose of 
issuing $120.0 million in trust preferred securities and lending the proceeds to Cullen/Frost. Cullen/Frost guarantees, 
on a limited basis, payments of distributions on the trust preferred securities and payments on redemption of the trust 
preferred securities.

WNB Capital Trust I (“WNB Trust”) is a Delaware statutory business trust formed in 2004 for the purpose of issuing 
$13.0 million in trust preferred securities and lending the proceeds to WNB Bancshares (“WNB”). Cullen/Frost, as 
WNB's successor, guarantees, on a limited basis, payments of distributions on the trust preferred securities and payments 
on redemption of the trust preferred securities.

Trust II and WNB Trust are variable interest entities for which we are not the primary beneficiary. As such, the 
accounts of Trust II and WNB Trust are not included in our consolidated financial statements. See our accounting policy 
related to consolidation in Note 1 - Summary of Significant Accounting Policies in the notes to consolidated financial 
statements included in Item 8. Financial Statements and Supplementary Data elsewhere in this report.

Although the accounts of Trust II and WNB Trust are not included in our consolidated financial statements, the 
$120.0 million in trust preferred securities issued by Trust II and the $13.0 million in trust preferred securities issued 
by WNB Trust are included in the regulatory capital of Cullen/Frost during the reported periods. See the section captioned 
“Supervision and Regulation - Capital Requirements” for a discussion of the regulatory capital treatment of our trust 
preferred securities.

Other Subsidiaries

Cullen/Frost has various other subsidiaries that are not significant to the consolidated entity.

Operating Segments

Our  operations  are  managed  along  two  reportable  operating  segments  consisting  of  Banking  and  Frost Wealth 
Advisors. See the sections captioned “Results of Segment Operations” in Item 7. Management’s Discussion and Analysis 
of  Financial  Condition  and  Results  of  Operations  and  Note 18 - Operating  Segments  in  the  notes  to  consolidated 
financial statements included in Item 8. Financial Statements and Supplementary Data elsewhere in this report.

6

Competition

There is significant competition among commercial banks in our market areas. In addition, we also compete with 
other providers of financial services, such as savings and loan associations, credit unions, consumer finance companies, 
securities firms, insurance companies, insurance agencies, commercial finance and leasing companies, full service 
brokerage firms and discount brokerage firms. Some of our competitors have greater resources and, as such, may have 
higher lending limits and may offer other services that are not provided by us. We generally compete on the basis of 
customer service and responsiveness to customer needs, available loan and deposit products, the rates of interest charged 
on loans, the rates of interest paid for funds, and the availability and pricing of trust, brokerage and insurance services.

Supervision and Regulation

Cullen/Frost, Frost Bank and most of its non-banking subsidiaries are subject to extensive regulation under federal 
and state laws. The regulatory framework is intended primarily for the protection of depositors, federal deposit insurance 
funds and the banking system as a whole and not for the protection of shareholders and creditors.

Significant elements of the laws and regulations applicable to Cullen/Frost and its subsidiaries are described below. 
The description is qualified in its entirety by reference to the full text of the statutes, regulations and policies that are 
described. Also, such statutes, regulations and policies are continually under review by Congress and state legislatures 
and federal and state regulatory agencies. A change in statutes, regulations or regulatory policies applicable to Cullen/
Frost and its subsidiaries could have a material effect on our business, financial condition or our results of operations. 

Regulatory Agencies

Cullen/Frost is a legal entity separate and distinct from Frost Bank and its other subsidiaries. As a financial holding 
company and a bank holding company, Cullen/Frost is regulated under the Bank Holding Company Act of 1956, as 
amended (“BHC Act”), and it and its subsidiaries are subject to inspection, examination and supervision by the Federal 
Reserve Board. The BHC Act provides generally for “umbrella” regulation of financial holding companies such as 
Cullen/Frost by the Federal Reserve Board, and for functional regulation of banking activities by bank regulators, 
securities activities by securities regulators, and insurance activities by insurance regulators. Cullen/Frost is also under 
the jurisdiction of the Securities and Exchange Commission (“SEC”) and is subject to the disclosure and regulatory 
requirements of the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as 
administered by the SEC. Cullen/Frost’s common stock is listed on the New York Stock Exchange (“NYSE”) under 
the trading symbol “CFR” and our 5.375% Non-Cumulative Perpetual Preferred Stock, Series A, is listed on the NYSE 
under  the  trading  symbol  “CFRpA.” Accordingly,  Cullen/Frost  is  also  subject  to  the  rules  of  the  NYSE  for  listed 
companies.

Frost Bank is a Texas state chartered bank and a member of the Federal Reserve System. Accordingly, the Texas 
Department of Banking and the Federal Reserve Board are the primary regulators of Frost Bank. Deposits at Frost 
Bank are insured by the Federal Deposit Insurance Corporation (“FDIC”) up to applicable limits.

All member banks of the Federal Reserve System, including Frost Bank, are required to hold stock in the Federal 
Reserve System's Reserve Banks in an amount equal to six percent of their capital stock and surplus (half paid to acquire 
the stock with the remainder held as a cash reserve). Member banks do not have any control over the Federal Reserve 
System as a result of owning the stock and the stock cannot be sold or traded. The annual dividend rate for member 
banks with total assets in excess of $10 billion, including Frost Bank, is tied to 10-year U.S. Treasuries with the maximum 
dividend rate capped at six percent. The total amount of stock dividends that Frost Bank received from the Federal 
Reserve totaled $688 thousand in 2019, $1.0 million in 2018 and $807 thousand in 2017.

Most of our non-bank subsidiaries also are subject to regulation by the Federal Reserve Board and other federal and 
state agencies. Frost Brokerage Services, Inc. is regulated by the SEC, the Financial Industry Regulatory Authority 
(“FINRA”) and state securities regulators. Frost Investment Advisors, LLC and Frost Investment Services, LLC are 
subject to the disclosure and regulatory requirements of the Investment Advisors Act of 1940, as administered by the 
SEC. Our insurance subsidiary is subject to regulation by applicable state insurance regulatory agencies. Other non-
bank subsidiaries are subject to both federal and state laws and regulations. Frost Bank and its affiliates are also subject 
to supervision, regulation, examination and enforcement by the Consumer Financial Protection Bureau (“CFPB”) with 
respect to consumer protection laws and regulations.

7

Bank Holding Company Activities

In general, the BHC Act limits the business of bank holding companies to banking, managing or controlling banks 
and other activities that the Federal Reserve Board has determined to be so closely related to banking as to be a proper 
incident thereto. In addition, bank holding companies that qualify and elect to be financial holding companies may 
engage in any activity, or acquire and retain the shares of a company engaged in any activity, that is either (i) financial 
in nature or incidental to such financial activity (as determined by the Federal Reserve Board in consultation with the 
Secretary of the Treasury) or (ii) complementary to a financial activity and does not pose a substantial risk to the safety 
and soundness of depository institutions or the financial system generally (as solely determined by the Federal Reserve 
Board), without prior approval of the Federal Reserve Board. Activities that are financial in nature include securities 
underwriting and dealing, insurance underwriting and making merchant banking investments.

To maintain financial holding company status, a financial holding company and all of its depository institution 
subsidiaries must be “well capitalized” and “well managed.” A depository institution subsidiary is considered to be 
“well capitalized” if it satisfies the requirements for this status discussed in the section captioned “Capital Adequacy 
and Prompt Corrective Action,” elsewhere in this item. A depository institution subsidiary is considered “well managed” 
if it received a composite rating and management rating of at least “satisfactory” in its most recent examination. A 
financial  holding  company’s  status  will  also  depend  upon  it  maintaining  its  status  as  “well  capitalized”  and  “well 
managed’ under applicable Federal Reserve Board regulations. If a financial holding company ceases to meet these 
capital  and  management  requirements,  the  Federal  Reserve  Board’s  regulations  provide  that  the  financial  holding 
company  must  enter  into  an  agreement  with  the  Federal  Reserve  Board  to  comply  with  all  applicable  capital  and 
management requirements. Until the financial holding company returns to compliance, the Federal Reserve Board may 
impose limitations or conditions on the conduct of its activities, and the company may not commence any of the broader 
financial activities permissible for financial holding companies or acquire a company engaged in such financial activities 
without prior approval of the Federal Reserve Board. If the company does not return to compliance within 180 days, 
the Federal Reserve Board may require divestiture of the holding company’s depository institutions. Bank holding 
companies and banks must also be both well capitalized and well managed in order to acquire banks located outside 
their home state.

In order for a financial holding company to commence any new activity permitted by the BHC Act or to acquire a 
company engaged in any new activity permitted by the BHC Act, each insured depository institution subsidiary of the 
financial holding company must have received a rating of at least “satisfactory” in its most recent examination under 
the Community Reinvestment Act. See the section captioned “Community Reinvestment Act” elsewhere in this item.

The Federal Reserve Board has the power to order any bank holding company or its subsidiaries to terminate any 
activity or to terminate its ownership or control of any subsidiary when the Federal Reserve Board has reasonable 
grounds to believe that continuation of such activity or such ownership or control constitutes a serious risk to the 
financial soundness, safety or stability of any bank subsidiary of the bank holding company.

The BHC Act, the Bank Merger Act, the Texas Banking Code and other federal and state statutes regulate acquisitions 
of commercial banks and their parent holding companies. The BHC Act requires the prior approval of the Federal 
Reserve Board for the direct or indirect acquisition by a bank holding company of more than 5.0% of the voting shares 
of a commercial bank or its parent holding company. Under the Bank Merger Act, the prior approval of the Federal 
Reserve Board or other appropriate bank regulatory authority is required for a member bank to merge with another 
bank or purchase substantially all of the assets or assume any deposits of another bank. In reviewing applications 
seeking approval of merger and acquisition transactions, the bank regulatory authorities will consider, among other 
things, the competitive effect and public benefits of the transactions, the applicant's managerial and financial resources, 
the capital position of the combined organization, the risks to the stability of the U.S. banking or financial system (e.g., 
systemic risk), the applicant’s performance record under the Community Reinvestment Act (see the section captioned 
“Community Reinvestment Act” elsewhere in this item) and its compliance with fair housing and other consumer 
protection laws and the effectiveness of the subject organizations in combating money laundering activities.

Dividends and Stock Repurchases

The principal source of Cullen/Frost’s liquidity is dividends from Frost Bank. The prior approval of the Federal 
Reserve Board is required if the total of all dividends declared by a state-chartered member bank in any calendar year 
would exceed the sum of the bank’s net profits for that year and its retained net profits for the preceding two calendar 
years, less any required transfers to surplus or to fund the retirement of preferred stock. Federal law also prohibits a 
state-chartered, member bank from paying dividends that would be greater than the bank’s undivided profits. Frost 
8

Bank is also subject to limitations under Texas state law regarding the level of dividends that may be paid. Under the 
foregoing dividend restrictions, and while maintaining its “well capitalized” status, Frost Bank could pay aggregate 
dividends of approximately $682.9 million to Cullen/Frost, without obtaining affirmative governmental approvals, at 
December 31, 2019. This amount is not necessarily indicative of amounts that may be paid or available to be paid in 
future periods.

In addition, Cullen/Frost and Frost Bank are subject to other regulatory policies and requirements relating to the 
payment of dividends, including requirements to maintain adequate capital above regulatory minimums. The appropriate 
federal regulatory authority is authorized to determine under certain circumstances relating to the financial condition 
of a bank holding company or a bank that the payment of dividends would be an unsafe or unsound practice and to 
prohibit payment thereof. The appropriate federal regulatory authorities have stated that paying dividends that deplete 
a  bank’s  capital  base  to  an  inadequate  level  would  be  an  unsafe  and  unsound  banking  practice  and  that  banking 
organizations should generally pay dividends only out of current operating earnings. In addition, in the current financial 
and economic environment, the Federal Reserve Board has indicated that bank holding companies should carefully 
review their dividend policy and has discouraged payment ratios that are at maximum allowable levels unless both 
asset quality and capital are very strong.

In July 2019, the federal bank regulators adopted final rules (the “Capital Simplifications Rules”) that, among other 
things, eliminated the standalone prior approval requirement in the Basel III Capital Rules for any repurchase of common 
stock. In certain circumstances, Cullen/Frost’s repurchases of its common stock may be subject to a prior approval or 
notice requirement under other regulations, policies or supervisory expectations of the Federal Reserve Board. Any 
redemption or repurchase of preferred stock or subordinated debt remains subject to the prior approval of the Federal 
Reserve Board.

Transactions with Affiliates

Transactions between Frost Bank and its subsidiaries, on the one hand, and Cullen/Frost or any other subsidiary, on 
the other hand, are regulated under federal banking law. The Federal Reserve Act imposes quantitative and qualitative 
requirements and collateral requirements on covered transactions by Frost Bank with, or for the benefit of, its affiliates, 
and generally requires those transactions to be on terms at least as favorable to Frost Bank as if the transaction were 
conducted with an unaffiliated third party. Covered transactions are defined by statute to include a loan or extension 
of credit, as well as a purchase of securities issued by an affiliate, a purchase of assets (unless otherwise exempted by 
the Federal Reserve Board) from the affiliate, certain derivative transactions that create a credit exposure to an affiliate, 
the acceptance of securities issued by the affiliate as collateral for a loan, and the issuance of a guarantee, acceptance 
or letter of credit on behalf of an affiliate. In general, any such transaction by Frost Bank or its subsidiaries must be 
limited to certain thresholds on an individual and aggregate basis and, for credit transactions with any affiliate, must 
be secured by designated amounts of specified collateral.

Federal law also limits a bank’s authority to extend credit to its directors, executive officers and 10% stockholders, 
as well as to entities controlled by such persons. Among other things, extensions of credit to insiders are required to 
be made on terms that are substantially the same as, and follow credit underwriting procedures that are not less stringent 
than, those prevailing for comparable transactions with unaffiliated persons. Also, the terms of such extensions of credit 
may not involve more than the normal risk of non-repayment or present other unfavorable features and may not exceed 
certain limitations on the amount of credit extended to such persons individually and in the aggregate.

Source of Strength Doctrine

Federal Reserve Board policy and federal law require bank holding companies to act as a source of financial and 
managerial strength to their subsidiary banks. Under this requirement, Cullen/Frost is expected to commit resources 
to support Frost Bank, including at times when Cullen/Frost may not be in a financial position to provide such resources. 
Any capital loans by a bank holding company to any of its subsidiary banks are subordinate in right of payment to 
depositors  and  to  certain  other  indebtedness  of  such  subsidiary  banks.  In  the  event  of  a  bank  holding  company’s 
bankruptcy, any commitment by the bank holding company to a federal bank regulatory agency to maintain the capital 
of a subsidiary bank will be assumed by the bankruptcy trustee and entitled to priority of payment.

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Capital Requirements

Cullen/Frost and Frost Bank are each required to comply with applicable capital adequacy standards established by 
the Federal Reserve Board. In July 2013, the federal bank regulators approved final rules (the “Basel III Capital Rules”) 
implementing  the  Basel III  framework  set  forth  by  the  Basel  Committee  on  Banking  Supervision  (the  “Basel 
Committee”) as well as certain provisions of the Dodd-Frank Act.

Since fully phased in on January 1, 2019, the Basel III Capital Rules require Cullen/Frost and Frost Bank to maintain 

the following:

•  A minimum ratio of Common Equity Tier 1 (“CET1”) to risk-weighted assets of at least 4.5%, plus a 2.5% 
“capital conservation buffer” (resulting in a minimum ratio of CET1 to risk-weighted assets of 7.0%);

•  A minimum ratio of Tier 1 capital to risk-weighted assets of at least 6.0%, plus the capital conservation buffer 

(resulting in a minimum Tier 1 capital ratio of 8.5%);

•  A minimum ratio of total capital (Tier 1 capital plus Tier 2 capital) to risk-weighted assets of at least 8.0%, 

plus the capital conservation buffer (resulting in a minimum total capital ratio of 10.5%); and

•  A minimum leverage ratio of 4.0%, calculated as the ratio of Tier 1 capital to average consolidated assets as 

reported on consolidated financial statements (known as the “leverage ratio”). .

Banking institutions that fail to meet the effective minimum ratios once the capital conservation buffer is taken into 
account,  as  detailed  above,  will  be  subject  to  constraints  on  capital  distributions,  including  dividends  and  share 
repurchases, and certain discretionary executive compensation. The severity of the constraints depends on the amount 
of the shortfall and the institution’s “eligible retained income” (that is, four quarter trailing net income, net of distributions 
and tax effects not reflected in net income).

The Basel III Capital Rules and the Capital Simplification Rules also provide for a number of deductions from and 
adjustments  to  CET1. These  include,  for  example,  the  requirement  that  certain  deferred  tax  assets  and  significant 
investments in non-consolidated financial entities be deducted from CET1 to the extent that any one such category 
exceeds 25% of CET1. Prior to the adoption of the Capital Simplification Rules in July 2019, amounts were deducted 
from CET1 to the extent that any one such category exceeded 10% of CET1 or all such items, in the aggregate, exceeded 
15% of CET1. The Capital Simplification Rules took effect for Cullen/Frost and Frost Bank as of January 1, 2020. 
These limitations did not impact our regulatory capital during any of the reported periods.

In addition, under the general risk-based capital rules, the effects of accumulated other comprehensive income items 
included in capital were excluded for the purposes of determining regulatory capital ratios. Under the Basel III Capital 
Rules, the effects of certain accumulated other comprehensive income items are not excluded; however, non-advanced 
approaches banking organizations, including Cullen/Frost and Frost Bank, were able to make a one-time permanent 
election to continue to exclude these items. Both Cullen/Frost and Frost Bank made this election in order to avoid 
significant variations in the level of capital depending upon the impact of interest rate fluctuations on the fair value of 
their  available-for-sale  securities  portfolio.  Under  the  Basel III  Capital  Rules,  trust  preferred  securities  no  longer 
included in our Tier 1 capital may nonetheless be included as a component of Tier 2 capital on a permanent basis without 
phase-out.

The Basel III Capital Rules prescribe a standardized approach for risk weightings that expanded the risk-weighting 
categories from the general risk-based capital rules to a much larger and more risk-sensitive number of categories, 
depending on the nature of the assets, generally ranging from 0% for U.S. government and agency securities, to 600% 
for certain equity exposures (and higher percentages for certain other types of interests), and resulting in higher risk 
weights for a variety of asset categories. In November 2019, the federal banking agencies adopted a rule revising the 
scope of commercial real estate mortgages subject to a 150% risk weight.

In December 2017, the Basel Committee published standards that it described as the finalization of the Basel III 
post-crisis  regulatory  reforms  (the  standards  are  commonly  referred  to  as  “Basel IV”). Among  other  things,  these 
standards revise the Basel Committee's standardized approach for credit risk (including by recalibrating risk weights 
and introducing new capital requirements for certain “unconditionally cancellable commitments,” such as unused credit 
card lines of credit) and provides a new standardized approach for operational risk capital. Under the Basel framework, 
these  standards  will  generally  be  effective  on  January 1,  2022,  with  an  aggregate  output  floor  phasing  in  through 
January 1, 2027. Under the current U.S. capital rules, operational risk capital requirements and a capital floor apply 
only to advanced approaches institutions, and not to Cullen/Frost or Frost Bank. The impact of Basel IV on us will 
depend on the manner in which it is implemented by the federal bank regulators.

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Liquidity Requirements

The Basel III liquidity framework requires banks and bank holding companies to measure their liquidity against 
specific liquidity tests. One test, referred to as the liquidity coverage ratio (“LCR”), is designed to ensure that the 
banking entity maintains an adequate level of unencumbered high-quality liquid assets equal to the entity’s expected 
net cash outflow for a 30-day time horizon (or, if greater, 25% of its expected total cash outflow) under an acute liquidity 
stress scenario. The other test, referred to as the net stable funding ratio (“NSFR”), is designed to promote more medium- 
and long-term funding of the assets and activities of banking entities over a one-year time horizon. Rules applicable 
to certain large banking organizations have been implemented for LCR and proposed for NSFR; however, based on 
our asset size, these rules do not currently apply to Cullen/Frost and Frost Bank.

Prompt Corrective Action

The Federal Deposit Insurance Act, as amended (“FDIA”), requires among other things, the federal banking agencies 
to take “prompt corrective action” in respect of depository institutions that do not meet minimum capital requirements. 
The FDIA includes the following five capital tiers: “well capitalized,” “adequately capitalized,” “undercapitalized,” 
“significantly undercapitalized” and “critically undercapitalized.”

A bank will be (i) “well capitalized” if the institution has a total risk-based capital ratio of 10.0% or greater, a CET1 
capital ratio of 6.5% or greater, a Tier 1 risk-based capital ratio of 8.0% or greater, and a leverage ratio of 5.0% or 
greater, and is not subject to any order or written directive by any such regulatory authority to meet and maintain a 
specific capital level for any capital measure; (ii) “adequately capitalized” if the institution has a total risk-based capital 
ratio of 8.0% or greater, a CET1 capital ratio of 4.5% or greater, a Tier 1 risk-based capital ratio of 6.0% or greater, 
and a leverage ratio of 4.0% or greater and is not “well capitalized”; (iii) “undercapitalized” if the institution has a total 
risk-based capital ratio that is less than 8.0%, a CET1 capital ratio less than 4.5%, a Tier 1 risk-based capital ratio of 
less than 6.0% or a leverage ratio of less than 4.0%; (iv) “significantly undercapitalized” if the institution has a total 
risk-based capital ratio of less than 6.0%, a CET1 capital ratio less than 3.0%, a Tier 1 risk-based capital ratio of less 
than 4.0% or a leverage ratio of less than 3.0%; and (v) “critically undercapitalized” if the institution’s tangible equity 
is equal to or less than 2.0% of average quarterly tangible assets. An institution may be downgraded to, or deemed to 
be in, a capital category that is lower than indicated by its capital ratios if it is determined to be in an unsafe or unsound 
condition or if it receives an unsatisfactory examination rating with respect to certain matters. A bank’s capital category 
is determined solely for the purpose of applying prompt corrective action regulations, and the capital category may not 
constitute an accurate representation of the bank’s overall financial condition or prospects for other purposes.

In addition, the FDIA prohibits an insured depository institution from accepting brokered deposits or offering interest 
rates  on  any  deposits  significantly  higher  than  the  prevailing  rate  in  the  bank’s  normal  market  area  or  nationally 
(depending upon where the deposits are solicited), unless it is well capitalized or is adequately capitalized and receives 
a waiver from the FDIC. A depository institution that is adequately capitalized and accepts brokered deposits under a 
waiver from the FDIC may not pay an interest rate on any deposit in excess of 75 basis points over certain prevailing 
market rates.

The FDIA generally prohibits a depository institution from making any capital distributions (including payment of 
a dividend) or paying any management fee to its parent holding company if the depository institution would thereafter 
be “undercapitalized.” “Undercapitalized” institutions are subject to growth limitations and are required to submit a 
capital restoration plan. The agencies may not accept such a plan without determining, among other things, that the 
plan is based on realistic assumptions and is likely to succeed in restoring the depository institution’s capital. In addition, 
for a capital restoration plan to be acceptable, the depository institution’s parent holding company must guarantee that 
the institution will comply with such capital restoration plan. The bank holding company must also provide appropriate 
assurances of performance. The aggregate liability of the parent holding company is limited to the lesser of (i) an amount 
equal to 5.0% of the depository institution’s total assets at the time it became undercapitalized and (ii) the amount which 
is necessary (or would have been necessary) to bring the institution into compliance with all capital standards applicable 
with respect to such institution as of the time it fails to comply with the plan. If a depository institution fails to submit 
an acceptable plan, it is treated as if it is “significantly undercapitalized.”

11

“Significantly undercapitalized” depository institutions may be subject to a number of requirements and restrictions, 
including orders to sell sufficient voting stock to become “adequately capitalized,” requirements to reduce total assets, 
and cessation of receipt of deposits from correspondent banks. “Critically undercapitalized” institutions are subject to 
the appointment of a receiver or conservator.

The  appropriate  federal  banking  agency  may,  under  certain  circumstances,  reclassify  a  well  capitalized  insured 
depository  institution  as  adequately  capitalized.  The  FDIA  provides  that  an  institution  may  be  reclassified  if  the 
appropriate federal banking agency determines (after notice and opportunity for hearing) that the institution is in an 
unsafe or unsound condition or deems the institution to be engaging in an unsafe or unsound practice. The appropriate 
agency  is  also  permitted  to  require  an  adequately  capitalized  or  undercapitalized  institution  to  comply  with  the 
supervisory provisions as if the institution were in the next lower category (but not treat a significantly undercapitalized 
institution as critically undercapitalized) based on supervisory information other than the capital levels of the institution.

Cullen/Frost believes that, as of December 31, 2019, its bank subsidiary, Frost Bank, was “well capitalized” based 
on the aforementioned ratios. For further information regarding the capital ratios and leverage ratio of Cullen/Frost 
and Frost Bank see the discussion under the section captioned “Capital and Liquidity” included in Item 7. Management’s 
Discussion and Analysis of Financial Condition and Results of Operations and Note 9 - Capital and Regulatory Matters 
in the notes to consolidated financial statements included in Item 8. Financial Statements and Supplementary Data, 
elsewhere in this report.

Safety and Soundness Standards

The FDIA requires the federal bank regulatory agencies to prescribe standards, by regulations or guidelines, relating 
to internal controls, information systems and internal audit systems, loan documentation, credit underwriting, interest 
rate risk exposure, asset growth, asset quality, earnings, stock valuation and compensation, fees and benefits, and such 
other operational and managerial standards as the agencies deem appropriate. Guidelines adopted by the federal bank 
regulatory agencies establish general standards relating to internal controls and information systems, internal audit 
systems, loan documentation, credit underwriting, interest rate exposure, asset growth and compensation, fees and 
benefits. In general, the guidelines require, among other things, appropriate systems and practices to identify and manage 
the risk and exposures specified in the guidelines. The guidelines prohibit excessive compensation as an unsafe and 
unsound practice and describe compensation as excessive when the amounts paid are unreasonable or disproportionate 
to the services performed by an executive officer, employee, director or principal stockholder. In addition, the agencies 
adopted regulations that authorize, but do not require, an agency to order an institution that has been given notice by 
an agency that it is not satisfying any of such safety and soundness standards to submit a compliance plan. If, after 
being so notified, an institution fails to submit an acceptable compliance plan or fails in any material respect to implement 
an acceptable compliance plan, the agency must issue an order directing action to correct the deficiency and may issue 
an  order  directing  other  actions  of  the  types  to  which  an  undercapitalized  institution  is  subject  under  the  “prompt 
corrective action” provisions of the FDIA. See “Prompt Corrective Action” above. If an institution fails to comply with 
such an order, the agency may seek to enforce such order in judicial proceedings and to impose civil money penalties.

Deposit Insurance

Substantially all of the deposits of Frost Bank are insured up to applicable limits by the Deposit Insurance Fund 
(“DIF”) of the FDIC and Frost Bank is subject to deposit insurance assessments to maintain the DIF. Deposit insurance 
assessments are based on average total assets minus average tangible equity. For larger institutions, such as Frost Bank, 
the FDIC uses a performance score and a loss-severity score that are used to calculate an initial assessment rate. In 
calculating these scores, the FDIC uses a bank’s capital level and supervisory ratings and certain financial measures to 
assess an institution’s ability to withstand asset-related stress and funding-related stress. The FDIC has the ability to 
make discretionary adjustments to the total score based upon significant risk factors that are not adequately captured 
in the calculations.

Under the FDIA, the FDIC may terminate deposit insurance upon a finding that the institution has engaged in unsafe 
and unsound practices, is in an unsafe or unsound condition to continue operations, or has violated any applicable law, 
regulation, rule, order or condition imposed by the FDIC. In addition, the FDIC is authorized to conduct examinations 
of and require reporting by FDIC-insured institutions.

12

Enhanced Prudential Standards 

The Federal Reserve Board is required to monitor emerging risks to financial stability and enact enhanced supervision 
and  prudential  standards  applicable  to  large  bank  holding  companies  and  certain  non-bank  covered  companies 
designated as systemically important by the Financial Stability Oversight Council. The Dodd-Frank Act mandates that 
certain regulatory requirements applicable to these systemically important financial institutions be more stringent than 
those applicable to other financial institutions. In 2019, the Federal Reserve Board adopted new rules impacting certain 
capital and liquidity requirements and other enhanced prudential standards. The final rules assign all domestic bank 
holding companies with $100 billion or more in total consolidated assets to one of four categories of tailored regulatory 
requirements. Cullen/Frost and Frost Bank are generally not impacted by these rules. The enhanced prudential standards 
rules, as amended in 2019, require publicly traded bank holding companies with $50 billion or more in total consolidated 
assets to establish risk committees. Prior to the amendment, the requirement to establish a risk committee was applicable 
to publicly traded bank holding companies with $10 billion or more in consolidated assets. Cullen/Frost has established 
and currently maintains a risk committee.

The Volcker Rule

The so-called Volcker Rule under the Dodd-Frank Act restricts banks and their affiliates from engaging in proprietary 
trading and investing in and sponsoring hedge funds and private equity funds. The Volcker Rule, which became effective 
in July 2015 and the implementing regulations of which were amended in 2019 and are subject to further amendment 
expected in 2020, does not significantly impact the operations of Cullen/Frost and its subsidiaries, as we do not have 
any engagement in the businesses prohibited by the Volcker Rule.

Depositor Preference

The FDIA provides that, in the event of the “liquidation or other resolution” of an insured depository institution, the 
claims of depositors of the institution, including the claims of the FDIC as subrogee of insured depositors, and certain 
claims for administrative expenses of the FDIC as a receiver, will have priority over other general unsecured claims 
against the institution. If an insured depository institution fails, insured and uninsured depositors, along with the FDIC, 
will have priority in payment ahead of unsecured, non-deposit creditors, including depositors whose deposits are payable 
only outside of the United States and the parent bank holding company, with respect to any extensions of credit they 
have made to such insured depository institution.

Interchange Fees

Under the Durbin Amendment to the Dodd-Frank Act, the Federal Reserve adopted rules establishing standards for 
assessing whether the interchange fees that may be charged with respect to certain electronic debit transactions are 
“reasonable and proportional” to the costs incurred by issuers for processing such transactions.

Interchange fees, or “swipe” fees, are charges that merchants pay to us and other card-issuing banks for processing 
electronic payment transactions. Federal Reserve Board rules applicable to financial institutions that have assets of 
$10 billion or more provide that the maximum permissible interchange fee for an electronic debit transaction is the 
sum of 21 cents per transaction and 5 basis points multiplied by the value of the transaction. An upward adjustment of 
no more than 1 cent to an issuer's debit card interchange fee is allowed if the card issuer develops and implements 
policies and procedures reasonably designed to achieve certain fraud-prevention standards. The Federal Reserve Board 
also has rules governing routing and exclusivity that require issuers to offer two unaffiliated networks for routing 
transactions on each debit or prepaid product.

Consumer Financial Protection

We are subject to a number of federal and state consumer protection laws that extensively govern our relationship 
with our customers. These laws include the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Truth in 
Lending Act, the Truth in Savings Act, the Electronic Fund Transfer Act, the Expedited Funds Availability Act, the 
Home  Mortgage  Disclosure Act,  the  Fair  Housing Act,  the  Real  Estate  Settlement  Procedures Act,  the  Fair  Debt 
Collection Practices Act, the Service Members Civil Relief Act and these laws’ respective state-law counterparts, as 
well as state usury laws and laws regarding unfair and deceptive acts and practices. These and other federal laws, among 
other things, require disclosures of the cost of credit and terms of deposit accounts, provide substantive consumer rights, 
prohibit discrimination in credit transactions, regulate the use of credit report information, provide financial privacy 
protections, prohibit unfair, deceptive and abusive practices, restrict our ability to raise interest rates and subject us to 

13

substantial regulatory oversight. Violations of applicable consumer protection laws can result in significant potential 
liability from litigation brought by customers, including actual damages, restitution and attorneys’ fees. Federal bank 
regulators, state attorneys general and state and local consumer protection agencies may also seek to enforce consumer 
protection requirements and obtain these and other remedies, including regulatory sanctions, customer rescission rights, 
action by the state and local attorneys general in each jurisdiction in which we operate and civil money penalties. Failure 
to comply with consumer protection requirements may also result in our failure to obtain any required bank regulatory 
approval  for  merger  or  acquisition  transactions  we  may  wish  to  pursue  or  our  prohibition  from  engaging  in  such 
transactions even if approval is not required.

The Consumer Financial Protection Bureau (“CFPB”) is a federal agency responsible for implementing, examining 
and enforcing compliance with federal consumer protection laws. The CFPB has broad rulemaking authority for a wide 
range of consumer financial laws that apply to all banks, including, among other things, the authority to prohibit “unfair, 
deceptive or abusive” acts and practices. Abusive acts or practices are defined as those that materially interfere with a 
consumer’s ability to understand a term or condition of a consumer financial product or service or take unreasonable 
advantage of a consumer’s (i) lack of financial savvy, (ii) inability to protect himself in the selection or use of consumer 
financial products or services, or (iii) reasonable reliance on a covered entity to act in the consumer’s interests. The 
CFPB can issue cease-and-desist orders against banks and other entities that violate consumer financial laws. The CFPB 
may also institute a civil action against an entity in violation of federal consumer financial law in order to impose a 
civil  penalty  or  injunction. The  CFPB  has  examination  and  enforcement  authority  over  all  banks  with  more  than 
$10 billion in assets, as well as their affiliates. Banking regulators take into account compliance with consumer protection 
laws when considering approval of a proposed transaction.

Community Reinvestment Act

The Community Reinvestment Act of 1977 (“CRA”) requires depository institutions to assist in meeting the credit 
needs of their market areas consistent with safe and sound banking practice. Under the CRA, each depository institution 
is required to help meet the credit needs of its market areas by, among other things, providing credit to low- and moderate-
income individuals and communities. Depository institutions are periodically examined for compliance with the CRA 
and are assigned ratings. In order for a financial holding company to commence any new activity permitted by the BHC 
Act,  or  to  acquire  any  company  engaged  in  any  new  activity  permitted  by  the  BHC Act,  each  insured  depository 
institution subsidiary of the financial holding company must have received a rating of at least “satisfactory” in its most 
recent examination under the CRA. Furthermore, banking regulators take into account CRA ratings when considering 
a request for an approval of a proposed transaction. Frost Bank received a rating of “satisfactory” in its most recent 
CRA examination.

In December 2019, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the 
Currency (“OCC”) jointly proposed rules that would significantly change existing CRA regulations. The proposed rules 
are intended to increase bank activity in low- and moderate-income communities where there is significant need for 
credit, more responsible lending, greater access to banking services, and improvements to critical infrastructure. The 
proposals change four key areas: (i) clarifying what activities qualify for CRA credit; (ii) updating where activities 
count for CRA credit; (iii) providing a more transparent and objective method for measuring CRA performance; and 
(iv) revising CRA-related data collection, record keeping, and reporting. However, the Federal Reserve Board has not 
joined the proposed rulemaking. As such, we will continue to evaluate the impact of any changes to the regulations 
implementing the CRA and their impact to our financial condition, results of operations, and/or liquidity.

Financial Privacy

The federal banking regulators adopted rules that limit the ability of banks and other financial institutions to disclose 
non-public information about consumers to nonaffiliated third parties. These limitations require disclosure of privacy 
policies to consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information 
to a nonaffiliated third party. These regulations affect how consumer information is transmitted through diversified 
financial companies and conveyed to outside vendors.

Anti-Money Laundering and the USA Patriot Act

A major focus of governmental policy on financial institutions in recent years has been aimed at combating money 
laundering and terrorist financing. The USA PATRIOT Act of 2001, or the USA Patriot Act, substantially broadened 
the scope of United States anti-money laundering laws and regulations by imposing significant new compliance and 
due diligence obligations, creating new crimes and penalties and expanding the extra-territorial jurisdiction of the 

14

United States. Financial institutions are also prohibited from entering into specified financial transactions and account 
relationships and must use enhanced due diligence procedures in their dealings with certain types of high-risk customers 
and  implement  a  written  customer  identification  program.  Financial  institutions  must  take  certain  steps  to  assist 
government agencies in detecting and preventing money laundering and report certain types of suspicious transactions. 
Regulatory authorities routinely examine financial institutions for compliance with these obligations, and failure of a 
financial institution to maintain and implement adequate programs to combat money laundering and terrorist financing, 
or to comply with all of the relevant laws or regulations, could have serious financial, legal and reputational consequences 
for  the  institution,  including  causing  applicable  bank  regulatory  authorities  not  to  approve  merger  or  acquisition 
transactions when regulatory approval is required or to prohibit such transactions even if approval is not required. 
Regulatory authorities have imposed cease and desist orders and civil money penalties against institutions found to be 
violating these obligations.

Office of Foreign Assets Control Regulation

The U.S. Treasury Department’s Office of Foreign Assets Control, or OFAC, administers and enforces economic 
and trade sanctions against targeted foreign countries and regimes, under authority of various laws, including designated 
foreign countries, nationals and others. OFAC publishes lists of specially designated targets and countries. We are 
responsible for, among other things, blocking accounts of, and transactions with, such targets and countries, prohibiting 
unlicensed trade and financial transactions with them and reporting blocked transactions after their occurrence. Failure 
to comply with these sanctions could have serious financial, legal and reputational consequences, including causing 
applicable bank regulatory authorities not to approve merger or acquisition transactions when regulatory approval is 
required or to prohibit such transactions even if approval is not required. Regulatory authorities have imposed cease 
and desist orders and civil money penalties against institutions found to be violating these obligations.

Incentive Compensation

The  Federal  Reserve  Board  reviews,  as  part  of  its  regular,  risk-focused  examination  process,  the  incentive 
compensation  arrangements  of  banking  organizations,  such  as  Cullen/Frost,  that  are  not  “large,  complex  banking 
organizations.” These reviews are tailored to each organization based on the scope and complexity of the organization’s 
activities  and  the  prevalence  of  incentive  compensation  arrangements.  Deficiencies  will  be  incorporated  into  the 
organization’s supervisory ratings, which can affect the organization’s ability to make acquisitions and take other actions. 
Enforcement actions may be taken against a banking organization if its incentive compensation arrangements, or related 
risk-management  control  or  governance  processes,  pose  a  risk  to  the  organization’s  safety  and  soundness  and  the 
organization is not taking prompt and effective measures to correct the deficiencies.

In  June 2010,  the  Federal  Reserve  Board,  OCC  and  FDIC  issued  comprehensive  final  guidance  on  incentive 
compensation policies intended to ensure that the incentive compensation policies of banking organizations do not 
undermine the safety and soundness of such organizations by encouraging excessive risk-taking. The guidance, which 
covers all employees that have the ability to materially affect the risk profile of an organization, either individually or 
as part of a group, is based upon the key principles that a banking organization’s incentive compensation arrangements 
should (i) provide incentives that do not encourage risk-taking beyond the organization’s ability to effectively identify 
and manage risks, (ii) be compatible with effective internal controls and risk management, and (iii) be supported by 
strong corporate governance, including active and effective oversight by the organization’s board of directors.

In 2016, the U.S. financial regulators, including the Federal Reserve Board and the SEC, proposed revised rules on 
incentive-based payment arrangements at specified regulated entities having at least $1 billion in total assets (including 
Cullen/Frost and Frost Bank), but these propose rules have not been finalized. 

Cybersecurity

In March 2015, federal regulators issued two related statements regarding cybersecurity. One statement indicates 
that financial institutions should design multiple layers of security controls to establish lines of defense and to ensure 
that their risk management processes also address the risk posed by compromised customer credentials, including 
security measures to reliably authenticate customers accessing internet-based services of the financial institution. The 
other statement indicates that a financial institution’s management is expected to maintain sufficient business continuity 
planning processes to ensure the rapid recovery, resumption and maintenance of the institution’s operations after a 
cyber-attack involving destructive malware. A financial institution is also expected to develop appropriate processes 
to enable recovery of data and business operations and address rebuilding network capabilities and restoring data if the 

15

institution or its critical service providers fall victim to this type of cyber-attack. If we fail to observe the regulatory 
guidance, we could be subject to various regulatory sanctions, including financial penalties.

In February 2018, the SEC published interpretive guidance to assist public companies in preparing disclosures about 
cybersecurity risks and incidents. These SEC guidelines, and any other regulatory guidance, are in addition to notification 
and disclosure requirements under state and federal banking law and regulations.

State  regulators  have  also  been  increasingly  active  in  implementing  privacy  and  cybersecurity  standards  and 
regulations.  Recently,  several  states  have  adopted  regulations  requiring  certain  financial  institutions  to  implement 
cybersecurity programs and providing detailed requirements with respect to these programs, including data encryption 
requirements. Many states, including Texas, have also recently implemented or modified their data breach notification 
and data privacy requirements. We expect this trend of state-level activity in those areas to continue, and are continually 
monitoring developments in the states in which our customers are located.

In the ordinary course of business, we rely on electronic communications and information systems to conduct our 
operations  and  to  store  sensitive  data. We  employ  an  in-depth,  layered,  defensive  approach  that  leverages  people, 
processes and technology to manage and maintain cybersecurity controls. We employ a variety of preventative and 
detective tools to monitor, block, and provide alerts regarding suspicious activity, as well as to report on any suspected 
advanced persistent threats. Notwithstanding the strength of our defensive measures, the threat from cyber attacks is 
severe,  attacks  are  sophisticated  and  increasing  in  volume,  and  attackers  respond  rapidly  to  changes  in  defensive 
measures. While to date, other than as described below, we have not detected a significant compromise, significant 
data loss or any material financial losses related to cybersecurity attacks, our systems and those of our customers and 
third-party service providers are under constant threat and it is possible that we could experience a significant event in 
the future. Risks and exposures related to cybersecurity attacks are expected to remain high for the foreseeable future 
due to the rapidly evolving nature and sophistication of these threats, as well as due to the expanding use of Internet 
banking, mobile banking and other technology-based products and services by us and our customers. See Item 1A. 
Risk Factors for a further discussion of risks related to cybersecurity. 

During 2018, we experienced a data security incident that resulted in unauthorized access to a third-party lockbox 
software program used by certain of our commercial lockbox customers to store digital images. We stopped the identified 
unauthorized access and consulted with a leading cybersecurity firm. We reported the incident to, and cooperated with, 
law-enforcement authorities. We contacted each of the affected commercial customers and we supported them in taking 
appropriate actions. The identified incident did not impact other Frost systems. Out-of-pocket costs incurred related to 
this incident totaled $2.1 million and no further costs are expected with respect to this incident.

Future Legislation and Regulation

Congress may enact legislation from time to time that affects the regulation of the financial services industry, and 
state legislatures may enact legislation from time to time affecting the regulation of financial institutions chartered by 
or operating in those states. Federal and state regulatory agencies also periodically propose and adopt changes to their 
regulations or change the manner in which existing regulations are applied. The substance or impact of pending or 
future legislation or regulation, or the application thereof, cannot be predicted, although any change could impact the 
regulatory  structure  under  which  we  or  our  competitors  operate  and  may  significantly  increase  costs,  impede  the 
efficiency of internal business processes, require an increase in regulatory capital, require modifications to our business 
strategy, and limit our ability to pursue business opportunities in an efficient manner. It could also affect our competitors 
differently than us, including in a manner that would make them more competitive. A change in statutes, regulations 
or regulatory policies applicable to Cullen/Frost or any of its subsidiaries could have a material, adverse effect on our 
business, financial condition and results of operations.

Employees

At December 31, 2019, we employed 4,659 full-time equivalent employees. None of our employees are represented 

by collective bargaining agreements. We believe our employee relations to be good.

16

Information About Our Executive Officers

The names, ages as of December 31, 2019, recent business experience and positions or offices held by each of the 

executive officers of Cullen/Frost are as follows:

Name and Position Held

Age Recent Business Experience

Phillip D. Green
  Chairman of the Board, Chief Executive
  Officer and Director of Cullen/Frost

Patrick B. Frost
  Director of Cullen/Frost, President of 
  Frost Bank, Group Executive Vice 
  President, Frost Wealth Advisors of Frost
  Bank and President of Frost Insurance
Jerry Salinas
  Group Executive Vice President, Chief
  Financial Officer of Cullen/Frost

Annette Alonzo
  Group Executive Vice President, Chief
  Human Resources Officer of Frost Bank

Robert A. Berman
  Group Executive Vice President,
  Research and Strategy of Frost Bank

Paul H. Bracher
  President of Cullen/Frost and Group 
  Executive Vice President, Chief
  Banking Officer of Frost Bank

William L. Perotti
  Group Executive Vice President, Chief
  Credit Officer of Frost Bank

Carol Severyn
  Group Executive Vice President, Chief
  Risk Officer of Frost Bank

Jimmy Stead
  Group Executive Vice President, Chief
  Consumer Banking Officer of Frost Bank

James L. Waters
  Group Executive Vice President, General
  Counsel and Secretary of Cullen/Frost

Candace Wolfshohl
  Group Executive Vice President, Culture
  and People Development of Frost Bank

65

59

61

51

57

63

62

55

44

53

59

Officer of Frost Bank since July 1980. Group Executive Vice President, 
Chief Financial Officer of Cullen/Frost from October 1995 to January 
2015.  President  of  Cullen/Frost  from  January  2015  to  March  2016. 
Chairman of the Board and Chief Executive Officer of Cullen/Frost 
since April 2016.
Officer of Frost Bank since 1985. President of Frost Bank from August 
1993 to present. Director of Cullen/Frost from May 1997 to present. 
Group Executive Vice President, Frost Wealth Advisors of Frost Bank 
from April 2016 to present. President of Frost Insurance since October 
2014.
Officer  of  Frost  Bank  since  March  1986.  Senior  Executive  Vice 
President, Treasurer of Cullen/Frost from 1997 to January 2015. Group 
Executive Vice President, Chief Financial Officer of Cullen/Frost since 
January 2015.
Officer of Frost Bank since 1993. Executive Vice President, Human 
Resources  of  Frost  Bank  from  July  2006  to  January  2015.  Senior 
Executive  Vice  President,  Human  Resources  of  Frost  Bank  from 
January 2015 to July 2015. Group Executive Vice President, Human 
Resources  of  Frost  Bank  from  July  2015  to  March  2016.  Group 
Executive  Vice President,  Chief  Human  Resources  Officer  of  Frost 
Bank since April 2016.
Officer  of  Frost  Bank  since  January  1989.  Group  Executive  Vice 
President, Research and Strategy of Frost Bank since May 2001.

Officer of Frost Bank since January 1982. President, State Regions of 
Frost Bank from February 2001 to January 2015. Group Executive Vice 
President, Chief Banking Officer of Frost Bank from January 2015 to 
present. President of Cullen/Frost since April 2016.

Officer of Frost Bank since December 1982. Group Executive Vice 
President, Chief Credit Officer of Frost Bank from May 2001 to January 
2015. Group Executive Vice President, Chief Risk Officer of Frost Bank 
from April 2005 to January 2019. Chief Credit Officer of Frost Bank 
since January 2019.

Officer of Frost Bank since December 1993. Executive Vice President 
and Auditor of Frost Bank from January 2004 to January 2019. Group 
Executive  Vice  President,  Chief  Risk  Officer  of  Frost  Bank  since 
January 2019.
Officer of Frost Bank since July 2001. Senior Vice President Electronic 
Commerce Operations of Frost Bank from October 2007 to December 
2015, Executive Vice President, Electronic Commerce Operations of 
Frost Bank from January 2016 to January 2017. Group Executive Vice 
President,  Chief  Consumer  Banking  Officer  of  Frost  Bank  since 
January 2017.
Officer  of  Frost  Bank  since  March  2018.  Group  Executive  Vice 
President, General Counsel and Secretary of Cullen/Frost since March 
2018. Prior to joining Frost, Mr. Waters was a partner at the law firm 
Haynes and Boone LLP.
Officer  of  Frost  Bank  since  1989.  Executive  Vice  President,  Staff 
Development of Frost Bank from January 2008 to January 2015. Senior 
Executive  Vice  President,  Staff  Development  of  Frost  Bank  from 
January 2015 to July 2015. Group Executive Vice President, Culture 
and People Development of Frost Bank since July 2015.

There are no arrangements or understandings between any executive officer of Cullen/Frost and any other person 

pursuant to which such executive officer was or is to be selected as an officer.

17

Available Information

Under the Securities Exchange Act of 1934, we are required to file annual, quarterly and current reports, proxy 
statements and other information with the Securities and Exchange Commission (“SEC”). The SEC maintains a website 
at http://www.sec.gov that contains reports, proxy and information statements, and other information regarding issuers 
that file electronically with the SEC. We file electronically with the SEC.

We make available, free of charge through our website, our reports on Forms 10-K, 10-Q and 8-K, and amendments 
to those reports, as soon as reasonably practicable after such reports are filed with or furnished to the SEC. Additionally, 
we have adopted and posted on our website a code of ethics that applies to our principal executive officer, principal 
financial officer and principal accounting officer. Our website also includes our corporate governance guidelines and 
the charters for our audit committee, our compensation and benefits committee, our risk committee, and our corporate 
governance and nominating committee. The address for our website is http://www.frostbank.com. We will provide a 
printed copy of any of the aforementioned documents to any requesting shareholder.

ITEM 1A. RISK FACTORS

An investment in our common stock is subject to risks inherent to our business. The material risks and uncertainties 
that management believes affect us are described below. Before making an investment decision, you should carefully 
consider the risks and uncertainties described below together with all of the other information included or incorporated 
by reference in this report. The risks and uncertainties described below are not the only ones facing us. Additional risks 
and uncertainties that management is not aware of or focused on or that management currently deems immaterial may 
also impair our business operations. This report is qualified in its entirety by these risk factors.

If any of the following risks actually occur, our business, financial condition and results of operations could be 
materially  and  adversely  affected.  If  this  were  to  happen,  the  market  price  of  our  common  stock  could  decline 
significantly, and you could lose all or part of your investment.

Risks Related To Our Business

We are Subject To Risk From Fluctuating Conditions In The Financial Markets and Economic and Political Conditions 
Generally

Our success depends, to a certain extent, upon local, national and global economic and political conditions, as well 
as governmental monetary policies. Our financial performance generally, and in particular the ability of borrowers to 
pay interest on and repay principal of outstanding loans and the value of collateral securing those loans, as well as 
demand for loans and other products and services we offer, is highly dependent upon the business environment in the 
markets where we operate, in the State of Texas and in the United States as a whole. A favorable business environment 
is  generally  characterized  by,  among  other  factors,  economic  growth,  efficient  capital  markets,  low  inflation,  low 
unemployment, high business and investor confidence, and strong business earnings. Unfavorable or uncertain economic 
and market conditions can be caused by a decline in economic growth both in the U.S. and internationally; declines in 
business activity or investor or business confidence; limitations on the availability of or increases in the cost of credit 
and capital; increases in inflation or interest rates; high unemployment, oil price volatility; natural disasters; trade 
policies and tariffs; or a combination of these or other factors. While recent economic conditions in the State of Texas, 
the United States and worldwide have seen improving trends, there can be no assurance that this improvement will 
continue. Economic pressure on consumers and uncertainty regarding continuing economic improvement could result 
in changes in consumer and business spending, borrowing and savings habits. Such conditions could have a material 
adverse effect on the credit quality of our loans and our business, financial condition and results of operations.

We Are Subject To Lending Risk and Lending Concentration Risk

There are inherent risks associated with our lending activities. These risks include, among other things, the impact 
of changes in interest rates and changes in the economic conditions in the markets where we operate as well as those 
across the State of Texas and the United States. Increases in interest rates and/or weakening economic conditions could 
adversely impact the ability of borrowers to repay outstanding loans or the value of the collateral securing these loans. 
We are also subject to various laws and regulations that affect our lending activities. Failure to comply with applicable 
laws and regulations could subject us to regulatory enforcement action that could result in the assessment of significant 
civil money penalties against us.

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As of December 31, 2019, approximately 88.4% of our loan portfolio consisted of commercial and industrial, energy, 
construction and commercial real estate mortgage loans. These types of loans are generally viewed as having more risk 
of  default  and  are  typically  larger  than  residential  real  estate  loans  or  consumer  loans.  Because  our  loan  portfolio 
contains a significant number of commercial and industrial, energy, construction and commercial real estate loans with 
relatively large balances, the deterioration of one or a few of these loans could cause a significant increase in non-
performing loans. Past increases in non-performing loans have resulted in a net loss of earnings from particular loans, 
an increase in the provision for loan losses and an increase in loan charge-offs, and these and future instances could 
have a material adverse effect on our business, financial condition and results of operations.

See the section captioned “Loans” in Item 7. Management’s Discussion and Analysis of Financial Condition and 
Results  of  Operations  elsewhere  in  this  report  for  further  discussion  related  to  commercial  and  industrial,  energy, 
construction and commercial real estate loans.

We Are Subject To Interest Rate Risk

Our earnings and cash flows are largely dependent upon our net interest income. Net interest income is the difference 
between interest income earned on interest-earning assets such as loans and securities and interest expense paid on 
interest-bearing liabilities such as deposits and borrowed funds. Interest rates are highly sensitive to many factors that 
are beyond our control, including general economic conditions and policies of various governmental and regulatory 
agencies and, in particular, the Federal Open Market Committee. Changes in monetary policy, including changes in 
interest rates, could influence not only the interest we receive on loans and securities and the amount of interest we 
pay on deposits and borrowings, but such changes could also affect (i) our ability to originate loans and obtain deposits, 
(ii) the fair value of our financial assets and liabilities, and (iii) the average duration of our mortgage-backed securities 
portfolio. If the interest rates paid on deposits and other borrowings increase at a faster rate than the interest rates 
received on loans and other investments, our net interest income, and therefore earnings, could be adversely affected. 
Earnings could also be adversely affected if the interest rates received on loans and other investments fall more quickly 
than the interest rates paid on deposits and other borrowings. Any substantial, unexpected, or prolonged change in 
market interest rates could have a material adverse effect on our business, financial condition and results of operations.

See Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations under the 
section captioned “Net Interest Income” and Item 7A. Quantitative and Qualitative Disclosures About Market Risk 
elsewhere in this report for further discussion related to interest rate sensitivity and our management of interest rate 
risk.

We May Be Adversely Impacted By The Transition From LIBOR As A Reference Rate

In 2017, the United Kingdom’s Financial Conduct Authority announced that after 2021 it would no longer compel 
banks to submit the rates required to calculate the London Interbank Offered Rate (“LIBOR”). This announcement 
indicates that the continuation of LIBOR on the current basis cannot and will not be guaranteed after 2021. Consequently, 
at this time, it is not possible to predict whether and to what extent banks will continue to provide submissions for the 
calculation of LIBOR. Similarly, it is not possible to predict whether LIBOR will continue to be viewed as an acceptable 
market benchmark, what rate or rates may become accepted alternatives to LIBOR, or what the effect of any such 
changes in views or alternatives may be on the markets for LIBOR-indexed financial instruments.

In particular, regulators, industry groups and certain committees (e.g., the Alternative Reference Rates Committee) 
have,  among  other  things,  published  recommended  fall-back  language  for  LIBOR-linked  financial  instruments, 
identified  recommended  alternatives  for  certain  LIBOR  rates  (e.g.,  the  Secured  Overnight  Financing  Rate  as  the 
recommended alternative to U.S. Dollar LIBOR), and proposed implementations of the recommended alternatives in 
floating rate instruments. At this time, it is not possible to predict whether these specific recommendations and proposals 
will be broadly accepted, whether they will continue to evolve, and what the effect of their implementation may be on 
the markets for floating-rate financial instruments.

We have a significant number of loans, derivative contracts, borrowings and other financial instruments with attributes 
that are either directly or indirectly dependent on LIBOR. The transition from LIBOR could create considerable costs 
and additional risk. Since proposed alternative rates are calculated differently, payments under contracts referencing 
new rates will differ from those referencing LIBOR. The transition will change our market risk profiles, requiring 
changes to risk and pricing models, valuation tools, product design and hedging strategies. Furthermore, failure to 
adequately manage this transition process with our customers could adversely impact our reputation. Although we are 

19

currently unable to assess what the ultimate impact of the transition from LIBOR will be, failure to adequately manage 
the transition could have a material adverse effect on our business, financial condition and results of operations.

Our Allowance For Loan Losses May Be Insufficient

We maintain an allowance for loan losses, which is a reserve established through a provision for loan losses charged 
to expense, which represents management’s best estimate of inherent losses that have been incurred within the existing 
portfolio of loans. The allowance, in the judgment of management, is necessary to reserve for estimated loan losses 
and risks inherent in the loan portfolio. The level of the allowance reflects management’s continuing evaluation of 
industry concentrations; specific credit risks; loan loss experience; current loan portfolio quality; present economic, 
political and regulatory conditions and unidentified losses inherent in the current loan portfolio. The determination of 
the appropriate level of the allowance for loan losses inherently involves a high degree of subjectivity and requires us 
to make significant estimates of current credit risks and future trends, all of which may undergo material changes. 
Continuing  deterioration  in  economic  conditions  affecting  borrowers,  new  information  regarding  existing  loans, 
identification of additional problem loans and other factors, both within and outside of our control, may require an 
increase in the allowance for loan losses. In addition, bank regulatory agencies periodically review our allowance for 
loan losses and may require an increase in the provision for loan losses or the recognition of further loan charge-offs, 
based  on  judgments  different  than  those  of  management.  Furthermore,  if  charge-offs  in  future  periods  exceed  the 
allowance for loan losses, we will need additional provisions to increase the allowance for loan losses. Any increases 
in the allowance for loan losses will result in a decrease in net income and, possibly, capital, and may have a material 
adverse effect on our business, financial condition and results of operations.

See  the  section  captioned  “Allowance  for  Loan  Losses”  in  Item 7.  Management’s  Discussion  and Analysis  of 
Financial Condition and Results of Operations elsewhere in this report for further discussion related to our process for 
determining the appropriate level of the allowance for loan losses.

In addition, the adoption of Accounting Standards Update (“ASU”) 2016-13, “Financial Instruments - Credit Losses 
(Topic 326): Measurement of Credit Losses on Financial Instruments,” as amended, on January 1, 2020 will impact 
our methodology for estimating the allowance for loan losses. See Note 20 - Accounting Standards Updates in the notes 
to consolidated financial statements included in Item 8. Financial Statements and Supplementary Data elsewhere in 
this report.

Our Profitability Depends Significantly On Economic Conditions In The State Of Texas

Our success depends primarily on the general economic conditions of the State of Texas and the specific local markets 
in which we operate. Unlike larger national or other regional banks that are more geographically diversified, we provide 
banking and financial services to customers across Texas through financial centers in the Austin, Corpus Christi, Dallas, 
Fort Worth, Houston, Permian Basin, Rio Grande Valley and San Antonio regions. The local economic conditions in 
these areas have a significant impact on the demand for our products and services as well as the ability of our customers 
to repay loans, the value of the collateral securing loans and the stability of our deposit funding sources. Moreover, 
approximately 99.7% of the securities in our municipal bond portfolio were issued by political subdivisions or agencies 
within the State of Texas. A significant decline in general economic conditions in Texas, whether caused by recession, 
inflation, unemployment, changes or prolonged stagnation in oil prices, changes in securities markets, acts of terrorism, 
outbreak of hostilities or other international or domestic occurrences or other factors could impact these local economic 
conditions and, in turn, have a material adverse effect on our business, financial condition and results of operations.

We Are Subject To Volatility Risk In Crude Oil Prices

As of December 31, 2019, energy loans comprised approximately 11.2% of our loan portfolio. Furthermore, energy 
production and related industries represent a large part of the economies in some of our primary markets. In recent 
years, actions by certain members of the Organization of Petroleum Exporting Countries (“OPEC”) impacting crude 
oil production levels have led to increased global oil supplies which has resulted in significant declines in market oil 
prices. Decreased market oil prices compressed margins for many U.S. and Texas-based oil producers, particularly 
those that utilize higher-cost production technologies such as hydraulic fracking and horizontal drilling, as well as 
oilfield service providers, energy equipment manufacturers and transportation suppliers, among others. The price per 
barrel  of  crude  oil  was  approximately  $61  at  December 31,  2019  up  from  $45  at  December 31,  2018.  We  have 
experienced increased losses within our energy portfolio in recent years as a result of oil price volatility, relative to our 
historical experience. Though oil prices have increased during 2019, future oil price volatility could have a negative 

20

impact on the U.S. economy and, in particular, the economies of energy-dominant states such as Texas and, accordingly, 
could have a material adverse effect on our business, financial condition and results of operations.

We Are Subject to Risk Arising From Conditions In The Commercial Real Estate Market

As  of December 31,  2019,  commercial  real  estate  mortgage  loans  comprised  approximately  31.1% of  our  loan 
portfolio. Commercial real estate mortgage loans generally involve a greater degree of credit risk than residential real 
estate mortgage loans because they typically have larger balances and are more affected by adverse conditions in the 
economy. Because payments on loans secured by commercial real estate often depend upon the successful operation 
and management of the properties and the businesses which operate from within them, repayment of such loans may 
be affected by factors outside the borrower’s control, such as adverse conditions in the real estate market or the economy 
or changes in government regulations. In recent years, commercial real estate markets have been experiencing substantial 
growth, and increased competitive pressures have contributed significantly to historically low capitalization rates and 
rising  property  values.  Commercial  real  estate  prices,  according  to  many  U.S.  commercial  real  estate  indices,  are 
currently above the 2007 peak levels that contributed to the financial crisis. Accordingly, the federal banking regulatory 
agencies have expressed concerns about weaknesses in the current commercial real estate market. Our failure to have 
adequate risk management policies, procedures and controls could adversely affect our ability to increase this portfolio 
going forward and could result in an increased rate of delinquencies in, and increased losses from, this portfolio, which, 
accordingly, could have a material adverse effect on our business, financial condition and results of operations.

We Are Subject to Risk Arising From The Soundness Of Other Financial Institutions

Financial services institutions are interrelated as a result of trading, clearing, counterparty, or other relationships. 
We have exposure to many different industries and counterparties, and routinely execute transactions with counterparties 
in  the  financial  services  industry,  including  commercial  banks,  brokers  and  dealers,  investment  banks,  and  other 
institutional clients. Many of these transactions expose us to credit risk in the event of a default by a counterparty or 
client. In addition, our credit risk may be exacerbated when the collateral held by us cannot be realized upon or is 
liquidated at prices not sufficient to recover the full amount of the credit or derivative exposure due to us. Any such 
losses could have a material adverse effect on our business, financial condition and results of operations.

We Operate In A Highly Competitive Industry and Market Area

We face substantial competition in all areas of our operations from a variety of different competitors, many of which 
are larger and may have more financial resources than us. Such competitors primarily include national, regional, and 
community banks within the various markets where we operate. We also face competition from many other types of 
financial institutions, including, without limitation, savings and loans, credit unions, finance companies, brokerage 
firms, insurance companies and other financial intermediaries. The financial services industry could become even more 
competitive as a result of legislative, regulatory and technological changes and continued consolidation. 

Also, technology and other changes have lowered barriers to entry and made it possible for non-banks to offer 
products and services traditionally provided by banks. In particular, the activity of financial technology companies 
(“fintechs”) has grown significantly over recent years and is expected to continue to grow. Fintechs have and may 
continue to offer bank or bank-like products and a number of fintechs have applied for bank or industrial loan charters. 
In addition, other fintechs have partnered with existing banks to allow them to offer deposit products to their customers.

Additionally, consumers can maintain funds that would have historically been held as bank deposits in brokerage 
accounts or mutual funds. Consumers can also complete transactions such as paying bills and/or transferring funds 
directly  without  the  assistance  of  banks.  The  process  of  eliminating  banks  as  intermediaries,  known  as 
“disintermediation,” could result in the loss of fee income, as well as the loss of customer deposits and the related 
income generated from those deposits. Further, many of our competitors have fewer regulatory constraints and may 
have lower cost structures than us. Additionally, due to their size, many competitors may be able to achieve economies 
of scale and, as a result, may offer a broader range of products and services as well as better pricing for those products 
and services than we can.

Our ability to compete successfully depends on a number of factors, including, among other things:

•  The ability to develop, maintain and build long-term customer relationships based on top quality service, high ethical 

standards and safe, sound assets.

•  The ability to expand within our marketplace and with our market position.

21

•  The scope, relevance and pricing of products and services offered to meet customer needs and demands.

•  The rate at which we introduce new products and services relative to our competitors.

•  Customer satisfaction with our level of service.

• 

Industry and general economic trends.

Failure to perform in any of these areas could significantly weaken our competitive position, which could adversely 
affect  our  growth  and  profitability,  which,  in  turn,  could  have  a  material  adverse  effect  on  our  business,  financial 
condition and results of operations.

We Are Subject To Extensive Government Regulation and Supervision and Related Enforcement Powers and Other 
Legal Remedies

We, primarily through Cullen/Frost, Frost Bank and certain non-bank subsidiaries, are subject to extensive federal 
and state regulation and supervision, which vests a significant amount of discretion in the various regulatory authorities. 
Banking regulations are primarily intended to protect depositors’ funds, federal deposit insurance funds and the banking 
system as a whole, not security holders. These regulations and supervisory guidance affect our lending practices, capital 
structure,  investment  practices,  dividend  policy  and  growth,  among  other  things.  Congress  and  federal  regulatory 
agencies continually review banking laws, regulations and policies for possible changes. The Dodd-Frank Act, enacted 
in July 2010, instituted major changes to the banking and financial institutions regulatory regimes. Other changes to 
statutes,  regulations  or  regulatory  policies  or  supervisory  guidance,  including  changes  in  interpretation  or 
implementation of statutes, regulations, policies or supervisory guidance, could affect us in substantial and unpredictable 
ways. Such changes could subject us to additional costs, limit the types of financial services and products we may offer 
and/or increase the ability of non-banks to offer competing financial services and products, among other things. Failure 
to comply with laws, regulations, policies or supervisory guidance could result in enforcement and other legal actions 
by Federal or state authorities, including criminal and civil penalties, the loss of FDIC insurance, the revocation of a 
banking charter, other sanctions by regulatory agencies, civil money penalties and/or reputational damage. In this regard, 
government  authorities,  including  the  bank  regulatory  agencies,  are  pursuing  aggressive  enforcement  actions  with 
respect to compliance and other legal matters involving financial activities, which heightens the risks associated with 
actual and perceived compliance failures. Directives issued to enforce such actions may be confidential and thus, in 
some instances, we are not permitted to publicly disclose these actions. Any of the foregoing could have a material 
adverse effect on our business, financial condition and results of operations.

See the sections captioned “Supervision and Regulation” included in Item 1. Business and Note 9 - Capital and 
Regulatory  Matters  in  the  notes  to  consolidated  financial  statements  included  in  Item 8.  Financial  Statements  and 
Supplementary Data elsewhere in this report.

Our Accounting Estimates and Risk Management Processes Rely On Analytical and Forecasting Models

The processes we use to estimate our inherent loan losses and to measure the fair value of financial instruments, as 
well as the processes used to estimate the effects of changing interest rates and other market measures on our financial 
condition and results of operations, depends upon the use of analytical and forecasting models. These models reflect 
assumptions that may not be accurate, particularly in times of market stress or other unforeseen circumstances. Even 
if these assumptions are adequate, the models may prove to be inadequate or inaccurate because of other flaws in their 
design or their implementation. If the models we use for interest rate risk and asset-liability management are inadequate, 
we may incur increased or unexpected losses upon changes in market interest rates or other market measures. If the 
models we use for determining our probable loan losses are inadequate, the allowance for loan losses may not be 
sufficient to support future charge-offs. If the models we use to measure the fair value of financial instruments are 
inadequate, the fair value of such financial instruments may fluctuate unexpectedly or may not accurately reflect what 
we could realize upon sale or settlement of such financial instruments. Any such failure in our analytical or forecasting 
models could have a material adverse effect on our business, financial condition and results of operations.

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Changes In Accounting Standards Could Materially Impact Our Financial Statements

From time to time accounting standards setters change the financial accounting and reporting standards that govern 
the preparation of our financial statements. These changes can be difficult to predict and can materially impact how 
we record and report our financial condition and results of operations. In some cases, we could be required to apply a 
new or revised standard retroactively, resulting in changes to previously reported financial results or a cumulative 
charge to retained earnings. See Note 20 - Accounting Standards Updates in the notes to consolidated financial statements 
included  in  Item  8.  Financial  Statements  and  Supplementary  Data  elsewhere  in  this  report  for  further  information 
regarding pending accounting standards updates.

The Repeal Of Federal Prohibitions On Payment Of Interest On Demand Deposits Could Increase Our Interest Expense

All federal prohibitions on the ability of financial institutions to pay interest on demand deposit accounts were 
repealed as part of the Dodd-Frank Act beginning on July 21, 2011. As a result, some financial institutions offer interest 
on demand deposits to compete for customers. We do not yet know what interest rates other institutions may offer as 
market interest rates increase. Our interest expense will increase and our net interest margin will decrease if we begin 
offering interest on demand deposits to attract additional customers or maintain current customers, which could have 
a material adverse effect on our business, financial condition and results of operations.

We May Need To Raise Additional Capital In The Future, and Such Capital May Not Be Available When Needed Or 
At All

We may need to raise additional capital in the future to provide us with sufficient capital resources and liquidity to 
meet our commitments and business needs, particularly if our asset quality or earnings were to deteriorate significantly. 
Our ability to raise additional capital, if needed, will depend on, among other things, conditions in the capital markets 
at that time, which are outside of our control, and our financial condition. Economic conditions and the loss of confidence 
in financial institutions may increase our cost of funding and limit access to certain customary sources of capital, 
including inter-bank borrowings, repurchase agreements and borrowings from the discount window of the Federal 
Reserve.

We cannot assure that such capital will be available on acceptable terms or at all. Any occurrence that may limit our 
access  to  the  capital  markets,  such  as  a  decline  in  the  confidence  of  debt  purchasers,  depositors  of  Frost  Bank  or 
counterparties participating in the capital markets, or a downgrade of Cullen/Frost’s or Frost Bank’s debt ratings, may 
adversely affect our capital costs and our ability to raise capital and, in turn, our liquidity. Moreover, if we need to raise 
capital in the future, we may have to do so when many other financial institutions are also seeking to raise capital and 
would have to compete with those institutions for investors. An inability to raise additional capital on acceptable terms 
when needed could have a materially adverse effect on our business, financial condition and results of operations.

The Value Of Our Goodwill and Other Intangible Assets May Decline In The Future

As of December 31, 2019, we had $657.4 million of goodwill and other intangible assets. A significant decline in 
our expected future cash flows, a significant adverse change in the business climate, slower growth rates or a significant 
and sustained decline in the price of Cullen/Frost’s common stock may necessitate taking charges in the future related 
to the impairment of our goodwill and other intangible assets. If we were to conclude that a future write-down of 
goodwill and other intangible assets is necessary, we would record the appropriate charge, which could have a material 
adverse effect on our business, financial condition and results of operations.

We Are Subject To Risk Arising From Failure Or Circumvention Of Our Controls and Procedures

Our internal controls, disclosure controls and procedures, and corporate governance policies and procedures are 
based in part on certain assumptions and can provide only reasonable, not absolute, assurances that the objectives of 
the system are met. Any failure or circumvention of our controls and procedures; failure to comply with regulations 
related to controls and procedures; and failure to comply with our corporate governance policies and procedures could 
have a material adverse effect on our reputation, business, financial condition and results of operations.

23

New Lines Of Business Or New Products and Services May Subject Us To Additional Risks

From time to time, we implement new lines of business or offer new products and services within existing lines of 
business. There are substantial risks and uncertainties associated with these efforts, particularly in instances where the 
markets are not fully developed. In developing and marketing new lines of business and/or new products and services 
we invest significant time and resources. Initial timetables for the introduction and development of new lines of business 
and/or new products or services may not be achieved and price and profitability targets may not prove feasible. External 
factors, such as compliance with regulations, competitive alternatives, and shifting market preferences, may also impact 
the successful implementation of a new line of business or a new product or service. Furthermore, any new line of 
business and/or new product or service could have a significant impact on the effectiveness of our system of internal 
controls. Failure to successfully manage these risks in the development and implementation of new lines of business 
or new products or services could have a material adverse effect on our business, financial condition and results of 
operations.

Our Reputation and Our Business Are Subject to Negative Publicity Risk 

Reputation risk, or the risk to our earnings and capital from negative public opinion, is inherent in our business. 
Negative public opinion could adversely affect our ability to keep and attract customers and expose us to adverse legal 
and regulatory consequences. Negative public opinion could result from our actual or alleged conduct in any number 
of activities, including lending practices, corporate governance, regulatory compliance, mergers and acquisitions, and 
disclosure, sharing or inadequate protection of customer information, and from actions taken by government regulators 
and community organizations in response to that conduct. Negative public opinion could also result from adverse news 
or publicity that impairs the reputation of the financial services industry generally. In addition, our reputation or prospects 
may be significantly damaged by adverse publicity or negative information regarding us, whether or not true, that may 
be posted on social media, non-mainstream news services or other parts of the internet, and this risk is magnified by 
the speed and pervasiveness with which information is disseminated through those channels. Because we conduct most 
of our business under the “Frost” brand, negative public opinion about one business could affect our other businesses.

Our Business, Financial Condition and Results Of Operations Are Subject To Risk From Changes in Customer Behavior 

Individual, economic, political, industry-specific conditions and other factors outside of our control, such as fuel 
prices, energy costs, real estate values or other factors that affect customer income levels, could alter anticipated customer 
behavior, including borrowing, repayment, investment and deposit practices. Such a change in these practices could 
materially adversely affect our ability to anticipate business needs and meet regulatory requirements. Further, difficult 
economic conditions may negatively affect consumer confidence levels. A decrease in consumer confidence levels 
would likely aggravate the adverse effects of these difficult market conditions on us, our customers and others in the 
financial institutions industry.

Cullen/Frost Relies On Dividends From Its Subsidiaries For Most Of Its Revenue

Cullen/Frost is a separate and distinct legal entity from its subsidiaries. It receives substantially all of its revenue 
from dividends from its subsidiaries. These dividends are the principal source of funds to pay dividends on Cullen/
Frost’s common stock and preferred stock and interest and principal on Cullen/Frost’s debt. Various federal and state 
laws and regulations limit the amount of dividends that Frost Bank and certain non-bank subsidiaries may pay to Cullen/
Frost. Also, Cullen/Frost’s right to participate in a distribution of assets upon a subsidiary’s liquidation or reorganization 
is subject to the prior claims of the subsidiary’s creditors. In the event Frost Bank is unable to pay dividends to Cullen/
Frost, Cullen/Frost may not be able to service debt, pay obligations or pay dividends on our common stock or our 
preferred stock. The inability to receive dividends from Frost Bank could have a material adverse effect on our business, 
financial condition and results of operations.

See the section captioned “Supervision and Regulation” in Item 1. Business and Note 9 - Capital and Regulatory 
Matters in the notes to consolidated financial statements included in Item 8. Financial Statements and Supplementary 
Data elsewhere in this report.

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Potential Acquisitions May Disrupt Our Business and Dilute Stockholder Value

We generally seek merger or acquisition partners that are culturally similar and have experienced management and 
possess either significant market presence or have potential for improved profitability through financial management, 
economies  of  scale  or  expanded  services. Acquiring  other  banks,  businesses,  or  branches  involves  various  risks 
commonly associated with acquisitions, including, among other things:

•  Potential exposure to unknown or contingent liabilities of the target company.

•  Exposure to potential asset quality issues of the target company.

•  Potential disruption to our business.

•  Potential diversion of our management’s time and attention.

•  The possible loss of key employees and customers of the target company.

•  Difficulty in estimating the value of the target company.

•  Potential changes in banking or tax laws or regulations that may affect the target company.

Acquisitions typically involve the payment of a premium over book and market values, and, therefore, some dilution 
of our tangible book value and net income per common share may occur in connection with any future transaction. 
Furthermore, failure to realize the expected revenue increases, cost savings, increases in geographic or product presence, 
and/or other projected benefits from an acquisition could have a material adverse effect on our business, financial 
condition and results of operations.

Acquisitions May Be Delayed, Impeded, Or Prohibited Due To Regulatory Issues

Acquisitions by financial institutions, including us, are subject to approval by a variety of federal and state regulatory 
agencies  (collectively,  “regulatory  approvals”). The  process  for  obtaining  these  required  regulatory  approvals  has 
become substantially more difficult since the global financial crisis, and our ability to engage in certain merger or 
acquisition transactions depends on the bank regulators' views at the time as to our capital levels, quality of management, 
and overall condition, in addition to their assessment of a variety of other factors, including our compliance with law. 
Regulatory approvals could be delayed, impeded, restrictively conditioned or denied due to existing or new regulatory 
issues we have, or may have, with regulatory agencies, including, without limitation, issues related to Bank Secrecy 
Act compliance, Community Reinvestment Act issues, fair lending laws, fair housing laws, consumer protection laws, 
unfair, deceptive, or abusive acts or practices regulations and other similar laws and regulations. We may fail to pursue, 
evaluate or complete strategic and competitively significant acquisition opportunities as a result of our inability, or 
perceived or anticipated inability, to obtain regulatory approvals in a timely manner, under reasonable conditions or at 
all. Difficulties associated with potential acquisitions that may result from these factors could have a material adverse 
effect on our business, financial condition and results of operations.

We Are Subject To Liquidity Risk

We require liquidity to meet our deposit and debt obligations as they come due. Our access to funding sources in 
amounts adequate to finance our activities or on terms that are acceptable to us could be impaired by factors that affect 
us specifically or the financial services industry or economy generally. Factors that could reduce our access to liquidity 
sources include a downturn in the Texas economy, difficult credit markets or adverse regulatory actions against us. Our 
access to deposits may also be affected by the liquidity needs of our depositors. In particular, a substantial majority of 
our liabilities are demand, savings, interest checking and money market deposits, which are payable on demand or 
upon several days’ notice, while by comparison, a substantial portion of our assets are loans, which cannot be called 
or sold in the same time frame. We may not be able to replace maturing deposits and advances as necessary in the 
future, especially if a large number of our depositors sought to withdraw their accounts, regardless of the reason. A 
failure to maintain adequate liquidity could have a material adverse effect on our business, financial condition and 
results of operations.

We May Not Be Able To Attract and Retain Skilled People

Our success depends, in large part, on our ability to attract and retain key people. Competition for the best people 
in many activities engaged in by us is intense and we may not be able to hire people or to retain them. We do not 
currently have employment agreements or non-competition agreements with any of our senior officers. The unexpected 
loss of services of key personnel could have a material adverse impact on our business, financial condition and results 
of operations because of their customer relationships, skills, knowledge of our market, years of industry experience 

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and  the  difficulty  of  promptly  finding  qualified  replacement  personnel.  In  addition,  the  scope  and  content  of  U.S. 
banking regulators' policies on incentive compensation, as well as changes to these policies, could adversely affect our 
ability to hire, retain and motivate our key employees.

We Are Subject To Government Regulation and Oversight Relating to Data and Privacy Protection

Our business requires the collection and retention of large volumes of customer data, including personally identifiable 
information in various information systems that we maintain and in those maintained by third parties with whom we 
contract to provide data services. We also maintain important internal company data such as personally identifiable 
information about our employees and information relating to our operations. The integrity and protection of that customer 
and company data is important to us. Our collection of such customer and company data is subject to extensive regulation 
and oversight. As further discussed below, such customer and company data may be jeopardized from the compromise 
of customers’ personal electronic devices or as a result of a data security breach in our systems or the systems of third 
parties. Losses due to unauthorized account activity could harm our reputation and may have adverse effects on our 
business, financial condition and results of operations.

We are subject to laws and regulations relating to the privacy of the information of our clients, employees or others, 
and any failure to comply with these laws and regulations could expose us to liability and/or reputational damage. As 
new privacy-related laws and regulations are implemented, the time and resources needed for us to comply with such 
laws and regulations, as well as our potential liability for non-compliance and reporting obligations in the case of data 
breaches, may significantly increase.

Our Information Systems May Experience Failure, Interruption Or Breach In Security

In the ordinary course of business, we rely on electronic communications and information systems to conduct our 
operations and to store sensitive data. Any failure, interruption or breach in security of these systems could result in 
significant disruption to our operations. Information security breaches and cybersecurity-related incidents include, but 
are  not  limited  to,  attempts  to  access  information,  including  customer  and  company  information,  malicious  code, 
computer viruses and denial of service attacks that could result in unauthorized access, misuse, loss or destruction of 
data (including confidential customer information), account takeovers, unavailability of service or other events. These 
types of threats may derive from human error, fraud or malice on the part of external or internal parties, or may result 
from accidental technological failure. Our technologies, systems, networks and software have been and continue to be 
subject to cybersecurity threats and attacks, which range from uncoordinated individual attempts to sophisticated and 
targeted measures directed at us. The risk of a security breach or disruption, particularly through cyber attack or cyber 
intrusion, has increased as the number, intensity and sophistication of attempted attacks and intrusions from around 
the world have increased.

Our customers and employees have been, and will continue to be, targeted by parties using fraudulent e-mails and 
other communications in attempts to misappropriate passwords, bank account information or other personal information 
or to introduce viruses or other malware through “Trojan horse” programs to our information systems, the information 
systems of our merchants or third party service providers and/or our customers' computers. Though we endeavor to 
mitigate these threats through product improvements, use of encryption and authentication technology and customer 
and employee education, such cyber attacks against us or our merchants and our third party service providers remain 
a serious issue. Further, to access our products and services our customers use personal electronic devices that are 
beyond our security control systems. The pervasiveness of cybersecurity incidents in general and the risks of cyber 
crime are complex and continue to evolve. More generally, publicized information concerning security and cyber-
related problems could inhibit the use or growth of electronic or web-based applications or solutions as a means of 
conducting commercial transactions.

Cloud technologies are also critical to the operation of our systems, and our reliance on cloud technologies is growing. 
Service disruptions in cloud technologies may lead to delays in accessing, or the loss of, data that is important to our 
businesses and may hinder our clients’ access to our products and services.

Although we make significant efforts to maintain the security and integrity of our information systems and have 
implemented various measures to manage the risk of a security breach or disruption, there can be no assurance that our 
security efforts and measures will be effective or that attempted security breaches or disruptions would not be successful 
or damaging. Even the most well protected information, networks, systems and facilities remain potentially vulnerable 
because attempted security breaches, particularly cyber attacks and intrusions, or disruptions will occur in the future, 
and because the techniques used in such attempts are constantly evolving and generally are not recognized until launched 
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against a target, and in some cases are designed not to be detected and, in fact, may not be detected. Accordingly, we 
may be unable to anticipate these techniques or to implement adequate security barriers or other preventative measures, 
and thus it is virtually impossible for us to entirely mitigate this risk. While we maintain specific “cyber” insurance 
coverage, which would apply in the event of various breach scenarios, the amount of coverage may not be adequate in 
any particular case. Furthermore, because cyber threat scenarios are inherently difficult to predict and can take many 
forms, some breaches may not be covered under our cyber insurance coverage. A security breach or other significant 
disruption of our information systems or those related to our customers, merchants and our third party vendors, including 
as a result of cyber attacks, could (i) disrupt the proper functioning of our networks and systems and therefore our 
operations and/or those of certain of our customers; (ii) result in the unauthorized access to, and destruction, loss, theft, 
misappropriation  or  release  of  confidential,  sensitive  or  otherwise  valuable  information  of  ours  or  our  customers; 
(iii) result in a violation of applicable privacy, data breach and other laws, subjecting us to additional regulatory scrutiny 
and  exposing  us  to  civil  litigation,  governmental  fines  and  possible  financial  liability;  (iv) require  significant 
management attention and resources to remedy the damages that result; or (v) harm our reputation or cause a decrease 
in the number of customers that choose to do business with us. The occurrence of any of the foregoing could have a 
material adverse effect on our business, financial condition and results of operations. 

Furthermore, notwithstanding the proliferation of technology and technology-based risk and control systems, our 
businesses ultimately rely on people as our greatest resource, and, from time-to-time, they make mistakes or engage 
in violations of applicable policies, laws, rules or procedures that are not always caught immediately by our technological 
processes or by our controls and other procedures, which are intended to prevent and detect such errors or violations. 
These  can  include  calculation  errors,  mistakes  in  addressing  emails,  errors  in  software  or  model  development  or 
implementation, or simple errors in judgment, as well as intentional efforts to ignore or circumvent applicable policies, 
laws, rules or procedures. Human errors, malfeasance and other misconduct, including the intentional misuse of client 
information in connection with insider trading or for other purposes, even if promptly discovered and remediated, can 
result in reputational damage, a material adverse effect on our business, financial condition, results of operations and 
legal risks.

During 2018, we experienced a data security incident that resulted in unauthorized access to a third-party lockbox 
software program used by certain of our commercial lockbox customers to store digital images. We stopped the identified 
unauthorized access and consulted with a leading cybersecurity firm. We reported the incident to, and cooperated with, 
law-enforcement authorities. We contacted each of the affected commercial customers and we supported them in taking 
appropriate actions. The identified incident did not impact other Frost systems.

Our Operations Rely On Certain External Vendors

We rely on certain external vendors to provide products and services necessary to maintain our day-to-day operations. 
These third party vendors are sources of operational and informational security risk to us, including risks associated 
with  operational  errors,  information  system  interruptions  or  breaches  and  unauthorized  disclosures  of  sensitive  or 
confidential client or customer information. If these vendors encounter any of these issues, or if we have difficulty 
communicating with them, we could be exposed to disruption of operations, loss of service or connectivity to customers, 
reputational damage, and litigation risk that could have a material adverse effect on our business and, in turn, our 
financial condition and results of operations.

In addition, our operations are exposed to risk that these vendors will not perform in accordance with the contracted 
arrangements under service level agreements. Although we have selected these external vendors carefully, we do not 
control their actions. The failure of an external vendor to perform in accordance with the contracted arrangements under 
service level agreements, because of changes in the vendor’s organizational structure, financial condition, support for 
existing products and services or strategic focus or for any other reason, could be disruptive to our operations, which 
could have a material adverse effect on our business and, in turn, our financial condition and results of operations. 
Replacing these external vendors could also entail significant delay and expense.

We Continually Encounter Technological Change

The financial services industry is continually undergoing rapid technological change with frequent introductions of 
new technology-driven products and services. The effective use of technology increases efficiency and enables financial 
institutions to better serve customers and to reduce costs. Our future success depends, in part, upon our ability to address 
the needs of our customers by using technology to provide products and services that will satisfy customer demands, 
as well as to create additional efficiencies in our operations. Many of our competitors have substantially greater resources 
to invest in technological improvements. We may not be able to effectively implement new technology-driven products 
27

and services or be successful in marketing these products and services to our customers. Failure to successfully keep 
pace with technological change affecting the financial services industry could have a material adverse effect on our 
business, financial condition and results of operations.

On the other hand, our implementation of certain new technologies, such as those related to artificial intelligence 
and algorithms, in our business processes may have unintended consequences due to their limitations or our failure to 
use them effectively, which could also have a material adverse effect on our business, financial condition, results of 
operations and legal risks.

We Are Subject To Litigation Risk Pertaining To Fiduciary Responsibility

From time to time, customers make claims and take legal action pertaining to our performance of our fiduciary 
responsibilities. Whether customer claims and legal action related to our performance of our fiduciary responsibilities 
are founded or unfounded, if such claims and legal actions are not resolved in a manner favorable to us they may result 
in significant financial liability and/or adversely affect the market perception of us and our products and services as 
well as impact customer demand for those products and services. Any financial liability or reputational damage could 
have a material adverse effect on our business, financial condition and results of operations.

We Are Subject To Litigation Risk Pertaining To Intellectual Property

Banking and other financial services companies, including us, rely on technology companies to provide information 
technology products and services necessary to support day-to-day operations. Technology companies frequently enter 
into litigation based on allegations of patent infringement or other violations of intellectual property rights. In addition, 
patent holding companies seek to monetize patents they have purchased or otherwise obtained. Competitors of our 
vendors, or other individuals or companies, have from time to time claimed to hold intellectual property sold to us by 
our vendors and we are, and may in the future be, named as defendants in various related litigation. Such claims may 
increase in the future as the financial services sector becomes more reliant on information technology vendors. The 
plaintiffs in these actions frequently seek injunctions and substantial damages.

Regardless of the scope or validity of such patents or other intellectual property rights, or the merits of any claims 
by potential or actual litigants, we may have to engage in protracted litigation. Such litigation is often expensive, time-
consuming, disruptive to our operations and distracting to management. If we are found to infringe upon one or more 
patents or other intellectual property rights, we may be required to pay substantial damages or royalties to a third-party. 
In certain cases, we may consider entering into licensing agreements for disputed intellectual property, although no 
assurance can be given that such licenses can be obtained on acceptable terms or that litigation will not occur. These 
licenses may also significantly increase our operating expenses. If legal matters related to intellectual property claims 
were resolved against us or settled, we could be required to make payments in amounts that could have a material 
adverse effect on our business, financial condition and results of operations.

We Are Subject To Environmental Liability Risk Associated With Lending Activities

A significant portion of our loan portfolio is secured by real property. During the ordinary course of business, we 
foreclose on and take title to properties securing certain loans. In doing so, there is a risk that hazardous or toxic 
substances  could  be  found  on  these  properties.  If  hazardous  or  toxic  substances  are  found,  we  may  be  liable  for 
remediation costs, as well as for personal injury and property damage. Environmental laws may require us to incur 
substantial expenses and may materially reduce the affected property’s value or limit our ability to use or sell the affected 
property. In addition, future laws or more stringent interpretations or enforcement policies with respect to existing laws 
may  increase  our  exposure  to  environmental  liability.  Environmental  reviews  of  real  property  before  initiating 
foreclosure actions may not be sufficient to detect all potential environmental hazards. The remediation costs and any 
other financial liabilities associated with an environmental hazard could have a material adverse effect on our business, 
financial condition and results of operations.

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Severe Weather, Natural Disasters, Acts Of War Or Terrorism and Other External Events Could Significantly Impact 
Our Business

Severe weather, natural disasters, acts of war or terrorism and other adverse external events could have a significant 
impact on our ability to conduct business. In addition, such events could affect the stability of our deposit base, impair 
the ability of borrowers to repay outstanding loans, impair the value of collateral securing loans, cause significant 
property damage, result in loss of revenue and/or cause us to incur additional expenses. The occurrence of any such 
event in the future could have a material adverse effect on our business, which, in turn, could have a material adverse 
effect on our business, financial condition and results of operations.

Financial Services Companies Depend On The Accuracy and Completeness Of Information About Customers and 
Counterparties

In deciding whether to extend credit or enter into other transactions, we rely on information furnished by or on behalf 
of customers and counterparties, including financial statements, credit reports and other financial information. We also 
rely on representations of those customers, counterparties or other third parties, such as independent auditors, as to the 
accuracy and completeness of that information. Reliance on inaccurate or misleading financial statements, credit reports 
or other financial information could have a material adverse impact on our business, financial condition and results of 
operations.

Changes In The Federal, State Or Local Tax Laws May Negatively Impact Our Financial Performance

We are subject to changes in tax law that could increase our effective tax rates. These law changes may be retroactive 
to previous periods and as a result could negatively affect our current and future financial performance. Furthermore, 
the full impact of the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, on us and our customers 
remains uncertain, creating uncertainty and risk related to our customers' future demand for credit and our future results. 
Increased economic activity expected to result from the decrease in federal income tax rates on businesses generally 
could spur additional economic activity that would encourage additional borrowing. At the same time, some customers 
may elect to use their additional cash flow from lower taxes to fund their existing levels of activity, decreasing borrowing 
needs. The elimination of the federal income tax deductibility of business interest expense for a significant number of 
our customers effectively increases the cost of borrowing and could make equity or hybrid funding relatively more 
attractive. This could have a long-term negative impact on business customer borrowing. There is no assurance that 
presently anticipated benefits of federal income tax reform for us will be realized.

We Are Subject To Examinations and Challenges By Tax Authorities

We are subject to federal and applicable state tax regulations. Such tax regulations are often complex and require 
interpretation and changes in these regulations could negatively impact our results of operations. In the normal course 
of business, we are routinely subject to examinations and challenges from federal and applicable state tax authorities 
regarding the amount of taxes due in connection with investments we have made and the businesses in which we have 
engaged. Recently, federal and state taxing authorities have become increasingly aggressive in challenging tax positions 
taken by financial institutions. These tax positions may relate to tax compliance, sales and use, franchise, gross receipts, 
payroll, property and income tax issues, including tax base, apportionment and tax credit planning. The challenges 
made by tax authorities may result in adjustments to the timing or amount of taxable income or deductions or the 
allocation of income among tax jurisdictions. If any such challenges are made and are not resolved in our favor, they 
could have a material adverse effect on our business, financial condition and results of operations.

Risks Associated With Our Common Stock

Our Stock Price Can Be Volatile

Stock price volatility may make it more difficult for you to resell your common stock when you want and at prices 
you find attractive. Our stock price can fluctuate significantly in response to a variety of factors including, among other 
things:

•  Actual or anticipated variations in quarterly results of operations.

•  Recommendations by securities analysts.

•  Operating and stock price performance of other companies that investors deem comparable to us.

•  News reports relating to trends, concerns and other issues in the financial services industry.

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•  Perceptions in the marketplace regarding us and/or our competitors.

•  New technology used, or services offered, by competitors. 

•  The issuance by us of additional securities, including common stock and securities that are convertible into or 

exchangeable for, or that represent the right to receive, common stock.

•  Sales of a large block of shares of our common stock or similar securities in the market after an equity offering, or 

the perception that such sales could occur.

•  Significant acquisitions or business combinations, strategic partnerships, joint ventures or capital commitments by 

or involving us or our competitors.

•  Failure to integrate acquisitions or realize anticipated benefits from acquisitions.

•  Changes in government regulations.

•  Geopolitical conditions such as acts or threats of terrorism or military conflicts.

General market fluctuations, including real or anticipated changes in the strength of the Texas economy; industry 
factors and general economic and political conditions and events, such as economic slowdowns or recessions; interest 
rate changes, oil price volatility or credit loss trends could also cause our stock price to decrease regardless of operating 
results.

The Trading Volume In Our Common Stock Is Less Than That Of Other Larger Financial Services Companies

Although our common stock is listed for trading on the New York Stock Exchange (NYSE), the trading volume in 
our common stock is less than that of other, larger financial services companies. A public trading market having the 
desired characteristics of depth, liquidity and orderliness depends on the presence in the marketplace of willing buyers 
and sellers of our common stock at any given time. This presence depends on the individual decisions of investors and 
general economic and market conditions over which we have no control. Given the lower trading volume of our common 
stock, significant sales of our common stock, or the expectation of these sales, could cause our stock price to fall.

Cullen/Frost May Not Continue To Pay Dividends On Its Common Stock In The Future

Holders of Cullen/Frost common stock are only entitled to receive such dividends as its board of directors may 
declare out of funds legally available for such payments. Although Cullen/Frost has historically declared cash dividends 
on its common stock, it is not required to do so and may reduce or eliminate its common stock dividend in the future. 
This could adversely affect the market price of Cullen/Frost’s common stock. Also, Cullen/Frost is a bank holding 
company, and its ability to declare and pay dividends is dependent on certain federal regulatory considerations, including 
the guidelines of the Federal Reserve Board regarding capital adequacy and dividends. 

As more fully discussed in Note 9 - Capital and Regulatory Matters in the notes to consolidated financial statements 
included in Item 8. Financial Statements and Supplementary Data elsewhere in this report, our ability to declare or pay 
dividends on our common stock may also be subject to certain restrictions in the event that we elect to defer the payment 
of interest on our junior subordinated deferrable interest debentures or do not declare and pay dividends on our Series 
A Preferred Stock.

An Investment In Our Common Stock Is Not An Insured Deposit

Our common stock is not a bank deposit and, therefore, is not insured against loss by the Federal Deposit Insurance 
Corporation (FDIC), any other deposit insurance fund or by any other public or private entity. Investment in our common 
stock is inherently risky for the reasons described in this “Risk Factors” section and elsewhere in this report and is 
subject to the same market forces that affect the price of common stock in any company. As a result, if you acquire our 
common stock, you could lose some or all of your investment.

Certain Banking Laws May Have An Anti-Takeover Effect

Provisions of federal banking laws, including regulatory approval requirements, could make it more difficult for a 
third party to acquire us, even if doing so would be perceived to be beneficial to our shareholders. These provisions 
effectively inhibit a non-negotiated merger or other business combination, which, in turn, could adversely affect the 
market price of our common stock.

30

ITEM 1B. UNRESOLVED STAFF COMMENTS

None

ITEM 2. PROPERTIES

Our headquarters is located in downtown San Antonio, Texas. These facilities, which we lease, house our executive 
and primary administrative offices, as well as the principal banking headquarters of Frost Bank. We also own or lease 
other facilities within our primary market areas in the regions of Austin, Corpus Christi, Dallas, Fort Worth, Houston, 
Permian Basin, Rio Grande Valley and San Antonio. We consider our properties to be suitable and adequate for our 
present needs.

ITEM 3. LEGAL PROCEEDINGS

We are subject to various claims and legal actions that have arisen in the course of conducting business. Management 
does not expect the ultimate disposition of these matters to have a material adverse effect on our business, financial 
condition and results of operations.

ITEM 4. MINE SAFETY DISCLOSURES

None

31

PART II

ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS 
AND ISSUER PURCHASES OF EQUITY SECURITIES

Market for Our Common Stock

Our common stock is traded on the New York Stock Exchange, Inc. (“NYSE”) under the symbol “CFR”. As of 
December 31, 2019, there were 62,669,004 shares of our common stock outstanding held by 1,130 holders of record. 
The closing price per share of common stock on December 31, 2019, the last trading day of our fiscal year, was $97.78.

Stock-Based Compensation Plans

Information  regarding  stock-based  compensation  awards  outstanding  and  available  for  future  grants  as  of 
December 31, 2019, segregated between stock-based compensation plans approved by shareholders and stock-based 
compensation plans not approved by shareholders, is presented in the table below. Additional information regarding 
stock-based compensation plans is presented in Note 11 - Employee Benefit Plans in the notes to consolidated financial 
statements included in Item 8. Financial Statements and Supplementary Data elsewhere in this report.

Plan Category
Plans approved by shareholders
Plans not approved by shareholders

Total

Number of Shares
to be Issued Upon
Exercise of
Outstanding Awards

2,654,171 (1) $
—
2,654,171

Weighted-Average
Exercise
Price of
Outstanding
Awards

64.60 (2)
—
64.60

Number of Shares
Available for
Future Grants

1,105,616
—
1,105,616

(1)  Includes 1,980,866 shares related to stock options, 440,647 shares related to non-vested stock units, 55,370 shares related to 
director deferred stock units and 177,288 shares related to performance stock units (assuming attainment of the maximum 
payout rate as set forth by the performance criteria).

(2)  Excludes outstanding stock units which are exercised for no consideration.

Stock Repurchase Plans

From time to time, our board of directors has authorized stock repurchase plans. In general, stock repurchase plans 
allow us to proactively manage our capital position and return excess capital to shareholders. Shares purchased under 
such plans also provide us with shares of common stock necessary to satisfy obligations related to stock compensation 
awards. On July 24, 2019, our board of directors authorized a $100.0 million stock repurchase program, allowing us 
to repurchase shares of our common stock over a one-year period from time to time at various prices in the open market 
or through private transactions. Under this plan, we repurchased 202,724 shares at a total cost of $17.2 million during 
2019. Under prior stock repurchase programs, we repurchased 496,307 shares at a total cost of $50.0 million during 
2019, 1,027,292 shares at a total cost of $100.0 million during 2018 and 1,134,966 shares at a total cost of $100.0 
million during 2017.

The following table provides information with respect to purchases made by or on behalf of us or any “affiliated 
purchaser” (as defined in Rule 10b-18(a)(3) under the Securities Exchange Act of 1934), of our common stock during 
the fourth quarter of 2019.

Period
October 1, 2019 to October 31, 2019
November 1, 2019 to November 30, 2019
December 1, 2019 to December 31, 2019
Total

Total Number of
Shares Purchased

Average Price
Paid Per Share
92.84
—
—

11,680 (1) $
—
—
11,680

(1)  Repurchases made in connection with the vesting of certain share awards.

32

Total Number of
Shares Purchased
as Part of Publicly
Announced Plans

Maximum Number 
(or Approximate 
Dollar Value) of 
Shares That May Yet 
Be Purchased Under 
the Plans at 
the End of the Period
82,809
82,809
82,809

— $
—
—
—

Performance Graph

The performance graph below compares the cumulative total shareholder return on Cullen/Frost Common Stock 
with the cumulative total return on the equity securities of companies included in the Standard & Poor’s 500 Stock 
Index and the Standard and Poor’s 500 Bank Index, measured at the last trading day of each year shown. The graph 
assumes an investment of $100 on December 31, 2014 and reinvestment of dividends on the date of payment without 
commissions. The performance graph represents past performance and should not be considered to be an indication of 
future performance.

Cullen/Frost
S&P 500
S&P 500 Banks

$

2014
100.00
100.00
100.00

$

2015

87.56
101.38
100.85

$

2016
133.10
113.51
125.36

$

2017
146.31
138.29
153.64

$

2018
139.22
132.23
128.38

$

2019
159.54
173.86
180.55

33

ITEM 6. SELECTED FINANCIAL DATA

The following consolidated selected financial data is derived from our audited financial statements as of and for the 
five  years  ended  December 31,  2019.  The  following  consolidated  financial  data  should  be  read  in  conjunction 
with Management’s Discussion and Analysis of Financial Condition and Results of Operations and the Consolidated 
Financial Statements and related notes included elsewhere in this report. Beginning in 2018, a new accounting standard 
required us to report network costs associated with debit card and ATM transactions netted against the related interchange 
and debit card fee income from such transactions. Previously, such network costs were reported as a component of 
other non-interest expense. The operating results of companies acquired during the periods presented are included with 
our results of operations since their respective dates of acquisition. Dollar amounts, except per share data, and common 
shares outstanding are in thousands.

Consolidated Statements of Income
Interest income:

Loans, including fees
Securities
Interest-bearing deposits
Federal funds sold and resell agreements

$

Total interest income

Interest expense:

Deposits
Federal funds purchased and repurchase
agreements
Junior subordinated deferrable interest
debentures
Subordinated notes payable and other
borrowings

Total interest expense

Net interest income
Provision for loan losses

Net interest income after provision
for loan losses
Non-interest income:

Trust and investment management fees
Service charges on deposit accounts
Insurance commissions and fees
Interchange and debit card transaction fees
Other charges, commissions and fees
Net gain (loss) on securities transactions
Other

Total non-interest income

Non-interest expense:
Salaries and wages
Employee benefits
Net occupancy
Technology, furniture and equipment
Deposit insurance
Intangible amortization
Other

Total non-interest expense

Income before income taxes
Income taxes
Net income

Preferred stock dividends

Net income available to common
shareholders

2019

2018

2017

2016

2015

Year Ended December 31,

$

741,747
350,924
35,590
5,524
1,133,785

$

669,002
319,728
56,968
5,500
1,051,198

$

534,804
315,599
41,608
936
892,947

$

458,094
313,943
16,103
272
788,412

99,742

19,675

5,706

4,657
129,780
1,004,005
33,759

75,337

17,188

8,021

5,291

4,657
93,306
957,892
21,613

1,522

3,955

3,860
26,525
866,422
35,460

7,248

204

3,281

1,343
12,076
776,336
51,673

433,872
307,394
8,123
107
749,496

9,024

167

2,725

948
12,864
736,632
51,845

970,246

936,279

830,962

724,663

684,787

126,722
88,983
52,345
14,873
37,123
293
43,563
363,902

375,029
86,230
89,466
91,995
10,126
1,168
180,665
834,679
499,469
55,870
443,599
8,063

119,391
85,186
48,967
13,877
37,231
(156)
46,790
351,286

350,312
77,323
76,788
83,102
16,397
1,424
173,538
778,884
508,681
53,763
454,918
8,063

110,675
84,182
46,169
23,232
39,931
(4,941)
37,222
336,470

337,068
74,575
75,971
74,335
20,128
1,703
175,289
759,069
408,363
44,214
364,149
8,063

104,240
81,203
47,154
21,369
39,623
14,975
41,144
349,708

318,665
72,615
71,627
71,208
17,428
2,429
178,988
732,960
341,411
37,150
304,261
8,063

105,512
81,350
48,926
19,666
37,551
69
35,656
328,730

310,504
69,746
65,690
64,373
14,519
3,325
165,561
693,718
319,799
40,471
279,328
8,063

$

435,536

$

446,855

$

356,086

$

296,198

$

271,265

34

Per Common Share Data

Net income - basic
Net income - diluted
Cash dividends declared and paid
Book value

Common Shares Outstanding

Period-end
Weighted-average shares - basic
Dilutive effect of stock compensation
Weighted - average shares - diluted

Performance Ratios

Return on average assets
Return on average common equity
Net interest income to average earning
assets
Dividend pay-out ratio

Balance Sheet Data

Period-end:
Loans
Earning assets
Total assets
Non-interest-bearing demand deposits
Interest-bearing deposits
Total deposits
Long-term debt and other borrowings
Shareholders’ equity

Average:
Loans
Earning assets
Total assets
Non-interest-bearing demand deposits
Interest-bearing deposits
Total deposits
Long-term debt and other borrowings
Shareholders’ equity

Asset Quality

Allowance for loan losses
Allowance for losses to year-end loans
Net loan charge-offs
Net loan charge-offs to average loans
Non-performing assets
Non-performing assets to:

Total loans plus foreclosed assets
Total assets

Consolidated Capital Ratios

Common equity tier 1 risk-based ratio
Tier 1 risk-based ratio
Total risk-based ratio
Leverage ratio
Average shareholders’ equity to average
total assets

As of or for the Year Ended December 31,

2019

2018

2017

2016

2015

$

$

6.89
6.84
2.80
60.11

62,669
62,742
700
63,442

1.36%
12.24

3.75
40.64

$

6.97
6.90
2.58
51.19

62,986
63,705
982
64,687

1.44%
14.23

3.64
37.03

$

5.56
5.51
2.25
49.68

63,476
63,694
968
64,662

1.17%
11.76

3.69
40.49

$

4.73
4.70
2.15
45.03

63,474
62,376
593
62,969

1.03%
10.16

3.56
45.54

4.31
4.28
2.10
44.30

61,982
62,758
715
63,473

0.97%
9.86

3.45
48.72

$ 14,750,332
31,280,550
34,027,428
10,873,629
16,765,935
27,639,564
235,164
3,911,668

$ 14,440,549
29,600,422
32,085,851
10,358,416
16,054,861
26,413,277
235,064
3,702,039

$ 14,099,733
29,894,185
32,292,966
10,997,494
16,151,710
27,149,204
234,950
3,368,917

$ 13,617,940
28,899,578
31,029,850
10,756,808
15,532,258
26,289,066
234,850
3,284,376

$ 13,145,665
29,595,375
31,747,880
11,197,093
15,675,296
26,872,389
234,736
3,297,863

$ 12,460,148
28,359,131
30,450,207
10,819,426
15,085,492
25,904,918
226,194
3,173,264

$ 11,975,392
28,025,439
30,196,319
10,513,369
15,298,206
25,811,575
236,117
3,002,528

$ 11,554,823
26,717,013
28,832,093
10,034,319
14,477,525
24,511,844
236,033
3,058,896

$ 11,486,531
26,431,176
28,565,942
10,270,233
14,073,362
24,343,595
235,939
2,890,343

$ 11,267,402
25,954,510
28,060,626
10,179,810
13,860,948
24,040,758
235,856
2,895,192

$

$

$

132,167

0.90%

33,724

0.23%

109,485

$

$

$

132,132

0.94%

44,845

0.33%

74,914

$

$

$

155,364

1.18%

33,141

0.27%

157,292

$

$

$

153,045

1.28%

34,487

0.30%

102,591

$

$

$

135,859

1.18%

15,528

0.14%

85,722

0.74%
0.32

12.36%
12.99
14.57
9.28

0.53%
0.23

12.27%
12.94
14.64
9.06

1.20%
0.50

12.42%
13.16
15.15
8.46

0.86%
0.34

12.52%
13.33
14.93
8.14

0.75%
0.30

11.37%
12.38
13.85
7.79

11.54

10.58

10.42

10.61

10.32

35

The following tables set forth unaudited consolidated selected quarterly statement of operations data for the years 

ended December 31, 2019 and 2018. Dollar amounts are in thousands, except per share data.

Interest income
Interest expense
Net interest income
Provision for loan losses
Non-interest income(1)
Non-interest expense
Income before income taxes
Income taxes
Net income
Preferred stock dividends
Net income available to common shareholders
Net income per common share:

Basic
Diluted

Interest income
Interest expense
Net interest income
Provision for loan losses
Non-interest income(2)
Non-interest expense
Income before income taxes
Income taxes
Net income
Preferred stock dividends
Net income available to common shareholders
Net income per common share:

Basic
Diluted

Year Ended December 31, 2019

4th
Quarter

3rd
Quarter

2nd
Quarter

1st
Quarter

$

$

$

$

$

$

278,054
26,956
251,098
8,355
95,255
220,806
117,192
13,511
103,681
2,016
101,665

1.61
1.60

4th
Quarter

281,205
31,996
249,209
3,767
87,118
199,697
132,863
13,610
119,253
2,016
117,237

1.84
1.82

$

$

$

$

$

$

286,273
33,266
253,007
8,001
89,224
208,864
125,366
13,530
111,836
2,016
109,820

1.74
1.73

$

$

$

288,137
34,706
253,431
6,400
82,638
203,209
126,460
14,874
111,586
2,015
109,571

1.73
1.72

Year Ended December 31, 2018

3rd
Quarter

2nd
Quarter

268,716
27,051
241,665
2,650
87,657
193,668
133,004
15,160
117,844
2,016
115,828

1.80
1.78

$

$

$

257,951
20,681
237,270
8,251
85,066
188,908
125,177
13,836
111,341
2,015
109,326

1.70
1.68

$

$

$

$

$

$

281,321
34,852
246,469
11,003
96,785
201,800
130,451
13,955
116,496
2,016
114,480

1.80
1.79

1st
Quarter

243,326
13,578
229,748
6,945
91,445
196,611
117,637
11,157
106,480
2,016
104,464

1.63
1.61

(1)  Includes net gains on securities transactions of $169 thousand, $96 thousand and $28 thousand during the second, third and 

fourth quarters of 2019, respectively.

(2)  Includes net losses on securities transactions of $19 thousand, $60 thousand, $34 thousand and $43 thousand during the first, 

second, third and fourth quarters of 2018, respectively.

36

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND 
RESULTS OF OPERATIONS

Forward-Looking Statements and Factors that Could Affect Future Results

Certain statements contained in this Annual Report on Form 10-K that are not statements of historical fact constitute 
forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995 (the “Act”), 
notwithstanding that such statements are not specifically identified as such. In addition, certain statements may be 
contained in our future filings with the SEC, in press releases, and in oral and written statements made by us or with 
our approval that are not statements of historical fact and constitute forward-looking statements within the meaning of 
the Act. Examples of forward-looking statements include, but are not limited to: (i) projections of revenues, expenses, 
income or loss, earnings or loss per share, the payment or nonpayment of dividends, capital structure and other financial 
items; (ii) statements of plans, objectives and expectations of Cullen/Frost or its management or Board of Directors, 
including  those  relating  to  products,  services  or  operations;  (iii) statements  of  future  economic  performance;  and 
(iv) statements  of  assumptions  underlying  such  statements.  Words  such  as  “believes”,  “anticipates”,  “expects”, 
“intends”, “targeted”, “continue”, “remain”, “will”, “should”, “may” and other similar expressions are intended to 
identify forward-looking statements but are not the exclusive means of identifying such statements.

Forward-looking statements involve risks and uncertainties that may cause actual results to differ materially from 
those in such statements. Factors that could cause actual results to differ from those discussed in the forward-looking 
statements include, but are not limited to:

•  Local, regional, national and international economic conditions and the impact they may have on us and our 

customers and our assessment of that impact.

•  Volatility and disruption in national and international financial and commodity markets.
•  Government intervention in the U.S. financial system.
•  Changes in the mix of loan geographies, sectors and types or the level of non-performing assets and charge-

offs.

•  Changes in estimates of future reserve requirements based upon the periodic review thereof under relevant 

regulatory and accounting requirements.

•  The effects of and changes in trade and monetary and fiscal policies and laws, including the interest rate 

policies of the Federal Reserve Board.
Inflation, interest rate, securities market and monetary fluctuations.

• 
•  The effect of changes in laws and regulations (including laws and regulations concerning taxes, banking, 

securities and insurance) with which we and our subsidiaries must comply.

Political instability.
Impairment of our goodwill or other intangible assets.

•  The soundness of other financial institutions.
• 
• 
•  Acts of God or of war or terrorism.
•  The timely development and acceptance of new products and services and perceived overall value of these 

products and services by users.

•  Changes in consumer spending, borrowings and savings habits.
•  Changes in the financial performance and/or condition of our borrowers.
•  Technological changes.
•  The cost and effects of failure, interruption, or breach of security of our systems.
•  Acquisitions and integration of acquired businesses.
•  Our ability to increase market share and control expenses.
•  Our ability to attract and retain qualified employees.
•  Changes in the competitive environment in our markets and among banking organizations and other financial 

service providers.

•  The effect of changes in accounting policies and practices, as may be adopted by the regulatory agencies, as 
well as the Public Company Accounting Oversight Board, the Financial Accounting Standards Board and other 
accounting standard setters.

•  Changes in the reliability of our vendors, internal control systems or information systems.
•  Changes in our liquidity position.
•  Changes in our organization, compensation and benefit plans.

37

•  The costs and effects of legal and regulatory developments, the resolution of legal proceedings or regulatory 
or other governmental inquiries, the results of regulatory examinations or reviews and the ability to obtain 
required regulatory approvals.

•  Greater than expected costs or difficulties related to the integration of new products and lines of business.
•  Our success at managing the risks involved in the foregoing items.

Forward-looking statements speak only as of the date on which such statements are made. We do not undertake any 
obligation to update any forward-looking statement to reflect events or circumstances after the date on which such 
statement is made, or to reflect the occurrence of unanticipated events.

Application of Critical Accounting Policies and Accounting Estimates

We follow accounting and reporting policies that conform, in all material respects, to accounting principles generally 
accepted in the United States and to general practices within the financial services industry. The preparation of financial 
statements in conformity with accounting principles generally accepted in the United States requires management to 
make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. 
While we base estimates on historical experience, current information and other factors deemed to be relevant, actual 
results could differ from those estimates.

We consider accounting estimates to be critical to reported financial results if (i) the accounting estimate requires 
management to make assumptions about matters that are highly uncertain and (ii) different estimates that management 
reasonably could have used for the accounting estimate in the current period, or changes in the accounting estimate 
that are reasonably likely to occur from period to period, could have a material impact on our financial statements.

Accounting policies related to the allowance for loan losses are considered to be critical, as these policies involve 
considerable subjective judgment and estimation by management. The allowance for loan losses is a reserve established 
through a provision for loan losses charged to expense, which represents management’s best estimate of probable losses 
that  have  been  incurred  within  the  existing  portfolio  of  loans. The  allowance,  in  the  judgment  of  management,  is 
necessary to reserve for estimated loan losses and risks inherent in the loan portfolio. Our allowance for loan loss 
methodology includes allowance allocations calculated in accordance with Accounting Standards Codification (ASC) 
Topic 310, “Receivables” and allowance allocations calculated in accordance with ASC Topic 450, “Contingencies.” 
The level of the allowance reflects management’s continuing evaluation of industry concentrations, specific credit risks, 
loan  loss  experience,  current  loan  portfolio  quality,  present  economic,  political  and  regulatory  conditions  and 
unidentified losses inherent in the current loan portfolio, as well as trends in the foregoing. Portions of the allowance 
may be allocated for specific credits; however, the entire allowance is available for any credit that, in management’s 
judgment, should be charged off. While management utilizes its best judgment and information available, the ultimate 
adequacy of the allowance is dependent upon a variety of factors beyond our control, including the performance of our 
loan  portfolio,  the  economy,  changes  in  interest  rates  and  the  view  of  the  regulatory  authorities  toward  loan 
classifications. See the section captioned “Allowance for Loan Losses” elsewhere in this discussion and Note 3 - Loans 
in the notes to consolidated financial statements included in Item 8. Financial Statements and Supplementary Data 
elsewhere in this report for further details of the risk factors considered by management in estimating the necessary 
level of the allowance for loan losses.

Overview

The following discussion and analysis presents the more significant factors that affected our financial condition as 
of December 31, 2019 and 2018 and results of operations for each of the years then ended. Refer to Management’s 
Discussion and Analysis of Financial Condition and Results of Operations included in our Annual Report on Form 10-
K filed with the SEC on February 6, 2019 (the “2018 Form 10-K”) for a discussion and analysis of the more significant 
factors that affected periods prior to 2018.

Certain reclassifications have been made to make prior periods comparable. This discussion and analysis should be 
read in conjunction with our consolidated financial statements, notes thereto and other financial information appearing 
elsewhere in this report. From time to time, we have acquired various small businesses through our insurance subsidiary. 
None of these acquisitions had a significant impact on our financial statements. We account for acquisitions using the 
acquisition method, and as such, the results of operations of acquired companies are included from the date of acquisition.

Taxable-equivalent adjustments are the result of increasing income from tax-free loans and investments by an amount 
equal to the taxes that would be paid if the income were fully taxable, thus making tax-exempt yields comparable to 

38

taxable asset yields. Taxable equivalent adjustments were based upon a 21% income tax in 2019 and 2018 and a 35% 
income tax rate for prior years.

Dollar amounts in tables are stated in thousands, except for per share amounts.

Results of Operations

Net income available to common shareholders totaled $435.5 million, or $6.84 diluted per common share, in 2019
compared to $446.9 million, or $6.90 diluted per common share, in 2018 and $356.1 million, or $5.51 diluted per 
common share, in 2017.

Selected  income  statement  data,  returns  on  average  assets  and  average  equity  and  dividends  per  share  for  the 

comparable periods were as follows:

Taxable-equivalent net interest income
Taxable-equivalent adjustment
Net interest income
Provision for loan losses
Non-interest income
Non-interest expense
Income before income taxes
Income taxes
Net income
Preferred stock dividends
Net income available to common shareholders
Earnings per common share - basic
Earnings per common share - diluted
Dividends per common share
Return on average assets
Return on average common equity
Average shareholders' equity to average assets

2019
$ 1,100,586
96,581
1,004,005
33,759
363,902
834,679
499,469
55,870
443,599
8,063
435,536
6.89
6.84
2.80
1.36%
12.24
11.54

$
$

2018
$ 1,052,564
94,672
957,892
21,613
351,286
778,884
508,681
53,763
454,918
8,063
446,855
6.97
6.90
2.58
1.44%
14.23
10.58

$
$

2017
$ 1,043,431
177,009
866,422
35,460
336,470
759,069
408,363
44,214
364,149
8,063
356,086
5.56
5.51
2.25
1.17%
11.76
10.42

$
$

Net income available to common shareholders decreased $11.3 million for 2019 compared to 2018. The decrease
was primarily the result of a $55.8 million increase in non-interest expense, a $12.1 million increase in the provision 
for loan losses and a $2.1 million increase in income tax expense partly offset by a $46.1 million increase in net interest 
income and a $12.6 million increase in non-interest income.

Details of the changes in the various components of net income are further discussed below.

Net Interest Income

Net interest income is the difference between interest income on earning assets, such as loans and securities, and 
interest expense on liabilities, such as deposits and borrowings, which are used to fund those assets. Net interest income 
is our largest source of revenue, representing 73.4% of total revenue during 2019. Net interest margin is the ratio of 
taxable-equivalent net interest income to average earning assets for the period. The level of interest rates and the volume 
and mix of earning assets and interest-bearing liabilities impact net interest income and net interest margin.

The Federal Reserve influences the general market rates of interest, including the deposit and loan rates offered by 
many financial institutions. Our loan portfolio is significantly affected by changes in the prime interest rate. The prime 
rate began 2017 at 3.75% and increased 75 basis points (25 basis points in each of March, June and December) to end 
the year at 4.50%. During 2018, the prime rate increased 100 basis points (25 basis points in each of March, June, 
September and December) to end the year at 5.50%. During 2019, the prime rate decreased 50 basis points during the 
third quarter of 2019 (25 basis points in each of August and September) and 25 basis points in October 2019 to end the 
year at 4.75%. Our loan portfolio is also significantly impacted, by changes in the London Interbank Offered Rate 
(LIBOR). At December 31, 2019, the one-month and three-month U.S. dollar LIBOR rates were 1.76% and 1.90%, 
respectively, while at December 31, 2018, the one-month and three-month U.S. dollar LIBOR rates were 2.50% and 
2.81% respectively, and at December 31, 2017, the one-month and three-month U.S. dollar LIBOR rates were 1.56% 

39

and 1.69% respectively. The effective federal funds rate, which is the cost of immediately available overnight funds, 
started 2017 at 0.75% and increased 75 basis points (25 basis points in each of March, June and December) to end the 
year at 1.50%. During 2018, the effective federal funds rate increased 100 basis points (25 basis points in each of March, 
June, September and December) to end the year at 2.50%. During 2019, the effective federal funds rate decreased 50 
basis points during the third quarter of 2019 (25 basis points in each of August and September) and 25 basis points in 
October 2019 to end the year at 1.75%.

We are primarily funded by core deposits, with non-interest-bearing demand deposits historically being a significant 
source of funds. This lower-cost funding base is expected to have a positive impact on our net interest income and net 
interest margin in a rising interest rate environment. Federal prohibitions on the payment of interest on demand deposits 
were repealed in 2011. Nonetheless, we have not experienced any significant additional costs as a result. See Item 7A. 
Quantitative and Qualitative Disclosures About Market Risk elsewhere in this report for information about our sensitivity 
to interest rates. Further analysis of the components of our net interest margin is presented below.

The following table presents the changes in taxable-equivalent net interest income and identifies the changes due 
to differences in the average volume of earning assets and interest-bearing liabilities and the changes due to changes 
in the average interest rate on those assets and liabilities. The changes in net interest income due to changes in both 
average volume and average interest rate have been allocated to the average volume change or the average interest rate 
change in proportion to the absolute amounts of the change in each. The comparison between 2018 and 2017 includes 
an additional change factor detailing the effect of the reduction in the U.S. statutory federal income tax rate under the 
Tax Cuts and Jobs Act, which was enacted on December 22, 2017. See Note 13 - Income Taxes in the accompanying 
notes to consolidated financial statements elsewhere in this report for information regarding the Tax Cuts and Jobs Act. 
Our consolidated average balance sheets along with an analysis of taxable-equivalent net interest income are presented 
in Item 8. Financial Statements and Supplementary Data of this report.

2019 vs. 2018

Increase (Decrease)
Due to Change in

2018 vs. 2017

Increase (Decrease)
Due to Change in

Interest-bearing deposits
Federal funds sold and resell agreements
Securities:
Taxable
Tax-exempt

Loans, net of unearned discounts

Total earning assets

Savings and interest checking
Money market deposit accounts
Time accounts
Public funds
Federal funds purchased and repurchase
agreements
Junior subordinated deferrable interest
debentures
Subordinated notes payable and other notes

Total interest-bearing liabilities

Net change

Rate

$

7,118
450

Volume
Total
$ (28,496) $ (21,378) $ 23,680
869

(426)

Rate

24

Volume
$ (8,320) $
3,695

Tax Rate

Total

— $ 15,360
4,564
—

13,909
(3,920)
30,916
48,473
(791)
11,723
8,022
1,302

16,803
6,123
42,019
36,023
72
686
1,835
1,556

30,712
2,203
72,935
84,496
(719)
12,409
9,857
2,858

5,131
(11,283)
81,949
100,346
4,005
46,205
4,620
2,990

(11,740)
28,033
53,525
65,193
61
249
57
(38)

9,602

2,052

11,654

6,367

132

413
(8)
30,263
$ 18,210

2
8
6,211
$ 29,812

415
—
36,474
$ 48,022

1,334
408
65,929
$ 34,417

2
389
852
$ 64,341

(85,625)
(4,000)
(89,625)
—
—
—
—

—

—
—
—

$ (89,625) $

(6,609)
(68,875)
131,474
75,914
4,066
46,454
4,677
2,952

6,499

1,336
797
66,781
9,133

Taxable-equivalent net interest income for 2019 increased $48.0 million, or 4.6%, compared to 2018.The increase 
was  primarily  related  to  increases  in  the  average  yields  on  loans,  taxable  securities  and  interest-bearing  deposits 
combined with increases in the average volumes of loans and both taxable and tax-exempt securities. The impact of 
these items was partly offset by increases in the average rates paid on and average volumes of interest-bearing deposits 
and other borrowed funds, a decrease in the average volume of interest bearing deposits (primarily excess reserves held 
in an interest-bearing account at the Federal Reserve) and a decrease in the average yield on tax-exempt securities. 

40

The average volume of interest-earning assets for 2019 increased $700.8 million, or 2.4%, compared to 2018. The 
increase in earning assets included an $825.9 million increase in average taxable securities, an $822.6 million increase 
in average loans and a $406.1 million increase in average tax-exempt securities partly offset by a $1.4 billion decrease
in average interest-bearing deposits, federal funds sold and resell agreements.

The taxable-equivalent net interest margin increased 11 basis points from 3.64% during 2018 to 3.75% during 2019. 
The average yield on interest-earning assets increased 24 basis points from 3.96% during 2018 to 4.20% during 2019
and average rate paid on interest-bearing liabilities increased 19 basis points from 0.55% in 2018 to 0.74% in 2019. 
The  average  yield  on  interest-earning  assets  and  the  average  rate  paid  on  interest-bearing  liabilities  are  primarily 
impacted by changes in market interest rates as well as changes in the volume and relative mix of the underlying assets 
and liabilities. The increase in the taxable-equivalent net interest margin was primarily related to increases in the average 
yields on loans; taxable securities; interest-bearing deposits; and federal funds sold and resell agreements partly offset 
by increases in the average cost of interest-bearing deposits and other borrowed funds and a decrease in the average 
yield on tax-exempt securities. The taxable-equivalent net interest margin was also positively impacted by a decrease 
in the relative proportion of interest-earning assets invested in lower-yielding interest-bearing deposits (primarily excess 
reserves held in an interest-bearing account at the Federal Reserve).

The average taxable-equivalent yield on loans was 5.17% during 2019 compared to 4.95% during 2018, increasing 
22 basis points during 2019 compared to 2018. The average taxable-equivalent yield on loans was positively impacted 
by higher average market interest rates in 2019 compared to 2018. The average volume of loans increased $822.6 
million, or 6.0%, in 2019 compared to 2018. Loans made up approximately 48.8% of average interest-earning assets 
during 2019 compared to 47.1% during 2018.

The average taxable-equivalent yield on securities was 3.40% during 2019 compared to 3.38% during 2018. The 
average taxable-equivalent yield on securities was positively impacted by increases in the average volume of tax-
exempt and taxable securities and an increase in the average yield on taxable securities but was negatively impacted 
by a decrease in the average yield on tax-exempt securities. The average yield on taxable securities was 2.33% during 
2019 compared to 2.03% during 2018 while the average yield on tax exempt securities was 4.06% during 2019 compared 
to 4.11% during 2018. The average taxable-equivalent yield on tax-exempt securities decreased 5 basis points during 
2019 compared to 2018, while the average yield on taxable securities increased 30 basis points during 2019 compared 
to 2018. Tax exempt securities made up approximately 62.0% of total average securities during 2019, compared to 
65.0% during 2018. The average volume of total securities increased $1.2 billion, or 10.2%, during 2019 compared to 
2018. Securities made up approximately 44.9% of average interest-earning assets in 2019 compared to 41.7% in 2018. 

Average interest-bearing deposits, federal funds sold and resell agreements during 2019 decreased $1.4 billion, or 
42.1%, compared to 2018. Interest-bearing deposits, federal funds sold and resell agreements made up approximately 
6.3% of average interest-earning assets during 2019 compared to approximately 11.1% in 2018. The decrease in the 
average volume of interest-bearing deposits, federal funds sold and resell agreements was primarily due to a decrease 
in the average volume of our excess reserves held in an interest-bearing account at the Federal Reserve during 2019
compared to 2018 as such funds were invested in higher yielding loans and securities. The combined average yield on 
federal funds sold and resell agreements and interest-bearing deposits was 2.21% during 2019 and 1.94% during 2018.

The average rate paid on interest-bearing liabilities was 0.74% during 2019, increasing 19 basis points from 0.55%
during 2018. Average deposits increased $124.2 million, or 0.5%, in 2019 compared to 2018. Average interest-bearing 
deposits increased $522.6 million in 2019 compared to 2018, while average non-interest-bearing deposits decreased
$398.4 million in 2019 compared to 2018. The ratio of average interest-bearing deposits to total average deposits was 
60.8% in 2019 compared to 59.1% in 2018. The average cost of deposits is primarily impacted by changes in market 
interest rates as well as changes in the volume and relative mix of interest-bearing deposits. The average rate paid on 
interest-bearing deposits and total deposits was 0.62% and 0.38% in 2019 compared to 0.49% and 0.29% in 2018. The 
average cost of deposits during 2019 was impacted by higher average interest rates paid on most of our interest-bearing 
deposit products, particularly during the first half of 2019, as a result of higher average market interest rates and market 
competition.

Our  taxable-equivalent  net  interest  spread,  which  represents  the  difference  between  the  average  rate  earned  on 
earning assets and the average rate paid on interest-bearing liabilities, was 3.46% in 2019 compared to 3.41% in 2018. 
The net interest spread, as well as the net interest margin, will be impacted by future changes in short-term and long-
term interest rate levels, as well as the impact from the competitive environment. A discussion of the effects of changing 

41

interest rates on net interest income is set forth in Item 7A. Quantitative and Qualitative Disclosures About Market 
Risk elsewhere in this report.

Our  hedging  policies  permit  the  use  of  various  derivative  financial  instruments,  including  interest  rate  swaps, 
swaptions, caps and floors, to manage exposure to changes in interest rates. Details of our derivatives and hedging 
activities are set forth in Note 15 - Derivative Financial Instruments in the accompanying notes to consolidated financial 
statements elsewhere in this report. Information regarding the impact of fluctuations in interest rates on our derivative 
financial instruments is set forth in Item 7A. Quantitative and Qualitative Disclosures About Market Risk elsewhere 
in this report.

Provision for Loan Losses

The provision for loan losses is determined by management as the amount to be added to the allowance for loan 
losses after net charge-offs have been deducted to bring the allowance to a level which, in management’s best estimate, 
is necessary to absorb inherent losses within the existing loan portfolio. The provision for loan losses totaled $33.8 
million in 2019 compared to $21.6 million in 2018. See the section captioned “Allowance for Loan Losses” elsewhere 
in this discussion for further analysis of the provision for loan losses.

Non-Interest Income

The components of non-interest income were as follows:

Trust and investment management fees
Service charges on deposit accounts
Insurance commissions and fees
Interchange and debit card transaction fees
Other charges, commissions and fees
Net gain (loss) on securities transactions
Other
Total

2019
126,722
88,983
52,345
14,873
37,123
293
43,563
363,902

$

$

2018
119,391
85,186
48,967
13,877
37,231
(156)
46,790
351,286

$

$

2017
110,675
84,182
46,169
23,232
39,931
(4,941)
37,222
336,470

$

$

Total non-interest income for 2019 increased $12.6 million, or 3.6%, compared to 2018. Changes in the various 

components of non-interest income are discussed in more detail below.

Trust and Investment Management Fees. Trust and investment management fee income for 2019 increased $7.3 
million,  or  6.1%,  compared  to  2018.  Investment  fees  are  the  most  significant  component  of  trust  and  investment 
management fees, making up approximately 82% and 83% of total trust and investment management fees in 2019 and 
2018, respectively. Investment and other custodial account fees are generally based on the market value of assets within 
a  trust  account. Volatility  in  the  equity  and  bond  markets  impacts  the  market  value  of  trust  assets  and  the  related 
investment fees. The increase in trust and investment management fees during 2019 compared to 2018 was primarily 
the result of an increase in trust investment fees (up $5.7 million) due to higher average equity valuations and an increase 
in the number of accounts. The increase was also partly related to increases in estate fees (up $740 thousand) and oil 
and gas fees (up $711 thousand).

At December 31, 2019, trust assets, including both managed assets and custody assets, were primarily composed of 
equity securities (50.7% of trust assets), fixed income securities (35.0% of trust assets) and cash equivalents (8.9% of 
trust assets). The estimated fair value of trust assets was $37.8 billion (including managed assets of $16.4 billion and 
custody assets of $21.4 billion) at December 31, 2019 compared to $33.3 billion (including managed assets of $14.7 
billion and custody assets of $18.7 billion) at December 31, 2018.

Service Charges on Deposit Accounts. Service charges on deposit accounts for 2019 increased $3.8 million, or 4.5%, 
compared to 2018. The increase was primarily related to increases in overdraft/insufficient funds charges on consumer 
and commercial accounts (up $3.3 million and $551 thousand, respectively) and, to a lesser extent, commercial service 
charges (up $354 thousand) partly offset by a decrease in consumer service charges (down $421 thousand). Overdraft/
insufficient  funds  charges  totaled  $42.3  million  during  2019  compared  to  $38.4  million  during  2018.  Overdraft/
insufficient funds charges included $33.1 million and $29.8 million related to consumer accounts during 2019 and 
2018, respectively, and $9.2 million and $8.7 million related to commercial accounts during 2019 and 2018, respectively. 

42

The  increases  in  overdraft/insufficient  funds  charges  were  partly  due  to  increases  in  the  number  of  accounts  and 
transaction volumes. Overdraft/insufficient funds charges were also partly impacted by a change in the fee schedule 
during the second quarter of 2019.

Insurance  Commissions  and  Fees.  Insurance  commissions  and  fees  for  2019  increased  $3.4  million,  or  6.9%, 
compared to 2018. The increase was related to an increase in commission income (up $3.6 million) partly offset by a 
decrease in contingent income (down $200 thousand). The increase in commission income was primarily related to 
increases  in  commissions  on  commercial  lines  property  and  casualty  policies,  benefit  plan  commissions  and  life 
insurance commissions. The increases in property and casualty commissions and benefit plan commissions were related 
to increased business volumes and market rates. The increase in life insurance commissions was related to increased 
business volumes.

Contingent income totaled $4.1 million in 2019 and $4.3 million in 2018. Contingent income primarily consists of 
amounts received from various property and casualty insurance carriers related to the loss performance of insurance 
policies  previously  placed. These  performance  related  contingent  payments  are  seasonal  in  nature  and  are  mostly 
received during the first quarter of each year. This performance related contingent income totaled $3.0 million in 2019
and $3.2 million in 2018. The decrease in performance related contingent income during 2019 was related to lower 
growth within the portfolio partly offset by the impact of improvement in the loss performance of insurance policies 
previously placed. Contingent income also includes amounts received from various benefit plan insurance companies 
related to the volume of business generated and/or the subsequent retention of such business. This benefit plan related 
contingent income totaled $1.2 million in both 2019 and 2018.

Interchange and Debit Card Transaction Fees. Interchange fees, or “swipe” fees, are charges that merchants pay to 
us and other card-issuing banks for processing electronic payment transactions. Interchange and debit card transaction 
fees consist of income from check card usage, point of sale income from PIN-based debit card transactions and ATM 
service fees. Interchange and debit card transaction fees for 2019 and 2018 are reported on a net basis and totaled $14.9 
million and $13.9 million, respectively. The increase in interchange and debit card transaction fees during 2019, on a 
net basis, was primarily related to increases in the number of accounts and transaction volumes. Prior to 2018, interchange 
and debit card transaction fees were reported on a gross basis. A comparison of gross and net interchange and debit 
card transaction fees for the reported periods is presented in the table below:

Income from debit card transactions
ATM service fees

Gross interchange and debit card transaction fees

Network costs

Net interchange and debit card transaction fees

2019

2018

2017

23,665
4,131
27,796
12,923
14,873

$

$

21,844
3,925
25,769
11,892
13,877

$

$

19,440
3,792
23,232
11,943
11,289

$

$

Other Charges, Commissions and Fees. Other charges, commissions and fees for 2019 decreased $108 thousand, 
or 0.3%, compared to 2018. The decrease was primarily related to decreases in processing fees (down $688 thousand), 
brokerage  commissions  (down  $424 thousand),  income  from  the  sale  of  annuities  and  mutual  funds  (down 
$356 thousand  and  $190 thousand,  respectively)  and  income  from  capital  markets  advisory  services  (down 
$323 thousand), among other things, mostly offset by increases in income from the sale of money market funds (up 
$1.4 million) and letter of credit fees (up $541 thousand), among other things.

Net Gain/Loss on Securities Transactions. During 2019 and 2018 we sold certain available-for-sale U.S Treasury 
securities  with  amortized  costs  totaling  $17.8 billion  and  $16.8  billion,  respectively.  We  realized  a  net  gain  of 
$127 thousand on the 2019 sales and a net loss of $156 thousand on the 2018 sales. The sales were primarily related 
to securities purchased and subsequently sold in the same period of their purchase in connection with our tax planning 
strategies related to the Texas franchise tax. The gross proceeds from the sales of these securities outside of Texas are 
included in total revenues/receipts from all sources reported for Texas franchise tax purposes, which results in a reduction 
in the overall percentage of revenues/receipts apportioned to Texas and subjected to taxation under the Texas franchise 
tax.

Additionally, during the second quarter of 2019, we sold certain available-for-sale U.S. Treasury securities with an 
amortized cost totaling $548.9 million and certain available-for-sale municipal securities with an amortized cost totaling 
$310.7 million. We realized a net gain of $166 thousand on those sales. The proceeds from the sales provided short-
term liquidity and were subsequently reinvested in other higher yielding securities.

43

Other Non-Interest Income. Other non-interest income for 2019 decreased $3.2 million, or 6.9%, compared to 2018. 
The decrease was primarily related to decreases in sundry and other miscellaneous income (down $3.4 million); income 
from  derivative  and  trading  activities,  primarily  customer-related,  (down  $1.8 million);  and  gains  on  the  sale  of 
foreclosed and other assets (down $624 thousand) partly offset by an increase in public finance underwriting fees (up 
$1.9 million), among other things. Sundry income during 2019 included $2.6 million in VISA check card incentives 
related to business volumes, $1.7 million related to settlements, $1.7 million related to the recovery of prior write-offs 
and $278 thousand related to distributions from a private equity investment, among other things, while sundry income 
for 2018 included $4.5 million related to the recovery of prior write-offs, $2.1 million in VISA check card incentives, 
$1.7 million related to a distribution from a private equity investment and $997 thousand related to the settlement of 
an insurance claim, among other things. The fluctuations in public finance underwriting fees and income from customer 
derivative and trading activities during 2019 were primarily related to changes in business volumes. Other non-interest 
income also included gains on the sale of various branch and operational facilities totaling $6.7 million during 2019
and $7.0 million during 2018.

Non-Interest Expense

The components of non-interest expense were as follows:

Salaries and wages
Employee benefits
Net occupancy
Technology, furniture and equipment
Deposit insurance
Intangible amortization
Other
Total

2019
375,029
86,230
89,466
91,995
10,126
1,168
180,665
834,679

$

$

2018
350,312
77,323
76,788
83,102
16,397
1,424
173,538
778,884

$

$

2017
337,068
74,575
75,971
74,335
20,128
1,703
175,289
759,069

$

$

Total non-interest expense for 2019 increased $55.8 million, or 7.2%, compared to 2018. Changes in the various 

components of non-interest expense are discussed below.

Salaries and Wages. Salaries and wages increased $24.7 million, or 7.1%, in 2019 compared to 2018. The increase 
was primarily related to an increase in salaries, due to an increase in the number of employees and normal annual merit 
and market increases and, to a lesser extent, an increase in stock compensation.

Employee Benefits. Employee benefits expense for 2019 increased $8.9 million, or 11.5%, compared to 2018. The 
increase was primarily due to increases in expenses related to our defined benefit retirement plans (up $2.3 million), 
expenses related to our 401(k) plan (up $2.3 million), medical benefits expense (up $2.2 million) and payroll taxes (up 
$1.4 million).

Our defined benefit retirement and restoration plans were frozen effective as of December 31, 2001 and were replaced 
by a profit sharing plan (which was merged with and into our 401(k) plan during 2019). Management believes these 
actions help reduce the volatility in retirement plan expense. However, we still have funding obligations related to the 
defined benefit and restoration plans and could recognize retirement expense related to these plans in future years, 
which would be dependent on the return earned on plan assets, the level of interest rates and employee turnover. We 
recognized a combined net periodic pension expense of $1.3 million related to our defined benefit retirement and 
restoration plans in 2019 compared to a combined net periodic pension benefit of $1.0 million in 2018. Future expense/
benefits related to these plans is dependent upon a variety of factors, including the actual return on plan assets. For 
additional information related to our employee benefit plans, see Note 11 - Employee Benefit Plans in the accompanying 
notes to consolidated financial statements elsewhere in this report.

Net Occupancy. Net occupancy expense for 2019 increased $12.7 million, or 16.5%, compared to 2018. The increase
was primarily related to increases in lease expense (up $11.6 million) and depreciation on leasehold improvements (up 
$2.0 million) partly offset by a decrease in property taxes (down $2.1 million). The increase in lease expense was 
primarily related to the commencement of the lease of our new corporate headquarters building in San Antonio and the 
renewal of the lease associated with our downtown Austin location. The increase was also partly related to renewals 
of other leases related to existing facilities and new locations, in part related to our expansion within the Houston market 
area. The increase in depreciation on leasehold improvements was primarily related to the new headquarters location 

44

in San Antonio and, to a lesser extent, other new locations. The decrease in property taxes was mostly related to our 
former headquarters location in downtown San Antonio.

Fluctuations in the foregoing categories of net occupancy expense were primarily related to the commencement of 
the lease of our new corporate headquarters building in San Antonio and other leases related to existing facilities and 
our expansion within the Houston market area.

Technology, Furniture and Equipment. Technology, furniture and equipment expense for 2019 increased $8.9 million, 
or 10.7%, compared to 2018. The increase was primarily related to an increase in software maintenance/cloud services 
expense (up $9.3 million) due to new and renewed software and an increase in volume-based service payments. 

Deposit Insurance. Deposit insurance expense totaled $10.1 million in 2019 compared to $16.4 million in 2018. 
The decrease was primarily related to the termination of the quarterly Deposit Insurance Fund surcharge in the fourth 
quarter of 2018. In August 2016, the Federal Deposit Insurance Corporation (“FDIC”) announced that the Deposit 
Insurance Fund reserve ratio had surpassed 1.15% as of June 30, 2016. As a result, beginning in the third quarter of 
2016, the range of initial assessment rates for all institutions was adjusted downward and institutions with $10 billion 
or more in assets were assessed a quarterly surcharge. The quarterly surcharge was terminated in the fourth quarter of 
2018 as the Deposit Insurance Fund reserve ratio as of September 30, 2018 exceeded the statutory minimum of 1.35% 
required by the Dodd-Frank Act.

Intangible Amortization. Intangible amortization is primarily related to core deposit intangibles and, to a lesser 
extent, intangibles related to customer relationships and non-compete agreements. Intangible amortization totaled $1.2 
million in 2019 compared to $1.4 million in 2018. The decrease was primarily related to the completion of amortization 
of certain previously recognized intangible assets as well as a reduction in the annual amortization rate of certain 
previously  recognized  intangible  assets  as  we  use  an  accelerated  amortization  approach  which  results  in  higher 
amortization rates during the earlier years of the useful lives of intangible assets. See Note 5 - Goodwill and Other 
Intangible Assets in the accompanying notes to consolidated financial statements elsewhere in this report.

Other Non-Interest Expense. Other non-interest expense for 2019 increased $7.1 million, or 4.1%, compared to 
2018. The increase included, among other things, increases in advertising/promotions expense, partly related to new 
sponsorship arrangements (up $5.5 million); professional services expense (up $3.3 million) and platform fees related 
to investment services (up $2.7 million). The increase from these items was partly offset by a decrease in donations 
expense, which was impacted by a significant contribution to our charitable foundation in 2018 (down $4.0 million).

Results of Segment Operations

Our  operations  are  managed  along  two  primary  operating  segments:  Banking  and  Frost  Wealth  Advisors.  A 
description of each business and the methodologies used to measure financial performance is described in Note 18 -
 Operating Segments in the accompanying notes to consolidated financial statements elsewhere in this report. Net 
income (loss) by operating segment is presented below:

Banking
Frost Wealth Advisors
Non-Banks

Consolidated net income

Banking

2019
436,416
19,975
(12,792)
443,599

$

$

2018
445,531
22,090
(12,703)
454,918

$

$

2017
347,034
24,395
(7,280)
364,149

$

$

Net income for 2019 decreased $9.1 million, or 2.0%, compared to 2018. The decrease was primarily the result of 
a $45.7 million increase in non-interest expense, a $12.1 million increase in the provision for loan losses and a $2.6 
million increase in income tax expense partly offset by a $46.6 million increase in net interest income and a $4.7 million
increase in non-interest income.

Net interest income for 2019 increased $46.6 million, or 4.8%, compared to 2018. The increase was primarily related 
to increases in the average yields on loans, taxable securities and interest-bearing deposits combined with increases in 
the average volumes of loans and both taxable and tax-exempt securities. The impact of these items was partly offset 
by increases in the average rates paid on and average volumes of interest-bearing deposits and other borrowed funds, 
a decrease in the average volume of interest bearing deposits (primarily excess reserves held in an interest-bearing 

45

account at the Federal Reserve) and a decrease in the average yield on tax-exempt securities. See the analysis of net 
interest income included in the section captioned “Net Interest Income” elsewhere in this discussion.

The provision for loan losses for 2019 totaled $33.8 million compared to $21.6 million in 2018. See the analysis of 
the provision for loan losses included in the section captioned “Allowance for Loan Losses” elsewhere in this discussion.

Non-interest income for 2019 increased $4.7 million, or 2.2%, compared to 2018. The increase was primarily due 
to increases in service charges on deposit accounts, insurance commissions and fees and interchange and debit card 
transactions fees partly offset by decreases in other non-interest income and other charges, commissions and fees. The 
increase in service charges on deposit accounts was primarily related to increases in overdraft/insufficient funds charges 
on consumer and commercial accounts and, to a lesser extent, commercial service charges partly offset by a decrease 
in consumer service charges. The increase in insurance commissions and fees was primarily related to increased business 
volumes and market rates partly offset by a decrease in contingent income. The increase in interchange and debit card 
transaction fees was primarily related to increased transaction volumes. The decrease in other non-interest income was 
primarily  related  to  decreases  in  sundry  and  other  miscellaneous  income  and  income  from  derivative  and  trading 
activities, primarily customer related, and a decrease on gains on the sale of foreclosed and other assets partly offset 
by an increase in public finance underwriting fees, among other things. The decrease in other charges, commissions 
and fees was primarily related to decreases in processing fees and income from capital markets advisory services, 
among other things, partly offset by an increase in letter of credit fees, among other things. See the analysis of these 
categories of non-interest income included in the section captioned “Non-Interest Income” included elsewhere in this 
discussion.

Non-interest expense for 2019 increased $45.7 million, or 6.9%, compared to 2018. The increase was primarily 
related  to  increases  in  salaries  and  wages;  technology,  furniture  and  equipment  expense;  employee  benefits;  net 
occupancy expense; and other non-interest expense partly offset by a decrease in deposit insurance expense. 

The increase in salaries and wages was primarily due to an increase in the number of employees and normal annual 
merit and market increases and, to a lesser extent, an increase in stock compensation. The increase in technology, 
furniture and equipment expense was primarily related to an increase in software maintenance/cloud services expense. 
The increase in employee benefits was primarily related to increases in expenses related to our defined benefit retirement 
plans, expenses related to our 401(k) plan, medical benefits expense and payroll taxes. The increase in net occupancy 
expense was primarily related to increases in lease expense and depreciation on leasehold improvements partly offset 
by decreases in property taxes and utilities expense. The increase in other non-interest expense included increases in 
advertising/promotions  expense;  professional  services  expense;  and  travel,  meals  and  entertainment;  among  other 
things, partly offset by decreases in donations expense; sundry and other miscellaneous expense; and losses on the sale 
of foreclosed and other assets; among other things. The decrease in deposit insurance expense was primarily related to 
the termination of the quarterly Deposit Insurance Fund surcharge in the fourth quarter of 2018. See the analysis of 
these categories of non-interest expense included in the section captioned “Non-Interest Expense” included elsewhere 
in this discussion.

Income tax expense for 2019 increased $2.6 million, or 4.9%, compared to 2018. See the section captioned “Income 

Taxes” elsewhere in this discussion.

Frost Insurance Agency, which is included in the Banking operating segment, had gross commission revenues of 
$53.1 million during 2019 compared to $49.6 million during 2018. The increase was primarily related to increases in 
commissions  on  commercial  lines  property  and  casualty  policies;  benefit  plan  commissions;  and  life  insurance 
commissions.  The  increases  in  property  and  casualty  commissions  and  benefit  plan  commissions  were  related  to 
increased business volumes and market rates. The increase in life insurance commissions was related to increased 
business volumes. See the analysis of insurance commissions and fees included in the section captioned “Non-Interest 
Income” included elsewhere in this discussion. 

Frost Wealth Advisors

Net income for 2019 decreased $2.1 million, or 9.6%, compared to 2018. The decrease was primarily due a $10.5 

million increase in non-interest expense partly offset by a $7.9 million increase in non-interest income. 

Non-interest income for 2019 increased $7.9 million, or 5.7%, compared to 2018. The increase was primarily related 
to an increase in trust and investment management fees, and to a lesser extent, an increase in other charges, commissions 
and fees. Trust and investment management fee income is the most significant income component for Frost Wealth 

46

Advisors. Investment fees are the most significant component of trust and investment management fees, making up 
approximately 82% and 83% of total trust and investment management fees for 2019 and 2018. Investment and other 
custodial account fees are generally based on the market value of assets within a trust account. Volatility in the equity 
and bond markets impacts the market value of trust assets and the related investment fees. The increase in trust and 
investment management fees during 2019 was primarily the result of increases in trust investment fees due to higher 
average equity valuations and an increase in the number of accounts. The increase was also partly related to increases 
in estate fees and oil and gas fees. The increase in other charges, commissions and fees was primarily related to an 
increase in income related to the sale of money market funds partly offset by decreases in brokerage commissions and 
income from the sale of annuities and mutual funds. See the analysis of trust and investment management fees included 
in the section captioned “Non-Interest Income” included elsewhere in this discussion.

Non-interest expense for 2019 increased $10.5 million, or 9.2%, compared to 2018. The increase was primarily 
related to increases in net occupancy expense, other non-interest expense and salaries and wages. The increase in net 
occupancy expense was partly related to increases in lease overhead allocations. The increase in other non-interest 
expense was primarily due to increases in platform fees related to investment services; professional service expense; 
and travel, meals and entertainment expense, among other things. The increase in salaries and wages was primarily 
due to an increase in the number of employees and normal annual merit and market increases, as well as increases in 
incentive compensation.

Non-Banks

The Non-Banks operating segment had a net loss of $12.8 million for 2019 compared to a net loss of $12.7 million
in 2018. The increased net loss was primarily due to an increase in net interest expense due to increases in the interest 
rate paid on our long-term borrowings and an increase in other non-interest expense partly offset by decreases in salaries 
and wages.

Income Taxes

We recognized income tax expense of $55.9 million, for an effective tax rate of 11.2%, in 2019 compared to $53.8 
million, for an effective tax rate of 10.6%, in 2018. The effective income tax rates differed from the U.S. statutory 
federal income tax rate of 21% during 2019 and 2018 primarily due to the effect of tax-exempt income from loans, 
securities and life insurance policies and certain non-deductible expenses as well as the discrete tax effect associated 
with stock-based compensation. The increase in the effective tax rate during 2019 compared to 2018 was partly related 
to an increase in the level of non-deductible compensation and a decrease in the net tax benefits associated with stock-
based  compensation.  See  Note 13  -  Income Taxes  in  the  accompanying  notes  to  consolidated  financial  statements 
elsewhere in this report.

47

Sources and Uses of Funds

The following table illustrates, during the years presented, the mix of our funding sources and the assets in which 
those funds are invested as a percentage of our average total assets for the period indicated. Average assets totaled $32.1 
billion in 2019 compared to $31.0 billion in 2018.

Sources of Funds:

Deposits:

Non-interest-bearing
Interest-bearing

Federal funds purchased and repurchase agreements
Long-term debt and other borrowings
Other non-interest-bearing liabilities
Equity capital

Total
Uses of Funds:

Loans
Securities
Federal funds sold, resell agreements and interest-bearing deposits
Other non-interest-earning assets

Total

2019

2018

2017

32.3%
50.1
4.0
0.7
1.4
11.5
100.0%

45.0%
41.4
5.8
7.8
100.0%

34.7%
50.1
3.4
0.8
0.5
10.5
100.0%

43.9%
38.9
10.3
6.9
100.0%

35.5%
49.6
3.2
0.8
0.5
10.4
100.0%

40.9%
40.2
12.0
6.9
100.0%

Deposits continue to be our primary source of funding. Average deposits increased $124.2 million, or 0.5%, in 2019
compared to 2018. Non-interest-bearing deposits remain a significant source of funding, which has been a key factor 
in maintaining our relatively low cost of funds. Average non-interest-bearing deposits totaled 39.2% of total average 
deposits in 2019 compared to 40.9% in 2018. Federal prohibitions on the payment of interest on demand deposits were 
repealed in 2011. Nonetheless, we have not experienced any significant additional costs as a result. Should the market 
dictate, we may increase the interest rates we pay on some or all of our various interest-bearing deposit products. This 
could lead to a decrease in the relative proportion of non-interest-bearing deposits to total deposits.

We  primarily  invest  funds  in  loans  and  securities. Average  securities  increased  $1.2  billion,  or  10.2%,  in  2019
compared to 2018 while average loans increased $822.6 million, or 6.0%, in 2019 compared to 2018. Average federal 
funds sold and resell agreements and interest-bearing deposits decreased $1.4 billion, or 42.1%, in 2019 compared to 
2018.

48

Loans

Year-end loans, including leases net of unearned discounts, consisted of the following:

Commercial and industrial
Energy:

Production
Service
Other

Total energy

Commercial real estate:
Commercial mortgages
Construction
Land

Total commercial real

estate

Consumer real estate:
Home equity loans
Home equity lines of credit
Other

Total consumer real estate

Total real estate
Consumer and other

Total loans

2019
$ 5,187,466

Percentage
of Total

2018

35.2% $ 5,111,957

2017
$ 4,792,388

2016
$ 4,344,000

2015
$ 4,120,522

1,348,900
192,996
110,986
1,652,882

4,594,113
1,312,659
289,467

6,196,239

9.2
1.3
0.7
11.2

31.1
8.9
2.0

42.0

1,309,314
168,775
124,509
1,602,598

4,121,966
1,267,717
306,755

1,182,326
171,795
144,972
1,499,093

3,887,742
1,066,696
331,986

971,767
221,213
193,081
1,386,061

3,481,157
1,043,261
311,030

1,249,678
272,934
235,583
1,758,195

3,285,041
720,695
286,991

5,696,438

5,286,424

4,835,448

4,292,727

375,596
354,671
464,146
1,194,413
7,390,652
519,332
$14,750,332

2.6
2.4
3.1
8.1
50.1
3.5

353,924
337,168
427,898
1,118,990
6,815,428
569,750
100.0% $14,099,733

355,342
291,950
376,002
1,023,294
6,309,718
544,466
$13,145,665

345,130
264,862
326,793
936,785
5,772,233
473,098
$11,975,392

340,528
233,525
306,696
880,749
5,173,476
434,338
$11,486,531

Overview. Year-end total loans increased $650.6 million, or 4.6%, during 2019 compared to 2018. The majority of 
our loan portfolio is comprised of commercial and industrial loans, energy loans and real estate loans. Commercial and 
industrial loans made up 35.2% and 36.3% of total loans at December 31, 2019 and 2018 while energy loans made up 
11.2% and 11.4% of total loans at both December 31, 2019 and 2018 and real estate loans made up 50.1% and 48.3%
of total loans at December 31, 2019 and 2018. Energy loans include commercial and industrial loans, leases and real 
estate loans to borrowers in the energy industry. Real estate loans include both commercial and consumer balances. 

Loan Origination/Risk Management. We have certain lending policies and procedures in place that are designed to 
maximize  loan  income  within  an  acceptable  level  of  risk.  Management  reviews  and  approves  these  policies  and 
procedures on a regular basis. A reporting system supplements the review process by providing management with 
frequent reports related to loan production, loan quality, concentrations of credit, loan delinquencies and non-performing 
and potential problem loans. Diversification in the loan portfolio is a means of managing risk associated with fluctuations 
in economic conditions.

Commercial and industrial loans are underwritten after evaluating and understanding the borrower’s ability to operate 
profitably and prudently expand its business. Underwriting standards are designed to promote relationship banking 
rather than transactional banking. Once it is determined that the borrower’s management possesses sound ethics and 
solid business acumen, our management examines current and projected cash flows to determine the ability of the 
borrower to repay their obligations as agreed. Commercial and industrial loans are primarily made based on the identified 
cash flows of the borrower and secondarily on the underlying collateral provided by the borrower. The cash flows of 
borrowers,  however,  may  not  be  as  expected  and  the  collateral  securing  these  loans  may  fluctuate  in  value.  Most 
commercial and industrial loans are secured by the assets being financed or other business assets such as accounts 
receivable or inventory and may incorporate a personal guarantee; however, some short-term loans may be made on 
an unsecured basis. In the case of loans secured by accounts receivable, the availability of funds for the repayment of 
these loans may be substantially dependent on the ability of the borrower to collect amounts due from its customers.

Our energy loan portfolio includes loans for production, energy services and other energy loans, which includes 
private clients, transportation and equipment providers, manufacturers, refiners and traders. The origination process 
for energy loans is similar to that of commercial and industrial loans. Because, however, of the average loan size, the 
significance of the portfolio and the specialized nature of the energy industry, our energy lending requires a highly 
prescriptive underwriting policy. Production loans are secured by proven, developed and producing reserves. Loan 
49

proceeds are used for the development and drilling of additional wells, the acquisition of additional production, and/
or the acquisition of additional properties to be developed and drilled. Our customers in this sector are generally large, 
independent,  private  owner-producers  or  large  corporate  producers.  These  borrowers  typically  have  large  capital 
requirements for drilling and acquisitions, and as such, loans in this portfolio are generally greater than $10 million. 
Production loans are collateralized by the oil and gas interests of the borrower. Collateral values are determined by the 
risk-adjusted and limited discounted future net revenue of the reserves. Our valuations take into consideration geographic 
and reservoir differentials as well as cost structures associated with each borrower. Collateral is calculated at least semi-
annually using third party engineer-prepared reserve studies. These reserve studies are conducted using a discount 
factor and base case assumptions for the current and future value of oil and gas. To qualify as collateral, typically 
reserves must be proven, developed and producing. For certain borrowers, collateral may include up to 20% proven, 
non-producing reserves. Loan commitments are limited to 65% of estimated reserve value. Cash flows must be sufficient 
to amortize the loan commitment within 120% of the half-life of the underlying reserves. Loan commitments generally 
must also be 100% covered by the risk-adjusted and limited discounted future net revenue of the reserves when stressed 
at 75% of our base case price assumptions. In addition, the ratio of the borrower's debt to earnings before interest, taxes, 
depreciation and amortization ("EBITDA") should generally not exceed 350%.

Oil and gas service, transportation, and equipment providers are economically aligned due to their reliance on drilling 
and active oil and gas development. Income for these borrowers is highly dependent on the level of drilling activity 
and rig utilization, both of which are driven by the current and future outlook for the price of oil and gas. We mitigate 
the credit risk in this sector through conservative concentration limits and guidelines on the profile of eligible borrowers. 
Guidelines require that the companies have extensive experience through several industry cycles, and that they be 
supported by financially competent and committed guarantors who provide a significant secondary source of repayment. 
Borrowers  in  this  sector  are  typically  privately-owned,  middle-market  companies  with  annual  sales  of  less  than 
$100 million. The services provided by companies in this sector are highly diversified, and include down-hole testing 
and maintenance, providing and threading drilling pipe, hydraulic fracturing services or equipment, seismic testing and 
equipment and other direct or indirect providers to the oil and gas production sector.

Our private client portfolio primarily consists of loans to wealthy individuals and their related oil and gas exploration 
and  production  entities,  where  the  oil  and  gas  producing  reserves  are  not  considered  to  be  the  primary  source  of 
repayment. These borrowers and guarantors typically have significant sources of wealth including significant liquid 
assets and/or cash flow from other investments which can fully repay the loans. The credit structures of these loans are 
generally similar to those of energy production loans, described above, with respect to the valuation of the reserves 
taken as collateral and the repayment structures.

Although no balances were outstanding at December 31, 2019 and 2018, in prior years, we have had a small portfolio 
of loans to refiners where our credit involvement with these customers was through purchases of shared national credit 
syndications. These borrowers refine crude oil into gasoline, diesel, jet fuel, asphalt and other petrochemicals and are 
not dependent on drilling or development. All of the borrowers in this portfolio are very large public companies that 
are important employers in several of our major markets. These borrowers, for the most part, have been long-term 
customers and we have a strong relationship with these companies and their executive management. There is no new 
customer origination process for this segment and any outstanding balances are expected to only reflect the needs of 
these existing relationships.

We also have a small portfolio of loans to energy trading companies that serve as intermediaries that buy and sell 
oil, gas, other petrochemicals, and ethanol. These companies are not dependent on drilling or development. As a general 
policy, we do not lend to energy traders; however, we have made an exception to this policy for certain customers based 
upon their underlying business models which minimize risk as commodities are bought only to fill existing orders 
(back-to-back trading). As such, the commodity price risk and sale risk are eliminated. There is no new customer 
origination process for this segment and any outstanding balances are expected to only reflect the needs of these existing 
relationships.

Commercial real estate loans are subject to underwriting standards and processes similar to commercial and industrial 
loans, in addition to those of real estate loans. These loans are viewed primarily as cash flow loans and secondarily as 
loans secured by real estate. Commercial real estate lending typically involves higher loan principal amounts and the 
repayment of these loans is generally largely dependent on the successful operation of the property securing the loan 
or the business conducted on the property securing the loan. Commercial real estate loans may be more adversely 
affected by conditions in the real estate markets or in the general economy. The properties securing our commercial 
real estate portfolio are diverse in terms of type and geographic location within Texas. This diversity helps reduce our 
exposure to adverse economic events that affect any single market or industry. Management monitors and evaluates 

50

commercial real estate loans based on collateral, geography and risk grade criteria. As a general rule, we avoid financing 
single-purpose projects unless other underwriting factors are present to help mitigate risk. We also utilize third-party 
experts to provide insight and guidance about economic conditions and trends affecting market areas we serve. In 
addition, management tracks the level of owner-occupied commercial real estate loans versus non-owner occupied 
loans. At December 31, 2019, approximately 43% of the outstanding principal balance of our commercial real estate 
loans were secured by owner-occupied properties.

With respect to loans to developers and builders that are secured by non-owner occupied properties that we may 
originate from time to time, we generally require the borrower to have had an existing relationship with us and have a 
proven  record  of  success.  Construction  loans  are  underwritten  utilizing  feasibility  studies,  independent  appraisal 
reviews, sensitivity analysis of absorption and lease rates and financial analysis of the developers and property owners. 
Construction loans are generally based upon estimates of costs and value associated with the completed project. These 
estimates may be inaccurate. Construction loans often involve the disbursement of substantial funds with repayment 
substantially dependent on the success of the ultimate project. Sources of repayment for these types of loans may be 
pre-committed  permanent  loans  from  approved  long-term  lenders,  sales  of  developed  property  or  an  interim  loan 
commitment from us until permanent financing is obtained. These loans are closely monitored by on-site inspections 
and are considered to have higher risks than other real estate loans due to their ultimate repayment being sensitive to 
interest rate changes, governmental regulation of real property, general economic conditions and the availability of 
long-term financing.

We originate consumer loans utilizing a computer-based credit scoring analysis to supplement the underwriting 
process. To monitor and manage consumer loan risk, policies and procedures are developed and modified, as needed, 
jointly by line and staff personnel. This activity, coupled with relatively small loan amounts that are spread across many 
individual borrowers, minimizes risk. Additionally, trend and outlook reports are reviewed by management on a regular 
basis. Underwriting standards for home equity loans are heavily influenced by statutory requirements, which include, 
but are not limited to, loan-to-value limitations, collection remedies, the number of such loans a borrower can have at 
one time and documentation requirements.

We maintain an independent loan review department that reviews and validates the credit risk program on a periodic 
basis. Results of these reviews are presented to management and the appropriate committees of our board of directors. 
The loan review process complements and reinforces the risk identification and assessment decisions made by lenders 
and credit personnel, as well as our policies and procedures.

Commercial and Industrial. Commercial and industrial loans increased $75.5 million, or 1.5%, during 2019 compared 
to 2018. Our commercial and industrial loans are a diverse group of loans to small, medium and large businesses. The 
purpose of these loans varies from supporting seasonal working capital needs to term financing of equipment. While 
some short-term loans may be made on an unsecured basis, most are secured by the assets being financed with collateral 
margins that are consistent with our loan policy guidelines. The commercial and industrial loan portfolio also includes 
the commercial lease and purchased shared national credits.

Energy. Energy loans include loans to entities and individuals that are engaged in various energy-related activities 
including (i) the development and production of oil or natural gas, (ii) providing oil and gas field servicing, (iii) providing 
energy-related  transportation  services  (iv) providing  equipment  to  support  oil  and  gas  drilling  (v) refining 
petrochemicals, or (vi) trading oil, gas and related commodities. Energy loans increased $50.3 million, or 3.1%, during 
2019 compared to 2018. The average loan size, the significance of the portfolio and the specialized nature of the energy 
industry requires a highly prescriptive underwriting policy. Exceptions to this policy are rarely granted. Due to the large 
borrowing requirements of this customer base, the energy loan portfolio includes participations and purchased shared 
national credits.

51

Industry Concentrations. As of December 31, 2019 and 2018, other than energy loans, there were no concentrations 
of loans within any single industry in excess of 10% of total loans, as segregated by Standard Industrial Classification 
code (“SIC code”). The SIC code system is a federally designed standard industrial numbering system used by us to 
categorize loans by the borrower’s type of business. The following table summarizes the industry concentrations of 
our loan portfolio, as segregated by SIC code. Industry concentrations, stated as a percentage of year-end total loans 
as of December 31, 2019 and 2018, are presented below:

Industry concentrations:

Energy
Public finance
Medical services
Automobile dealers
General and specific trade contractors
Manufacturing, other
Building materials and contractors
Services
Religion
Investor
Financial services, consumer credit
All other

Total loans

2019

2018

11.2%
5.1
3.9
3.8
3.4
3.1
3.1
2.3
2.3
2.2
2.0
57.6
100.0%

11.4%
5.4
4.0
2.9
3.4
2.9
3.2
2.1
2.5
2.1
2.3
57.8
100.0%

Large Credit Relationships. The market areas served by us include three of the top ten most populated cities in the 
United States. These market areas are also home to a significant number of Fortune 500 companies. As a result, we 
originate and maintain large credit relationships with numerous commercial customers in the ordinary course of business. 
We consider large credit relationships to be those with commitments equal to or in excess of $10.0 million, excluding 
treasury management lines exposure, prior to any portion being sold. Large relationships also include loan participations 
purchased if the credit relationship with the agent is equal to or in excess of $10.0 million. In addition to our normal 
policies and procedures related to the origination of large credits, one of our Regional Credit Committees must approve 
all new credit facilities which are part of large credit relationships and renewals of such credit facilities with exposures 
between $20.0 million and $30.0 million. Our Central Credit Committee must approve all new credit facilities which 
are part of large credit relationships and renewals of such credit facilities with exposures that exceed $30.0 million. 
The Regional and Central Credit Committees meet regularly to review large credit relationship activity and discuss the 
current pipeline, among other things. 

The following table provides additional information on our large credit relationships outstanding at year-end.

Committed amount:

$20.0 million and greater
$10.0 million to $19.9 million

Average amount:

$20.0 million and greater
$10.0 million to $19.9 million

Number of
Relationships

2019
Period-End Balances

Committed

Outstanding

Number of
Relationships

2018
Period-End Balances

Committed

Outstanding

261
179

$ 11,855,203
2,451,804

$ 6,657,382
1,451,453

247
165

$ 10,815,882
2,296,908

$ 6,236,133
1,395,082

45,422
13,697

25,507
8,109

43,789
13,921

25,248
8,455

Purchased Shared National Credits (“SNCs”). Purchased SNCs are participations purchased from upstream financial 
organizations and tend to be larger in size than our originated portfolio. Our purchased SNC portfolio totaled $948.8 
million at December 31, 2019 increasing $191.3 million, or 25.2%, from $757.5 million at December 31, 2018. At 
December 31, 2019, 45.6% of outstanding purchased SNCs were related to the energy industry, 17.7% of outstanding 
purchased SNCs were related to the construction industry and 10.5% of outstanding purchased SNCs were related to 
the financial services industry. The remaining purchased SNCs were diversified throughout various other industries, 
with no other single industry exceeding 10% of the total purchased SNC portfolio. Additionally, almost all of the 
outstanding balance of purchased SNCs was included in the energy and commercial and industrial portfolios, with the 

52

remainder included in the real estate categories. SNC participations are originated in the normal course of business to 
meet  the  needs  of  our  customers. As  a  matter  of  policy,  we  generally  only  participate  in  SNCs  for  companies 
headquartered in or which have significant operations within our market areas. In addition, we must have direct access 
to the company’s management, an existing banking relationship or the expectation of broadening the relationship with 
other banking products and services within the following 12 to 24 months. SNCs are reviewed at least quarterly for 
credit quality and business development successes. 

The following table provides additional information about certain credits within our purchased SNCs portfolio as 

of year-end.

2019

2018

Number of
Relationships

Period-End Balances

Committed

Outstanding

Number of
Relationships

Period-End Balances

Committed

Outstanding

Committed amount:

$20.0 million and greater
$10.0 million to $19.9 million

Average amount:

$20.0 million and greater
$10.0 million to $19.9 million

43
19

$ 1,619,398
269,974

$

804,608
136,541

38
18

$ 1,431,117
268,974

$

605,402
149,233

37,660
14,209

18,712
7,186

37,661
14,943

15,932
8,291

Real Estate Loans. Real estate loans increased $575.2 million, or 8.4%, during 2019 compared to 2018. Real estate 
loans include both commercial and consumer balances. Commercial real estate loans totaled $6.2 billion, or 83.8% of 
total real estate loans, at December 31, 2019 and $5.7 billion, or 83.6% of total real estate loans, at December 31, 2018. 
The  majority  of  this  portfolio  consists  of  commercial  real  estate  mortgages,  which  includes  both  permanent  and 
intermediate term loans. Loans secured by owner-occupied properties make up a significant portion of our commercial 
real estate portfolio. These loans are viewed primarily as cash flow loans and secondarily as loans secured by real estate. 
Consequently, these loans must undergo the analysis and underwriting process of a commercial and industrial loan, as 
well as that of a real estate loan.

The following tables summarize our commercial real estate loan portfolio, including commercial real estate loans 
reported as a component of our energy loan portfolio segment, as segregated by (i) the type of property securing the 
credit and (ii) the geographic region in which the loans were originated. Property type concentrations are stated as a 
percentage of year-end total commercial real estate loans as of December 31, 2019 and 2018:

Property type:

Office building
Office/warehouse
Multifamily
Retail
Non-farm/non-residential
Dealerships
Medical offices and services
Religious
Hotel
Strip centers
1-4 family construction
All other

Total commercial real estate loans

53

2019

2018

21.0%
17.2
9.9
8.1
6.5
5.3
4.8
3.5
3.4
3.3
2.6
14.4
100.0%

20.9%
16.1
9.2
8.4
5.8
4.9
4.7
4.0
2.6
3.4
3.2
16.8
100.0%

Geographic region:

San Antonio
Houston
Fort Worth
Dallas
Austin
Rio Grande Valley
Permian Basin
Corpus Christi

Total commercial real estate loans

2019

2018

27.8%
24.1
16.3
14.0
9.8
3.6
2.7
1.7
100.0%

26.2%
23.8
16.1
15.4
9.1
4.8
2.7
1.9
100.0%

Consumer  Loans.  The  consumer  loan  portfolio  at  December 31,  2019  increased  $25.0  million,  or  1.5%,  from 
December 31, 2018. As the following table illustrates, the consumer loan portfolio has two distinct segments, including 
consumer real estate and consumer and other.

Consumer real estate:
Home equity loans
Home equity lines of credit
Other

Total consumer real estate

Consumer and other

Total consumer loans

2019

2018

$

$

375,596
354,671
464,146
1,194,413
519,332
1,713,745

$

$

353,924
337,168
427,898
1,118,990
569,750
1,688,740

Consumer  real  estate  loans  at  December 31,  2019  increased  $75.4  million,  or  6.7%,  from  December 31,  2018. 
Combined, home equity loans and lines of credit made up 61.1% and 61.8% of the consumer real estate loan total at 
December 31, 2019 and 2018, respectively. We offer home equity loans up to 80% of the estimated value of the personal 
residence of the borrower, less the value of existing mortgages and home improvement loans. In general, we do not 
originate 1-4 family mortgage loans; however, from time to time, we may invest in such loans to meet the needs of our 
customers. Under the Tax Cuts and Jobs Act enacted on December 22, 2017, interest on home equity loans and lines 
of credit is no longer deductible. This change could adversely impact the level of originations and outstanding volumes 
of home equity loans and lines of credit in the future. The consumer and other loan portfolio at December 31, 2019
decreased $50.4 million, or 8.8%, from December 31, 2018. This portfolio primarily consists of automobile loans, 
unsecured revolving credit products, personal loans secured by cash and cash equivalents, and other similar types of 
credit facilities. 

Foreign Loans. We make U.S. dollar-denominated loans and commitments to borrowers in Mexico. The outstanding 
balance  of  these  loans  and  the  unfunded  amounts  available  under  these  commitments  were  not  significant  at 
December 31, 2019 or 2018.

54

Maturities  and  Sensitivities  of  Loans  to  Changes  in  Interest  Rates.  The  following  table  presents  the  maturity 
distribution of our commercial and industrial loans, energy loans and commercial real estate loans at December 31, 
2019. The table also presents the portion of loans that have fixed interest rates or variable interest rates that fluctuate 
over the life of the loans in accordance with changes in an interest rate index such as the prime rate or LIBOR.

Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Total

Loans with fixed interest rates
Loans with floating interest rates

Total

Due in
One Year
or Less
2,066,527
995,548

After One,
but Within
Five Years

After
Five Years

$

2,240,596
643,061

$

880,343
14,273

$

Total
5,187,466
1,652,882

507,956
351,449
$ 3,921,480

2,311,538
817,411
$ 6,012,606

2,064,086
143,799
$ 3,102,501

4,883,580
1,312,659
$ 13,036,587

427,676
3,493,804
3,921,480

$

$

1,830,400
4,182,206
6,012,606

$

$

1,767,077
1,335,424
3,102,501

$

4,025,153
9,011,434
$ 13,036,587

$

$

$

We generally structure commercial loans with shorter-term maturities in order to match our funding sources and to 
enable us to effectively manage the loan portfolio by providing the flexibility to respond to liquidity needs, changes in 
interest rates and changes in underwriting standards and loan structures, among other things. Due to the shorter-term 
nature of such loans, from time to time and in the ordinary course of business, we will renew/extend maturing lines of 
credit or refinance existing loans at their maturity dates. Some loans may renew multiple times in a given year as a 
result of general customer practice and need. These renewals, extensions and refinancings are made in the ordinary 
course  of  business  for  customers  that  meet  our  normal  level  of  credit  standards.  Such  borrowers  typically  request 
renewals to support their on-going working capital needs to finance their operations. Such borrowers are not experiencing 
financial difficulties and generally could obtain similar financing from another financial institution. In connection with 
each renewal, extension or refinancing, we may require a principal reduction, adjust the rate of interest and/or modify 
the  structure  and  other  terms  to  reflect  the  current  market  pricing/structuring  for  such  loans  or  to  maintain 
competitiveness with other financial institutions. In such cases, we do not generally grant concessions, and, except for 
those reported in Note 3 - Loans, any such renewals, extensions or refinancings that occurred during the reported periods 
were  not  deemed  to  be  troubled  debt  restructurings  pursuant  to  applicable  accounting  guidance.  Loans  exceeding 
$1.0 million undergo a complete underwriting process at each renewal.

55

Non-Performing Assets and Potential Problem Loans

Non-Performing Assets. Year-end non-performing assets and accruing past due loans were as follows:

Non-accrual loans:

Commercial and industrial
Energy
Commercial real estate
Consumer real estate
Consumer and other

Total non-accrual loans

Restructured loans
Foreclosed assets:

Real estate
Other

Total foreclosed assets
Total non-performing assets

Ratio of non-performing assets to:
Total loans and foreclosed assets
Total assets

Accruing past due loans:
30 to 89 days past due
90 or more days past due

Total accruing past due loans

Ratio of accruing past due loans to total loans:

30 to 89 days past due
90 or more days past due

Total accruing past due loans

2019

2018

2017

2016

2015

$ 26,038
65,761
9,577
922
5
102,303
6,098

1,084
—
1,084
$ 109,485

$

9,239
46,932
15,268
892
1,408
73,739
—

1,175
—
1,175
$ 74,914

$ 46,186
94,302
7,589
2,109
128
150,314
4,862

2,116
—
2,116
$ 157,292

$ 31,475
57,571
8,550
2,130
425
100,151
—

2,440
—
2,440
$ 102,591

$ 25,111
21,180
35,088
1,862
226
83,467
—

2,255
—
2,255
$ 85,722

0.74%
0.32

0.53%
0.23

1.20%
0.50

0.86%
0.34

0.75%
0.30

$ 50,784
7,421
$ 58,205

$ 59,595
20,468
$ 80,063

$ 93,428
14,432
$ 107,860

$ 55,456
24,864
$ 80,320

$ 59,480
8,108
$ 67,588

0.34%
0.05
0.39%

0.42%
0.15
0.57%

0.71%
0.11
0.82%

0.46%
0.21
0.67%

0.52%
0.07
0.59%

Non-performing assets include non-accrual loans, restructured loans and foreclosed assets. Non-performing assets 
at December 31, 2019 increased $34.6 million compared to December 31, 2018 reflecting increases in non-accrual 
commercial and industrial loans and non-accrual energy loans and restructured loans partly offset by a decrease in non-
accrual commercial real estate loans. Non-accrual commercial and industrial loans included one credit relationship in 
excess  of  $5.0 million  totaling  $8.4 million  at  December 31,  2019. This  credit  relationship  was  first  reported  as  a 
potential problem loan during the third quarter of 2019. There were no non-accrual commercial and industrial loans in 
excess of $5.0 million at December 31, 2018. Non-accrual energy loans included two credit relationships in excess of 
$5 million totaling $61.7 million at December 31, 2019. This included a single credit relationship totaling $34.0 million 
that was classified as non-accrual during the third quarter of 2019. The other credit relationship, which totaled $27.7 
million at December 31, 2019, was previously reported as non-accrual with an aggregate balance of $37.6 million at 
December 31, 2018. We charged off $7.5 million related to this credit relationship during 2019. Non-accrual energy 
loans at December 31, 2018 included one other credit relationship in excess of $5 million totaling $6.4 million. Non-
accrual real estate loans primarily consist of land development, 1-4 family residential construction credit relationships 
and loans secured by office buildings and religious facilities. There were no non-accrual commercial real estate loans 
in excess of $5.0 million at December 31, 2019. Non-accrual commercial real estate loans included one relationship 
in excess of $5.0 million totaling $12.2 million at December 31, 2018. This credit relationship was sold during the 
second quarter of 2019.

Generally, loans are placed on non-accrual status if principal or interest payments become 90 days past due and/or 
management deems the collectibility of the principal and/or interest to be in question, as well as when required by 
regulatory requirements. Once interest accruals are discontinued, accrued but uncollected interest is charged to current 
year operations. Subsequent receipts on non-accrual loans are recorded as a reduction of principal, and interest income 
is recorded only after principal recovery is reasonably assured. Classification of a loan as non-accrual does not preclude 
the ultimate collection of loan principal or interest.

56

Foreclosed assets represent property acquired as the result of borrower defaults on loans. Foreclosed assets are 
recorded  at  estimated  fair  value,  less  estimated  selling  costs,  at  the  time  of  foreclosure. Write-downs  occurring  at 
foreclosure are charged against the allowance for loan losses. Regulatory guidelines require us to reevaluate the fair 
value of foreclosed assets on at least an annual basis. Our policy is to comply with the regulatory guidelines. Write-
downs are provided for subsequent declines in value and are included in other non-interest expense along with other 
expenses related to maintaining the properties. There were no write-downs of foreclosed assets in 2019 while write-
downs  totaled  $473  thousand  and  $16  thousand  during  2018  and  2017,  respectively.  There  were  no  significant 
concentrations of any properties, to which the aforementioned write-downs relate, in any single geographic region.

Accruing  past  due  loans  at  December 31,  2019  decreased  $21.9 million  compared  to  December 31,  2018.  The 
decrease was primarily related to decreases in past due commercial real estate loans (down $9.8 million) and past due 
commercial and industrial loans (down $7.7 million).

Potential problem loans consist of loans that are performing in accordance with contractual terms but for which 
management has concerns about the ability of an obligor to continue to comply with repayment terms because of the 
obligor’s  potential  operating  or  financial  difficulties.  Management  monitors  these  loans  closely  and  reviews  their 
performance on a regular basis. At December 31, 2019 and 2018, we had $46.8 million and $63.4 million in loans of 
this type which are not included in any one of the non-accrual, restructured or 90 days past due loan categories. At 
December 31, 2019, potential problem loans consisted of ten credit relationships. Of the total outstanding balance at 
December 31, 2019, 23.8% was related to the restaurant industry, 23.2% was related to the energy industry, 15.4% was 
related to the real estate industry and 12.9% was related to building contractors. Weakness in these organizations’ 
operating performance and financial condition, among other factors, have caused us to heighten the attention given to 
these credits. As such, all of the loans identified as potential problem loans at December 31, 2019 were graded as 
“substandard - accrual” (risk grade 11). Potential problem loans impact the allocation of our allowance for loan losses 
as a result of our risk grade based allocation methodology. See Note 3 - Loans in the accompanying consolidated 
financial statements for details regarding our allowance allocation methodology.

Allowance For Loan Losses

The allowance for loan losses is a reserve established through a provision for loan losses charged to expense, which 
represents management’s best estimate of inherent losses that have been incurred within the existing portfolio of loans. 
The allowance, in the judgment of management, is necessary to reserve for estimated loan losses and risks inherent in 
the loan portfolio. Our allowance for loan losses consists of: (i) specific valuation allowances determined in accordance 
with ASC Topic 310, “Receivables,” based on probable losses on specific loans; (ii) historical valuation allowances 
determined in accordance with ASC Topic 450, “Contingencies,” based on historical loan loss experience for similar 
loans  with  similar  characteristics  and  trends,  adjusted,  as  necessary,  to  reflect  the  impact  of  current  conditions; 
(iii) general valuation allowances determined in accordance with ASC Topic 450 based on various risk factors that are 
internal to us; and (iv) macroeconomic valuation allowances determined in accordance with ASC Topic 450 based upon 
management's assessment of current and expected economic conditions, trends and other quantitative and qualitative 
portfolio risk factors that are external to us or that are not otherwise captured in our allowance modeling process but 
could impact the credit risk or inherent losses within our loan portfolio segments.

Our model for the determination of the allowance for loan losses is largely prescriptive, based on policy, and calculated 
using quantitative data related to our loan portfolio. This calculation yields the minimum level of allowance required 
(“minimum calculated need”). In that the model is constructed to address aspects of the loan portfolio quantitatively 
as they move over time (both good and bad), the model output of the minimum calculated need will move directionally 
with the overall health of the portfolio and inherent losses in the portfolio at any period end. While the model inherently 
captures loan portfolio characteristics and actions such as risk grade migration, required specific reserves, net charge-
offs, among other things, the model contains a degree of imprecision arising from various items and portfolio risk 
factors that are not and cannot be incorporated in to the model but nonetheless have an impact on the overall level of 
allowance deemed appropriate by management. To adequately address this imprecision, our methodology to determine 
the allowance for loan losses provides for additional reserves in excess of the minimum calculated need. This process 
entails  the  application  of  management  judgment  related  to  various  non-model  items  and  portfolio  risk  factors  not 
addressed by the quantitative model but reflective of inherent losses in the portfolio. These additional reserves, which 
are reported as a component of our macroeconomic valuation allowances, are determined at the portfolio level and 
allocated as reserves for general economic risk to our various portfolio segments based upon management judgment.

57

On January 1, 2020, we adopted a new accounting standard which replaces the “incurred loss” model for measuring 
credit losses discussed above with a new “expected loss” model. See Note 20 - Accounting Standard Updates in the 
notes to consolidated financial statements included in Item 8. Financial Statements and Supplementary Data elsewhere 
in this report for additional details.

The table below provides an allocation of the year-end allowance for loan losses by loan type; however, allocation 
of a portion of the allowance to one category of loans does not preclude its availability to absorb losses in other categories. 
See Note 3 - Loans in the accompanying notes to consolidated financial statements elsewhere in this report for further 
details regarding our methodology for estimating the appropriate level of the allowance for loan losses and the amounts 
allocated to specific portfolio segments.

2019

2018

2017

2016

2015

Percentage
of Loans
in each
Category
to Total
Loans

Allowance
for
Loan
Losses

Percentage
of Loans
in each
Category
to Total
Loans

Allowance
for
Loan
Losses

Percentage
of Loans
in each
Category
to Total
Loans

Allowance
for
Loan
Losses

Percentage
of Loans
in each
Category
to Total
Loans

Allowance
for
Loan
Losses

Percentage
of Loans
in each
Category
to Total
Loans

Allowance
for
Loan
Losses

Commercial

and
industrial

Energy

Commercial
real estate

Consumer
real estate

Consumer
and other

Total

$ 51,593

35.2% $ 48,580

36.3% $ 59,614

36.4% $ 52,915

36.3% $ 42,993

37,382

11.2

29,052

11.4

51,528

11.4

60,653

11.6

54,696

35.9%

15.3

31,037

42.0

38,777

40.4

30,948

40.2

30,213

40.4

24,313

37.4

4,113

8,042

8.1

3.5

6,103

9,620

7.9

4.0

5,657

7,617

7.8

4.2

4,238

5,026

7.8

3.9

4,659

9,198

7.6

3.8

$ 132,167

100.0% $ 132,132

100.0% $ 155,364

100.0% $ 153,045

100.0% $ 135,859

100.0%

Allocation of the Allowance for Loan Losses at December 31, 2019 vs. December 31, 2018

The reserve allocated to commercial and industrial loans at December 31, 2019 increased $3.0 million compared to 
December 31, 2018. The increase was primarily due to increases in specific valuation allowances and historical valuation 
allowances  partly  offset  by  a  decrease  in  macroeconomic  valuation  allowances.  Specific  valuation  allowances  for 
commercial and industrial loans increased $5.3 million from $2.6 million at December 31, 2018 to $7.8 million at 
December 31, 2019. The increase included new specific valuation allowances totaling $5.6 million on three credit 
relationships which had an aggregate outstanding balance totaling $14.0 million at December 31, 2019. Historical 
valuation allowances increased $3.7 million from $25.4 million at December 31, 2018 to $29.0 million at December 31, 
2019. The increase was primarily related to an increase in the volume of non-classified loans graded "watch" (risk 
grade 9). Classified loans consist of loans having a risk grade of 11, 12 or 13. Classified commercial and industrial 
loans totaled $79.9 million at December 31, 2019 compared to $78.9 million at December 31, 2018. The weighted-
average risk grade of commercial and industrial loans was 6.44 at December 31, 2019 compared to 6.30 at December 31, 
2018. Commercial loan net charge-offs totaled $10.1 million during 2019 compared to $22.4 million during 2018. 
Charge-offs in 2018 included $15.3 million related to four credit relationships. Macroeconomic valuation allowances 
for commercial and industrial loans decreased $5.7 million from $10.6 million at December 31, 2018 to $4.9 million
at December 31, 2019. The decrease was primarily related to a decrease in the general macroeconomic risk allocation 
(down  $5.3  million),  as  further  discussed  below,  and  a  decrease  in  the  environmental  risk  adjustment  (down 
$454 thousand) as a result of a decrease in the environmental adjustment factor. 

The reserve allocated to energy loans at December 31, 2019 increased $8.3 million compared to December 31, 2018. 
As a result, reserves allocated to energy loans as a percentage of total energy loans totaled 2.26% at December 31, 2019
compared  to  1.81%  at  December 31,  2018.  This  increase  was  primarily  related  to  increases  in  specific  valuation 
allowances and, to a lesser extent, macroeconomic valuation allowances, partly offset by decreases in historical valuation 
allowances and general valuation allowances. Specific valuation allowances for energy loans totaled $20.2 million at 
December 31, 2019 and related to three credit relationships totaling $62.5 million while specific valuation allowances 
for energy loans totaled $9.7 million at December 31, 2018 and related to four credit relationships totaling $39.9 million. 
Macroeconomic  valuation  allowances  related  to  energy  loans  increased  $397  thousand  from  $3.7  million  at 
December 31, 2018 to $4.1 million at December 31, 2019, primarily due to an increase in the general macroeconomic 
risk  allocation  (up  $1.0  million),  as  further  discussed  below,  partly  offset  by  a  decrease  in  the  environmental  risk 

58

adjustment (down $590 thousand) as a result of decreases in the environmental adjustment factor and the historical 
loss valuation allowances to which the environmental risk adjustment factor is applied. Historical valuation allowances 
decreased $1.8 million from $9.7 million at December 31, 2018 to $7.9 million at December 31, 2019. The decrease 
was partly related to decreases in the historical loss allocation factors for both non-classified energy loans and classified 
energy loans. The decrease was also partly related to decreases in the volume of classified energy loans graded as 
"substandard - accrual" (risk grade 11) (down $10.7 million) and non-classified energy loans graded as "watch" (risk 
grade 9) (down $3.4 million) partly offset by increases in the volume of non-classified energy loans graded as "pass"(risk 
grades below 9) (up $36.6 million) and "special mention" (risk grade 10) (up $8.9 million). Total classified energy 
loans increased $8.2 million from $72.4 million at December 31, 2018 to $80.5 million at December 31, 2019. The 
weighted-average risk grade of energy loans increased to 6.39 at December 31, 2019 from to 6.22 at December 31, 
2018. Energy loan net charge-offs totaled $6.1 million during 2019 compared to net charge-offs of $13.1 million during 
2018. Charge-offs in 2019 included $7.5 million related to a single credit relationship. We also charged-off $6.0 million 
related to this credit relationship in 2018 as well as $7.3 million related to two other credit relationships. General 
valuation allowances decreased $818 thousand from $6.0 million at December 31, 2018 $5.2 million at December 31, 
2019. The decrease was primarily related to a decrease in the allocation for highly-leveraged transactions and an increase 
in the adjustment for recoveries partly offset by an increase in the allocation for excess concentrations. 

The reserve allocated to commercial real estate loans at December 31, 2019 decreased $7.7 million compared to 
December 31,  2018. The  decrease  was  primarily  related  to  decreases  in  macroeconomic  valuation  allowances  and 
specific valuation allowances partly offset by an increase in historical valuation allowances. Macroeconomic valuation 
allowances decreased $6.5 million from $11.0 million at December 31, 2018 to $4.5 million at December 31, 2019. 
The decrease was primarily related to a decrease in the general macroeconomic risk allocation (down $5.7 million), as 
further discussed below, and a decrease in the environmental risk adjustment (down $796 thousand), primarily resulting 
from a decrease in the environmental risk adjustment factor. Specific valuation allowances for commercial real estate 
loans totaled $383 thousand at December 31, 2019 decreasing $2.2 million from $2.6 million at December 31, 2018. 
Specific valuation allowances for commercial real estate loans at December 31, 2019 related to two credit relationships 
totaling $2.4 million. Specific valuation allowances at December 31, 2018 primarily related to a single credit relationship 
totaling $12.2 million. This relationship was sold during the second quarter of 2019. We recognized net charge-offs 
totaling $266 thousand in connection with the sale. Historical valuation allowances related to commercial real estate 
loans increased $1.1 million from $20.8 million at December 31, 2018 to $21.9 million at December 31, 2019. Non-
classified commercial real estate loans increased $523.3 million from $5.6 billion at December 31, 2018 to $6.1 billion
at December 31, 2019 while classified commercial real estate loans decreased $23.5 million from $118.3 million at 
December 31, 2018 to $94.8 million at December 31, 2019. The weighted-average risk grade of commercial real estate 
loans was 7.07 at December 31, 2019 and 7.05 at December 31, 2018. General valuation allowances for commercial 
real estate loans decreased $165 thousand from $4.4 million at December 31, 2018 to $4.2 million at December 31, 
2019. 

The reserve allocated to consumer real estate loans at December 31, 2019 decreased $2.0 million compared to 
December 31, 2018. This decrease was primarily due to a $1.1 million decrease in the general macroeconomic risk 
allocation,  as  further  discussed  below,  and  a  $767  thousand  decrease  in  general  valuation  allowances,  which  was 
primarily related to an increase in the adjustment for recoveries combined with a decrease in the allocation for loans 
not reviewed by concurrence.

The  reserve  allocated  to  consumer  and  other  loans  at  December 31,  2019  decreased  $1.6  million  compared  to 
December 31,  2018. The  decrease  was  primarily  related  to  decreases  in  specific  valuation  allowances  (down  $1.4 
million), macroeconomic valuation allowances (down $497 thousand) and general valuation allowances (down $396 
thousand) partly offset by an increase in historical valuation allowances (up $717 thousand). Specific allocations at 
December 31, 2018 included $1.4 million related to a single credit relationship of the same amount. The decrease in 
macroeconomic valuation allowances was primarily related to a decrease in the general macroeconomic risk allocation, 
as further discussed below, and a decrease in the environmental risk adjustment due to a decrease in the environmental 
risk adjustment factor. The decrease in general valuation allowances was primarily related to an increase in the adjustment 
for  recoveries  combined  with  a  decrease  in  the  allocation  for  loans  not  reviewed  by  concurrence. The  increase  in 
historical valuation allowances was primarily due to an increase in the historical loss allocation factor combined with 
an increase in the volume of consumer loans.

As discussed above, under our allowance methodology, we allocate additional reserves for general macroeconomic 
risk in excess of our minimum calculated need calculated using our allowance model. These additional reserves are 
based upon management's assessment of current and expected economic conditions, trends and other quantitative and 

59

qualitative portfolio risk factors that are external to us or that are not otherwise captured in our allowance modeling 
process but impact the credit risk or inherent losses within our loan portfolio segments. These additional reserves are 
allocated to our various portfolio segments based upon management judgment.

Activity in the allowance for loan losses is presented in the following table.

Balance of allowance for loan
losses at beginning of year
Provision for loan losses
Charge-offs:

Commercial and industrial
Energy
Commercial real estate
Consumer real estate
Consumer and other
Total charge-offs

Recoveries:

Commercial and industrial
Energy
Commercial real estate
Consumer real estate
Consumer and other
Total recoveries

Net charge-offs
Balance at end of year
Net loan charge-offs to average
loans
Allowance for loan losses to
year-end loans
Allowance for loan losses to
year-end non-accrual loans
Average loans
Year-end loans
Year-end non-accrual loans

2019

2018

2017

2016

2015

$

132,132
33,759

$

155,364
21,613

$

153,045
35,460

$

135,859
51,673

$

99,542
51,845

(14,117)
(7,500)
(1,025)
(3,665)
(24,725)
(51,032)

3,986
1,442
219
1,208
10,453
17,308
(33,724)
132,167

$

(26,076)
(13,940)
(619)
(2,143)
(17,197)
(59,975)

3,688
819
369
605
9,649
15,130
(44,845)
132,132

$

(20,619)
(10,595)
(86)
(925)
(15,579)
(47,804)

3,166
586
832
419
9,660
14,663
(33,141)
155,364

$

(15,910)
(18,644)
(82)
(814)
(12,878)
(48,328)

3,651
56
918
557
8,659
13,841
(34,487)
153,045

$

(11,092)
(6,000)
(657)
(577)
(11,246)
(29,572)

4,557
3
989
486
8,009
14,044
(15,528)
135,859

$

0.23%

0.90

0.33%

0.94

0.27%

1.18

0.30%

0.14%

1.28

1.18

129.19
$14,440,549
14,750,332
102,303

179.19
$13,617,940
14,099,733
73,739

103.36
$12,460,148
13,145,665
150,314

152.81
$11,554,823
11,975,392
100,151

162.77
$11,267,402
11,486,531
83,467

The provision for loan losses reflects loan quality trends, including the levels of and trends related to non-accrual 
loans, past due loans, potential problem loans, classified and criticized loans and net charge-offs or recoveries, among 
other factors. The provision for loan losses also reflects the totality of actions taken on all loans for a particular period. 
In other words, the amount of the provision reflects not only the necessary increases in the allowance for loan losses 
related to newly identified criticized loans, but it also reflects actions taken related to other loans including, among 
other things, any necessary increases or decreases in required allowances for specific loans or loan pools.

The provision for loan losses increased $12.1 million, or 56.2%, in 2019 compared to 2018. The provision for loan 
losses during 2019 primarily reflects the level of net charge-offs and specific valuation allowances as well as the impact 
of the overall growth in the loan portfolio since December 31, 2018. Net charge-offs totaled $33.7 million during 2019
compared to $44.8 million during 2018. Specific valuation allowances totaled $28.5 million at December 31, 2019
compared to $16.2 million at December 31, 2018. Classified energy, commercial and industrial and commercial real 
estate loans totaled $255.2 million at December 31, 2019 compared to $269.6 million at December 31, 2018. The overall 
weighted-average risk grade of our energy, commercial and industrial and commercial real estate loan portfolios was 
6.73 at December 31, 2019 compared to 6.63 at December 31, 2018. 

The ratio of the allowance for loan losses to total loans was 0.90% at December 31, 2019 compared to 0.94% at 
December 31, 2018. Management believes the recorded amount of the allowance for loan losses is appropriate based 
upon management’s best estimate of probable losses that have been incurred within the existing portfolio of loans. 
Should any of the factors considered by management in evaluating the appropriate level of the allowance for loan losses 

60

change, our estimate of probable loan losses could also change, which could affect the level of future provisions for 
loan losses.

Securities

Year-end securities were as follows:

2019

2018

2017

Amount

Percentage
of Total

Amount

Percentage
of Total

Amount

Percentage
of Total

Held to maturity:

Residential mortgage-backed
securities
States and political subdivisions
Other

$

Total

Available for sale:
U.S. Treasury
Residential mortgage-backed
securities
States and political subdivisions
Other

Total
Trading:

530,861
1,497,644
1,500
2,030,005

1,948,133

2,207,594
7,070,997
42,867
11,269,591

4.0% $

11.2
—
15.2

14.6

16.6
53.1
0.3
84.6

2,737
1,101,820
1,500
1,106,057

3,427,689

829,740
7,087,202
42,690
11,387,321

—% $
8.8
—
8.8

3,610
1,428,488
—
1,432,098

27.4

6.6
56.6
0.4
91.0

3,445,153

665,086
6,336,209
42,561
10,489,009

—%

12.0
—
12.0

28.8

5.6
53.1
0.3
87.8

U.S. Treasury
States and political subdivisions

Total
Total securities

24,298
—
24,298
$ 13,323,894

0.2
—
0.2

21,928
2,158
24,086
100.0% $ 12,517,464

0.2
—
0.2

19,210
1,888
21,098
100.0% $ 11,942,205

0.2
—
0.2
100.0%

The following tables summarize the maturity distribution schedule with corresponding weighted-average yields of 
securities held to maturity and securities available for sale as of December 31, 2019. Weighted-average yields have 
been computed on a fully taxable-equivalent basis using a tax rate of 21%. Mortgage-backed securities are included in 
maturity categories based on their stated maturity date. Expected maturities may differ from contractual maturities 
because issuers may have the right to call or prepay obligations. Other securities classified as available for sale include 
stock in the Federal Reserve Bank and the Federal Home Loan Bank, which have no maturity date. These securities 
have been included in the total column only.

Within 1 Year

1-5 Years

5-10 Years

After 10 Years

Total

Weighted
Average
Yield

Amount

Weighted
Average
Yield

Weighted
Average
Yield

Amount

Weighted
Average
Yield

Amount

Amount

Weighted
Average
Yield

Amount

Held to maturity:

Residential mortgage-
backed securities
States and political

subdivisions

Other

Total

Available for sale:

U.S. Treasury

Residential mortgage-
backed securities
States and political

subdivisions

Other

Total

$

—

—% $

386

3.58% $

517,112

2.28% $

13,363

2.68% $

530,861

2.29%

11,273

1,500

$

12,773

4.23

2.57

4.04

165,519

—

3.33

—

527,907

—

3.14

—

792,945

—

3.57

—

1,497,644

1,500

$

165,905

3.33

$ 1,045,019

2.71

$

806,308

3.55

$ 2,030,005

3.40

2.57

3.11

$

348,885

1.53% $ 1,102,170

2.26% $

—

—% $

497,078

2.27% $ 1,948,133

2.13%

385

160,519

—

5.23

3.01

—

77,332

241,865

—

2.37

3.20

—

11,791

478,800

—

4.06

3.52

—

2,118,086

6,189,813

—

3.11

3.74

—

2,207,594

7,070,997

42,867

$

509,789

2.00

$ 1,421,367

2.43

$

490,591

3.53

$ 8,804,977

3.51

$ 11,269,591

3.09

3.69

—

3.29

Securities are classified as held to maturity and carried at amortized cost when management has the positive intent 
and ability to hold them to maturity. Securities are classified as available for sale when they might be sold before 

61

maturity. Securities available for sale are carried at fair value, with unrealized holding gains and losses reported in other 
comprehensive income, net of tax. The remaining securities are classified as trading. Trading securities are held primarily 
for sale in the near term and are carried at their fair values, with unrealized gains and losses included immediately in 
other income. Management determines the appropriate classification of securities at the time of purchase. Securities 
with limited marketability, such as stock in the Federal Reserve Bank and the Federal Home Loan Bank, are carried at 
cost.

All  mortgage-backed  securities  included  in  the  above  tables  were  issued  by  U.S.  government  agencies  and 
corporations. At December 31, 2019, approximately 99.7% of the securities in our municipal bond portfolio were issued 
by the State of Texas or political subdivisions or agencies within the State of Texas, of which approximately 69.1% are 
either guaranteed by the Texas Permanent School Fund, which has a “triple-A” insurer financial strength rating, or 
secured by U.S. Treasury securities via defeasance of the debt by the issuers. At December 31, 2019, we held general 
obligation bonds issued by the State of Texas with an aggregate amortized cost of $998.4 million and an aggregate fair 
value of $1.1 billion. Such amounts were in excess of 10% of our shareholders’ equity at December 31, 2019. At such 
date, all of these securities were considered "high grade" or better by various credit rating agencies. At December 31, 
2019, there were no other holdings of any one issuer, other than the U.S. government and its agencies, in an amount 
greater than 10% of our shareholders’ equity.

The average taxable-equivalent yield on the securities portfolio based on a 21% tax rate was 3.40% in 2019 compared 
to 3.38% in 2018. Tax-exempt municipal securities totaled 62.0% of average securities in 2019 compared to 65.0% in 
2018. The average yield on taxable securities was 2.33% in 2019 compared to 2.03% in 2018, while the average taxable-
equivalent yield on tax-exempt securities was 4.06% in 2019 compared to 4.11% in 2018. See the section captioned 
“Net Interest Income” elsewhere in this discussion. The overall growth in the securities portfolio in 2019 was primarily 
funded by the reinvestment of excess reserves held in an interest-bearing account at the Federal Reserve.

Deposits

The table below presents the daily average balances of deposits by type and weighted-average rates paid thereon 

during the years presented:

2019

2018

2017

Average
Balance

Average
Rate Paid

Average
Balance

Average
Rate Paid

Average
Balance

Average
Rate Paid

Non-interest-bearing demand deposits:

Commercial and individual
Correspondent banks
Public funds
Total

Interest-bearing deposits:

Private accounts:

Savings and interest checking
Money market accounts
Time accounts of $100,000 or more
Time accounts under $100,000

Public funds
Total
Total deposits

$

9,829,635
213,442
315,339
10,358,416

6,777,473
7,738,654
647,215
342,692
548,827
16,054,861
$ 26,413,277

$ 10,164,396
205,727
386,685
10,756,808

$ 10,155,502
245,759
418,165
10,819,426

0.07%
0.93
1.73
1.49
1.31
0.62
0.38

6,667,695
7,645,624
474,472
325,624
418,843
15,532,258
$ 26,289,066

0.08%
0.77
0.87
0.71
1.04
0.49
0.29

6,376,855
7,502,494
446,695
329,245
430,203
15,085,492
$ 25,904,918

0.02%
0.17
0.26
0.18
0.33
0.11
0.07

Average deposits increased $124.2 million, or 0.5%, in 2019 compared to 2018. The most significant volume growth 
during 2019 compared to 2018 was in time, interest-bearing public funds, savings and interest checking and money 
market deposits. This growth was mostly offset by decreases in the volume of non-interest bearing commercial and 
individual deposits as well as non-interest bearing public funds deposits. The ratio of average interest-bearing deposits 
to total average deposits was 60.8% in 2019 compared to 59.1% in 2018. The average cost of interest-bearing deposits 
and total deposits was 0.62% and 0.38% during 2019 compared to 0.49% and 0.29% during 2018. The increase in the 
average cost of interest-bearing deposits in 2019 as compared to 2018 was related to higher average interest rates paid 
on most of our interest-bearing deposit products, particularly during the first half of 2019, as a result of higher average 
market interest rates.

62

The following table presents the proportion of each component of average non-interest-bearing deposits to the total 

of such non-interest-bearing deposits during the years presented:

Commercial and individual
Correspondent banks
Public funds

Total

2019

2018

2017

94.9%
2.1
3.0
100.0%

94.5%
1.9
3.6
100.0%

93.8%
2.3
3.9
100.0%

Average non-interest-bearing deposits decreased $398.4 million, or 3.7%, in 2019 compared to 2018. The decrease 
was primarily due to a $334.8 million, or 3.3%, decrease in average commercial and individual deposits and a $71.3 
million, or 18.5%, decrease in average public fund deposits partly offset by a $7.7 million, or 3.8%, increase in average 
correspondent bank deposits. 

The following table presents the proportion of each component of average interest-bearing deposits to the total of 

such interest-bearing deposits during the years presented:

Private accounts:

Savings and interest checking
Money market accounts
Time accounts of $100,000 or more
Time accounts under $100,000

Public funds

Total

2019

2018

2017

42.2%
48.2
4.1
2.1
3.4
100.0%

42.9%
49.2
3.1
2.1
2.7
100.0%

42.3%
49.7
2.9
2.2
2.9
100.0%

Total average interest-bearing deposits increased $522.6 million, or 3.4%, in 2019 compared to 2018 primarily due 
to a $189.8 million, or 23.7%, increase in average time deposits, a $130.0 million, or 31.0%, increase in average public 
funds deposits, a $109.8 million, or 1.6%, increase in average savings and interest checking deposits and a $93.0 million, 
or 1.2%, increase in average money market deposits.

From time to time, we have obtained interest-bearing deposits through brokered transactions including participation 
in the Certificate of Deposit Account Registry Service (“CDARS”). Brokered deposits were not significant during the 
reported periods.

Geographic Concentrations. The following table summarizes our average total deposit portfolio, as segregated by 
the geographic region from which the deposit accounts were originated. Certain accounts, such as correspondent bank 
deposits and deposits allocated to certain statewide operational units, are recorded at the statewide level.

Percent

Percent

San Antonio
Fort Worth
Houston
Austin
Dallas
Corpus Christi
Permian Basin
Rio Grande Valley
Statewide
Total

$

2019
7,981,160
4,699,142
4,467,132
3,285,637
2,160,684
1,465,586
1,326,517
747,713
279,706
$ 26,413,277

of Total

2018
7,846,388
4,813,424
4,578,782
3,175,030
2,157,648
1,483,365
1,232,892
744,952
256,585
100.0% $ 26,289,066

30.2% $
17.8
16.9
12.5
8.2
5.6
5.0
2.8
1.0

of Total

2017
7,890,139
4,784,241
4,544,448
3,089,645
2,048,712
1,458,044
1,218,402
775,646
95,641
100.0% $ 25,904,918

29.9% $
18.3
17.4
12.1
8.2
5.6
4.7
2.8
1.0

Percent

of Total

30.5%
18.5
17.5
11.9
7.9
5.6
4.7
3.0
0.4
100.0%

Foreign Deposits. Mexico has historically been considered a part of the natural trade territory of our banking offices. 
Accordingly, U.S. dollar-denominated foreign deposits from sources within Mexico have traditionally been a significant 
source  of  funding. Average  deposits  from  foreign  sources,  primarily  Mexico,  totaled  $774.0 million  in  2019  and 
$737.6 million in 2018.

63

Short-Term Borrowings

Our primary source of short-term borrowings is federal funds purchased from correspondent banks and repurchase 
agreements in our natural trade territory, as well as from upstream banks. Federal funds purchased and repurchase 
agreements totaled $1.7 billion, $1.4 billion and $1.1 billion at December 31, 2019, 2018 and 2017. The maximum 
amount of these borrowings outstanding at any month-end was $1.7 billion in 2019, $1.4 billion in 2018 and $1.1 billion 
in  2017. The  weighted-average  interest  rate  on  federal  funds  purchased  and  repurchase  agreements  was  0.81%  at 
December 31, 2019, 1.33% at December 31, 2018 and 0.23% at December 31, 2017.

The following table presents our average net funding position during the years indicated:

2019

2018

2017

Average
Balance

Average
Rate

Average
Balance

Average
Rate

Average
Balance

Average
Rate

Federal funds sold and resell
agreements
Federal funds purchased and
repurchase agreements
Net funds position

$

245,613

2.25% $

265,085

2.07% $

73,140

1.28%

(1,283,381)
$(1,037,768)

1.53

(1,054,915)
$ (789,830)

0.76

(978,571)
$ (905,431)

0.16

The net funds purchased position increased $247.9 million in 2019 compared to 2018. Average interest-bearing 
deposits (primarily excess reserves held in an interest-bearing account at the Federal Reserve) totaled $1.6 billion in 
2019 compared to $3.0 billion in 2018 and $3.6 billion in 2017. During the reported periods, we have maintained excess 
liquid funds in interest-bearing deposits with the Federal Reserve rather than federal funds sold in order to capitalize 
on higher available yields.

Off Balance Sheet Arrangements, Commitments, Guarantees, and Contractual Obligations

The following table summarizes our contractual obligations and other commitments to make future payments as of 
December 31, 2019. Payments for borrowings do not include interest. Payments related to leases are based on actual 
payments  specified  in  the  underlying  contracts.  Loan  commitments  and  standby  letters  of  credit  are  presented  at 
contractual amounts; however, since many of these commitments are expected to expire unused or only partially used, 
the total amounts of these commitments do not necessarily reflect future cash requirements.

Contractual obligations:

Subordinated notes payable
Junior subordinated deferrable

interest debentures

Operating leases
Deposits with stated maturity dates

Other commitments:

Commitments to extend credit
Standby letters of credit

Total contractual obligations and
other commitments

Payments Due by Period

Less than 1
Year

1-3 Years

3-5 Years

More than 5
Years

Total

$

— $

— $

— $

100,000

$

100,000

—
28,225
891,005
919,230

—
58,988
217,591
276,579

—
51,893
—
51,893

137,115
283,300
—
520,415

3,641,886
187,176
3,829,062

3,490,284
67,559
3,557,843

1,044,979
5,008
1,049,987

1,128,894
844
1,129,738

137,115
422,406
1,108,596
1,768,117

9,306,043
260,587
9,566,630

$ 4,748,292

$ 3,834,422

$ 1,101,880

$ 1,650,153

$ 11,334,747

64

Financial  Instruments  with  Off-Balance-Sheet  Risk.  In  the  normal  course  of  business,  we  enter  into  various 
transactions, which, in accordance with accounting principles generally accepted in the United States, are not included 
in our consolidated balance sheets. We enter into these transactions to meet the financing needs of our customers. These 
transactions include commitments to extend credit and standby letters of credit, which involve, to varying degrees, 
elements of credit risk and interest rate risk in excess of the amounts recognized in the consolidated balance sheets. 
We minimize our exposure to loss under these commitments by subjecting them to credit approval and monitoring 
procedures. We also hold certain assets which are not included in our consolidated balance sheets including assets held 
in fiduciary or custodial capacity on behalf of our trust customers.

Commitments  to  Extend  Credit.  We  enter  into  contractual  commitments  to  extend  credit,  normally  with  fixed 
expiration dates or termination clauses, at specified rates and for specific purposes. Substantially all of our commitments 
to  extend  credit  are  contingent  upon  customers  maintaining  specific  credit  standards  at  the  time  of  loan  funding. 
Commitments to extend credit outstanding at December 31, 2019 are included in the table above.

Standby Letters of Credit. Standby letters of credit are written conditional commitments issued by us to guarantee 
the performance of a customer to a third party. In the event the customer does not perform in accordance with the terms 
of the agreement with the third party, we would be required to fund the commitment. The maximum potential amount 
of future payments we could be required to make is represented by the contractual amount of the commitment. If the 
commitment is funded, we would be entitled to seek recovery from the customer. Our policies generally require that 
standby letter of credit arrangements contain security and debt covenants similar to those contained in loan agreements. 
Standby letters of credit outstanding at December 31, 2019 are included in the table above.

Trust Accounts. We also hold certain assets in fiduciary or custodial capacity on behalf of our trust customers. The 
estimated fair value of trust assets was approximately $37.8 billion (including managed assets of $16.4 billion and 
custody assets of $21.4 billion) at December 31, 2019. These assets were primarily composed of equity securities 
(50.7% of trust assets), fixed income securities (35.0% of trust assets) and cash equivalents (8.9% of trust assets).

Capital and Liquidity

Capital. Shareholders’ equity totaled $3.9 billion at December 31, 2019 and $3.4 billion at December 31, 2018. In 
addition to net income of $443.6 million, other sources of capital during 2019 included other comprehensive income, 
net of tax, of $331.0 million, $20.8 million in proceeds from stock option exercises and $15.9 million related to stock-
based compensation. Uses of capital during 2019 included $185.1 million of dividends paid on preferred and common 
stock, $68.8 million of treasury stock purchases and $14.7 million related to the cumulative effect of a new accounting 
principle adopted during the first quarter of 2019. See Note 1 - Summary of Significant Accounting Policies.

The  accumulated  other  comprehensive  income/loss  component  of  shareholders’  equity  totaled  a  net,  after-tax, 
unrealized gain of $267.4 million at December 31, 2019 compared to a net, after-tax, unrealized loss of $63.6 million
at December 31, 2018. The change was primarily due to a $329.4 million net after-tax change in the net unrealized 
gain/loss on securities available for sale and securities transferred to held to maturity.

Under  the  Basel III  Capital  Rules,  we  elected  to  opt-out  of  the  requirement  to  include  most  components  of 
accumulated other comprehensive income in regulatory capital. Accordingly, amounts reported as accumulated other 
comprehensive income/loss related to securities available for sale, effective cash flow hedges and defined benefit post-
retirement benefit plans do not increase or reduce regulatory capital and are not included in the calculation of risk-
based capital and leverage ratios. Regulatory agencies for banks and bank holding companies utilize capital guidelines 
designed to measure capital and take into consideration the risk inherent in both on-balance sheet and off-balance sheet 
items. See Note 9 - Capital and Regulatory Matters in the accompanying notes to consolidated financial statements 
elsewhere in this report.

We paid quarterly dividends of $0.67, $0.71, $0.71 and $0.71 per common share during the first, second, third and 
fourth quarters of 2019, respectively, and quarterly dividends of $0.57, $0.67, $0.67 and $0.67 per common share during 
the first, second, third and fourth quarters of 2018, respectively. This equates to a dividend payout ratio of 40.6% in 
2019 and 37.0% in 2018. Under the terms of the junior subordinated deferrable interest debentures that Cullen/Frost 
has issued to Cullen/Frost Capital Trust II and WNB Capital Trust I, we have the right at any time during the term of 
the debentures to defer the payment of interest any time or from time to time for an extension period not exceeding 20 
consecutive quarterly periods with respect to each extension period. Our ability to declare or pay dividends on, or 
purchase, redeem or otherwise acquire, shares of our capital stock is subject to certain restrictions during any such 
extension period. Under the terms of the Series A Preferred Stock, our ability to declare or pay dividends on, or purchase, 

65

redeem or otherwise acquire, shares of our common stock or any of our securities that rank junior to the Series A 
Preferred Stock is subject to certain restrictions in the event that we do not declare and pay dividends on the Series A 
Preferred Stock for the most recent dividend period.

Stock Repurchase Plans. From time to time, our board of directors has authorized stock repurchase plans. In general, 
stock repurchase plans allow us to proactively manage our capital position and return excess capital to shareholders. 
Shares purchased under such plans also provide us with shares of common stock necessary to satisfy obligations related 
to stock compensation awards. On July 24, 2019, our board of directors authorized a $100.0 million stock repurchase 
program, allowing us to repurchase shares of our common stock over a one-year period from time to time at various 
prices in the open market or through private transactions. Under this plan, we repurchased 202,724 shares at a total 
cost of $17.2 million during 2019. Under prior stock repurchase programs, we repurchased 496,307 shares at a total 
cost of $50.0 million during 2019 and 1,027,292 shares at a total cost of $100.0 million during 2018. See Part II, Item 5 -
 Market  for  Registrant’s  Common  Equity,  Related  Stockholder  Matters  and  Issuer  Purchases  of  Equity  Securities, 
elsewhere in this report.

Liquidity. Liquidity measures the ability to meet current and future cash flow needs as they become due. The liquidity 
of a financial institution reflects its ability to meet loan requests, to accommodate possible outflows in deposits and to 
take advantage of interest rate market opportunities. The ability of a financial institution to meet its current financial 
obligations is a function of its balance sheet structure, its ability to liquidate assets and its access to alternative sources 
of funds. The objective of our liquidity management is to manage cash flow and liquidity reserves so that they are 
adequate to fund our operations and to meet obligations and other commitments on a timely basis and at a reasonable 
cost. We seek to achieve this objective and ensure that funding needs are met by maintaining an appropriate level of 
liquid funds through asset/liability management, which includes managing the mix and time to maturity of financial 
assets and financial liabilities on our balance sheet. Our liquidity position is enhanced by our ability to raise additional 
funds as needed in the wholesale markets.

Asset liquidity is provided by liquid assets which are readily marketable or pledgeable or which will mature in the 
near future. Liquid assets include cash, interest-bearing deposits in banks, securities available for sale, maturities and 
cash flow from securities held to maturity, and federal funds sold and resell agreements.

Liability liquidity is provided by access to funding sources which include core deposits and correspondent banks 
in our natural trade area that maintain accounts with and sell federal funds to Frost Bank, as well as federal funds 
purchased and repurchase agreements from upstream banks and deposits obtained through financial intermediaries.

Our liquidity position is continuously monitored and adjustments are made to the balance between sources and uses 
of funds as deemed appropriate. Liquidity risk management is an important element in our asset/liability management 
process. We regularly model liquidity stress scenarios to assess potential liquidity outflows or funding problems resulting 
from economic disruptions, volatility in the financial markets, unexpected credit events or other significant occurrences 
deemed  problematic  by  management. These  scenarios  are  incorporated  into  our  contingency  funding  plan,  which 
provides the basis for the identification of our liquidity needs. As of December 31, 2019, management is not aware of 
any events that are reasonably likely to have a material adverse effect on our liquidity, capital resources or operations. 
In addition, management is not aware of any regulatory recommendations regarding liquidity that would have a material 
adverse effect on us.

Since  Cullen/Frost  is  a  holding  company  and  does  not  conduct  operations,  its  primary  sources  of  liquidity  are 
dividends upstreamed from Frost Bank and borrowings from outside sources. Banking regulations may limit the amount 
of dividends that may be paid by Frost Bank. See Note 9 - Capital and Regulatory Matters in the accompanying notes 
to consolidated financial statements elsewhere in this report regarding such dividends. At December 31, 2019, Cullen/
Frost had liquid assets, including cash and resell agreements, totaling $267.1 million.

Impact of Inflation and Changing Prices

Our financial statements included herein have been prepared in accordance with accounting principles generally 
accepted in the United States (“GAAP”). GAAP presently requires us to measure financial position and operating results 
primarily in terms of historic dollars. Changes in the relative value of money due to inflation or recession are generally 
not  considered.  The  primary  effect  of  inflation  on  our  operations  is  reflected  in  increased  operating  costs.  In 
management’s opinion, changes in interest rates affect the financial condition of a financial institution to a far greater 
degree than changes in the inflation rate. While interest rates are greatly influenced by changes in the inflation rate, 
they do not necessarily change at the same rate or in the same magnitude as the inflation rate. Interest rates are highly 

66

sensitive to many factors that are beyond our control, including changes in the expected rate of inflation, the influence 
of general and local economic conditions and the monetary and fiscal policies of the United States government, its 
agencies and various other governmental regulatory authorities, among other things, as further discussed in the next 
section.

Regulatory and Economic Policies

Our business and earnings are affected by general and local economic conditions and by the monetary and fiscal 
policies of the United States government, its agencies and various other governmental regulatory authorities, among 
other things. The Federal Reserve Board regulates the supply of money in order to influence general economic conditions. 
Among the instruments of monetary policy historically available to the Federal Reserve Board are (i) conducting open 
market  operations  in  United  States  government  obligations,  (ii) changing  the  discount  rate  on  financial  institution 
borrowings, (iii) imposing or changing reserve requirements against financial institution deposits, and (iv) restricting 
certain borrowings and imposing or changing reserve requirements against certain borrowings by financial institutions 
and their affiliates. These methods are used in varying degrees and combinations to affect directly the availability of 
bank loans and deposits, as well as the interest rates charged on loans and paid on deposits. For that reason alone, the 
policies of the Federal Reserve Board have a material effect on our earnings.

Governmental policies have had a significant effect on the operating results of commercial banks in the past and are 
expected to continue to do so in the future; however, we cannot accurately predict the nature, timing or extent of any 
effect such policies may have on our future business and earnings.

Accounting Standards Updates

See  Note 20 - Accounting  Standards  Updates  in  the  accompanying  notes  to  consolidated  financial  statements 
elsewhere in this report for details of recently issued accounting pronouncements and their expected impact on our 
financial statements.

ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

The disclosures set forth in this item are qualified by Item 1A. Risk Factors and the section captioned “Forward-
Looking Statements and Factors that Could Affect Future Results” included in Item 7. Management’s Discussion and 
Analysis of Financial Condition and Results of Operations, of this report, and other cautionary statements set forth 
elsewhere in this report.

Market risk refers to the risk of loss arising from adverse changes in interest rates, foreign currency exchange rates, 
commodity prices, and other relevant market rates and prices, such as equity prices. The risk of loss can be assessed 
from  the  perspective  of  adverse  changes  in  fair  values,  cash  flows,  and  future  earnings.  Due  to  the  nature  of  our 
operations, we are primarily exposed to interest rate risk and, to a lesser extent, liquidity risk.

Interest rate risk on our balance sheets consists of reprice, option, and basis risks. Reprice risk results from differences 
in the maturity, or repricing, of asset and liability portfolios. Option risk arises from “embedded options” present in 
many financial instruments such as loan prepayment options, deposit early withdrawal options and interest rate options. 
These options allow customers opportunities to benefit when market interest rates change, which typically results in 
higher costs or lower revenue for us. Basis risk refers to the potential for changes in the underlying relationship between 
market rates and indices, which subsequently result in a narrowing of the profit spread on an earning asset or liability. 
Basis risk is also present in administered rate liabilities, such as savings accounts, negotiable order of withdrawal 
accounts, and money market accounts where historical pricing relationships to market rates may change due to the level 
or directional change in market interest rates.

We seek to avoid fluctuations in our net interest margin and to maximize net interest income within acceptable levels 
of risk through periods of changing interest rates. Accordingly, our interest rate sensitivity and liquidity are monitored 
on an ongoing basis by our Asset and Liability Committee (“ALCO”), which oversees market risk management and 
establishes risk measures, limits and policy guidelines for managing the amount of interest rate risk and its effect on 
net interest income and capital. A variety of measures are used to provide for a comprehensive view of the magnitude 
of interest rate risk, the distribution of risk, the level of risk over time and the exposure to changes in certain interest 
rate relationships.

67

We utilize an earnings simulation model as the primary quantitative tool in measuring the amount of interest rate 
risk associated with changing market rates. The model quantifies the effects of various interest rate scenarios on projected 
net interest income and net income over the next 12 months. The model measures the impact on net interest income 
relative  to  a  flat-rate  case  scenario  of  hypothetical  fluctuations  in  interest  rates  over  the  next  12 months.  These 
simulations incorporate assumptions regarding balance sheet growth and mix, pricing and the repricing and maturity 
characteristics of the existing and projected balance sheet. The impact of interest rate derivatives, such as interest rate 
swaps, caps and floors, is also included in the model. Other interest rate-related risks such as prepayment, basis and 
option risk are also considered.

ALCO continuously monitors and manages the balance between interest rate-sensitive assets and liabilities. The 
objective is to manage the impact of fluctuating market rates on net interest income within acceptable levels. In order 
to meet this objective, management may lengthen or shorten the duration of assets or liabilities or enter into derivative 
contracts to mitigate potential market risk.

For modeling purposes, as of December 31, 2019, the model simulations projected that 100 and 200 basis point 
ratable increases in interest rates would result in positive variances in net interest income of 1.0% and 2.6%, respectively, 
relative to the flat-rate case over the next 12 months, while 100 and 175 basis point ratable decreases in interest rates 
would result in negative variances in net interest income of 1.9% and 6.4%, respectively, relative to the flat-rate case 
over the next 12 months. The December 31, 2019 model simulations for increased interest rates were impacted by the 
assumption, for modeling purposes, that we will begin to pay interest on commercial demand deposits (those not already 
receiving an earnings credit rate) in the first quarter of 2020, as further discussed below. As of December 31, 2018, the 
model simulations projected that 100 and 200 basis point ratable increases in interest rates would result in positive 
variances in net interest income of 0.3% and 1.5%, respectively, relative to the flat-rate case over the next 12 months, 
while 100 and 200 basis point ratable decreases in interest rates would result in negative variances in net interest income 
of 2.7% and 7.5%, respectively, relative to the flat-rate case over the next 12 months. The December 31, 2018 model 
simulations for increased interest rates were impacted by the assumption, for modeling purposes, that we would begin 
to pay interest on commercial demand deposits (those not already receiving an earnings credit rate) in the first quarter 
of  2019,  as  further  discussed  below.  The  likelihood  of  a  decrease  in  interest  rates  beyond  175  basis  points  as  of 
December 31, 2019 was considered to be remote given prevailing interest rate levels.

The model simulations as of December 31, 2019 indicate that our projected balance sheet is more asset sensitive in 
comparison to our balance sheet as of December 31, 2018. The shift to a more asset sensitive position was primarily 
due to a decrease in the assumed interest rate paid on projected commercial demand deposits (those not already receiving 
an earnings credit rate), as further discussed below. The impact of this change in assumptions was partly offset by the 
effect of a decrease in the relative proportion of interest-bearing deposits and federal funds sold to projected average 
interest-earning assets. Interest-bearing deposits and federal funds sold are more immediately impacted by changes in 
interest rates in comparison to our other categories of earning assets.

We do not currently pay interest on a significant portion of our commercial demand deposits. Any interest rate that 
would ultimately be paid on these commercial demand deposits would likely depend upon a variety of factors, some 
of  which  are  beyond  our  control.  Our  modeling  simulation  as  of  December 31,  2019  assumed  a  moderate  pricing 
structure with regards to interest payments on commercial demand deposits (those not already receiving an earnings 
credit)  with  interest  payments  assumed  to  begin  in  the  first  quarter  of  2020.  This  moderate  pricing  structure  on 
commercial demand deposits assumes a deposit pricing beta of 25%. The pricing beta is a measure of how much deposit 
rates reprice, up or down, given a defined change in market rates. Our modeling simulation as of December 31, 2018 
assumed a much more aggressive pricing structure with regards to interest payments for commercial demand deposits 
(those not already receiving and earnings credit) with interest payments assumed to begin in the first quarter of 2019. 
We modified our assumed pricing structure during 2019 compared to 2018 based upon our market observations during 
the most recent interest rate cycle.

As of December 31, 2019, the effects of a 200 basis point increase and a 175 basis point decrease in interest rates 

on our derivative holdings would not result in a significant variance in our net interest income.

The effects of hypothetical fluctuations in interest rates on our securities classified as “trading” under ASC Topic 320, 
“Investments - Debt and Equity Securities” are not significant, and, as such, separate quantitative disclosure is not 
presented.

68

ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of 
Cullen/Frost Bankers, Incorporated

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of Cullen/Frost Bankers, Inc. (the Company) as of 
December 31, 2019 and 2018, and the related consolidated statements of income, comprehensive income, changes in 
shareholders’ equity and cash flows for each of the three years in the period ended December 31, 2019, and the related 
notes  (collectively  referred  to  as  the  consolidated  financial  statements).  In  our  opinion,  the  consolidated  financial 
statements present fairly, in all material respects, the financial position of the Company at December 31, 2019 and 
2018, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 
2019, in conformity with U.S. generally accepted accounting principles.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United 
States) (PCAOB), the Company’s internal control over financial reporting as of December 31, 2019, based on criteria 
established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the 
Treadway Commission (2013 framework) and our report dated February 4, 2020 expressed an unqualified opinion 
thereon.

Basis for Opinion 

These financial statements are the responsibility of the Company’s management. Our responsibility is to express an 
opinion on the Company’s financial statements based on our audits. We are a public accounting firm registered with 
the  PCAOB  and  are  required  to  be  independent  with  respect  to  the  Company  in  accordance  with  the  U.S.  federal 
securities laws and applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and 
perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, 
whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement 
of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such 
procedures  included  examining,  on  a  test  basis,  evidence  regarding  the  amounts  and  disclosures  in  the  financial 
statements.  Our  audits  also  included  evaluating  the  accounting  principles  used  and  significant  estimates  made  by 
management, as well as evaluating the overall presentation of the financial statements. We believe that our audits 
provide a reasonable basis for our opinion.

Critical Audit Matter

The critical audit matter communicated below is a matter arising from the current period audit of the financial 
statements that was communicated or required to be communicated to the audit committee and that: (1) relates to 
accounts  or  disclosures  that  are  material  to  the  financial  statements  and  (2)  involved  our  especially  challenging, 
subjective or complex judgments. The communication of the critical audit matter does not alter in any way our opinion 
on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit matter 
below, providing a separate opinion on the critical audit matter or on the account or disclosures to which it relates.

Allowance for Loan Losses

Description of the Matter

The Company’s loan portfolio totaled $14.8 billion as of December 31, 2019 and the associated allowance for loan 
losses (ALL) was $132.2 million. As discussed in Notes 1 and 3 to the consolidated financial statements, the ALL is 
established to absorb inherent losses that have been incurred within the existing portfolio of loans. Management’s 
estimate  of  inherent  losses  within  the  loan  portfolio  is  established  using  quantitative,  as  well  as  qualitative, 
considerations.  The  Company’s  methodology 
the  ALL  considers  quantitative  calculations 
to  determine 
including: specific valuation allowances determined in accordance with ASC Topic 310 based on probable losses on 

69

specific loans, historical valuation allowances determined in accordance with ASC topic 450 based on historical loan 
loss experience for similar loans with similar characteristics and trends, adjusted, as necessary, to reflect the impact of 
current conditions, and general valuation allowances determined in accordance with ASC Topic 450 based on various 
risk factors that are internal to the Company. The Company’s ALL methodology also includes qualitative amounts that 
include  macroeconomic  valuation  allowances  based  on  general  economic  conditions  and  other  risk  factors  to  the 
Company. The Company’s methodology for determining the appropriate ALL considers the imprecision inherent in 
the application of quantitative portions of the ALL. The components of the macroeconomic valuation allowances include 
an environmental risk adjustment factor, consideration for distressed industries, and current economic trends and other 
factors.

Auditing  management’s  estimate  of  the ALL  involved  a  high  degree  of  subjectivity  due  to  the  nature  of  the 
macroeconomic  valuation  allowances  included  in  the ALL.  Management’s  identification  and  measurement  of  the 
macroeconomic valuation allowances is highly judgmental and could have a significant effect on the ALL.

How We Addressed the Matter in Our Audit

We obtained an understanding of the Company’s process for establishing the ALL, including the macroeconomic 
valuation allowances of the ALL. We evaluated the design and tested the operating effectiveness of related controls 
over the reliability and accuracy of data used to calculate and estimate the various components of the ALL, the accuracy 
of the calculation of the ALL, management’s review and approval of methodologies used to establish the ALL, analysis 
of changes in various components of the ALL relative to changes in the Company’s loan portfolio and economy and 
evaluation  of  the  overall  reasonableness  and  appropriateness  of  the ALL.  In  doing  so,  we  tested  the  operating 
effectiveness of review and approval controls in the Company’s governance process designed to identify and assess 
the macroeconomic valuation allowances which is meant to measure inherent loan losses associated with factors not 
captured fully in the other components of the ALL.

To test the reasonableness of the macroeconomic valuation allowances, we performed audit procedures that included, 
among others testing the appropriateness of the methodologies used by the Company to estimate the ALL, testing the 
completeness and accuracy of data and information used by the Company in estimating the components of the ALL, 
evaluating the appropriateness of assumptions used in estimating the macroeconomic valuation allowances, analyzing 
the changes in assumptions and various components of the ALL relative to changes in the Company’s loan portfolio 
and the economy and evaluating the appropriateness and level of the macroeconomic valuation allowances. For example, 
specific  to  the  macroeconomic  valuation  allowances,  we  1) evaluated  the  inherent  limitations  of  the  Company’s 
quantitative components of the ALL and hence the need for and levels of the macroeconomic valuation allowances; 
2) analyzed  the  changes,  assumptions  and  adjustments  made  to  the  macroeconomic  valuation  allowances;  and 
3) evaluated the appropriateness and completeness of risk factors used in determining the amount of the macroeconomic 
valuation  allowances.  We  also  evaluated  the  data  and  information  utilized  by  management  to  estimate  the 
macroeconomic valuation allowances by independently obtaining internal and external data and information to assess 
the appropriateness of the data and information used by management and to consider the existence of new and potentially 
contradictory information used. In addition, we evaluated the overall ALL amount, inclusive of the adjustments for the 
macroeconomic valuation allowances, and whether the amount appropriately reflects losses incurred in the loan portfolio 
as  of  the  consolidated  balance  sheet  date  by  comparing  the  overall ALL  to  those  established  by  similar  banking 
institutions with similar loan portfolios. We also reviewed subsequent events and transactions and considered whether 
they corroborate or contradict the Company’s conclusion.

We have served as the Company’s auditor since 1969.
San Antonio, Texas
February 4, 2020 

70

Cullen/Frost Bankers, Inc.
Consolidated Balance Sheets
(Dollars in thousands, except per share amounts) 

Assets:
Cash and due from banks
Interest-bearing deposits
Federal funds sold and resell agreements

Total cash and cash equivalents

Securities held to maturity, at amortized cost
Securities available for sale, at estimated fair value
Trading account securities
Loans, net of unearned discounts
Less: Allowance for loan losses

Net loans

Premises and equipment, net
Goodwill
Other intangible assets, net
Cash surrender value of life insurance policies
Accrued interest receivable and other assets

Total assets

Liabilities:
Deposits:

Non-interest-bearing demand deposits
Interest-bearing deposits

Total deposits

Federal funds purchased and repurchase agreements
Junior subordinated deferrable interest debentures, net of unamortized issuance

costs

Subordinated notes, net of unamortized issuance costs
Accrued interest payable and other liabilities

Total liabilities

December 31,

2019

2018

$

581,857
2,849,950
356,374
3,788,181
2,030,005
11,269,591
24,298
14,750,332
(132,167)
14,618,165
1,011,947
654,952
2,481
187,156
440,652
$ 34,027,428

$

678,791
2,641,971
635,017
3,955,779
1,106,057
11,387,321
24,086
14,099,733
(132,132)
13,967,601
552,330
654,952
3,649
183,473
457,718
$ 32,292,966

$ 10,873,629
16,765,935
27,639,564
1,695,342

$ 10,997,494
16,151,710
27,149,204
1,367,548

136,299
98,865
545,690
30,115,760

136,242
98,708
172,347
28,924,049

Shareholders’ Equity:
Preferred stock, par value $0.01 per share; 10,000,000 shares authorized;

6,000,000 Series A shares ($25 liquidation preference) issued in both 2019 and
2018

Common stock, par value $0.01 per share; 210,000,000 shares authorized;

64,236,306 shares issued in both 2019 and 2018

Additional paid-in capital
Retained earnings
Accumulated other comprehensive income, net of tax
Treasury stock, at cost; 1,567,302 shares in 2019 and 1,250,464 in 2018.

Total shareholders’ equity

Total liabilities and shareholders’ equity

144,486

144,486

642
983,250
2,667,534
267,370
(151,614)
3,911,668
$ 34,027,428

642
967,304
2,440,002
(63,600)
(119,917)
3,368,917
$ 32,292,966

See accompanying Notes to Consolidated Financial Statements. 

71

 
 
Cullen/Frost Bankers, Inc.
Consolidated Statements of Income
(Dollars in thousands, except per share amounts)

Interest income:

Loans, including fees
Securities:
Taxable
Tax-exempt

Interest-bearing deposits
Federal funds sold and resell agreements

Total interest income

Interest expense:

Deposits
Federal funds purchased and repurchase agreements
Junior subordinated deferrable interest debentures
Other long-term borrowings
Total interest expense

Net interest income
Provision for loan losses

Net interest income after provision for loan losses

Non-interest income:

Trust and investment management fees
Service charges on deposit accounts
Insurance commissions and fees
Interchange and debit card transaction fees
Other charges, commissions and fees
Net gain (loss) on securities transactions
Other

Total non-interest income

Non-interest expense:
Salaries and wages
Employee benefits
Net occupancy
Technology, furniture and equipment
Deposit insurance
Intangible amortization
Other

Total non-interest expense
Income before income taxes
Income taxes
Net income

Preferred stock dividends

Net income available to common shareholders

Earnings per common share:

Basic
Diluted

$

$

See accompanying Notes to Consolidated Financial Statements. 

72

Year Ended December 31,

2019

2018

2017

$

741,747

$

669,002

$

534,804

117,082
233,842
35,590
5,524
1,133,785

99,742
19,675
5,706
4,657
129,780
1,004,005
33,759
970,246

126,722
88,983
52,345
14,873
37,123
293
43,563
363,902

375,029
86,230
89,466
91,995
10,126
1,168
180,665
834,679
499,469
55,870
443,599
8,063
435,536

6.89
6.84

$

$

86,370
233,358
56,968
5,500
1,051,198

75,337
8,021
5,291
4,657
93,306
957,892
21,613
936,279

119,391
85,186
48,967
13,877
37,231
(156)
46,790
351,286

350,312
77,323
76,788
83,102
16,397
1,424
173,538
778,884
508,681
53,763
454,918
8,063
446,855

6.97
6.90

$

$

92,979
222,620
41,608
936
892,947

17,188
1,522
3,955
3,860
26,525
866,422
35,460
830,962

110,675
84,182
46,169
23,232
39,931
(4,941)
37,222
336,470

337,068
74,575
75,971
74,335
20,128
1,703
175,289
759,069
408,363
44,214
364,149
8,063
356,086

5.56
5.51

 
 
 
 
 
 
 
 
 
 
 
Cullen/Frost Bankers, Inc.
Consolidated Statements of Comprehensive Income
(Dollars in thousands)

Net income
Other comprehensive income (loss), before tax:

Securities available for sale and transferred securities:

Year Ended December 31,

2019
443,599

$

2018
454,918

$

2017
364,149

$

Change in net unrealized gain/loss during the period
Change in net unrealized gain on securities transferred to

held to maturity

418,556

(182,340)

157,016

(1,292)

(8,818)

(16,193)

(293)

156

4,941

416,971

(191,002)

145,764

(3,644)

(7,225)

(597)

5,623
1,979
418,950
87,980
330,970
774,569

$

5,002
(2,223)
(193,225)
(40,578)
(152,647)
302,271

$

5,429
4,832
150,596
46,461
104,135
468,284

$

Reclassification adjustment for net (gains) losses included

in net income
Total securities available for sale and transferred

securities

Defined-benefit post-retirement benefit plans:

Change in the net actuarial gain/loss
Reclassification adjustment for net amortization of actuarial
gain/loss included in net income as a component of net
periodic cost (benefit)

Total defined-benefit post-retirement benefit plans

Other comprehensive income (loss), before tax

Deferred tax expense (benefit)

Other comprehensive income (loss), net of tax
Comprehensive income

See accompanying Notes to Consolidated Financial Statements. 

73

 
 
 
 
 
 
 
 
 
 
 
Cullen/Frost Bankers, Inc.
Consolidated Statement of Changes in Shareholders’ Equity
(Dollars in thousands, except per share amounts) 

Balance at January 1, 2017

$ 144,486

$

637

$ 906,732

$1,985,569

$

(24,623) $ (10,273) $ 3,002,528

Preferred
Stock

Common
Stock

Additional
Paid-In
Capital

Retained
Earnings

Accumulated
Other
Comprehensive
Income (Loss),
Net of Tax

Treasury
Stock

Total

Net income

Other comprehensive income, net of tax

Stock option exercises/stock unit conversions

(1,150,920 shares)

Stock-based compensation expense

recognized in earnings

Purchase of treasury stock (1,149,555 shares)

Cash dividends - preferred stock
(approximately $1.34 per share)

Cash dividends - common stock ($2.25 per

share)

Balance at December 31, 2017

Cumulative effect of accounting change

Adjusted beginning balance

Net income

Other comprehensive income, net of tax

Reclassification of certain income tax effects
related to the change in the U.S. statutory
federal income tax rate under the Tax Cuts
and Jobs Act

Stock option exercises/stock unit conversions

(548,238 shares)

Stock-based compensation expense

recognized in earnings

Purchase of treasury stock (1,037,982 shares)

Cash dividends – preferred stock
(approximately $1.34 per share)

Cash dividends – common stock ($2.58 per

share)

Balance at December 31, 2018

Cumulative effect of accounting change

Adjusted beginning balance

Net income

Other comprehensive income, net of tax

Stock option exercises/stock unit conversions

(399,244 shares)

Stock-based compensation expense

recognized in earnings

Purchase of treasury stock (716,062 shares)

Cash dividends – preferred stock
(approximately $1.34 per share)

Cash dividends – common stock ($2.80 per

share)

—

—

—

—

—

—

—

144,486

—

144,486

—

—

—

—

—

—

—

—

144,486

—

144,486

—

—

—

—

—

—

—

—

—

5

—

—

—

—

642

—

642

—

—

—

—

—

—

—

—

642

—

642

—

—

—

—

—

—

—

—

—

364,149

—

—

104,135

—

—

364,149

104,135

33,616

(10,414)

13,013

—

—

—

—

—

(8,063)

(144,172)

—

—

44,539

67,746

—

13,013

— (101,473)

(101,473)

—

—

—

—

(8,063)

(144,172)

953,361

2,187,069

79,512

(67,207)

3,297,863

—

(2,285)

—

—

(2,285)

953,361

2,184,784

79,512

(67,207)

3,295,578

—

—

—

—

13,943

—

—

—

454,918

—

—

(152,647)

(9,535)

9,535

—

—

—

454,918

(152,647)

—

(16,653)

—

—

(8,063)

(165,449)

—

—

48,300

31,647

—

13,943

— (101,010)

(101,010)

—

—

—

—

(8,063)

(165,449)

967,304

2,440,002

(63,600)

(119,917)

3,368,917

—

(14,672)

—

—

(14,672)

967,304

2,425,330

(63,600)

(119,917)

3,354,245

—

—

—

15,946

—

—

—

443,599

—

—

330,970

—

—

443,599

330,970

(16,326)

—

—

(8,063)

(177,006)

—

—

—

—

—

37,096

20,770

—

15,946

(68,793)

(68,793)

—

—

(8,063)

(177,006)

Balance at December 31, 2019

$ 144,486

$

642

$ 983,250

$2,667,534

$

267,370

$ (151,614) $ 3,911,668

See accompanying Notes to Consolidated Financial Statements

74

 
Cullen/Frost Bankers, Inc.
Consolidated Statements of Cash Flows
(Dollars in thousands)

Operating Activities:
Net income
Adjustments to reconcile net income to net cash from operating

activities:
Provision for loan losses
Deferred tax expense (benefit)
Accretion of loan discounts
Securities premium amortization (discount accretion), net
Net (gain) loss on securities transactions
Depreciation and amortization
Net (gain) loss on sale/write-down of assets/foreclosed assets
Stock-based compensation
Net tax benefit from stock-based compensation
Earnings on life insurance policies
Net change in:

Trading account securities
Lease right-of-use assets
Accrued interest receivable and other assets
Accrued interest payable and other liabilities

Net cash from operating activities

Investing Activities:

Securities held to maturity:

Purchases
Maturities, calls and principal repayments

Securities available for sale:

Purchases
Sales
Maturities, calls and principal repayments

Proceeds from sale of loans
Net change in loans
Benefits received on life insurance policies
Proceeds from sales of premises and equipment
Purchases of premises and equipment
Proceeds from sales of repossessed properties
Net cash from investing activities

Financing Activities:

Net change in deposits
Net change in short-term borrowings
Proceeds from issuance of subordinated notes
Principal payments on subordinated notes
Proceeds from stock option exercises
Purchase of treasury stock
Cash dividends paid on preferred stock
Cash dividends paid on common stock
Net cash from financing activities
Net change in cash and cash equivalents
Cash and cash equivalents at beginning of year
Cash and cash equivalents at end of year

See accompanying Notes to Consolidated Financial Statements.

75

Year Ended December 31,

2019

2018

2017

$

443,599

$

454,918

$

364,149

33,759
7,614
(15,197)
115,558
(293)
54,091
(5,712)
15,946
2,447
(3,683)

(212)
20,124
(15,570)
(18,381)
634,090

21,613
52,923
(14,341)
100,528
156
50,172
(5,272)
13,943
3,865
(3,380)

(2,658)
—
(85,898)
(24,181)
562,388

35,460
(14,493)
(16,062)
89,933
4,941
47,812
(4,697)
13,013
9,062
(3,190)

(3,842)
—
(55,179)
71,172
538,079

(649,326)
81,762

(1,500)
300,632

—
783,176

(23,306,694)
18,660,147
4,694,927
24,036
(693,587)
—
8,038
(206,716)
663
(1,386,750)

(18,191,057)
16,806,062
221,906
21,318
(1,008,789)
384
13,628
(79,270)
3,366
(1,913,320)

(13,529,192)
11,963,359
1,328,143
—
(1,187,631)
597
4,525
(34,089)
517
(670,595)

490,360
327,794
—
—
20,770
(68,793)
(8,063)
(177,006)
585,062
(167,598)
3,955,779
$ 3,788,181

276,815
219,724
—
—
31,647
(101,010)
(8,063)
(165,449)
253,664
(1,097,268)
5,053,047
$ 3,955,779

1,060,814
170,832
98,434
(100,000)
67,746
(101,473)
(8,063)
(144,172)
1,044,118
911,602
4,141,445
$ 5,053,047

Cullen/Frost Bankers, Inc.
Notes To Consolidated Financial Statements
(Table amounts in thousands, except share and per share amounts)

Note 1 - Summary of Significant Accounting Policies

Nature of Operations. Cullen/Frost Bankers, Inc. (“Cullen/Frost”) is a financial holding company and a bank holding 
company headquartered in San Antonio, Texas that provides, through its subsidiaries, a broad array of products and 
services throughout numerous Texas markets. The terms “Cullen/Frost,” “the Corporation,” “we,” “us” and “our” mean 
Cullen/Frost Bankers, Inc. and its subsidiaries, when appropriate. In addition to general commercial and consumer 
banking, other products and services offered include trust and investment management, insurance, brokerage, mutual 
funds, leasing, treasury management, capital markets advisory and item processing.

Basis of Presentation. The consolidated financial statements include the accounts of Cullen/Frost and all other entities 
in which Cullen/Frost has a controlling financial interest. All significant intercompany balances and transactions have 
been eliminated in consolidation. The accounting and financial reporting policies we follow conform, in all material 
respects, to accounting principles generally accepted in the United States and to general practices within the financial 
services industry.

We determine whether we have a controlling financial interest in an entity by first evaluating whether the entity is 
a voting interest entity or a variable interest entity (“VIE”) under accounting principles generally accepted in the United 
States. Voting interest entities are entities in which the total equity investment at risk is sufficient to enable the entity 
to finance itself independently and provides the equity holders with the obligation to absorb losses, the right to receive 
residual returns and the right to make decisions about the entity’s activities. We consolidate voting interest entities in 
which we have all, or at least a majority of, the voting interest. As defined in applicable accounting standards, VIEs 
are entities that lack one or more of the characteristics of a voting interest entity. A controlling financial interest in a 
VIE is present when an enterprise has both the power to direct the activities of the VIE that most significantly impact 
the VIE’s economic performance and an obligation to absorb losses or the right to receive benefits that could potentially 
be  significant  to  the  VIE.  The  enterprise  with  a  controlling  financial  interest,  known  as  the  primary  beneficiary, 
consolidates the VIE. Our wholly owned subsidiaries Cullen/Frost Capital Trust II and WNB Capital Trust I are VIEs 
for which we are not the primary beneficiary. Accordingly, the accounts of these trusts are not included in our consolidated 
financial statements.

Acquisitions are accounted for using the purchase method with the operating results of the acquired companies 

included with our results of operations since their respective dates of acquisition.

We have evaluated subsequent events for potential recognition and/or disclosure through the date these consolidated 

financial statements were issued. 

Use of Estimates. The preparation of financial statements in conformity with accounting principles generally accepted 
in the United States requires management to make estimates and assumptions that affect the reported amounts of assets 
and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements. Actual results 
could differ from those estimates. The allowance for loan losses and the fair values of financial instruments and the 
status of contingencies are particularly subject to change.

Concentrations  and  Restrictions  on  Cash  and  Cash  Equivalents.  We  maintain  deposits  with  other  financial 
institutions in amounts that exceed federal deposit insurance coverage. Furthermore, federal funds sold are essentially 
uncollateralized loans to other financial institutions. Management regularly evaluates the credit risk associated with 
the counterparties to these transactions and believes that we are not exposed to any significant credit risks on cash and 
cash equivalents.

We were required to have $918.0 million and $447.9 million of cash on hand or on deposit with the Federal Reserve 
Bank  to  meet  regulatory  reserve  and  clearing  requirements  at  December 31,  2019  and  2018. Additionally,  as  of 
December 31, 2019 and 2018, we had $37.5 million and $10.0 million in cash collateral on deposit with other financial 
institution counterparties to interest rate swap transactions.

76

Cash Flow Reporting. Cash and cash equivalents include cash, deposits with other financial institutions that have 
an initial maturity of less than 90 days when acquired by us, federal funds sold and resell agreements. Net cash flows 
are reported for loans, deposit transactions and short-term borrowings. Additional cash flow information was as follows:

Cash paid for interest
Cash paid for income tax
Significant non-cash transactions:

Year Ended December 31,

$

2019
124,781
45,352

$

2018
89,270
5,112

$

2017
24,371
56,359

Transfer of securities from available for sale to held to maturity
Unsettled purchases/sales of securities
Loans foreclosed and transferred to other real estate owned and

foreclosed assets

Loans to facilitate the sale of other real estate owned
Lease right-of-use assets obtained in exchange for lessee operating

lease liabilities

377,812
—

1,348
847

319,286

—
330

2,899
—

—

—
37,481

279
—

—

Repurchase/Resell Agreements. We purchase certain securities under agreements to resell. The amounts advanced 
under these agreements represent short-term loans and are reflected as assets in the accompanying consolidated balance 
sheets. The  securities  underlying  these  agreements  are  book-entry  securities. We  also  sell  certain  securities  under 
agreements to repurchase. The agreements are treated as collateralized financing transactions and the obligations to 
repurchase securities sold are reflected as a liability in the accompanying consolidated balance sheets. The dollar amount 
of the securities underlying the agreements remains in the asset accounts.

Securities. Securities are classified as held to maturity and carried at amortized cost when management has the 
positive intent and ability to hold them until maturity. Securities to be held for indefinite periods of time are classified 
as available for sale and carried at fair value, with the unrealized holding gains and losses reported as a component of 
other comprehensive income, net of tax. Securities held for resale in anticipation of short-term market movements are 
classified as trading and are carried at fair value, with changes in unrealized holding gains and losses included in income. 
Management determines the appropriate classification of securities at the time of purchase. Securities with limited 
marketability, such as stock in the Federal Reserve Bank and the Federal Home Loan Bank, are carried at cost.

Interest income on securities includes amortization of purchase premiums and discounts. Premiums and discounts 
on securities are generally amortized using the interest method with a constant effective yield without anticipating 
prepayments, except for mortgage-backed securities where prepayments are anticipated. Premiums on callable securities 
are amortized to their earliest call date. Prior to the adoption of a new accounting standard in 2019, as further discussed 
below, premiums on callable securities were amortized to their respective maturity dates unless such securities were 
included in pools for the purposes of assessing prepayment expectations.

Realized gains and losses are derived from the amortized cost of the security sold. Declines in the fair value of held-
to-maturity and available-for-sale securities below their cost that are deemed to be other than temporary are reflected 
in earnings as realized losses. In estimating other-than-temporary impairment losses, management considers, among 
other things, (i) the length of time and the extent to which the fair value has been less than cost, (ii) the financial 
condition and near-term prospects of the issuer and (iii) the intent and our ability to retain our investment in the issuer 
for a period of time sufficient to allow for any anticipated recovery in fair value.

Loans. Loans are reported at the principal balance outstanding net of unearned discounts. Interest income on loans 
is reported on the level-yield method and includes amortization of deferred loan fees and costs over the loan term. Net 
loan commitment fees or costs for commitment periods greater than one year are deferred and amortized into fee income 
or other expense on a straight-line basis over the commitment period. Income on direct financing leases is recognized 
on a basis that achieves a constant periodic rate of return on the outstanding investment. Further information regarding 
our accounting policies related to past due loans, non-accrual loans, impaired loans and troubled-debt restructurings is 
presented in Note 3 - Loans.

Allowance for Loan Losses. The allowance for loan losses is a reserve established through a provision for loan losses 
charged to expense, which represents management’s best estimate of inherent losses that have been incurred within the 
existing portfolio of loans. The allowance, in the judgment of management, is necessary to reserve for estimated loan 
losses  inherent  in  the  loan  portfolio.  The  allowance  for  loan  losses  includes  allowance  allocations  calculated  in 

77

accordance  with  Financial  Accounting  Standards  Board  (“FASB”)  Accounting  Standards  Codification  (“ASC”) 
Topic 310, “Receivables” and allowance allocations calculated in accordance with ASC Topic 450, “Contingencies.” 
Further information regarding our policies and methodology used to estimate the allowance for loan losses is presented 
in Note 3 - Loans.

Premises and Equipment. Land is carried at cost. Building and improvements, and furniture and equipment are 
carried at cost, less accumulated depreciation, computed principally by the straight-line method based on the estimated 
useful lives of the related property. Leasehold improvements are generally depreciated over the lesser of the term of 
the respective leases or the estimated useful lives of the improvements.

We lease certain office facilities and office equipment under operating leases. We also own certain office facilities 
which we lease to outside parties under operating lessor leases; however, such leases are not significant. In 2019, we 
adopted certain accounting standard updates related to accounting for leases as further discussed below. Under the new 
standards, for operating leases other than those considered to be short-term, we recognize lease right-of-use assets and 
related lease liabilities. Such amounts are reported as components of premises and equipment and accrued interest 
payable and other liabilities, respectively, on our accompanying consolidated balance sheet. We do not recognize short-
term operating leases on our balance sheet. A short-term operating lease has an original term of 12 months or less and 
does not have a purchase option that is likely to be exercised. 

In recognizing lease right-of-use assets and related lease liabilities, we account for lease and non-lease components 
(such  as  taxes,  insurance,  and  common  area  maintenance  costs)  separately  as  such  amounts  are  generally  readily 
determinable under our lease contracts. Lease payments over the expected term are discounted using our incremental 
borrowing rate referenced to the Federal Home Loan Bank Secure Connect advance rates for borrowings of similar 
term. We also consider renewal and termination options in the determination of the term of the lease. If it is reasonably 
certain that a renewal or termination option will be exercised, the effects of such options are included in the determination 
of the expected lease term. Generally, we cannot be reasonably certain about whether or not we will renew a lease until 
such time the lease is within the last two years of the existing lease term. However, renewal options related to our 
regional headquarters facilities or operations centers are evaluated on a case-by-case basis, typically in advance of such 
time frame. When we are reasonably certain that a renewal option will be exercised, we measure/remeasure the right-
of-use asset and related lease liability using the lease payments specified for the renewal period or, if such amounts are 
unspecified, we generally assume an increase (evaluated on a case-by-case basis in light of prevailing market conditions) 
in the lease payment over the final period of the existing lease term.

Foreclosed Assets. Assets acquired through or instead of loan foreclosure are held for sale and are initially recorded 
at fair value less estimated selling costs when acquired, establishing a new cost basis. Costs after acquisition are generally 
expensed. If the fair value of the asset declines, a write-down is recorded through expense. The valuation of foreclosed 
assets is subjective in nature and may be adjusted in the future because of changes in economic conditions. Foreclosed 
assets are included in other assets in the accompanying consolidated balance sheets and totaled $1.1 million and $1.2 
million at December 31, 2019 and 2018.

Goodwill. Goodwill represents the excess of the cost of businesses acquired over the fair value of the net assets 
acquired. Goodwill is assigned to reporting units and tested for impairment at least annually on October 1st, or on an 
interim basis if an event occurs or circumstances change that would more likely than not reduce the fair value of the 
reporting unit below its carrying value. See Note 5 - Goodwill and Other Intangible Assets.

Intangibles and Other Long-Lived Assets. Intangible assets are acquired assets that lack physical substance but can 
be distinguished from goodwill because of contractual or other legal rights or because the asset is capable of being sold 
or exchanged either on its own or in combination with a related contract, asset, or liability. Our intangible assets relate 
to core deposits, non-compete agreements and customer relationships. Intangible assets with definite useful lives are 
amortized on an accelerated basis over their estimated life. Intangible assets with indefinite useful lives are not amortized 
until their lives are determined to be definite. Intangible assets, premises and equipment and other long-lived assets 
are tested for impairment whenever events or changes in circumstances indicate the carrying amount of the assets may 
not be recoverable from future undiscounted cash flows. If impaired, the assets are recorded at fair value. See Note 5 - 
Goodwill and Other Intangible Assets.

Revenue  Recognition.  In  general,  for  revenue  not  associated  with  financial  instruments,  guarantees  and  lease 
contracts,  we  apply  the  following  steps  when  recognizing  revenue  from  contracts  with  customers:  (i) identify  the 
contract, (ii) identify the performance obligations, (iii) determine the transaction price, (iv) allocate the transaction 
price to the performance obligations and (v) recognize revenue when a performance obligation is satisfied. Our contracts 
78

with customers are generally short term in nature, typically due within one year or less or cancellable by us or our 
customer upon a short notice period. Performance obligations for our customer contracts are generally satisfied at a 
single point in time, typically when the transaction is complete, or over time. For performance obligations satisfied 
over time, we primarily use the output method, directly measuring the value of the products/services transferred to the 
customer, to determine when performance obligations have been satisfied. We typically receive payment from customers 
and recognize revenue concurrent with the satisfaction of our performance obligations. In most cases, this occurs within 
a single financial reporting period. For payments received in advance of the satisfaction of performance obligations, 
revenue recognition is deferred until such time as the performance obligations have been satisfied. In cases where we 
have not received payment despite satisfaction of our performance obligations, we accrue an estimate of the amount 
due in the period our performance obligations have been satisfied. For contracts with variable components, only amounts 
for which collection is probable are accrued. We generally act in a principal capacity, on our own behalf, in most of 
our contracts with customers. In such transactions, we recognize revenue and the related costs to provide our services 
on a gross basis in our financial statements. In some cases, we act in an agent capacity, deriving revenue through 
assisting other entities in transactions with our customers. In such transactions, we recognize revenue and the related 
costs to provide our services on a net basis in our financial statements. These transactions recognized on a net basis 
primarily relate to insurance and brokerage commissions and fees derived from our customers' use of various interchange 
and ATM/debit card networks.

Share-Based Payments. Compensation expense for stock options, non-vested stock awards/stock units and deferred 
stock units is based on the fair value of the award on the measurement date, which, for us, is the date of the grant and 
is recognized ratably over the service period of the award. Compensation expense for performance stock units is based 
on the fair value of the award on the measurement date, which, for us, is the date of the grant and is recognized over 
the service period of the award based upon the probable number of units expected to vest. The fair value of stock options 
is estimated using a binomial lattice-based valuation model. The fair value of non-vested stock awards/stock units and 
deferred stock units is generally the market price of our stock on the date of grant. The fair value of performance stock 
units is generally the market price of our stock on the date of grant discounted by the present value of the dividends 
expected to be paid on our common stock during the service period of the award because dividend equivalent payments 
on performance stock units are deferred until such time that the units vest and shares are issued. The impact of forfeitures 
of share-based payment awards on compensation expense is recognized as forfeitures occur.

Advertising Costs. Advertising costs are expensed as incurred.

Income Taxes. Income tax expense is the total of the current year income tax due or refundable and the change in 
deferred  tax  assets  and  liabilities  (excluding  deferred  tax  assets  and  liabilities  related  to  business  combinations  or 
components of other comprehensive income). Deferred tax assets and liabilities are the expected future tax amounts 
for the temporary differences between carrying amounts and tax bases of assets and liabilities, computed using enacted 
tax rates. A valuation allowance, if needed, reduces deferred tax assets to the expected amount most likely to be realized. 
Realization  of  deferred  tax  assets  is  dependent  upon  the  generation  of  a  sufficient  level  of  future  taxable  income. 
Although realization is not assured, management believes it is more likely than not that all of the deferred tax assets 
will be realized. Interest and/or penalties related to income taxes are reported as a component of income tax expense. 
The income tax effects related to settlements of share-based payment awards are reported in earnings as an increase 
(or decrease) to income tax expense (see Note 13 - Income Taxes).

We file a consolidated income tax return with our subsidiaries. Federal income tax expense or benefit has been 

allocated to subsidiaries on a separate return basis.

Basic and Diluted Earnings Per Common Share. Earnings per common share is computed using the two-class method 
prescribed under ASC Topic 260, “Earnings Per Share.” ASC Topic 260 provides that unvested share-based payment 
awards that contain nonforfeitable rights to dividends or dividend equivalents (whether paid or unpaid) are participating 
securities and shall be included in the computation of earnings per share pursuant to the two-class method. We have 
determined that our outstanding non-vested stock awards/stock units and deferred stock units are participating securities.

Under the two-class method, basic earnings per common share is computed by dividing net earnings allocated to 
common stock by the weighted-average number of common shares outstanding during the applicable period, excluding 
outstanding  participating  securities.  Diluted  earnings  per  common  share  is  computed  using  the  weighted-average 
number of shares determined for the basic earnings per common share computation plus the dilutive effect of stock 
compensation using the treasury stock method. A reconciliation of the weighted-average shares used in calculating 

79

basic earnings per common share and the weighted average common shares used in calculating diluted earnings per 
common share for the reported periods is provided in Note 10 - Earnings Per Common Share.

Comprehensive Income. Comprehensive income includes all changes in shareholders’ equity during a period, except 
those  resulting  from  transactions  with  shareholders.  Besides  net  income,  other  components  of  our  comprehensive 
income include the after tax effect of changes in the net unrealized gain/loss on securities available for sale, changes 
in the net unrealized gain on securities transferred to held to maturity and changes in the net actuarial gain/loss on 
defined benefit post-retirement benefit plans. See Note 14 - Other Comprehensive Income (Loss).

Derivative Financial Instruments. Our hedging policies permit the use of various derivative financial instruments 
to manage interest rate risk or to hedge specified assets and liabilities. All derivatives are recorded at fair value on our 
balance sheet. Derivatives executed with the same counterparty are generally subject to master netting arrangements, 
however, fair value amounts recognized for derivatives and fair value amounts recognized for the right/obligation to 
reclaim/return cash collateral are not offset for financial reporting purposes. We may be required to recognize certain 
contracts  and  commitments  as  derivatives  when  the  characteristics  of  those  contracts  and  commitments  meet  the 
definition of a derivative.

To qualify for hedge accounting, derivatives must be highly effective at reducing the risk associated with the exposure 
being hedged and must be designated as a hedge at the inception of the derivative contract. We consider a hedge to be 
highly effective if the change in fair value of the derivative hedging instrument is within 80% to 125% of the opposite 
change in the fair value of the hedged item attributable to the hedged risk. If derivative instruments are designated as 
hedges of fair values, and such hedges are highly effective, both the change in the fair value of the hedge and the hedged 
item  are  included  in  current  earnings.  Fair  value  adjustments  related  to  cash  flow  hedges  are  recorded  in  other 
comprehensive income and are reclassified to earnings when the hedged transaction is reflected in earnings. Ineffective 
portions of hedges are reflected in earnings as they occur. Actual cash receipts and/or payments and related accruals 
on derivatives related to hedges are recorded as adjustments to the interest income or interest expense associated with 
the hedged item. During the life of the hedge, we formally assess whether derivatives designated as hedging instruments 
continue to be highly effective in offsetting changes in the fair value or cash flows of hedged items. If it is determined 
that  a  hedge  has  ceased  to  be  highly  effective,  we  will  discontinue  hedge  accounting  prospectively. At  such  time, 
previous adjustments to the carrying value of the hedged item are reversed into current earnings and the derivative 
instrument is reclassified to a trading position recorded at fair value.

Fair Value Measurements. In general, fair values of financial instruments are based upon quoted market prices, 
where available. If such quoted market prices are not available, fair value is based upon internally developed models 
that primarily use, as inputs, observable market-based parameters. Valuation adjustments may be made to ensure that 
financial instruments are recorded at fair value. These adjustments may include amounts to reflect counterparty credit 
quality  and  our  creditworthiness,  among  other  things,  as  well  as  unobservable  parameters.  Any  such  valuation 
adjustments are applied consistently over time. See Note 17 - Fair Value Measurements.

Transfers of Financial Assets. Transfers of financial assets are accounted for as sales when control over the assets 
has been surrendered. Control over transferred assets is deemed to be surrendered when (i) the assets have been isolated 
from us, (ii) the transferee obtains the right (free of conditions that constrain it from taking advantage of that right) to 
pledge or exchange the transferred assets, and (iii) we do not maintain effective control over the transferred assets 
through an agreement to repurchase them before their maturity.

Loss Contingencies. Loss contingencies, including claims and legal actions arising in the ordinary course of business 
are recorded as liabilities when the likelihood of loss is probable and an amount or range of loss can be reasonably 
estimated.

Trust Assets. Assets  of  our  trust  department,  other  than  cash  on  deposit  at  Frost  Bank,  are  not  included  in  the 

accompanying financial statements because they are not our assets.

Accounting Changes, Reclassifications and Restatements. Certain items in prior financial statements have been 

reclassified to conform to the current presentation. 

On January 1, 2019, we adopted certain accounting standard updates related to accounting for leases, primarily 
Accounting Standards Update (“ASU”) 2016-02 “Leases (Topic 842)” and subsequent updates. Among other things, 
these  updates  require  lessees  to  recognize  a  lease  liability,  measured  on  a  discounted  basis,  related  to  the  lessee's 
obligation to make lease payments arising under a lease contract; and a right-of-use asset related to the lessee’s right 

80

to use, or control the use of, a specified asset for the lease term. The updates did not significantly change lease accounting 
requirements applicable to lessors and did not significantly impact our financial statements in relation to contracts 
whereby we act as a lessor. We adopted the updates using a modified-retrospective transition approach and recognized 
right-of-use lease assets and related lease liabilities totaling $170.5 million and $174.4 million, respectively, as of 
January 1, 2019. We elected to apply certain practical adoption expedients provided under the updates whereby we did 
not reassess (i) whether any expired or existing contracts are or contain leases, (ii) the lease classification for any expired 
or existing leases and (iii) initial direct costs for any existing leases. We did not elect to apply the recognition requirements 
of the updates to any short-term leases. See Note 4 - Premises and Equipment and Lease Commitments.

On January 1, 2019, we also adopted ASU 2017-08 “Receivables - Nonrefundable Fees and Other Costs (Subtopic 
310-20) - Premium Amortization on Purchased Callable Debt Securities.” ASU 2017-08 shortens the amortization 
period for certain callable debt securities held at a premium to require such premiums to be amortized to the earliest 
call date unless applicable guidance related to certain pools of securities is applied to consider estimated prepayments. 
Under prior guidance, entities were generally required to amortize premiums on individual, non-pooled callable debt 
securities as a yield adjustment over the contractual life of the security. ASU 2017-08 does not change the accounting 
for  callable  debt  securities  held  at  a  discount.  Upon  adoption,  using  a  modified  retrospective  transition  adoption 
approach, we recognized a cumulative effect reduction to retained earnings totaling $14.7 million. Premium amortization 
expense for 2019 was approximately $5.2 million higher than what would have been the case had we continued to 
amortize the affected securities to their respective maturity dates.

On January 1, 2018, we adopted ASU 2018-02, “Income Statement - Reporting Comprehensive Income (Topic 220) 
- Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income.” In accordance with ASU 
2018-02, we elected to reclassify certain income tax effects related to the change in the U.S. statutory federal income 
tax rate under the Tax Cuts and Jobs Act, which was enacted on December 22, 2017 (see Note 13 - Income Taxes), 
from accumulated other comprehensive income to retained earnings. Such amounts, which totaled $9.5 million, related 
to a net actuarial loss on defined benefit post-retirement plans and unrealized gains on securities available for sale and 
securities transferred to held to maturity. See Note 14 - Other Comprehensive Income (Loss). Notwithstanding this 
election made in accordance with ASU 2018-02, our policy is to release such income tax effects only when the entire 
portfolio to which the underlying transactions relate is liquidated, sold or extinguished.

On January 1, 2018, we also adopted, ASU 2014-09, "Revenue from Contracts with Customers (Topic 606).” Using 
a modified retrospective transition approach for contracts that were not complete as of our adoption, we recognized a 
cumulative effect reduction to beginning retained earnings totaling $2.3 million. The amount was related to certain 
revenue streams within trust and investment management fees. Additionally, based on our underlying contracts, ASU 
2014-09 requires us to report network costs associated with debit card and ATM transactions netted against the related 
fee income from such transactions. Previously, such network costs were reported as a component of other non-interest 
expense. For 2019 and 2018, gross interchange and debit card transaction fees totaled $27.8 million and $25.8 million, 
respectively, while related network costs totaled $12.9 million and $11.9 million, respectively. On a net basis, we 
reported  $14.9  million  and  $13.9  million  as  interchange  and  debit  card  transaction  fees  in  the  accompanying 
Consolidated Statement of Income for 2019 and 2018, respectively. For 2017, we reported interchange and debit card 
transaction fees totaling $23.2 million on a gross basis in the accompanying Consolidated Statement of Income while 
related network cost totaling $11.9 million was reported as a component of other non-interest expense. ASU 2014-09 
also required us to change the way we recognize certain recurring revenue streams reported as components of trust and 
investment management fees, insurance commissions and fees and other categories of non-interest income, however, 
such changes were not significant to our financial statements.

81

Note 2 - Securities

Securities. Year-end securities held to maturity and available for sale consisted of the following:

Held to Maturity:

Residential mortgage-
backed securities

States and political

subdivisions

Other

Total

Available for Sale:

2019

2018

Amortized
Cost

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Estimated
Fair Value

Amortized
Cost

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Estimated
Fair Value

$

530,861

$

22

$

9,365

$

521,518

$

2,737

$

8

$

85

$

2,660

1,497,644

28,909

1,525,657

1,101,820

11,525

1,500

$ 2,030,005

—

28,931

18,934

$

$

$

$

1,500

1,500

10,261

$ 2,048,675

$ 1,106,057

12,084

$ 1,948,133

$ 3,455,417

—

11,533

1,772

$

$

$

$

896

—

552

—

1,112,793

1,500

637

$ 1,116,953

29,500

$ 3,427,689

U.S. Treasury

$ 1,941,283

Residential mortgage-
backed securities

States and political

subdivisions

Other

Total

2,176,275

32,608

1,289

2,207,594

823,208

13,079

6,547

829,740

6,717,344

353,857

42,867

—

204

—

7,070,997

7,089,132

70,760

72,690

7,087,202

42,867

42,690

—

—

42,690

$ 10,877,769

$

405,399

$

13,577

$ 11,269,591

$11,410,447

$

85,611

$

108,737

$11,387,321

All mortgage-backed securities included in the above table were issued by U.S. government agencies and corporations. 
At December 31, 2019, approximately 99.7% of the securities in our municipal bond portfolio were issued by the State of 
Texas or political subdivisions or agencies within the State of Texas, of which approximately 69.1% are either guaranteed 
by the Texas Permanent School Fund, which has a “triple-A” insurer financial strength rating, or are secured by U.S. 
Treasury securities via defeasance of the debt by the issuers. Securities with limited marketability, such as stock in the 
Federal Reserve Bank and the Federal Home Loan Bank, are carried at cost and are reported as other available for sale 
securities in the table above. The carrying value of securities pledged to secure public funds, trust deposits, repurchase 
agreements and for other purposes, as required or permitted by law was $3.9 billion at December 31, 2019 and $3.8 billion
December 31, 2018.

From time to time, we have reclassified certain securities from available for sale to held to maturity. During 2019, we 
reclassified securities with an aggregate fair value of $377.8 million and an aggregate net unrealized gain of $3.3 million
($2.6 million, net of tax) on the date of the transfer. The net unamortized, unrealized gain remaining on transferred securities, 
including  those  transferred  in  2019  and  in  years  prior,  included  in  accumulated  other  comprehensive  income  in  the 
accompanying balance sheet totaled $4.8 million ($3.8 million, net of tax) at December 31, 2019 and $2.7 million ($2.2 
million, net of tax) at December 31, 2018. This amount will be amortized out of accumulated other comprehensive income 
over the remaining life of the underlying securities as an adjustment of the yield on those securities.

Unrealized Losses. Year-end securities with unrealized losses, segregated by length of impairment, were as follows:

Less than 12 Months

More than 12 Months

Total

Estimated
Fair Value

Unrealized
Losses

Estimated
Fair Value

Unrealized
Losses

Estimated
Fair Value

Unrealized
Losses

2019
Held to Maturity:

Residential mortgage-backed

securities

States and political subdivisions

Total

Available for Sale:
U.S. Treasury
Residential mortgage-backed

securities

States and political subdivisions

Total

$ 519,099
371,434
$ 890,533

$ 636,999

276,249
59,678
$ 972,926

$

$

$

$

9,361
896
10,257

$

$

408
—
408

12,070

$ 199,980

782
204
13,056

31,456
—
$ 231,436

$

$

$

$

4
—
4

$ 519,507
371,434
$ 890,941

14

$ 836,979

507
—
521

307,705
59,678
$ 1,204,362

$

$

$

$

9,365
896
10,261

12,084

1,289
204
13,577

82

2018
Held to Maturity:

Residential mortgage-backed
securities
States and political subdivisions

Total

Available for Sale:
U.S. Treasury

Residential mortgage-backed

securities

States and political subdivisions

Total

Less than 12 Months

More than 12 Months

Total

Estimated
Fair Value

Unrealized
Losses

Estimated
Fair Value

Unrealized
Losses

Estimated
Fair Value

Unrealized
Losses

$

— $

205,686
$ 205,686

$

— $

541
541

$

2,034
5,952
7,986

$

— $

— $ 3,139,639

$

$

$

85
11
96

$

2,034
211,638
$ 213,672

29,500

$ 3,139,639

$

$

$

85
552
637

29,500

152,682
1,136,322
$ 1,289,004

$

205
7,026
7,231

213,982
2,058,048
$ 5,411,669

6,342
65,664
$ 101,506

366,664
3,194,370
$ 6,700,673

6,547
72,690
$ 108,737

Declines in the fair value of held-to-maturity and available-for-sale securities below their cost that are deemed to be 
other than temporary are reflected in earnings as realized losses to the extent the impairment is related to credit losses. The 
amount of the impairment related to other factors is recognized in other comprehensive income. In estimating other-than-
temporary impairment losses, management considers, among other things, (i) the length of time and the extent to which 
the fair value has been less than cost, (ii) the financial condition and near-term prospects of the issuer, and (iii) the intent 
and our ability to retain our investment in the issuer for a period of time sufficient to allow for any anticipated recovery 
in cost.

Management has the ability and intent to hold the securities classified as held to maturity in the table above until they 
mature, at which time we expect to receive full value for the securities. Furthermore, as of December 31, 2019, management 
does not have the intent to sell any of the securities classified as available for sale in the table above and believes that it 
is more likely than not that we will not have to sell any such securities before a recovery of cost. Any unrealized losses 
are due to increases in market interest rates over the yields available at the time the underlying securities were purchased. 
The fair value is expected to recover as the securities approach their maturity date or repricing date or if market yields for 
such investments decline. Management does not believe any of the securities are impaired due to reasons of credit quality. 
Accordingly, as of December 31, 2019, management believes the impairments detailed in the table above are temporary 
and no impairment loss has been realized in our consolidated income statement.

Contractual  Maturities.  The  amortized  cost  and  estimated  fair  value  of  securities,  excluding  trading  securities,  at 
December 31, 2019 are presented below by contractual maturity. Expected maturities may differ from contractual maturities 
because issuers may have the right to call or prepay obligations. Residential mortgage-backed securities and equity securities 
are shown separately since they are not due at a single maturity date.

Due in one year or less
Due after one year through five years
Due after five years through ten years
Due after ten years
Residential mortgage-backed securities
Equity securities

Total

Held to Maturity

Available for Sale

Amortized
Cost

Estimated
Fair Value

$

$

12,773
165,519
527,907
792,945
530,861
—
2,030,005

$

$

12,847
169,970
541,249
803,091
521,518
—
2,048,675

$

Amortized
Cost
508,575
1,317,774
451,885
6,380,393
2,176,275
42,867
$ 10,877,769

Estimated
Fair Value

$

509,404
1,344,035
478,800
6,686,891
2,207,594
42,867
$ 11,269,591

83

Sales of Securities. Sales of securities available for sale were as follows:

Proceeds from sales
Gross realized gains
Gross realized losses
Tax benefit (expense) related to securities gains/losses

2019
$ 18,660,147
930
(637)
(62)

2018
$ 16,806,062
3
(159)
33

2017
$ 11,963,359
1
(4,942)
1,729

Premiums and Discounts. Premium amortization and discount accretion included in interest income on securities was 

as follows:

Premium amortization
Discount accretion

Net (premium amortization) discount accretion

2019
(120,785) $
5,227
(115,558) $

2018
(108,483) $
7,955
(100,528) $

2017

(97,841)
7,908
(89,933)

$

$

Trading Account Securities. Year-end trading account securities, at estimated fair value, were as follows:

U.S. Treasury
States and political subdivisions

Total

Net gains and losses on trading account securities were as follows:

Net gain on sales transactions
Net mark-to-market gains (losses)

Net gain on trading account securities

2019

2018

24,298
—
24,298

2018

1,816
105
1,921

$

$

$

$

21,928
2,158
24,086

2017

1,408
(43)
1,365

$

$

$

$

2019

2,173
(176)
1,997

$

$

84

Note 3 - Loans

Year-end loans, including leases net of unearned discounts, consisted of the following:

Commercial and industrial
Energy:

Production
Service
Other

Total energy
Commercial real estate:
Commercial mortgages
Construction
Land

Total commercial real estate

Consumer real estate:
Home equity loans
Home equity lines of credit
Other

Total consumer real estate

Total real estate

Consumer and other

Total loans

2019
5,187,466

$

2018
5,111,957

$

1,348,900
192,996
110,986
1,652,882

4,594,113
1,312,659
289,467
6,196,239

1,309,314
168,775
124,509
1,602,598

4,121,966
1,267,717
306,755
5,696,438

375,596
354,671
464,146
1,194,413
7,390,652
519,332
$ 14,750,332

353,924
337,168
427,898
1,118,990
6,815,428
569,750
$ 14,099,733

Concentrations of Credit. Most of our lending activity occurs within the State of Texas, including the four largest 
metropolitan areas of Austin, Dallas/Ft. Worth, Houston and San Antonio, as well as other markets. The majority of 
our loan portfolio consists of commercial and industrial and commercial real estate loans. As of December 31, 2019
and 2018, there were no concentrations of loans related to any single industry in excess of 10% of total loans other 
than energy loans, which totaled 11.2% and 11.4% of total loans at such dates, respectively. Unfunded commitments 
to extend credit and standby letters of credit issued to customers in the energy industry totaled $1.2 billion and $75.5 
million, respectively, as of December 31, 2019.

Foreign Loans. We have U.S. dollar denominated loans and commitments to borrowers in Mexico. The outstanding 
balance  of  these  loans  and  the  unfunded  amounts  available  under  these  commitments  were  not  significant  at 
December 31, 2019 or 2018.

Overdrafts. Deposit account overdrafts reported as loans totaled $9.0 million and $8.5 million at December 31, 2019

and 2018. 

Related Party Loans. In the ordinary course of business, we have granted loans to certain directors, executive officers 
and their affiliates (collectively referred to as “related parties”). Activity in related party loans during 2019 is presented 
in the following table. Other changes were primarily related to changes in related-party status. 

Balance outstanding at December 31, 2018
Principal additions
Principal reductions
Other changes
Balance outstanding at December 31, 2019

$

$

256,056
304,407
(257,687)
(4,248)
298,528

Non-Accrual and Past Due Loans. Loans are considered past due if the required principal and interest payments 
have  not  been  received  as  of  the  date  such  payments  were  due.  Loans  are  placed  on  non-accrual  status  when,  in 
management’s opinion, the borrower may be unable to meet payment obligations as they become due, as well as when 
required by regulatory provisions. In determining whether or not a borrower may be unable to meet payment obligations 
for each class of loans, we consider the borrower’s debt service capacity through the analysis of current financial 
information, if available, and/or current information with regards to our collateral position. Regulatory provisions would 
typically require the placement of a loan on non-accrual status if (i) principal or interest has been in default for a period 
85

of 90 days or more unless the loan is both well secured and in the process of collection or (ii) full payment of principal 
and interest is not expected. Loans may be placed on non-accrual status regardless of whether or not such loans are 
considered past due. When interest accrual is discontinued, all unpaid accrued interest is reversed. Interest income on 
non-accrual loans is recognized only to the extent that cash payments are received in excess of principal due. A loan 
may be returned to accrual status when all the principal and interest amounts contractually due are brought current and 
future  principal  and  interest  amounts  contractually  due  are  reasonably  assured,  which  is  typically  evidenced  by  a 
sustained period (at least six months) of repayment performance by the borrower.

Year-end non-accrual loans, segregated by class of loans, were as follows:

Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

2019

2018

$

$

$

26,038
65,761

8,912
665
922
5
102,303

$

9,239
46,932

15,268
—
892
1,408
73,739

Had  non-accrual  loans  performed  in  accordance  with  their  original  contract  terms,  we  would  have  recognized 
additional interest income, net of tax, of approximately $3.9 million in 2019, $5.2 million in 2018 and $3.7 million in 
2017.

An age analysis of past due loans (including both accruing and non-accruing loans), segregated by class of loans, 

as of December 31, 2019 was as follows:

Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

$

$

Loans
30-89 Days
Past Due

Loans
90 or More
Days
Past Due

Total Past
Due Loans

25,474
6,136

$

21,268
62,566

$

46,742
68,702

Current
Loans
$ 5,140,724
1,584,180

Total Loans
$ 5,187,466
1,652,882

12,384
195
7,442
4,476
56,107

$

2,725
1,066
2,129
1,112
90,866

15,109
1,261
9,571
5,588
146,973

4,868,471
1,311,398
1,184,842
513,744
$14,603,359

4,883,580
1,312,659
1,194,413
519,332
$14,750,332

$

Accruing
Loans 90 or
More Days
Past Due

$

$

3,430
85

967
402
1,425
1,112
7,421

Impaired Loans. Loans are considered impaired when, based on current information and events, it is probable we 
will be unable to collect all amounts due in accordance with the original contractual terms of the loan agreement, 
including scheduled principal and interest payments. Impairment is evaluated in total for smaller-balance loans of a 
similar nature and on an individual loan basis for other loans. If a loan is impaired, a specific valuation allowance is 
allocated, if necessary, so that the loan is reported net, at the present value of estimated future cash flows using the 
loan’s existing rate or at the fair value of collateral if repayment is expected solely from the collateral. Interest payments 
on impaired loans are typically applied to principal unless collectibility of the principal amount is reasonably assured, 
in which case interest is recognized on a cash basis. Impaired loans, or portions thereof, are charged off when deemed 
uncollectible.

Regulatory guidelines require us to reevaluate the fair value of collateral supporting impaired collateral dependent 
loans on at least an annual basis. While our policy is to comply with the regulatory guidelines, our general practice is 
to reevaluate the fair value of collateral supporting impaired collateral dependent loans on a quarterly basis. Thus, 
appraisals are generally not considered to be outdated, and we typically do not make any adjustments to the appraised 
values. The fair value of collateral supporting impaired collateral dependent loans is evaluated by our internal appraisal 
services using a methodology that is consistent with the Uniform Standards of Professional Appraisal Practice. The 
fair value of collateral supporting impaired collateral dependent construction loans is based on an “as is” valuation.

86

Year-end impaired loans are set forth in the following table. No interest income was recognized on impaired loans 

subsequent to their classification as impaired.

2019
Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

2018
Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

2017
Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

Unpaid
Contractual
Principal
Balance

Recorded
Investment
With No
Allowance

Recorded
Investment
With
Allowance

Total
Recorded
Investment

Related
Allowance

Average
Recorded
Investment

$

30,909
87,103

$

11,588
2,764

$

12,772
62,480

$

24,360
65,244

$

7,849
20,246

$

14,913
53,563

9,252
697
570
5
$ 128,536

$

$

$

9,094
67,900

15,774
—
293
1,475
94,536

60,781
99,606

10,795
—
1,214
—
$ 172,396

$

$

$

$

$

6,255
665
570
—
21,842

2,842
6,817

2,168
—
293
—
12,120

28,038
33,080

6,394
—
1,214
—
68,726

$

$

$

$

$

2,354
—
—
5
77,611

4,287
39,890

12,517
—
—
1,407
58,101

15,722
61,162

—
—
—
—
76,884

8,609
665
570
5
99,453

7,129
46,707

14,685
—
293
1,407
70,221

43,760
94,242

$

$

$

$

6,394
—
1,214
—
$ 145,610

$

$

$

$

$

383
—
—
5
28,483

2,558
9,671

2,599
—
—
1,407
16,235

13,690
354
547
1,285
84,352

18,246
75,453

$

$

12,799
—
704
925
$ 108,127

7,553
13,267

$

30,073
76,492

—
—
—
—
20,820

6,164
—
1,167
11
$ 113,907

Troubled Debt Restructurings. The restructuring of a loan is considered a “troubled debt restructuring” if both (i) the 
borrower is experiencing financial difficulties and (ii) the creditor has granted a concession. Concessions may include 
interest  rate  reductions  or  below  market  interest  rates,  principal  forgiveness,  restructuring  amortization  schedules, 
reductions  in  collateral  and  other  actions  intended  to  minimize  potential  losses.  Troubled  debt  restructurings  that 
occurred during 2019, 2018 and 2017 are set forth in the following table.

2019

2018

2017

Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate

Balance at
Restructure
3,845
$
—

9,457
—
124
13,426

$

$

$

Balance at
Year-end

2,161
—

9,393
—
120
11,674

Balance at
Restructure
2,203
$
13,708

—
—
—
15,911

$

$

$

87

Balance at
Year-end

Balance at
Restructure
4,026
56,096

— $
—

—
—
—
— $

—
388
—
60,510

Balance at
Year-end

$

$

3,766
54,330

—
388
—
58,484

Loan modifications are typically related to extending amortization periods, converting loans to interest only for a 
limited period of time, deferral of interest payments, waiver of certain covenants, consolidating notes and/or reducing 
collateral or interest rates. The modifications during the reported periods did not significantly impact our determination 
of the allowance for loan losses.

Additional information related to restructured loans was as follows:

Restructured loans past due in excess of 90 days at period-end:

Number of loans
Dollar amount of loans

Restructured loans on non-accrual status at period end
Charge-offs of restructured loans:

Recognized in connection with restructuring
Recognized on previously restructured loans

Proceeds from sale of restructured loans

2019

2018

2017

$

$

4
3,340
5,576

—
1,500
—

—
— $
—

1
43,137
53,622

—
7,650
15,750

—
9,951
—

Credit Quality Indicators. As part of the on-going monitoring of the credit quality of our loan portfolio, management 
tracks certain credit quality indicators including trends related to (i) the weighted-average risk grade of commercial 
loans, (ii) the level of classified commercial loans, (iii) the delinquency status of consumer loans (see details above) 
(iv) net charge-offs, (v) non-performing loans (see details above) and (vi) the general economic conditions in the State 
of Texas.

We utilize a risk grading matrix to assign a risk grade to each of our commercial loans. Loans are graded on a scale 

of 1 to 14. A description of the general characteristics of the 14 risk grades is as follows:

• 

• 

• 

• 

• 

• 

• 

Grades 1, 2 and 3 - These grades include loans to very high credit quality borrowers of investment or near 
investment  grade. These  borrowers  are  generally  publicly  traded  (grades  1  and  2),  have  significant  capital 
strength, moderate leverage, stable earnings and growth, and readily available financing alternatives. Smaller 
entities, regardless of strength, would generally not fit in these grades.

Grades 4 and 5 - These grades include loans to borrowers of solid credit quality with moderate risk. Borrowers 
in these grades are differentiated from higher grades on the basis of size (capital and/or revenue), leverage, 
asset quality and the stability of the industry or market area.

Grades 6, 7 and 8 - These grades include “pass grade” loans to borrowers of acceptable credit quality and risk. 
Such borrowers are differentiated from Grades 4 and 5 in terms of size, secondary sources of repayment or they 
are of lesser stature in other key credit metrics in that they may be over-leveraged, under capitalized, inconsistent 
in performance or in an industry or an economic area that is known to have a higher level of risk, volatility, or 
susceptibility to weaknesses in the economy.

Grade 9 - This grade includes loans on management’s “watch list” and is intended to be utilized on a temporary 
basis for pass grade borrowers where a significant risk-modifying action is anticipated in the near term.

Grade 10 - This grade is for “Other Assets Especially Mentioned” in accordance with regulatory guidelines. 
This  grade  is  intended  to  be  temporary  and  includes  loans  to  borrowers  whose  credit  quality  has  clearly 
deteriorated and are at risk of further decline unless active measures are taken to correct the situation.

Grade 11 - This grade includes “Substandard” loans, in accordance with regulatory guidelines, for which the 
accrual of interest has not been stopped. By definition under regulatory guidelines, a “Substandard” loan has 
defined weaknesses which make payment default or principal exposure likely, but not yet certain. Such loans 
are apt to be dependent upon collateral liquidation, a secondary source of repayment or an event outside of the 
normal course of business.

Grade 12 - This grade includes “Substandard” loans, in accordance with regulatory guidelines, for which the 
accrual of interest has been stopped. This grade includes loans where interest is more than 120 days past due 
and not fully secured and loans where a specific valuation allowance may be necessary, but generally does not 
exceed 30% of the principal balance.

88

• 

• 

Grade 13 - This grade includes “Doubtful” loans in accordance with regulatory guidelines. Such loans are 
placed on non-accrual status and may be dependent upon collateral having a value that is difficult to determine 
or upon some near-term event which lacks certainty. Additionally, these loans generally have a specific valuation 
allowance in excess of 30% of the principal balance.

Grade 14 - This grade includes “Loss” loans in accordance with regulatory guidelines. Such loans are to be 
charged-off or charged-down when payment is acknowledged to be uncertain or when the timing or value of 
payments cannot be determined. “Loss” is not intended to imply that the loan or some portion of it will never 
be paid, nor does it in any way imply that there has been a forgiveness of debt.

In monitoring credit quality trends in the context of assessing the appropriate level of the allowance for loan losses, 
we monitor portfolio credit quality by the weighted-average risk grade of each class of commercial loan. Individual 
relationship managers, under the oversight of credit administration, review updated financial information for all pass 
grade loans to reassess the risk grade on at least an annual basis. When a loan has a risk grade of 9, it is still considered 
a pass grade loan; however, it is considered to be on management’s “watch list,” where a significant risk-modifying 
action is anticipated in the near term. When a loan has a risk grade of 10 or higher, a special assets officer monitors the 
loan on an on-going basis. The following tables present weighted average risk grades for all commercial loans by class.

Commercial and industrial
Risk grades 1-8
Risk grade 9
Risk grade 10
Risk grade 11
Risk grade 12
Risk grade 13

Total

Energy

Risk grades 1-8
Risk grade 9
Risk grade 10
Risk grade 11
Risk grade 12
Risk grade 13

Total

Commercial real estate:

Buildings, land and other

Risk grades 1-8
Risk grade 9
Risk grade 10
Risk grade 11
Risk grade 12
Risk grade 13

Total

Construction

Risk grades 1-8
Risk grade 9
Risk grade 10
Risk grade 11
Risk grade 12
Risk grade 13

Total

December 31, 2019

December 31, 2018

Weighted
Average
Risk Grade

6.17
9.00
10.00
11.00
12.00
13.00
6.44

5.90
9.00
10.00
11.00
12.00
13.00
6.39

6.78
9.00
10.00
11.00
12.00
13.00
7.01

7.25
9.00
10.00
11.00
12.00
13.00
7.31

$

$

$

$

$

$

$

$

Loans

4,788,857
247,212
71,472
53,887
18,189
7,849
5,187,466

1,488,301
32,163
51,898
14,760
45,514
20,246
1,652,882

4,523,271
163,714
103,626
84,057
8,529
383
4,883,580

1,274,098
21,509
15,243
1,144
665
—
1,312,659

Weighted
Average
Risk Grade

6.12
9.00
10.00
11.00
12.00
13.00
6.30

5.76
9.00
10.00
11.00
12.00
13.00
6.22

6.76
9.00
10.00
11.00
12.00
13.00
6.98

7.13
9.00
10.00
11.00
12.00
13.00
7.29

$

$

$

$

$

$

$

$

Loans

4,862,275
112,431
58,328
69,684
6,681
2,558
5,111,957

1,451,673
35,565
43,001
25,427
37,261
9,671
1,602,598

4,143,264
109,660
62,353
98,176
12,669
2,599
4,428,721

1,177,260
60,754
24,877
4,826
—
—
1,267,717

89

We have established maximum loan to value standards to be applied during the origination process of commercial 
and  consumer  real  estate  loans.  We  do  not  subsequently  monitor  loan-to-value  ratios  (either  individually  or  on  a 
weighted-average basis) for loans that are subsequently considered to be of a pass grade (grades 9 or better) and/or 
current with respect to principal and interest payments. As stated above, when an individual commercial real estate 
loan has a calculated risk grade of 10 or higher, a special assets officer analyzes the loan to determine whether the loan 
is impaired. At that time, we reassess the loan to value position in the loan. If the loan is determined to be impaired and 
collateral dependent, specific allocations of the allowance for loan losses are made for the amount of any collateral 
deficiency. If a collateral deficiency is ultimately deemed to be uncollectible, the amount is charged-off. These loans 
and related assessments of collateral position are monitored on an individual, case-by-case basis. We do not monitor 
loan-to-value ratios on a weighted-average portfolio-basis for commercial real estate loans having a calculated risk 
grade of 10 or higher as excess collateral from one borrower cannot be used to offset a collateral deficit for another 
borrower. When an individual consumer real estate loan becomes past due by more than 10 days, the assigned relationship 
manager will begin collection efforts. We only reassess the loan to value position in a consumer real estate loan if, 
during the course of the collections process, it is determined that the loan has become impaired and collateral dependent, 
and any collateral deficiency is recognized as a charge-off to the allowance for loan losses. Accordingly, we do not 
monitor loan-to-value ratios on a weighted-average basis for collateral dependent consumer real estate loans.

Generally, a commercial loan, or a portion thereof, is charged-off immediately when it is determined, through the 
analysis of any available current financial information with regards to the borrower, that the borrower is incapable of 
servicing unsecured debt, there is little or no prospect for near term improvement and no realistic strengthening action 
of significance is pending or, in the case of secured debt, when it is determined, through analysis of current information 
with regards to our collateral position, that amounts due from the borrower are in excess of the calculated current fair 
value of the collateral. Notwithstanding the foregoing, generally, commercial loans that become past due 180 cumulative 
days are charged-off. Generally, a consumer loan, or a portion thereof, is charged-off in accordance with regulatory 
guidelines which provide that such loans be charged-off when we become aware of the loss, such as from a triggering 
event that may include new information about a borrower’s intent/ability to repay the loan, bankruptcy, fraud or death, 
among other things, but in any event the charge-off must be taken within specified delinquency time frames. Such 
delinquency time frames state that closed-end retail loans (loans with pre-defined maturity dates, such as real estate 
mortgages, home equity loans and consumer installment loans) that become past due 120 cumulative days and open-
end retail loans (loans that roll-over at the end of each term, such as home equity lines of credit) that become past due 
180 cumulative days should be classified as a loss and charged-off.

Net (charge-offs)/recoveries, segregated by class of loan, were as follows:

Commercial and industrial
Energy
Commercial real estate:

Buildings, land and other
Construction

Consumer real estate
Consumer and other

Total

2019

2018

2017

(10,131) $
(6,058)

(22,388) $
(13,121)

(17,453)
(10,009)

(830)
24
(2,457)
(14,272)
(33,724) $

(263)
13
(1,538)
(7,548)
(44,845) $

735
11
(506)
(5,919)
(33,141)

$

$

In assessing the general economic conditions in the State of Texas, management monitors and tracks the Texas 
Leading Index (“TLI”), which is produced by the Federal Reserve Bank of Dallas. The TLI is a single summary statistic 
that is designed to signal the likelihood of the Texas economy’s transition from expansion to recession and vice versa. 
Management believes this index provides a reliable indication of the direction of overall credit quality. The TLI is a 
composite of the following eight leading indicators: (i) Texas Value of the Dollar, (ii) U.S. Leading Index, (iii) real oil 
prices (iv) well permits, (v) initial claims for unemployment insurance, (vi) Texas Stock Index, (vii) Help-Wanted Index 
and (viii) average weekly hours worked in manufacturing. The TLI totaled 128.8 at November 30, 2019 (most recent 
date available) and 126.4 at December 31, 2018. A higher TLI value implies more favorable economic conditions.

90

Allowance for Loan Losses. The allowance for loan losses is a reserve established through a provision for loan losses 
charged to expense, which represents management’s best estimate of inherent losses that have been incurred within the 
existing portfolio of loans. The allowance, in the judgment of management, is necessary to reserve for estimated loan 
losses and risks inherent in the loan portfolio. Our allowance for loan loss methodology follows the accounting guidance 
set forth in U.S. generally accepted accounting principles and the Interagency Policy Statement on the Allowance for 
Loan and Lease Losses, which was jointly issued by U.S. bank regulatory agencies. In that regard, our allowance for 
loan losses includes allowance allocations calculated in accordance with ASC Topic 310, “Receivables” and allowance 
allocations calculated in accordance with ASC Topic 450, “Contingencies.” Accordingly, the methodology is based on 
historical loss experience by type of credit and internal risk grade, specific homogeneous risk pools and specific loss 
allocations, with adjustments for current events and conditions. Our process for determining the appropriate level of 
the allowance for loan losses is designed to account for credit deterioration as it occurs. The provision for loan losses 
reflects loan quality trends, including the levels of and trends related to non-accrual loans, past due loans, potential 
problem loans, criticized loans and net charge-offs or recoveries, among other factors. The provision for loan losses 
also reflects the totality of actions taken on all loans for a particular period. In other words, the amount of the provision 
reflects not only the necessary increases in the allowance for loan losses related to newly identified criticized loans, 
but it also reflects actions taken related to other loans including, among other things, any necessary increases or decreases 
in required allowances for specific loans or loan pools. 

The level of the allowance reflects management’s continuing evaluation of industry concentrations, specific credit 
risks,  loan  loss  and  recovery  experience,  current  loan  portfolio  quality,  present  economic,  political  and  regulatory 
conditions and unidentified losses inherent in the current loan portfolio. Portions of the allowance may be allocated 
for specific credits; however, the entire allowance is available for any credit that, in management’s judgment, should 
be charged off. While management utilizes its best judgment and information available, the ultimate determination of 
the appropriate level of the allowance is dependent upon a variety of factors beyond our control, including, among 
other things, the performance of our loan portfolio, the economy, changes in interest rates and the view of the regulatory 
authorities toward loan classifications. We monitor whether or not the allowance for loan loss allocation model, as a 
whole,  calculates  an  appropriate  level  of  allowance  for  loan  losses  that  moves  in  direct  correlation  to  the  general 
macroeconomic and loan portfolio conditions we experience over time.

Our allowance for loan losses consists of: (i) specific valuation allowances determined in accordance with ASC 
Topic 310 based on probable losses on specific loans; (ii) historical valuation allowances determined in accordance 
with ASC Topic 450 based on historical loan loss experience for similar loans with similar characteristics and trends, 
adjusted, as necessary, to reflect the impact of current conditions; (iii) general valuation allowances determined in 
accordance with ASC Topic 450 based on various risk factors that are internal to us; and (iv) macroeconomic valuation 
allowances determined in accordance with ASC Topic 450 based on general economic conditions and other risk factors 
that are external to us.

The allowances established for probable losses on specific loans are based on a regular analysis and evaluation of 
problem loans. Loans are classified based on an internal credit risk grading process that evaluates, among other things: 
(i) the obligor’s ability to repay; (ii) the underlying collateral, if any; and (iii) the economic environment and industry 
in which the borrower operates. This analysis is performed at the relationship manager level for all commercial loans. 
When a loan has a calculated grade of 10 or higher, a special assets officer analyzes the loan to determine whether the 
loan is impaired and, if impaired, the need to specifically allocate a portion of the allowance for loan losses to the loan. 
Specific valuation allowances are determined by analyzing the borrower’s ability to repay amounts owed, collateral 
deficiencies, the relative risk grade of the loan and economic conditions affecting the borrower’s industry, among other 
things.

Historical valuation allowances are calculated based on the historical gross loss experience of specific types of loans 
and the internal risk grade of such loans. We calculate historical gross loss ratios for pools of similar loans with similar 
characteristics based on the proportion of actual charge-offs experienced to the total population of loans in the pool. 
The historical gross loss ratios are periodically (no less than annually) updated based on actual charge-off experience. 
A historical valuation allowance is established for each pool of similar loans based upon the product of the historical 
gross loss ratio and the total dollar amount of the loans in the pool. Our pools of similar loans include similarly risk-
graded groups of commercial and industrial loans, energy loans, commercial real estate loans, consumer real estate 
loans, consumer and other loans and overdrafts.

91

General valuation allowances include allocations for groups of similar loans with similar risk characteristics that 
exceed certain concentration limits established by management and/or our board of directors. Concentration risk limits 
have been established, among other things, for certain industry concentrations, large balance and highly leveraged 
credit relationships that exceed specified risk grades and loans originated with policy exceptions that exceed specified 
risk  grades.  Additionally,  general  valuation  allowances  are  provided  for  loans  that  did  not  undergo  a  separate, 
independent  concurrence  review  during  the  underwriting  process  (generally  those  loans  under  $1.0  million  at 
origination). Our allowance methodology for general valuation allowances also includes a reduction factor for recoveries 
of prior charge-offs to compensate for the fact that historical loss allocations are based upon gross charge-offs rather 
than net. The adjustment for recoveries is based on the lower of annualized, year-to-date gross recoveries or the total 
gross recoveries by loan portfolio segment for the preceding four quarters, adjusted, when necessary, for expected 
future trends in recoveries. 

The components of the macroeconomic valuation allowance include (i) reserves allocated as a result of applying 
an environmental risk adjustment factor to the base historical loss allocation, (ii) reserves allocated for loans to borrowers 
in  distressed  industries  and  (iii) reserves  allocated  based  upon  current  economic  trends  and  other  quantitative  and 
qualitative factors that could impact our loan portfolio segments. The aggregate sum of these components for each 
portfolio segment reflects management's assessment of current and expected economic conditions and other external 
factors that impact the inherent credit quality of loans in that portfolio segment.

The environmental adjustment factor is based upon a more qualitative analysis of risk and is calculated through a 
survey of senior officers who are involved in credit making decisions at a corporate-wide and/or regional level. On a 
quarterly basis, survey participants rate the degree of various risks utilizing a numeric scale that translates to varying 
grades of high, moderate or low levels of risk. The results are then input into a risk-weighting matrix to determine an 
appropriate environmental risk adjustment factor. The various risks that may be considered in the determination of the 
environmental adjustment factor include, among other things, (i) the experience, ability and effectiveness of the bank’s 
lending management and staff; (ii) the effectiveness of our loan policies, procedures and internal controls; (iii) changes 
in  asset  quality;  (iv) the  impact  of  legislative  and  governmental  influences  affecting  industry  sectors;  (v) the 
effectiveness of the internal loan review function; (vi) the impact of competition on loan structuring and pricing; and 
(vii) the impact of rising interest rates on portfolio risk. In periods where the surveyed risks are perceived to be higher, 
the risk-weighting matrix will generally result in a higher environmental adjustment factor, which, in turn will result 
in  higher  levels  of  macroeconomic  valuation  allowance  allocations. The  opposite  holds  true  in  periods  where  the 
surveyed risks are perceived to be lower.

Macroeconomic valuation allowances also include amounts allocated for loans to borrowers in distressed industries 
within our commercial loan portfolio segments. To determine the amount of the allocation for our commercial and 
industrial and commercial real estate loan portfolio segments, management calculates the weighted-average risk grade 
for all loans to borrowers in distressed industries by loan portfolio segment. A multiple is then applied to the amount 
by which the weighted-average risk grade for loans to borrowers in distressed industries exceeds the weighted-average 
risk grade for all pass-grade loans within the loan portfolio segment to derive an allocation factor for loans to borrowers 
in distressed industries. The amount of the allocation for each loan portfolio segment is the product of this allocation 
factor and the outstanding balance of pass-grade loans within the identified distressed industries that have a risk grade 
of  6  or  higher.  Management  identifies  potential  distressed  industries  by  analyzing  industry  trends  related  to 
delinquencies, classifications and charge-offs as well as individual borrower financial information.

The aforementioned methodology for allocating reserves for distressed industries within commercial and industrial 
and commercial real estate loan portfolio segments does not translate to our energy loan portfolio segment as the segment 
is made up of a single industry. For energy loans, management analyzes current economic trends, commodity prices 
and various other quantitative and qualitative factors that impact the inherent credit quality of our energy loan portfolio 
segment. If, based upon this analysis, management concludes that the prevailing conditions could have an adverse 
impact on the credit quality of our energy loan portfolio, management performs a sensitivity stress test on individual 
loans within our energy loan portfolio. The sensitivity stress test includes a commodity price shock to 75% of the 
commodity price deck. We also assess the financial strength of individual borrowers, the quality of collateral, the relative 
experience of the individual borrowers and their ability to withstand an economic downturn. The sensitivity stress test 
allows us to identify potential credit issues during periods of economic uncertainty. Reserve allocations resulting from 
the sensitivity stress test are calculated by hypothetically increasing the risk grades for affected borrowers and applying 
our allowance methodology to determine the incremental reserves that would be required.

92

Macroeconomic valuation allowances may also include additional reserves allocated based upon management's 
assessment of current and expected economic conditions, trends and other quantitative and qualitative portfolio risk 
factors that are external to us or that are not otherwise captured in our allowance modeling process but could impact 
the credit risk or inherent losses within our loan portfolio segments. Additional reserves are allocated when, based upon 
this assessment, management believes that there are inherent credit risks for a given portfolio segment that have not 
yet materialized through the migration of loan risk grades and, therefore, have not yet impacted our historical or general 
valuation allowances.

The following table presents details of the allowance for loan losses, segregated by loan portfolio segment.

December 31, 2019

Historical valuation allowances
Specific valuation allowances
General valuation allowances
Macroeconomic valuation

allowances
Total

December 31, 2018

Historical valuation allowances
Specific valuation allowances
General valuation allowances
Macroeconomic valuation

allowances
Total

Commercial
and
Industrial

Energy

Commercial
Real Estate

Consumer
Real Estate

Consumer
and Other

Total

$

$

$

$

29,015
7,849
9,840

4,889
51,593

25,351
2,558
10,062

10,609
48,580

$

$

$

$

7,873
20,246
5,196

4,067
37,382

9,697
9,671
6,014

3,670
29,052

$

$

$

$

21,947
383
4,201

4,506
31,037

20,817
2,599
4,366

10,995
38,777

$

$

$

$

2,690
—
904

519
4,113

2,688
—
1,671

1,744
6,103

$

$

$

$

$

7,562
5
(409)

69,087
28,483
19,732

884
8,042

14,865
$ 132,167

$

6,845
1,407
(13)

65,398
16,235
22,100

1,381
9,620

28,399
$ 132,132

We monitor whether or not the allowance for loan loss allocation model, as a whole, calculates an appropriate level 
of allowance for loan losses that moves in direct correlation to the general macroeconomic and loan portfolio conditions 
we  experience  over  time.  In  assessing  the  general  macroeconomic  trends/conditions,  we  analyze  trends  in  the 
components of the TLI, as well as any available information related to regional, national and international economic 
conditions and events and the impact such conditions and events may have on us and our customers. With regard to 
assessing loan portfolio conditions, we analyze trends in weighted-average portfolio risk-grades, classified and non-
performing loans and charge-off activity. In periods where general macroeconomic and loan portfolio conditions are 
in a deteriorating trend or remain at deteriorated levels, based on historical trends, we would expect to see the allowance 
for loan loss allocation model, as a whole, calculate higher levels of required allowances than in periods where general 
macroeconomic and loan portfolio conditions are in an improving trend or remain at an elevated level, based on historical 
trends.

Our recorded investment in loans related to each balance in the allowance for loan losses by portfolio segment and 

detailed on the basis of the impairment methodology we used was as follows:

December 31, 2019
Individually evaluated

Collectively evaluated

Total

December 31, 2018
Individually evaluated

Collectively evaluated

Total

Commercial
and
Industrial

Energy

Commercial
Real Estate

Consumer
Real Estate

Consumer
and Other

Total

$

24,360

$

65,244

$

9,274

$

570

5,163,106
$ 5,187,466

1,587,638
$ 1,652,882

6,186,965
$ 6,196,239

1,193,843
$ 1,194,413

$

7,129

$

46,707

$

14,685

$

293

5,104,828
$ 5,111,957

1,555,891
$ 1,602,598

5,681,753
$ 5,696,438

1,118,697
$ 1,118,990

$

$

$

$

5

$

99,453

519,327
519,332

14,650,879
$ 14,750,332

1,407

$

70,221

568,343
569,750

14,029,512
$ 14,099,733

93

The following table details activity in the allowance for loan losses by portfolio segment for 2019, 2018 and 2017. 
Allocation of a portion of the allowance to one category of loans does not preclude its availability to absorb losses in 
other categories.

2019
Beginning balance
Provision for loan losses
Charge-offs
Recoveries

Net charge-offs
Ending balance
Allocated to loans:

Individually evaluated for

impairment

Collectively evaluated for

impairment
Ending balance

2018
Beginning balance
Provision for loan losses
Charge-offs
Recoveries

Net charge-offs
Ending balance
Allocated to loans:

Individually evaluated for

impairment

Collectively evaluated for

impairment
Ending balance

2017
Beginning balance
Provision for loan losses
Charge-offs
Recoveries

Net charge-offs
Ending balance
Allocated to loans:

Individually evaluated for

impairment

Collectively evaluated for

impairment
Ending balance

Commercial
and
Industrial

Energy

Commercial
Real Estate

Consumer
Real Estate

Consumer
and Other

Total

$

$

$

$

$

$

$

$

$

$

$

$

48,580
13,144
(14,117)
3,986
(10,131)
51,593

$

$

29,052
14,388
(7,500)
1,442
(6,058)
37,382

$

$

38,777
(6,934)
(1,025)
219
(806)
31,037

$

$

6,103
467
(3,665)
1,208
(2,457)
4,113

$

$

9,620
12,694
(24,725)
10,453
(14,272)
8,042

$ 132,132
33,759
(51,032)
17,308
(33,724)
$ 132,167

7,849

$

20,246

$

383

$

— $

5

$

28,483

43,744
51,593

59,614
11,354
(26,076)
3,688
(22,388)
48,580

$

$

$

17,136
37,382

51,528
(9,355)
(13,940)
819
(13,121)
29,052

$

$

$

30,654
31,037

30,948
8,079
(619)
369
(250)
38,777

$

$

$

4,113
4,113

5,657
1,984
(2,143)
605
(1,538)
6,103

$

$

$

8,037
8,042

103,684
$ 132,167

7,617
9,551
(17,197)
9,649
(7,548)
9,620

$ 155,364
21,613
(59,975)
15,130
(44,845)
$ 132,132

2,558

$

9,671

$

2,599

$

— $

1,407

$

16,235

46,022
48,580

52,915
24,152
(20,619)
3,166
(17,453)
59,614

$

$

$

19,381
29,052

60,653
884
(10,595)
586
(10,009)
51,528

$

$

$

36,178
38,777

30,213
(11)
(86)
832
746
30,948

$

$

$

6,103
6,103

4,238
1,925
(925)
419
(506)
5,657

$

$

$

8,213
9,620

115,897
$ 132,132

5,026
8,510
(15,579)
9,660
(5,919)
7,617

$ 153,045
35,460
(47,804)
14,663
(33,141)
$ 155,364

7,553

$

13,267

$

— $

— $

— $

20,820

52,061
59,614

$

38,261
51,528

$

30,948
30,948

$

5,657
5,657

$

7,617
7,617

134,544
$ 155,364

94

Note 4 - Premises and Equipment and Lease Commitments

Year-end premises and equipment were as follows:

Land
Buildings
Technology, furniture and equipment
Leasehold improvements
Construction and projects in progress
Lease right-of-use assets

Less accumulated depreciation and amortization

Total premises and equipment, net

2019
112,818
441,404
226,925
156,144
44,251
297,736
1,279,278
(267,331)
1,011,947

$

$

$

$

2018
104,045
373,276
196,871
83,320
45,456
—
802,968
(250,638)
552,330

Depreciation of premises and equipment totaled $41.0 million in 2019, $37.2 million 2018 and $36.3 million in 

2017. Amortization of lease right of use-assets totaled $27.6 million in 2019.

Lease Commitments. We lease certain office facilities and office equipment under operating leases. Rent expense 
for all operating leases totaled $42.1 million in 2019, $31.1 million in 2018 and $30.5 million in 2017. On January 1, 
2019, we adopted a new accounting standard which required the recognition of certain operating leases on our balance 
sheet  as  lease  right-of-use  assets  (reported  as  component  of  premises  and  equipment)  and  related  lease  liabilities 
(reported  as  a  component  of  accrued  interest  payable  and  other  liabilities).  See  Note  1  -  Summary  of  Significant 
Accounting Policies. Rent expense includes amounts related to items that are not included in the determination of lease 
right-of-use  assets  including  expenses  related  to  short-term  leases  totaling  $4.6  million  in  2019  and  non-lease 
components such as taxes, insurance, and common area maintenance costs totaling $9.9 million in 2019. 

Lease payments under operating leases that were applied to our operating lease liability totaled $27.5 million during 
2019. The following table reconciles future undiscounted lease payments due under non-cancelable operating leases 
(those amounts subject to recognition) to the aggregate operating lessee lease liability as of December 31, 2019:

Future lease payments

2020
2021
2022
2023
2024
Thereafter

Total undiscounted operating lease liability
Imputed interest

Total operating lease liability included in the accompanying balance sheet

Weighted-average lease term in years
Weighted-average discount rate

$

$

28,225
30,813
28,175
26,661
25,232
283,300
422,406
98,718
323,688

16.49
3.17%

We lease certain buildings and branch facilities from various entities which are controlled by or affiliated with certain 
directors. Payments related to these leases totaled $5.9 million in 2019, $464 thousand in 2018 and $1.4 million in 
2017. The increase in these lease payments during 2019 compared to 2018 was primarily related to the commencement 
of the lease of our new headquarters building during the second quarter of 2019. We recognized a right-of-use asset 
totaling $121.7 million and a related lease liability totaling $121.7 million in connection with this lease. The lease was 
a separate agreement under a comprehensive development agreement between us, the City of San Antonio and a third 
party controlled by one of our directors. We sold our old headquarters building to the City of San Antonio in 2016 and 
leased it back during the construction period of our new headquarters building. A portion of the gain from the sale of 
our old headquarters building was deferred and amortized to income over the term of the lease, which ended in the 
second quarter of 2019. Amortization of the deferred gain totaled $1.4 million in 2019, $2.8 million in 2018 and $2.9 
million in 2017. 

95

Note 5 - Goodwill and Other Intangible Assets

Goodwill. Year-end goodwill was as follows:

Goodwill

Other Intangible Assets. Year-end other intangible assets were as follows:

2019

Core deposits
Customer relationships

2018

Core deposits
Customer relationships
Non-compete agreements

Gross
Intangible
Assets

$

$

$

$

9,300
3,388
12,688

9,300
4,206
74
13,580

2019
654,952

$

2018
654,952

Accumulated
Amortization

Net
Intangible
Assets

(7,257) $
(2,950)
(10,207) $

(6,341) $
(3,534)
(56)
(9,931) $

2,043
438
2,481

2,959
672
18
3,649

$

$

$

$

$

Other intangible assets are amortized on an accelerated basis over their estimated lives, which range from 5 to 
10 years. Amortization expense related to intangible assets totaled $1.2 million in 2019, $1.4 million in 2018, and $1.7 
million in 2017. The estimated aggregate future amortization expense for intangible assets remaining as of December 31, 
2019 is as follows:

2020
2021
2022
2023
2024
Thereafter

$

$

918
697
481
282
87
16
2,481

96

Note 6 - Deposits

Year-end deposits were as follows:

Non-interest-bearing demand deposits:

Commercial and individual
Correspondent banks
Public funds

Total non-interest-bearing demand deposits

Interest-bearing deposits:

Private accounts:

Savings and interest checking
Money market accounts
Time accounts of $100,000 or more
Time accounts under $100,000

Total private accounts

Public funds:

Savings and interest checking
Money market accounts
Time accounts of $100,000 or more
Time accounts under $100,000

Total public funds

Total interest-bearing deposits

Total deposits

The following table presents additional information about our year-end deposits:

Deposits from the Certificate of Deposit Account Registry Service (CDARS)
Deposits from foreign sources (primarily Mexico)
Deposits not covered by deposit insurance
Deposits from certain directors, executive officers and their affiliates

2019

2018

$ 10,212,265
246,181
415,183
10,873,629

$ 10,305,850
235,748
455,896
10,997,494

7,147,327
7,888,433
736,481
347,418
16,119,659

6,977,813
7,777,470
526,789
331,511
15,613,583

548,399
73,180
24,672
25
646,276
16,765,935
$ 27,639,564

473,754
59,953
4,332
88
538,127
16,151,710
$ 27,149,204

$

2019

361
805,828
13,115,796
197,919

$

2018

—
752,658
13,111,210
199,321

Scheduled  maturities  of  time  deposits,  including  both  private  and  public  funds,  at  December 31,  2019  were  as 

follows:

2020
2021

$

$

891,005
217,591
1,108,596

Scheduled maturities of time deposits in amounts of $100,000 or more, including both private and public funds, at 

December 31, 2019, were as follows:

Due within 3 months or less
Due after 3 months and within 6 months
Due after 6 months and within 12 months
Due after 12 months

$

$

191,563
140,654
271,209
157,727
761,153

97

Note 7 - Borrowed Funds

Federal Funds Purchased and Securities Sold Under Agreements to Repurchase. Federal funds purchased are short-
term borrowings that typically mature within one to ninety days. Federal funds purchased totaled $27.2 million and 
$7.3 million at December 31, 2019 and 2018. Securities sold under agreements to repurchase are secured short-term 
borrowings that typically mature overnight or within thirty to ninety days. Securities sold under agreements to repurchase 
are stated at the amount of cash received in connection with the transaction. We may be required to provide additional 
collateral based on the fair value of the underlying securities. Securities sold under agreements to repurchase totaled 
$1.7 billion and $1.4 billion at December 31, 2019 and 2018.

Subordinated Notes Payable. In March 2017, we issued $100 million of 4.50% subordinated notes that mature on 
March 17, 2027. The notes, which qualify as Tier 2 capital for Cullen/Frost, bear interest at the rate of 4.50% per annum, 
payable semi-annually on each March 17 and September 17. The notes are unsecured and subordinated in right of 
payment to the payment of our existing and future senior indebtedness and structurally subordinated to all existing and 
future indebtedness of our subsidiaries. Unamortized debt issuance costs related to these notes, totaled approximately 
$1.1 million and $1.3 million December 31, 2019 and 2018. Proceeds from sale of the notes were used for general 
corporate purposes.

Our $100 million of 5.75% fixed-to-floating rate subordinated notes originally issued in February 2007 matured 
and were redeemed on February 15, 2017. The notes qualified as Tier 2 capital for Cullen/Frost under the capital rules 
in effect prior to 2015. Prior to February 2012, the notes had a fixed interest rate of 5.75% per annum, after which the 
notes bore interest at a rate per annum equal to three-month LIBOR for the related interest period plus 0.53% (1.43% 
at December 31, 2016), paid quarterly.

Junior Subordinated Deferrable Interest Debentures. At December 31, 2019 and 2018, we had $123.7 million of 
junior subordinated deferrable interest debentures issued to Cullen/Frost Capital Trust II (“Trust II”), a wholly owned 
Delaware statutory business trust. Unamortized debt issuance costs related to Trust II totaled $816 thousand and $873 
thousand  at  December 31,  2019  and  2018. At  December 31,  2019  and  2018,  we  also  had  $13.4  million  of  junior 
subordinated deferrable interest debentures issued to WNB Capital Trust I (“WNB Trust”), a wholly owned Delaware 
statutory business trust acquired in connection with the acquisition of WNB Bancshares, Inc. (“WNB”) in 2014. Trust II 
and WNB Trust are variable interest entities for which we are not the primary beneficiary. As such, the accounts of 
Trust II and WNB Trust are not included in our consolidated financial statements. See Note 1 - Summary of Significant 
Accounting Policies for additional information about our consolidation policy. Details of our transactions with the 
capital trust are presented below.

Trust II was formed in 2004 for the purpose of issuing $120.0 million of floating rate (three-month LIBOR plus a 
margin of 1.55%) trust preferred securities, which represent beneficial interests in the assets of the trust. The trust 
preferred securities will mature on March 1, 2034 and are currently redeemable with the approval of the Federal Reserve 
Board in whole or in part at our option. Distributions on the trust preferred securities are payable quarterly in arrears 
on March 1, June 1, September 1 and December 1 of each year. Trust II also issued $3.7 million of common equity 
securities to Cullen/Frost. The proceeds of the offering of the trust preferred securities and common equity securities 
were used to purchase $123.7 million of floating rate (three-month LIBOR plus a margin of 1.55%, which was equal 
to 3.46% and 4.29% at December 31, 2019 and 2018) junior subordinated deferrable interest debentures issued by us, 
which have terms substantially similar to the trust preferred securities. 

WNB Trust was formed in 2004 by WNB for the purpose of issuing $13.0 million of floating rate (three-month 
LIBOR plus a margin of 2.35%) trust preferred securities, which represent beneficial interests in the assets of the trust. 
The trust preferred securities will mature on July 23, 2034 and are currently redeemable with the approval of the Federal 
Reserve Board in whole or in part at our option. Distributions on the trust preferred securities are payable quarterly in 
arrears on January 23, April 23, July 23 and October 23 of each year. WNB Trust also issued $403 thousand of common 
equity securities to WNB. The proceeds of the offering of the trust preferred securities and common equity securities 
were used to purchase $13.4 million of floating rate (three-month LIBOR plus a margin of 2.35%, which was equal to 
4.28% and 4.83% at December 31, 2019 and 2018) junior subordinated deferrable interest debentures issued by WNB, 
which have terms substantially similar to the trust preferred securities.

We have the right at any time during the term of the debentures issued to Trust II and WNB Trust to defer payments 
of interest at any time or from time to time for an extension period not exceeding 20 consecutive quarterly periods with 
respect to each extension period. Under the terms of the debentures, in the event that under certain circumstances there 
is an event of default under the debentures or we have elected to defer interest on the debentures, we may not, with 
98

certain exceptions, declare or pay any dividends or distributions on our capital stock or purchase or acquire any of our 
capital stock.

Payments of distributions on the trust preferred securities and payments on redemption of the trust preferred securities 
are guaranteed by us on a limited basis. We are obligated by agreement to pay any costs, expenses or liabilities of 
Trust II and WNB Trust other than those arising under the trust preferred securities. Our obligations under the junior 
subordinated debentures, the related indentures, the trust agreements establishing the trusts, the guarantees and the 
agreements as to expenses and liabilities, in the aggregate, constitute a full and unconditional guarantee by us of Trust II’s 
and WNB Trust's obligations under the trust preferred securities.

Although the accounts of Trust II and WNB Trust are not included in our consolidated financial statements, the 
$120.0 million in trust preferred securities issued by Trust II and the $13.0 million in trust preferred securities issued 
by WNB Trust are included in the capital of Cullen/Frost for regulatory capital purposes as of December 31, 2019 and 
2018. See Note 9 - Capital and Regulatory Matters.

Note 8 - Off-Balance-Sheet Arrangements, Commitments, Guarantees and Contingencies

Financial  Instruments  with  Off-Balance-Sheet  Risk.  In  the  normal  course  of  business,  we  enter  into  various 
transactions, which, in accordance with generally accepted accounting principles are not included in our consolidated 
balance sheets. We enter into these transactions to meet the financing needs of our customers. These transactions include 
commitments to extend credit and standby letters of credit, which involve, to varying degrees, elements of credit risk 
and interest rate risk in excess of the amounts recognized in the consolidated balance sheets. We minimize our exposure 
to loss under these commitments by subjecting them to credit approval and monitoring procedures.

We enter into contractual commitments to extend credit, normally with fixed expiration dates or termination clauses, 
at specified rates and for specific purposes. Substantially all of our commitments to extend credit are contingent upon 
customers  maintaining  specific  credit  standards  at  the  time  of  loan  funding.  Standby  letters  of  credit  are  written 
conditional commitments we issued to guarantee the performance of a customer to a third party. In the event the customer 
does not perform in accordance with the terms of the agreement with the third party, we would be required to fund the 
commitment. The maximum potential amount of future payments we could be required to make is represented by the 
contractual amount of the commitment. If the commitment were funded, we would be entitled to seek recovery from 
the customer. Our policies generally require that standby letter of credit arrangements contain security and debt covenants 
similar to those contained in loan agreements.

We consider the fees collected in connection with the issuance of standby letters of credit to be representative of the 
fair value of our obligation undertaken in issuing the guarantee. In accordance with applicable accounting standards 
related to guarantees, we defer fees collected in connection with the issuance of standby letters of credit. The fees are 
then recognized in income proportionately over the life of the standby letter of credit agreement. The deferred standby 
letter of credit fees represent the fair value of our potential obligations under the standby letter of credit guarantees.

Year-end financial instruments with off-balance-sheet risk were as follows:

Commitments to extend credit
Standby letters of credit
Deferred standby letter of credit fees

$

2019
9,306,043
260,587
1,276

$

2018
8,369,721
271,575
2,069

Credit Card Guarantees. We guarantee the credit card debt of certain customers to the merchant bank that issues 
the cards. At December 31, 2019 and 2018, the guarantees totaled approximately $8.5 million and $8.1 million, of 
which amounts, $1.3 million and $1.4 million were fully collateralized.

Change in Control Agreements. We have change-in-control agreements with certain executive officers. Under these 
agreements,  each  covered  person  could  receive,  upon  the  effectiveness  of  a  change-in-control,  two  to  three  times 
(depending on the person) his or her base compensation plus the target bonus established for the year, and any unpaid 
base salary and pro rata target bonus for the year in which the termination occurs, including vacation pay. Additionally, 
the  executive’s  insurance  benefits  will  continue  for  two  to  three  full  years  after  the  termination  and  all  long-term 
incentive awards will immediately vest.

99

Litigation. We are subject to various claims and legal actions that have arisen in the course of conducting business. 
Management does not expect the ultimate disposition of these matters to have a material adverse impact on our financial 
statements.

Note 9 - Capital and Regulatory Matters

Banks and bank holding companies are subject to various regulatory capital requirements administered by state and 
federal banking agencies. Capital adequacy guidelines and, additionally for banks, prompt corrective action regulations, 
involve  quantitative  measures  of  assets,  liabilities,  and  certain  off-balance-sheet  items  calculated  under  regulatory 
accounting practices. Capital amounts and classifications are also subject to qualitative judgments by regulators about 
components, risk weighting and other factors.

The Basel III Capital Rules, a new comprehensive capital framework for U.S. banking organizations, became effective 
for Cullen/Frost and Frost Bank on January 1, 2015 (subject to a phase-in period for certain provisions). Quantitative 
measures established by the Basel III Capital Rules designed to ensure capital adequacy require the maintenance of 
minimum amounts and ratios (set forth in the table below) of Common Equity Tier 1 capital, Tier 1 capital and Total 
capital (as defined in the regulations) to risk-weighted assets (as defined), and of Tier 1 capital to adjusted quarterly 
average assets (as defined).

Cullen/Frost’s and Frost Bank’s Common Equity Tier 1 capital includes common stock and related paid-in capital, 
net of treasury stock, and retained earnings. In connection with the adoption of the Basel III Capital Rules, we elected 
to opt-out of the requirement to include most components of accumulated other comprehensive income in Common 
Equity Tier 1. Common Equity Tier 1 for both Cullen/Frost and Frost Bank is reduced by, goodwill and other intangible 
assets, net of associated deferred tax liabilities, and subject to transition provisions. Frost Bank's Common Equity Tier 1 
is also reduced by its equity investment in its financial subsidiary, Frost Insurance Agency (“FIA”). 

Tier 1 capital includes Common Equity Tier 1 capital and Additional Tier 1 capital. For Cullen/Frost, Additional 
Tier 1 capital at December 31, 2019 and 2018 included $144.5 million of 5.375% non-cumulative perpetual preferred 
stock. Frost Bank did not have any Additional Tier 1 capital beyond Common Equity Tier 1 at December 31, 2019 or 
2018.

Total capital includes Tier 1 capital and Tier 2 capital. Tier 2 capital for both Cullen/Frost and Frost Bank includes 
a  permissible  portion  of  the  allowance  for  loan  losses. Tier 2  capital  for  Cullen/Frost  also  includes  trust  preferred 
securities that were excluded from Tier 1 capital and qualified subordinated debt. At both December 31, 2019 and 2018, 
Cullen/Frost's Tier 2 capital included $133.0 million of trust preferred securities. At both December 31, 2019 and 2018, 
Tier 2 Capital for Cullen/Frost also included $100.0 million related to the permissible portion of our aggregate $100 
million of 4.50% subordinated notes. The permissible portion of qualified subordinated notes decreases 20% per year 
during the final five years of the term of the notes.

The Common Equity Tier 1, Tier 1 and Total capital ratios are calculated by dividing the respective capital amounts 
by risk-weighted assets. Risk-weighted assets are calculated based on regulatory requirements and include total assets, 
with certain exclusions, allocated by risk weight category, and certain off-balance-sheet items, among other things. The 
leverage ratio is calculated by dividing Tier 1 capital by adjusted quarterly average total assets, which exclude goodwill 
and other intangible assets, among other things.

Fully phased in on January 1, 2019, the Basel III Capital Rules require Cullen/Frost and Frost Bank to maintain 
(i) a minimum ratio of Common Equity Tier 1 capital to risk-weighted assets of at least 4.5%, plus a 2.5% “capital 
conservation buffer” (which is added to the 4.5% Common Equity Tier 1 capital ratio, effectively resulting in a minimum 
ratio of Common Equity Tier 1 capital to risk-weighted assets of at least 7.0%), (ii) a minimum ratio of Tier 1 capital 
to risk-weighted assets of at least 6.0%, plus the capital conservation buffer (which is added to the 6.0% Tier 1 capital 
ratio, effectively resulting in a minimum Tier 1 capital ratio of 8.5%), (iii) a minimum ratio of Total capital (that is, 
Tier 1 plus Tier 2) to risk-weighted assets of at least 8.0%, plus the capital conservation buffer (which is added to the 
8.0% total capital ratio, effectively resulting in a minimum total capital ratio of 10.5%) and (iv) a minimum leverage 
ratio of 4.0%, calculated as the ratio of Tier 1 capital to average quarterly assets.

The implementation of the capital conservation buffer began on January 1, 2016 at the 0.625% level and was phased 
in over a four-year period (increasing by that amount on each subsequent January 1, until it reached 2.5% on January 1, 
2019). The Basel III Capital Rules also provide for a “countercyclical capital buffer” that is applicable to only certain 
covered institutions and does not have any current applicability to Cullen/Frost or Frost Bank. The capital conservation 

100

buffer is designed to absorb losses during periods of economic stress and, as detailed above, effectively increases the 
minimum required risk-weighted capital ratios. Banking institutions with a ratio of Common Equity Tier 1 capital to 
risk-weighted assets below the effective minimum (4.5% plus the capital conservation buffer and, if applicable, the 
countercyclical capital buffer) will face constraints on dividends, equity repurchases and compensation based on the 
amount of the shortfall and the institution's “eligible retained income” (that is, four quarter trailing net income, net of 
distributions and tax effects not reflected in net income).

The following table presents actual and required capital ratios as of December 31, 2019 and December 31, 2018
for Cullen/Frost and Frost Bank under the Basel III Capital Rules. The minimum required capital amounts presented 
include the minimum required capital levels as of December 31, 2019 and December 31, 2018 based on the phase-in 
provisions of the Basel III Capital Rules and the minimum required capital levels as of January 1, 2019 when the 
Basel III Capital Rules have been fully phased-in. Capital levels required to be considered well capitalized are based 
upon prompt corrective action regulations, as amended to reflect the changes under the Basel III Capital Rules.

2019
Common Equity Tier 1 to Risk-Weighted Assets

Cullen/Frost
Frost Bank

Tier 1 Capital to Risk-Weighted Assets

Cullen/Frost
Frost Bank

Total Capital to Risk-Weighted Assets

Cullen/Frost
Frost Bank
Leverage Ratio
Cullen/Frost
Frost Bank

Actual

Minimum Capital
Required - Basel III
Fully Phased-In

Required to be
Considered Well
Capitalized

Capital
Amount

Ratio

Capital
Amount

Ratio

Capital
Amount

Ratio

$2,857,250
2,958,326

12.36% $1,617,886
1,615,206
12.82

7.00% $1,502,323
1,499,834
7.00

6.50%
6.50

3,001,736
2,958,326

12.99
12.82

1,964,576
1,961,322

8.50
8.50

1,849,013
1,845,950

8.00
8.00

3,367,403
3,090,993

14.57
13.40

2,426,829
2,422,809

10.50
10.50

2,311,266
2,307,438

10.00
10.00

3,001,736
2,958,326

9.28
9.15

1,293,188
1,292,743

4.00
4.00

1,616,485
1,615,929

5.00
5.00

Actual

Minimum Capital
Required - Basel III
Phase-In Schedule

Minimum Capital
Required - Basel III
Fully Phased-In

Required to be
Considered Well
Capitalized

Capital
Amount

Ratio

Capital
Amount

Ratio

Capital
Amount

Ratio

Capital
Amount

Ratio

$2,642,475
2,743,973

12.27% $1,372,573
1,368,701
12.78

6.375% $1,507,139
1,502,887
6.375

7.00% $1,399,486
1,395,538
7.00

6.50%
6.50

2,786,961
2,743,973

12.94
12.78

1,695,532
1,690,748

7.875
7.875

1,830,098
1,824,934

8.50
8.50

1,722,445
1,717,585

8.00
8.00

3,152,593
2,876,605

14.64
13.40

2,126,143
2,120,144

9.875
9.875

2,260,709
2,254,331

10.50
10.50

2,153,056
2,146,982

10.00
10.00

2,786,961
2,743,973

9.06
8.93

1,231,028
1,229,650

4.00
4.00

1,231,028
1,229,650

4.00
4.00

1,538,785
1,537,062

5.00
5.00

2018
Common Equity Tier 1 to
Risk-Weighted Assets

Cullen/Frost
Frost Bank

Tier 1 Capital to Risk-
Weighted Assets
Cullen/Frost
Frost Bank

Total Capital to Risk-
Weighted Assets
Cullen/Frost
Frost Bank
Leverage Ratio
Cullen/Frost
Frost Bank

Management believes that, as of December 31, 2019, Cullen/Frost and its bank subsidiary, Frost Bank, were “well 

capitalized” based on the ratios presented above.

101

Cullen/Frost and Frost Bank are subject to the regulatory capital requirements administered by the Federal Reserve 
Board and, for Frost Bank, the Federal Deposit Insurance Corporation (“FDIC”). Regulatory authorities can initiate 
certain mandatory actions if Cullen/Frost or Frost Bank fail to meet the minimum capital requirements, which could 
have a direct material effect on our financial statements. Management believes, as of December 31, 2019, that Cullen/
Frost and Frost Bank meet all capital adequacy requirements to which they are subject.

Preferred  Stock.  On  February 15,  2013,  we  issued  and  sold  6,000,000  shares,  or  $150.0  million  in  aggregate 
liquidation  preference,  of  our  5.375%  Non-Cumulative  Perpetual  Preferred  Stock,  Series A,  par  value  $0.01  and 
liquidation preference $25 per share (“Series A Preferred Stock”). Dividends on the Series A Preferred stock, if declared, 
accrue and are payable quarterly, in arrears, at a rate of 5.375%. The Series A Preferred Stock qualifies as Tier 1 capital 
for the purposes of the regulatory capital calculations. The net proceeds from the issuance and sale of the Series A 
Preferred  Stock,  after  deducting  underwriting  discount  and  commissions,  and  the  payment  of  expenses,  were 
approximately $144.5 million. The net proceeds from the offering were used to fund the repurchase of common stock.

Stock Repurchase Plans. From time to time, our board of directors has authorized stock repurchase plans. In general, 
stock repurchase plans allow us to proactively manage our capital position and return excess capital to shareholders. 
Shares purchased under such plans also provide us with shares of common stock necessary to satisfy obligations related 
to stock compensation awards. On July 24, 2019, our board of directors authorized a $100.0 million stock repurchase 
program, allowing us to repurchase shares of our common stock over a one-year period from time to time at various 
prices in the open market or through private transactions. Under this plan, we repurchased 202,724 shares at a total 
cost of $17.2 million during 2019. Under a prior stock repurchase programs, we repurchased 496,307 shares at a total 
cost of $50.0 million during 2019, 1,027,292 shares at a total cost of $100.0 million during 2018 and 1,134,966 shares 
at a total cost of $100.0 million during 2017. Under the Basel III Capital Rules, Cullen/Frost may not repurchase its 
common stock (or repurchase or redeem any of its preferred stock or subordinated notes) without the prior approval 
of the Federal Reserve Board.

Dividend Restrictions. In the ordinary course of business, Cullen/Frost is dependent upon dividends from Frost Bank 
to provide funds for the payment of dividends to shareholders and to provide for other cash requirements, including to 
repurchase its common stock. Banking regulations may limit the amount of dividends that may be paid. Approval by 
regulatory authorities is required if the effect of dividends declared would cause the regulatory capital of Frost Bank 
to fall below specified minimum levels. Approval is also required if dividends declared exceed the net profits for that 
year combined with the retained net profits for the preceding two years. Under the foregoing dividend restrictions and 
while maintaining its “well capitalized” status, at December 31, 2019, Frost Bank could pay aggregate dividends of up 
to $682.9 million to Cullen/Frost without prior regulatory approval.

Under the terms of the junior subordinated deferrable interest debentures that Cullen/Frost has issued to Cullen/
Frost Capital Trust II and WNB Capital Trust I, Cullen/Frost has the right at any time during the term of the debentures 
to defer the payment of interest at any time or from time to time for an extension period not exceeding 20 consecutive 
quarterly  periods  with  respect  to  each  extension  period.  In  the  event  that  we  have  elected  to  defer  interest  on  the 
debentures, we may not, with certain exceptions, declare or pay any dividends or distributions on our capital stock or 
purchase or acquire any of our capital stock.

Under the terms of the Series A Preferred Stock, in the event that we do not declare and pay dividends on the Series 
A Preferred Stock for the most recent dividend period, we may not, with certain exceptions, declare or pay dividends 
on, or purchase, redeem or otherwise acquire, shares of our common stock or any of our securities that rank junior to 
the Series A Preferred Stock.

Note 10 - Earnings Per Common Share

Earnings Per Common Share. Earnings per common share is computed using the two-class method. Basic earnings 
per common share is computed by dividing net earnings allocated to common stock by the weighted-average number 
of common shares outstanding during the applicable period, excluding outstanding participating securities. Participating 
securities include non-vested stock awards/stock units, deferred stock units and performance stock units (during the 
performance period), though no actual shares of common stock related to any type of stock unit have been issued. Non-
vested stock awards/stock units and deferred stock units are considered participating securities because holders of these 
securities receive non-forfeitable dividends at the same rate as holders of our common stock. Holders of performance 
stock units receive dividend equivalent payments for dividends paid during the performance period at the vesting date 
of the award based upon the number of units that ultimately vest. Diluted earnings per common share is computed 

102

using the weighted-average number of shares determined for the basic earnings per common share computation plus 
the dilutive effect of stock compensation using the treasury stock method.

The following table presents a reconciliation of net income available to common shareholders, net earnings allocated 

to common stock and the number of shares used in the calculation of basic and diluted earnings per common share.

Net Income
Less: Preferred stock dividends
Net income available to common shareholders
Less: Earnings allocated to participating securities

Net earnings allocated to common stock

Distributed earnings allocated to common stock
Undistributed earnings allocated to common stock

Net earnings allocated to common stock

2019
443,599
8,063
435,536
3,687
431,849

175,540
256,309
431,849

$

$

$

$

2018
454,918
8,063
446,855
3,169
443,686

164,268
279,418
443,686

$

$

$

$

2017
364,149
8,063
356,086
2,016
354,070

143,356
210,714
354,070

$

$

$

$

Weighted-average shares outstanding for basic earnings per

common share

Dilutive effect of stock compensation
Weighted-average shares outstanding for diluted earnings per

common share

62,741,769
700,101

63,704,508
982,208

63,693,927
968,161

63,441,870

64,686,716

64,662,088

Note 11 - Employee Benefit Plans

Retirement Plans

Profit Sharing Plans. Prior to 2019, we maintained a qualified defined contribution profit sharing plan that covered 
employees who had completed at least one year of service and were age 21 or older. The Plan was merged with and 
into our 401(k) plan effective January 1, 2019, as further discussed below. Expense related to this plan totaled $11.9 
million in 2018 and $11.6 million in 2017. 

We continue to maintain a separate non-qualified profit sharing plan for certain employees whose participation in 
the  qualified  profit  sharing  plan  was  limited.  The  plan  offers  such  employees  an  alternative  means  of  receiving 
comparable benefits. Expense related to this plan totaled $930 thousand in 2019, $568 thousand in 2018 and $1.1 
million in 2017.

Retirement Plan and Restoration Plan. We maintain a non-contributory defined benefit plan (the “Retirement Plan”) 
that was frozen as of December 31, 2001. The plan provides pension and death benefits to substantially all employees 
who were at least 21 years of age and had completed at least one year of service prior to December 31, 2001. Defined 
benefits are provided based on an employee’s final average compensation and years of service at the time the plan was 
frozen and age at retirement. The freezing of the plan provides that future salary increases will not be considered. Our 
funding policy is to contribute yearly, at least the amount necessary to satisfy the funding standards of the Employee 
Retirement Income Security Act (“ERISA”).

Our Restoration of Retirement Income Plan (the “Restoration Plan”) provides benefits for eligible employees that 
are in excess of the limits under Section 415 of the Internal Revenue Code of 1986, as amended, that apply to the 
Retirement Plan. The Restoration Plan is designed to comply with the requirements of ERISA. The entire cost of the 
plan, which was also frozen as of December 31, 2001, is supported by our contributions.

103

We use a December 31 measurement date for our defined benefit plans. Combined activity in our defined benefit 

pension plans was as follows:

2019

2018

2017

Change in plan assets:

Fair value of plan assets at beginning of year
Actual return on plan assets
Employer contributions
Benefits paid

Fair value of plan assets at end of year

Change in benefit obligation:

Benefit obligation at beginning of year
Interest cost
Actuarial (gain) loss
Benefits paid

Benefit obligation at end of year

$

$

152,820
29,945
1,163
(9,755)
174,173

167,107
6,472
22,817
(9,755)
186,641

$

168,450
(7,739)
1,077
(8,968)
152,820

182,607
5,898
(12,430)
(8,968)
167,107

Funded status of the plan at end of year and accrued benefit

(liability) recognized

Accumulated benefit obligation at end of year

$
$

(12,468) $
$
186,641

(14,287) $
$
167,107

157,214
23,518
1,049
(13,331)
168,450

176,751
6,189
12,998
(13,331)
182,607

(14,157)
182,607

Certain disaggregated information related to our defined benefit pension plans as of year-end was as follows:

Projected benefit obligation
Accumulated benefit obligation
Fair value of plan assets
Funded status of the plan at end of year and
accrued benefit (liability) recognized

Retirement Plan

$

2019
170,541
170,541
174,173

$

2018
152,035
152,035
152,820

$

Restoration Plan

2019

2018

$

16,100
16,100
—

15,072
15,072
—

3,632

785

(16,100)

(15,072)

The components of the combined net periodic cost (benefit) for our defined benefit pension plans are presented in 

the table below. 

Expected return on plan assets, net of expenses
Interest cost on projected benefit obligation
Net amortization and deferral

Net periodic expense (benefit)

2019

2018

2017

$

$

(10,772) $
6,472
5,623
1,323

$

(11,916) $
5,898
5,002
(1,016) $

(11,117)
6,189
5,429
501

Amounts related to our defined benefit pension plans recognized as a component of other comprehensive income 

were as follows:

Net actuarial gain (loss)
Deferred tax (expense) benefit

Other comprehensive income (loss), net of tax

2019

2018

2017

$

$

1,979
(416)
1,563

$

$

(2,223) $
466
(1,757) $

4,832
(1,774)
3,058

Amounts recognized as a component of accumulated other comprehensive loss as of year-end that have not been 
recognized as a component of the combined net period benefit cost of our defined benefit pension plans are presented 
in the following table. We expect to recognize approximately $5.3 million of the net actuarial loss reported in the 
following table as of December 31, 2019 as a component of net periodic benefit cost during 2020.

Net actuarial loss
Deferred tax benefit
Amounts included in accumulated other comprehensive income/loss, net of tax

$

(57,964) $
12,210
(45,934)

(60,123)
12,626
(47,497)

2019

2018

104

The weighted-average assumptions used to determine the benefit obligations as of the end of the years indicated 
and the net periodic benefit cost for the years indicated are presented in the table below. Because the plans were frozen, 
increases in compensation are not considered after 2001.

Benefit obligations:

Discount rate

Net periodic benefit cost:

Discount rate
Expected return on plan assets

2019

2018

2017

3.20%

4.36%
7.25

4.36%

3.68%
7.25

3.68%

4.24%
7.25

Management uses an asset allocation optimization model to analyze the potential risks and rewards associated with 
various asset allocation strategies on a quarterly basis. As of December 31, 2019, management’s investment objective 
for our defined benefit plans is to achieve long-term growth. This strategy provides for a target asset allocation of 
approximately 64% invested in equity securities, approximately 32% invested in fixed income debt securities with any 
remainder invested in cash or short-term cash equivalents. The asset allocation optimization process provides portfolio 
allocations which best represent the potential risk associated with a given asset allocation over a full market cycle. This 
is used to help management determine an appropriate mix of assets in order to achieve the plan's long term investment 
goals. The plan assets are reviewed annually to determine if the obligations can be met with the current investment mix 
and funding strategy.

The major categories of assets in our Retirement Plan as of year-end are presented in the following table. Assets are 
segregated by the level of the valuation inputs within the fair value hierarchy established by ASC Topic 820 “Fair Value 
Measurements  and  Disclosures,”  utilized  to  measure  fair  value  (see  Note 17 - Fair  Value  Measurements).  Our 
Restoration Plan is unfunded.

Level 1:

Mutual funds
Cash and cash equivalents

Total fair value of plan assets

2019

2018

$

$

172,773
1,400
174,173

$

$

152,477
343
152,820

Mutual  funds  include  various  equity,  fixed-income  and  blended  funds  with  varying  investment  strategies. 
Approximately 68% of mutual fund investments consist of equity investments as of December 31, 2019. The investment 
objective of equity funds is long-term capital appreciation with current income. The remaining mutual fund investments 
consist of U.S. fixed-income securities, including investment-grade U.S. Treasury securities, U.S. government agency 
securities and mortgage-backed securities, corporate bonds and notes and collateralized mortgage obligations. The 
investment objective of fixed-income funds is to maximize investment return while preserving investment principal. 
U.S. government agency securities include obligations of Ginnie Mae. Our investment strategies prohibit selling assets 
short and the use of derivatives. Additionally, our defined benefit plans do not directly invest in real estate, commodities, 
or private investments.

The asset allocation optimization model is used to estimate the expected long-term rate of return for a given asset 
allocation strategy. Expectations of returns for each asset class are based on comprehensive reviews of historical data 
and economic/financial market theory. During periods with volatile interest rates and equity security prices, the model 
may call for changes in the allocation of plan investments to achieve desired returns. Management assumed a long-
term rate of return of 7.25% in the determination of the net periodic benefit cost for 2019. The expected long-term rate 
of return on assets was selected from within the reasonable range of rates determined by historical real returns, net of 
inflation, for the asset classes covered by the plan’s investment policy and projections of inflation over the long-term 
period during which benefits are payable to plan participants.

105

As of December 31, 2019, expected future benefit payments related to our defined benefit plans were as follows:

2020
2021
2022
2023
2024
2025 through 2029

$

$

10,662
10,968
11,177
11,423
11,578
57,122
112,930

We expect to contribute $1.2 million to the defined benefit plans during 2020.

Savings Plans

401(k) Plan and Thrift Incentive Plan. We maintain a 401(k) stock purchase plan that permits each participant to 
make before-tax contributions in an amount not less than 2% and not exceeding 50% of eligible compensation and 
subject to dollar limits from Internal Revenue Service regulations. We match 100% of the employee’s contributions to 
the plan based on the amount of each participant’s contributions up to a maximum of 6% of eligible compensation. 
Eligible  employees  must  complete  30  days  of  service  in  order  to  enroll  and  vest  in  our  matching  contributions 
immediately.  Our  matching  contribution  is  initially  invested  in  the  Cullen/Frost  common  stock  fund.  However, 
employees may immediately reallocate our matching portion, as well as invest their individual contribution, to any of 
a variety of investment alternatives offered under the 401(k) Plan. In 2019, we merged our qualified profit sharing plan 
with and into the 401(k) plan. All profit contributions to the plan are made at our discretion and may be made without 
regard to current or accumulated profits. Contributions are allocated to eligible participants uniformly, based upon 
compensation, age and other factors. Plan participants self-direct the investment of allocated contributions by choosing 
from a menu of investment options. Profit sharing contributions are subject to withdrawal restrictions and participants 
vest in their allocated contributions after three years of service. Expense related to the plan totaled $28.9 million ($16.3 
million matching contributions and $12.6 million profit sharing) in 2019, $15.0 million in 2018, and $14.3 million in 
2017.

We maintain a thrift incentive stock purchase plan to offer certain employees whose participation in the 401(k) plan 
is limited an alternative means of receiving comparable benefits. Expense related to this plan was not significant during 
2019, 2018 and 2017.

Stock Compensation Plans

We have three active stock compensation plans (the 2005 Omnibus Incentive Plan, the 2007 Outside Directors 
Incentive Plan and the 2015 Omnibus Incentive Plan). All of the plans have been approved by our shareholders. During 
2015, the 2015 Omnibus Incentive Plan (“2015 Plan”) was established to replace both the 2005 Omnibus Incentive 
Plan (“2005 Plan”) and the 2007 Outside Directors Incentive Plan (the “2007 Directors Plan”). All remaining shares 
authorized for grant under the superseded 2005 Plan and 2007 Directors Plan were transferred to the 2015 Plan. Our 
stock  compensation  plans  were  established  to  (i) motivate  superior  performance  by  means  of  performance-related 
incentives, (ii) encourage and provide for the acquisition of an ownership interest in our company by employees and 
non-employee directors and (iii) enable us to attract and retain qualified and competent persons as employees and to 
serve as members of our board of directors.

Under the 2015 Plan, we may grant, among other things, nonqualified stock options, incentive stock options, stock 
awards, stock appreciation rights, restricted stock units, performance share units or any combination thereof to certain 
employees and non-employee directors. Any of the authorized shares may be used for any type of award allowable 
under the Plan. The Compensation and Benefits Committee (“Committee”) of our Board of Directors has sole authority 
to (i) establish the awards to be issued, (ii) select the employees and non-employee directors to receive awards, and 
(iii) approve the terms and conditions of each award contract. Each award under the stock plans is evidenced by an 
award agreement that specifies the award price, the duration of the award, the number of shares to which the award 
pertains, and such other provisions as the Committee determines. For stock options, the option price for each grant is 
at least equal to the fair market value of a share of Cullen/Frost’s common stock on the date of grant. Options granted 
expire at such time as the Committee determines at the date of grant and in no event does the exercise period exceed 
a maximum of ten years. As defined in the plans, outstanding awards may immediately vest upon a change-in-control 

106

of Cullen/Frost and, in the case of awards granted under the 2015 Plan, subsequent termination resulting from the 
change in control.

A  combined  summary  of  activity  in  our  active  stock  plans  is  presented  in  the  table.  Performance  stock  units 
outstanding are presented assuming attainment of the maximum payout rate as set forth by the performance criteria. 
The target award level for performance stock units granted in 2019, 2018 and 2017 was 34,317, 30,466 and 24,162, 
respectively. As of December 31, 2019, there were 1,105,616 shares remaining available for grant for future awards.

Director Deferred
Stock Units
Outstanding

Non-Vested Stock
Awards/Stock Units
Outstanding

Performance Stock
Units Outstanding

Stock Options
Outstanding

January 1, 2017
Authorized
Granted
Exercised/vested
Forfeited/expired
December 31, 2017

Authorized
Granted
Exercised/vested
Forfeited/expired
December 31, 2018

Authorized
Granted
Exercised/vested
Forfeited/expired
December 31, 2019

Number
of Units
53,659
—
5,447
(6,098)
—
53,008
—
6,576
(10,674)
—
48,910
—
7,592
(1,132)
—
55,370

Weighted-
Average
Fair Value
at Grant
61.48
$
—
95.37
62.29
—
64.87
—
109.58
63.68
—
71.14
—
102.70
106.03

Number
of 
Shares/
Units
256,850
—
99,833
(39,740)
(4,287)
312,656
—
109,847
(32,050)
(6,656)
383,797
—
127,091
(53,990)
— (16,251)
440,647

74.76

$

Weighted-
Average
Fair Value
at Grant
73.43
$
—
98.90
71.59
79.52
81.71
—
94.81
78.92
87.60
85.59
—
93.46
65.11
89.71
90.22

$

Number
of Units
43,860
—
36,246
—
—
80,106
—
45,703
—
—
125,809
—
51,479
—
—
177,288

Weighted-
Average
Fair Value
at Grant
69.70
$
—
92.27

Number
of Shares
4,089,028
—
—
— (1,118,122)
(53,764)
—
2,917,142
79.91
—
—
87.18
—
(513,134)
—
—
(52,000)
2,352,008
82.55
—
—
—
85.74
(359,892)
—
—
(11,250)
1,980,866
83.48

$

Weighted-
Average
Exercise
Price

$

$

62.67
—
—
60.59
69.78
63.34
—
—
61.68
70.42
63.55
—
—
57.71
65.11
64.60

Options awarded to employees generally have a ten-year life and vest in equal annual installments over a four-year 
period. Non-vested stock awards/stock units awarded to employees generally have a four-year-cliff vesting period. 
Deferred stock units awarded to non-employee directors generally have immediate vesting. Upon retirement from our 
board of directors, non-employee directors will receive one share of our common stock for each deferred stock unit 
held.  Outstanding  non-vested  stock  units  and  deferred  stock  units  receive  equivalent  dividend  payments  as  such 
dividends are declared on our common stock.

Performance stock units represent shares potentially issuable in the future. Issuance is based upon the measure of 
our achievement of relative return on assets over a three-year performance period compared to an identified peer group's 
achievement of relative return on assets over the same three-year performance period. The ultimate number of shares 
issuable under each performance award is the product of the award target and the award payout percentage for the given 
level of achievement. The level of achievement is measured as the percentile rank of relative return on assets among 
the peer group. The award payout percentages by level of achievement are as follows: (i) less than 25th percentile pays 
out at 0% of target, (ii) 25th percentile pays out at 50% of target, (iii) 50th percentile pays out at 100% of target and 
(iv) 75th percentile or more pays out at 150% of target. Achievement between the aforementioned percentiles will result 
in an award payout percentage determined based on straight-line interpolation between the percentiles. Performance 
stock units are eligible to receive equivalent dividend payments as such dividends are declared on our common stock 
during the performance period. Equivalent dividend payments are based upon the ultimate number of shares issued 
under each performance award and are deferred until such time that the units vest and shares are issued.

107

Other information regarding options outstanding and exercisable as of December 31, 2019 is as follows:

$

45.01
50.01
65.01
70.01
75.01

Range of
Exercise Prices
to
$
to
to
to
to
Total
Total intrinsic value

50.00
55.00
70.00
75.00
80.00

Options Outstanding

Options Exercisable

Weighted-
Average
Exercise Price
48.00
$
53.75
65.11
71.39
78.95
64.60

Number
of Shares

238,055
464,009
526,096
275,654
477,052
1,980,866
65,725

$

Weighted-
Average
Remaining
Contractual 
Life
in Years

1.82
2.04
5.67
3.80
4.71
3.87

Weighted-
Average
Exercise
Price

48.00
53.75
65.11
71.39
78.95
64.60

$

Number
of Shares

238,055
464,009
526,096
275,654
477,052
1,980,866
65,725

$

Shares issued in connection with stock compensation awards are issued from available treasury shares. If no treasury 
shares are available, new shares are issued from available authorized shares. Shares issued in connection with stock 
compensation awards along with other related information were as follows:

New shares issued from available authorized shares
Issued from available treasury stock

Total

Proceeds from stock option exercises
Intrinsic value of stock options exercised
Fair value of stock awards/units vested

2019

2018

—
399,224
399,224
20,770
13,713
5,192

$

—
548,238
548,238
31,647
23,292
4,212

$

2017
603,842
547,078
1,150,920
67,746
38,275
4,578

$

Stock-based Compensation Expense. Stock-based compensation expense is recognized ratably over the requisite 
service period for all awards. For most stock option awards, the service period generally matches the vesting period. 
For stock options granted to certain executive officers and for non-vested stock units granted to all participants, the 
service period does not extend past the date the participant reaches 65 years of age. Deferred stock units granted to 
non-employee directors generally have immediate vesting and the related expense is fully recognized on the date of 
grant. For performance stock units, the service period generally matches the three-year performance period specified 
by the award, however, the service period does not extend past the date the participant reaches 65 years of age. Expense 
recognized each period is dependent upon our estimate of the number of shares that will ultimately be issued. 

Stock-based compensation expense and the related income tax benefit is presented in the following table. The service 

period for performance stock units granted each year begins on January 1 of the following year.

Stock options
Non-vested stock awards/stock units
Deferred stock-units
Performance stock units

Total

Income tax benefit

2019

2018

2017

1,185
9,339
780
4,642
15,946
2,359

$

$
$

3,652
6,983
721
2,587
13,943
2,831

$

$
$

6,230
4,992
519
1,272
13,013
4,555

$

$
$

108

Unrecognized  stock-based  compensation  expense  and  the  weighted-average  period  over  which  the  expense  is 
expected  to  be  recognized  at  December 31,  2019  is  presented  in  the  table  below.  Unrecognized  stock-based 
compensation expense related to performance stock units is presented assuming attainment of the maximum payout 
rate as set forth by the performance criteria.

Non-vested stock awards/stock units
Performance stock units

Total

Weighted-
Average Number
of Years for
Expense
Recognition

2.81
2.11

Unrecognized
Expense

$

$

18,882
6,299
25,181

Valuation of Stock-Based Compensation. For the purposes of recognizing stock-based compensation expense, the 
fair value of non-vested stock awards/stock units and deferred stock units is generally the market price of the stock on 
the measurement date, which, for us, is the date of the award. The fair value of performance stock units is determined 
in a similar manner except that the market price of the stock on the measurement date is discounted by the present value 
of the dividends expected to be paid on our common stock during the service period of the award because dividend 
equivalent payments on performance stock units are deferred until such time that the units vest and shares are issued. 
In applying this discount to the market price of our stock on the measurement date, we assumed we would pay a flat 
quarterly dividend during the service period equal to our most recent dividend payment, which was $0.71, $0.67 and 
$0.57 in 2019, 2018, and 2017 respectively discounted at a weighted-average risk-free rate of 1.65%, 2.95% and 1.73%
in 2019, 2018, and 2017 respectively. 

The fair value of employee stock options granted is estimated on the measurement date, which, for us, is the date 
of grant. The fair value of stock options is estimated using a binomial lattice-based valuation model that takes into 
account employee exercise patterns based on changes in our stock price and other variables, and allows for the use of 
dynamic assumptions about interest rates and expected volatility. No stock options have been granted since 2015. 

Note 12 - Other Non-Interest Income and Expense

Other non-interest income and expense totals are presented in the following tables. Components of these totals 
exceeding 1% of the aggregate of total net interest income and total non-interest income for any of the years presented 
are stated separately.

Other non-interest income:

Other

Total

Other non-interest expense:

Professional services
Advertising, promotions and public relations
Travel/meals and entertainment
Check card expense
Other

Total

2019

2018

2017

$
$

$

$

43,563
43,563

39,238
38,001
16,459
5,947
81,020
180,665

$
$

$

$

46,790
46,790

35,941
32,514
15,030
4,744
85,309
173,538

$
$

$

$

37,222
37,222

27,968
29,337
15,066
16,501
86,417
175,289

As discussed in Note 1 - Summary of Significant Accounting Policies, a new accounting standard adopted in 2018 
requires us to report network costs associated with debit card and ATM transactions netted against the related fee income 
from such transactions. Previously, such network costs were reported as a component of check card expense and included 
in other non-interest expense. In 2019 and 2018, network costs totaling $12.9 million and $11.9 million are reported 
as a component of interchange and debit card transaction fees in the accompanying Consolidated Statement of Income 
rather than as a component of check card expense in the table above. For 2017, network costs totaling $11.9 million
were reported as a component of check card expense in the table above.

In the ordinary course of business, we transact with certain directors and/or their affiliates. Payments for services 

provided totaled $567 thousand in 2019, $568 thousand in 2018 and $833 thousand in 2017.

109

Note 13 - Income Taxes

Tax Cuts and Jobs Act. The Tax Cuts and Jobs Act was enacted on December 22, 2017. Among other things, the 
new law (i) established a new, flat corporate federal statutory income tax rate of 21%, (ii) eliminated the corporate 
alternative minimum tax and allowed the use of any such carryforwards to offset regular tax liability for any taxable 
year,  (iii) limited  the  deduction  for  net  interest  expense  incurred  by  U.S.  corporations,  (iv) allowed  businesses  to 
immediately expense, for tax purposes, the cost of new investments in certain qualified depreciable assets, (v) eliminated 
or reduced certain deductions related to meals and entertainment expenses, (vi) modified the limitation on excessive 
employee remuneration to eliminate the exception for performance-based compensation and clarified the definition of 
a covered employee and (vii) limited the deductibility of deposit insurance premiums. The Tax Cuts and Jobs Act also 
significantly changes U.S. tax law related to foreign operations, however, such changes do not currently impact us.

Income Taxes. Income tax expense was as follows:

Current income tax expense
Deferred income tax expense (benefit)
Income tax expense, as reported

2019
48,256
7,614
55,870

$

$

2018

840
52,923
53,763

$

$

2017
58,707
(14,493)
44,214

$

$

Effective tax rate

11.2%

10.6%

10.8%

A reconciliation between reported income tax expense and the amounts computed by applying the U.S. federal 
statutory income tax rate of 21% in 2019 and 2018 and 35% in 2017 to income before income taxes is presented in the 
following table. 

Income tax expense computed at the statutory rate
Effect of tax-exempt interest
Tax benefit on dividends paid in our 401k plan
Bank owned life insurance income
Non-deductible compensation
Non-deductible FDIC premiums
Non-deductible meals and entertainment
Net tax benefit from stock-based compensation
Deferred tax adjustment related to reduction in U.S. federal
statutory income tax rate
Correction for prior year tax-exempt interest
Other
Income tax expense, as reported

$

2019
104,888
(49,166)
(1,743)
(774)
1,708
1,267
1,299
(2,447)

$

2018
106,823
(49,700)
(1,551)
(710)
210
1,771
1,193
(3,865)

—
—
838
55,870

$

(231)
—
(177)
53,763

$

2017
142,927
(81,034)
(2,372)
(1,116)
158
—
983
(9,062)

(4,047)
(2,906)
683
44,214

$

$

Income tax expense for 2017 was impacted by the adjustment of our deferred tax assets and liabilities related to the 
reduction in the U.S. federal statutory income tax rate to 21% under the Tax Cuts and Jobs Act. As a result of the new 
law, and as detailed in the table above, we recognized a provisional net tax benefit totaling $4.0 million in 2017 and 
an additional net tax benefit resulting from a finalization of those calculations totaling $231 thousand in 2018. Income 
tax expense for 2017 was also impacted by the correction of an over-accrual of taxes that resulted from incorrectly 
classifying certain tax-exempt loans as taxable for federal income tax purposes since 2013. As a result, we recognized 
tax benefits of $2.9 million in 2017 related to the 2013 through 2016 tax years, as detailed in the table above. There 
were no unrecognized tax benefits during any of the reported periods. Interest and/or penalties related to income taxes 
are reported as a component of income tax expense. Such amounts were not significant during the reported periods. 

110

Year-end deferred taxes are presented in the table below. Deferred taxes are based on the U.S. statutory federal 

income tax rate of 21%. 

Deferred tax assets:

Lease liabilities under operating leases
Allowance for loan losses
Net actuarial loss on defined benefit post-retirement benefit plans
Stock-based compensation
Bonus accrual
Net unrealized loss on securities available for sale and transferred securities
Deferred loan and lease origination fees
Other

Total gross deferred tax assets

Deferred tax liabilities:

Net unrealized gain on securities available for sale and transferred securities
Right-of-use assets under operating leases
Premises and equipment
Intangible assets
Defined benefit post-retirement benefit plans
Partnership interests
Leases
Other

Total gross deferred tax liabilities
Net deferred tax asset (liability)

2019

2018

$

$

$

67,975
27,755
12,210
11,211
5,055
—
2,254
2,163
128,623

(83,281)
(63,463)
(29,730)
(12,642)
(9,419)
(2,894)
(1,572)
(1,440)
(204,441)
(75,818) $

—
27,748
12,626
10,622
4,586
4,283
2,153
4,761
66,779

—
—
(23,859)
(10,726)
(9,452)
—
(1,709)
(1,257)
(47,003)
19,776

No valuation allowance for deferred tax assets was recorded at December 31, 2019 and 2018 as management believes 
it is more likely than not that all of the deferred tax assets will be realized against deferred tax liabilities and projected 
future taxable income. There were no unrecognized tax benefits during any of the reported periods.

We file income tax returns in the U.S. federal jurisdiction. We are no longer subject to U.S. federal income tax 

examinations by tax authorities for years before 2016.

111

Note 14 - Other Comprehensive Income (Loss)

The tax effects allocated to each component of other comprehensive income (loss) were as follows:

Before Tax
Amount

Tax Expense,
(Benefit)

Net of Tax
Amount

$

$ 418,556
(1,292)
(293)
416,971

87,897
(271)
(62)
87,564

$ 330,659
(1,021)
(231)
329,407

(3,644)

(765)

(2,879)

5,623
1,979
$ 418,950

$

1,181
416
87,980

4,442
1,563
$ 330,970

$ (182,340) $ (38,292) $ (144,048)
(6,965)
123
(150,890)

(8,818)
156
(191,002)

(1,853)
33
(40,112)

(7,225)

(1,517)

(5,708)

5,002
(2,223)

3,951
(1,757)
$ (193,225) $ (40,578) $ (152,647)

1,051
(466)

$

$ 157,016
(16,193)
4,941
145,764

48,626
(5,668)
1,729
44,687

$ 108,390
(10,525)
3,212
101,077

(597)

(126)

(471)

5,429
4,832
$ 150,596

$

1,900
1,774
46,461

3,529
3,058
$ 104,135

2019
Securities available for sale and transferred securities:
Change in net unrealized gain/loss during the period
Change in net unrealized gain on securities transferred to held to maturity
Reclassification adjustment for net (gains) losses included in net income

Total securities available for sale and transferred securities

Defined-benefit post-retirement benefit plans:

Change in the net actuarial gain/loss
Reclassification adjustment for net amortization of actuarial gain/loss
included in net income as a component of net periodic cost (benefit)
Total defined-benefit post-retirement benefit plans

Total other comprehensive income (loss)

2018
Securities available for sale and transferred securities:
Change in net unrealized gain/loss during the period
Change in net unrealized gain on securities transferred to held to maturity
Reclassification adjustment for net (gains) losses included in net income

Total securities available for sale and transferred securities

Defined-benefit post-retirement benefit plans:

Change in the net actuarial gain/loss
Reclassification adjustment for net amortization of actuarial gain/loss
included in net income as a component of net periodic cost (benefit)
Total defined-benefit post-retirement benefit plans

Total other comprehensive income (loss)

2017
Securities available for sale and transferred securities:
Change in net unrealized gain/loss during the period
Change in net unrealized gain on securities transferred to held to maturity
Reclassification adjustment for net (gains) losses included in net income

Total securities available for sale and transferred securities

Defined-benefit post-retirement benefit plans:

Change in the net actuarial gain/loss
Reclassification adjustment for net amortization of actuarial gain/loss
included in net income as a component of net periodic cost (benefit)
Total defined-benefit post-retirement benefit plans

Total other comprehensive income (loss)

112

Activity in accumulated other comprehensive income, net of tax, was as follows:

Balance January 1, 2019

Other comprehensive income (loss) before reclassification
Reclassification of amounts included in net income
Net other comprehensive income (loss) during period

Balance December 31, 2019

Balance January 1, 2018

Other comprehensive income (loss) before reclassification
Reclassification of amounts included in net income
Net other comprehensive income (loss) during period
Reclassification of certain income tax effects related to the change in
the U.S. statutory federal income tax rate under the Tax Cuts and
Jobs Act to retained earnings

Balance December 31, 2018

Balance January 1, 2017

Other comprehensive income (loss) before reclassification
Reclassification of amounts included in net income
Net other comprehensive income (loss) during period

Balance December 31, 2017

Note 15 - Derivative Financial Instruments

$

$

$

$

$

$

Securities
Available
For Sale

(16,103) $
329,638
(231)
329,407
313,304

$

Defined
Benefit
Plans
(47,497) $
(2,879)
4,442
1,563
(45,934) $

Accumulated
Other
Comprehensive
Income

(63,600)
326,759
4,211
330,970
267,370

$

117,230
(151,013)
123
(150,890)

(37,718) $
(5,708)
3,951
(1,757)

79,512
(156,721)
4,074
(152,647)

17,557
(16,103) $

(8,022)
(47,497) $

9,535
(63,600)

16,153
97,865
3,212
101,077
117,230

$

$

(40,776) $
(471)
3,529
3,058
(37,718) $

(24,623)
97,394
6,741
104,135
79,512

The fair value of derivative positions outstanding is included in accrued interest receivable and other assets and 
accrued interest payable and other liabilities in the accompanying consolidated balance sheets and in the net change in 
each of these financial statement line items in the accompanying consolidated statements of cash flows.

Interest Rate Derivatives. We utilize interest rate swaps, caps and floors to mitigate exposure to interest rate risk 
and to facilitate the needs of our customers. Our objectives for utilizing these derivative instruments are described 
below:

We have entered into certain interest rate swap contracts that are matched to specific fixed-rate commercial loans 
or leases that we have entered into with our customers. These contracts have been designated as hedging instruments 
to hedge the risk of changes in the fair value of the underlying commercial loan/lease due to changes in interest rates. 
The related contracts are structured so that the notional amounts reduce over time to generally match the expected 
amortization of the underlying loan/lease.

We have entered into certain interest rate swap, cap and floor contracts that are not designated as hedging instruments. 
These derivative contracts relate to transactions in which we enter into an interest rate swap, cap and/or floor with a 
customer while at the same time entering into an offsetting interest rate swap, cap and/or floor with a third-party financial 
institution. In connection with each swap transaction, we agree to pay interest to the customer on a notional amount at 
a variable interest rate and receive interest from the customer on a similar notional amount at a fixed interest rate. At 
the same time, we agree to pay a third-party financial institution the same fixed interest rate on the same notional amount 
and  receive  the  same  variable  interest  rate  on  the  same  notional  amount. The  transaction  allows  our  customer  to 
effectively convert a variable rate loan to a fixed rate. Because we act as an intermediary for our customer, changes in 
the fair value of the underlying derivative contracts for the most part offset each other and do not significantly impact 
our results of operations.

113

The notional amounts and estimated fair values of interest rate derivative contracts outstanding at December 31, 
2019 and 2018 are presented in the following table. The fair values of interest rate derivative contracts are estimated 
utilizing internal valuation models with observable market data inputs, or as determined by the Chicago Mercantile 
Exchange (“CME”) for centrally cleared derivative contracts. CME rules legally characterize variation margin payments 
for centrally cleared derivatives as settlements of the derivatives' exposure rather than collateral. As a result, the variation 
margin  payment  and  the  related  derivative  instruments  are  considered  a  single  unit  of  account  for  accounting  and 
financial  reporting  purposes. Variation  margin,  as  determined  by  the  CME,  is  settled  daily. As  a  result,  derivative 
contracts that clear through the CME have an estimated fair value of zero as of December 31, 2019 and 2018. 

December 31, 2019

December 31, 2018

Notional
Amount

Estimated
Fair Value

Notional
Amount

Estimated
Fair Value

Derivatives designated as hedges of fair value:

Financial institution counterparties:

Loan/lease interest rate swaps - assets
Loan/lease interest rate swaps - liabilities

$

$

2,545
6,000

$

6
(138)

$

10,941
3,885

207
(199)

Non-hedging interest rate derivatives:
Financial institution counterparties:

Loan/lease interest rate swaps - assets
Loan/lease interest rate swaps - liabilities
Loan/lease interest rate caps - assets

Customer counterparties:

Loan/lease interest rate swaps - assets
Loan/lease interest rate swaps - liabilities
Loan/lease interest rate caps - liabilities

122,788
1,002,860
107,835

1,002,860
122,788
107,835

67
(19,483)
266

43,857
(310)
(266)

496,887
691,143
122,791

691,143
496,887
122,791

2,384
(8,921)
509

16,706
(8,891)
(509)

The weighted-average rates paid and received for interest rate swaps outstanding at December 31, 2019 were as 

follows:

Interest rate swaps:

Fair value hedge loan/lease interest rate swaps
Non-hedging interest rate swaps - financial institution counterparties
Non-hedging interest rate swaps - customer counterparties

Weighted-Average

Interest
Rate
Paid

Interest
Rate
Received

2.66%
4.12
3.45

1.75%
3.45
4.12

The weighted-average strike rate for outstanding interest rate caps was 3.14% at December 31, 2019.

114

 
 
 
 
Commodity Derivatives. We enter into commodity swaps and option contracts that are not designated as hedging 
instruments primarily to accommodate the business needs of our customers. Upon the origination of a commodity swap 
or option contract with a customer, we simultaneously enter into an offsetting contract with a third party financial 
institution to mitigate the exposure to fluctuations in commodity prices.

The notional amounts and estimated fair values of non-hedging commodity swap and option derivative positions 
outstanding are presented in the following table. We obtain dealer quotations and use internal valuation models with 
observable market data inputs to value our commodity derivative positions.

December 31, 2019

December 31, 2018

Notional
Units

Notional
Amount

Estimated
Fair Value

Notional
Amount

Estimated
Fair Value

Financial institution counterparties:

Oil - assets
Oil - liabilities
Natural gas - assets
Natural gas - liabilities
Customer counterparties:

Oil - assets
Oil - liabilities
Natural gas - assets
Natural gas - liabilities

Barrels
Barrels
MMBTUs
MMBTUs

Barrels
Barrels
MMBTUs
MMBTUs

$

1,214
2,148
8,295
2,689

2,172
1,190
2,689
8,295

2,796
(6,916)
2,131
(70)

7,208
(2,652)
83
(2,039)

$

2,416
415
5,745
9,314

415
2,416
10,236
4,823

24,332
(646)
417
(1,272)

646
(24,009)
1,373
(393)

Foreign Currency Derivatives. We enter into foreign currency forward contracts that are not designated as hedging 
instruments primarily to accommodate the business needs of our customers. Upon the origination of a foreign currency 
denominated transaction with a customer, we simultaneously enter into an offsetting contract with a third party financial 
institution to negate the exposure to fluctuations in foreign currency exchange rates. We also utilize foreign currency 
forward contracts that are not designated as hedging instruments to mitigate the economic effect of fluctuations in 
foreign currency exchange rates on foreign currency holdings and certain short-term, non-U.S. dollar denominated 
loans. The notional amounts and fair values of open foreign currency forward contracts were as follows:

December 31, 2019

December 31, 2018

Notional
Currency

Notional
Amount

Estimated
Fair Value

Notional
Amount

Estimated
Fair Value

Financial institution counterparties:

Forward contracts - liabilities
Forward contracts - liabilities
Forward contracts - liabilities

Customer counterparties:

Forward contracts - assets
Forward contracts - assets
Forward contracts - assets

CAD
GBP
MXN

CAD
GBP
MXN

$

4,593
—
—

4,583
—
—

(33)
—
—

45
—
—

$

11,003
142
3,015

10,979
145
3,000

(13)
(2)
(132)

40
4
149

115

Gains, Losses and Derivative Cash Flows. For fair value hedges, the changes in the fair value of both the derivative 
hedging instrument and the hedged item are included in other non-interest income or other non-interest expense. The 
extent that such changes in fair value do not offset represents hedge ineffectiveness. Net cash flows from interest rate 
swaps on commercial loans/leases designated as hedging instruments in effective hedges of fair value are included in 
interest income on loans. For non-hedging derivative instruments, gains and losses due to changes in fair value and all 
cash flows are included in other non-interest income and other non-interest expense.

Amounts included in the consolidated statements of income related to interest rate derivatives designated as hedges 

of fair value were as follows:

Commercial loan/lease interest rate swaps:

Amount of gain (loss) included in interest income on loans
Amount of (gain) loss included in other non-interest expense

$

$

86
—

$

25
(1)

(726)
(14)

2019

2018

2017

As stated above, we enter into non-hedge related derivative positions primarily to accommodate the business needs 
of  our  customers.  Upon  the  origination  of  a  derivative  contract  with  a  customer,  we  simultaneously  enter  into  an 
offsetting derivative contract with a third party financial institution. We recognize immediate income based upon the 
difference in the bid/ask spread of the underlying transactions with our customers and the third party. Because we act 
only as an intermediary for our customer, subsequent changes in the fair value of the underlying derivative contracts 
for the most part offset each other and do not significantly impact our results of operations.

Amounts included in the consolidated statements of income related to non-hedging interest rate, commodity, foreign 

currency and other derivative instruments are presented in the table below.

Non-hedging interest rate derivatives:

Other non-interest income
Other non-interest expense

Non-hedging commodity derivatives:

Other non-interest income

Non-hedging foreign currency derivatives:

Other non-interest income
Non-hedging other derivatives:
Other non-interest income

2019

2018

2017

$

$

2,005
(1)

$

4,112
—

3,123
1

503

51

750

795

246

—

440

300

—

Counterparty Credit Risk. Derivative contracts involve the risk of dealing with both bank customers and institutional 
derivative counterparties and their ability to meet contractual terms. Institutional counterparties must have an investment 
grade credit rating and be approved by our Asset/Liability Management Committee. Our credit exposure on interest 
rate swaps is limited to the net favorable value and interest payments of all swaps by each counterparty, while our credit 
exposure on commodity swaps/options and foreign currency forward contracts is limited to the net favorable value of 
all  contracts  by  each  counterparty.  Credit  exposure  may  be  reduced  by  the  amount  of  collateral  pledged  by  the 
counterparty. There are no credit-risk-related contingent features associated with any of our derivative contracts. Certain 
derivative contracts with upstream financial institution counterparties may be terminated with respect to a party in the 
transaction, if such party does not have at least a minimum level rating assigned to either its senior unsecured long-
term debt or its deposit obligations by certain third-party rating agencies.

Our credit exposure relating to interest rate swaps, commodity swaps/options and foreign currency forward contracts 
with bank customers was approximately $47.1 million at December 31, 2019. This credit exposure is partly mitigated 
as transactions with customers are generally secured by the collateral, if any, securing the underlying transaction being 
hedged. Our credit exposure, net of collateral pledged, relating to interest rate swaps, commodity swaps/options and 
foreign currency forward contracts with upstream financial institution counterparties was approximately $16.1 million
at December 31, 2019. This amount was primarily related to excess collateral we posted to counterparties. Collateral 
levels for upstream financial institution counterparties are monitored and adjusted as necessary. See Note 16 – Balance 
Sheet Offsetting and Repurchase Agreements for additional information regarding our credit exposure with upstream 
financial institution counterparties. At December 31, 2019 we had $37.5 million in cash collateral related to derivative 
contracts on deposit with other financial institution counterparties.

116

Note 16 - Balance Sheet Offsetting and Repurchase Agreements

Balance Sheet Offsetting. Certain financial instruments, including resell and repurchase agreements and derivatives, 
may be eligible for offset in the consolidated balance sheet and/or subject to master netting arrangements or similar 
agreements. Our derivative transactions with upstream financial institution counterparties are generally executed under 
International  Swaps  and  Derivative  Association  (“ISDA”)  master  agreements  which  include  “right  of  set-off” 
provisions. In such cases there is generally a legally enforceable right to offset recognized amounts and there may be 
an intention to settle such amounts on a net basis. Nonetheless, we do not generally offset such financial instruments 
for financial reporting purposes. 

Information  about  financial  instruments  that  are  eligible  for  offset  in  the  consolidated  balance  sheet  as  of 

December 31, 2019 is presented in the following tables.

Gross Amount
Recognized

Gross Amount
Offset

Net Amount
Recognized

December 31, 2019
Financial assets:
Derivatives:

Loan/lease interest rate swaps and caps
Commodity swaps and options

Total derivatives

Resell agreements

Total

Financial liabilities:

Derivatives:

Loan/lease interest rate swaps
Commodity swaps and options
Foreign currency forward contracts

Total derivatives
Repurchase agreements

Total

December 31, 2019
Financial assets:
Derivatives:

Counterparty A
Counterparty B
Counterparty C
Other counterparties
Total derivatives

Resell agreements

Total

Financial liabilities:

Derivatives:

Counterparty A
Counterparty B
Counterparty C
Other counterparties
Total derivatives
Repurchase agreements

Total

$

$

$

$

$

$

$

$

339
4,927
5,266
31,299
36,565

19,621
6,986
33
26,640
1,668,142
1,694,782

$

$

$

$

— $
—
—
—
— $

— $
—
—
—
—
— $

339
4,927
5,266
31,299
36,565

19,621
6,986
33
26,640
1,668,142
1,694,782

Gross Amounts Not Offset

Financial
Instruments

Collateral

Net
Amount

(39) $

(1,650)
(1)
(3,546)
(5,236)
—
(5,236) $

— $
—
—
—
—
(31,299)
(31,299) $

(39) $

(1,650)
(1)
(3,546)
(5,236)
—
(5,236) $

(5,153) $
(5,774)
(134)
(10,343)
(21,404)
(1,668,142)
(1,689,546) $

—
—
—
30
30
—
30

—
—
—
—
—
—
—

Net Amount
Recognized

$

$

$

$

39
1,650
1
3,576
5,266
31,299
36,565

5,192
7,424
135
13,889
26,640
1,668,142
1,694,782

117

Information  about  financial  instruments  that  are  eligible  for  offset  in  the  consolidated  balance  sheet  as  of 

December 31, 2018 is presented in the following tables.

December 31, 2018
Financial assets:
Derivatives:

Loan/lease interest rate swaps and caps
Commodity swaps and options

Total derivatives

Resell agreements

Total

Financial liabilities:

Derivatives:

Loan/lease interest rate swaps
Commodity swaps and options
Foreign currency forward contracts

Total derivatives

Repurchase agreements

Total

December 31, 2018
Financial assets:
Derivatives:

Counterparty A
Counterparty B
Counterparty C
Other counterparties
Total derivatives

Resell agreements

Total

Financial liabilities:

Derivatives:

Counterparty A
Counterparty B
Counterparty C
Other counterparties
Total derivatives
Repurchase agreements

Total

Gross Amount
Recognized

Gross Amount
Offset

Net Amount
Recognized

$

$

$

$

3,100
24,749
27,849
11,642
39,491

9,120
1,918
147
11,185
1,360,298
1,371,483

$

$

$

$

— $
—
—
—
— $

— $
—
—
—
—
— $

3,100
24,749
27,849
11,642
39,491

9,120
1,918
147
11,185
1,360,298
1,371,483

Gross Amounts Not Offset

Net Amount
Recognized

Financial
Instruments

Collateral

Net
Amount

$

$

$

$

598
7,255
81
19,915
27,849
11,642
39,491

4,293
3,380
326
3,186
11,185
1,360,298
1,371,483

$

$

$

$

(598) $

(3,380)
(81)
(2,084)
(6,143)
—
(6,143) $

— $

(3,875)
—
(17,776)
(21,651)
(11,642)
(33,293) $

(598) $

(3,380)
(81)
(2,084)
(6,143)
—
(6,143) $

(3,651) $
—
(245)
(725)
(4,621)
(1,360,298)
(1,364,919) $

—
—
—
55
55
—
55

44
—
—
377
421
—
421

118

Repurchase Agreements. We utilize securities sold under agreements to repurchase to facilitate the needs of our 
customers and to facilitate secured short-term funding needs. Securities sold under agreements to repurchase are stated 
at the amount of cash received in connection with the transaction. We monitor collateral levels on a continuous basis. 
We may be required to provide additional collateral based on the fair value of the underlying securities. Securities 
pledged as collateral under repurchase agreements are maintained with our safekeeping agents.

The remaining contractual maturity of repurchase agreements in the consolidated balance sheets as of December 31, 

2019 and December 31, 2018 is presented in the following tables.

Remaining Contractual Maturity of the Agreements

Overnight and
Continuous

Up to 30 Days

30-90 Days

Greater than 90
Days

Total

December 31, 2019

Repurchase agreements:

U.S. Treasury
Residential mortgage-
backed securities

Total borrowings

$

435,904

1,232,238
$ 1,668,142

$

$

— $

—
— $

— $

—
— $

Gross amount of recognized liabilities for repurchase agreements

Amounts related to agreements not included in offsetting disclosures above

December 31, 2018

Repurchase agreements:

U.S. Treasury
Residential mortgage-
backed securities

Total borrowings

$ 1,334,063

26,235
$ 1,360,298

$

$

— $

—
— $

— $

—
— $

Gross amount of recognized liabilities for repurchase agreements

Amounts related to agreements not included in offsetting disclosures above

Note 17 - Fair Value Measurements

— $

435,904

—
— $

$

$

1,232,238
1,668,142

1,668,142

—

— $

1,334,063

—
— $

$

$

26,235
1,360,298

1,360,298

—

The fair value of an asset or liability is the price that would be received to sell that asset or paid to transfer that 
liability in an orderly transaction occurring in the principal market (or most advantageous market in the absence of a 
principal market) for such asset or liability. In estimating fair value, we utilize valuation techniques that are consistent 
with the market approach, the income approach and/or the cost approach. Such valuation techniques are consistently 
applied. Inputs to valuation techniques include the assumptions that market participants would use in pricing an asset 
or liability. ASC Topic 820 establishes a fair value hierarchy for valuation inputs that gives the highest priority to quoted 
prices in active markets for identical assets or liabilities and the lowest priority to unobservable inputs. The fair value 
hierarchy is as follows:

• 

• 

• 

Level 1 Inputs - Unadjusted quoted prices in active markets for identical assets or liabilities that the reporting 
entity has the ability to access at the measurement date.

Level 2 Inputs - Inputs other than quoted prices included in Level 1 that are observable for the asset or liability, 
either directly or indirectly. These might include quoted prices for similar assets or liabilities in active markets, 
quoted prices for identical or similar assets or liabilities in markets that are not active, inputs other than quoted 
prices that are observable for the asset or liability (such as interest rates, volatilities, prepayment speeds, credit 
risks, etc.) or inputs that are derived principally from or corroborated by market data by correlation or other 
means.

Level 3 Inputs - Unobservable inputs for determining the fair values of assets or liabilities that reflect an entity’s 
own assumptions about the assumptions that market participants would use in pricing the assets or liabilities.

In general, fair value is based upon quoted market prices, where available. If such quoted market prices are not 
available, fair value is based upon internally developed models that primarily use, as inputs, observable market-based 
parameters. Valuation adjustments may be made to ensure that financial instruments are recorded at fair value. These 

119

adjustments may include amounts to reflect counterparty credit quality and our creditworthiness, among other things, 
as well as unobservable parameters. Any such valuation adjustments are applied consistently over time. Our valuation 
methodologies may produce a fair value calculation that may not be indicative of net realizable value or reflective of 
future fair values. While management believes our valuation methodologies are appropriate and consistent with other 
market participants, the use of different methodologies or assumptions to determine the fair value of certain financial 
instruments could result in a different estimate of fair value at the reporting date. Furthermore, the reported fair value 
amounts have not been comprehensively revalued since the presentation dates, and therefore, estimates of fair value 
after the balance sheet date may differ significantly from the amounts presented herein. A more detailed description of 
the valuation methodologies used for assets and liabilities measured at fair value is set forth below. Transfers between 
levels of the fair value hierarchy are recognized on the actual date of the event or circumstances that caused the transfer, 
which generally coincides with our monthly and/or quarterly valuation process.

Financial Assets and Financial Liabilities: Financial assets and financial liabilities measured at fair value on a 

recurring basis include the following:

Securities Available  for  Sale.  U.S. Treasury  securities  are  reported  at  fair  value  utilizing  Level 1  inputs.  Other 
securities classified as available for sale are reported at fair value utilizing Level 2 inputs. For these securities, we 
obtain fair value measurements from an independent pricing service. The fair value measurements consider observable 
data that may include dealer quotes, market spreads, cash flows, the U.S. Treasury yield curve, live trading levels, trade 
execution data, market consensus prepayment speeds, credit information and the bond’s terms and conditions, among 
other things.

We review the prices supplied by the independent pricing service, as well as their underlying pricing methodologies, 
for reasonableness and to ensure such prices are aligned with traditional pricing matrices. In general, we do not purchase 
investment portfolio securities that are esoteric or that have a complicated structure. Our entire portfolio consists of 
traditional investments, nearly all of which are U.S. Treasury obligations, federal agency bullet or mortgage pass-
through securities, or general obligation or revenue based municipal bonds. Pricing for such instruments is fairly generic 
and  is  easily  obtained.  From  time  to  time,  we  will  validate  prices  supplied  by  the  independent  pricing  service  by 
comparison to prices obtained from third-party sources or derived using internal models.

Trading Securities. U.S. Treasury securities and exchange-listed common stock are reported at fair value utilizing 
Level 1 inputs. Other securities classified as trading are reported at fair value utilizing Level 2 inputs in the same manner 
as described above for securities available for sale.

Derivatives. Derivatives are generally reported at fair value utilizing Level 2 inputs, except for foreign currency 
contracts, which are reported at fair value utilizing Level 1 inputs. We obtain dealer quotations and utilize internally 
developed valuation models to value commodity swaps/options. We utilize internally developed valuation models and/
or third-party models with observable market data inputs to validate the valuations provided by the dealers. Though 
there has never been a significant discrepancy in the valuations, should such a significant discrepancy arise, we would 
obtain price verification from a third-party dealer. We utilize internal valuation models with observable market data 
inputs to estimate fair values of customer interest rate swaps, caps and floors. We also obtain dealer quotations for these 
derivatives for comparative purposes to assess the reasonableness of the model valuations. In cases where significant 
credit valuation adjustments are incorporated into the estimation of fair value, reported amounts are considered to have 
been derived utilizing Level 3 inputs.

For  purposes  of  potential  valuation  adjustments  to  our  derivative  positions,  we  evaluate  the  credit  risk  of  our 
counterparties as well as ours. Accordingly, we have considered factors such as the likelihood of our default and the 
default of our counterparties, our net exposures and remaining contractual life, among other things, in determining if 
any fair value adjustments related to credit risk are required. Counterparty exposure is evaluated by netting positions 
that are subject to master netting arrangements, as well as considering the amount of collateral securing the position. 
We review our counterparty exposure on a regular basis, and, when necessary, appropriate business actions are taken 
to adjust the exposure. We also utilize this approach to estimate our own credit risk on derivative liability positions. To 
date, we have not realized any significant losses due to a counterparty’s inability to pay any net uncollateralized position. 
The change in value of derivative assets and derivative liabilities attributable to credit risk was not significant during 
the reported periods.

120

The following tables summarize financial assets and financial liabilities measured at fair value on a recurring basis 
as of December 31, 2019 and 2018, segregated by the level of the valuation inputs within the fair value hierarchy 
utilized to measure fair value:

Level 1
Inputs

Level 2
Inputs

Level 3
Inputs

Total
Fair Value

2019
Securities available for sale:

U.S. Treasury
Residential mortgage-backed securities
States and political subdivisions
Other

$

1,948,133
—
—
—

$

— $

2,207,594
7,070,997
42,867

— $
—
—
—

1,948,133
2,207,594
7,070,997
42,867

Trading account securities:

U.S. Treasury
Derivative assets:

Interest rate swaps, caps and floors
Commodity swaps and options
Foreign currency forward contracts

Derivative liabilities:

Interest rate swaps, caps and floors
Commodity swaps and options
Foreign currency forward contracts

2018
Securities available for sale:

24,298

—

—
—
45

—
—
33

44,196
12,218
—

20,197
11,677
—

—

—
—
—

—
—
—

24,298

44,196
12,218
45

20,197
11,677
33

U.S. Treasury
Residential mortgage-backed securities
States and political subdivisions
Other

$

3,427,689
—
—
—

$

— $

829,740
7,087,202
42,690

— $
—
—
—

3,427,689
829,740
7,087,202
42,690

Trading account securities:

U.S. Treasury
States and political subdivisions

Derivative assets:

Interest rate swaps, caps and floors
Commodity swaps and options
Foreign currency forward contracts

Derivative liabilities:

Interest rate swaps, caps and floors
Commodity swaps and options
Foreign currency forward contracts

21,928
—

—
—
193

—
—
147

—
2,158

19,806
26,768
—

18,520
26,320
—

—
—

—
—
—

—
—
—

21,928
2,158

19,806
26,768
193

18,520
26,320
147

Certain  financial  assets  and  financial  liabilities  are  measured  at  fair  value  on  a  nonrecurring  basis;  that  is,  the 
instruments are not measured at fair value on an ongoing basis but are subject to fair value adjustments in certain 
circumstances (for example, when there is evidence of impairment). Financial assets measured at fair value on a non-
recurring basis during the reported periods include certain impaired loans reported at the fair value of the underlying 
collateral if repayment is expected solely from the collateral. Collateral values are estimated using Level 2 inputs based 
on observable market data, typically in the case of real estate collateral, or Level 3 inputs based on customized discounting 
criteria, typically in the case of non-real estate collateral such as inventory, oil and gas reserves, accounts receivable, 
equipment or other business assets.

121

The following table presents impaired loans that were remeasured and reported at fair value through a specific 
valuation allowance allocation of the allowance for loan losses based upon the fair value of the underlying collateral:

Level 2

Carrying value of impaired loans before allocations
Specific valuation allowance allocations

Fair value

Level 3

Carrying value of impaired loans before allocations
Specific valuation allowance allocations

Fair value

2019

2018

2017

$

$

$

$

2,354
(383)
1,971

65,176
(18,019)
47,157

$

$

$

$

12,517
(2,599)
9,918

22,688
9,260
31,948

$

$

$

$

—
—
—

75,435
(19,533)
55,902

Non-Financial Assets  and  Non-Financial  Liabilities: We  do  not  have  any  non-financial  assets  or  non-financial 
liabilities measured at fair value on a recurring basis. Certain non-financial assets measured at fair value on a non-
recurring basis include foreclosed assets (upon initial recognition or subsequent impairment), non-financial assets and 
non-financial liabilities measured at fair value in the second step of a goodwill impairment test, and intangible assets 
and  other  non-financial  long-lived  assets  measured  at  fair  value  for  impairment  assessment.  Non-financial  assets 
measured at fair value on a non-recurring basis during the reported periods include certain foreclosed assets which, 
upon initial recognition, were remeasured and reported at fair value through a charge-off to the allowance for loan 
losses and certain foreclosed assets which, subsequent to their initial recognition, were remeasured at fair value through 
a write-down included in other non-interest expense. The fair value of a foreclosed asset is estimated using Level 2 
inputs based on observable market data or Level 3 inputs based on customized discounting criteria. During the reported 
periods, all fair value measurements for foreclosed assets utilized Level 2 inputs.

The following table presents foreclosed assets that were remeasured and reported at fair value:

2019

2018

2017

Foreclosed assets remeasured at initial recognition:

Carrying value of foreclosed assets prior to remeasurement
Charge-offs recognized in the allowance for loan losses

Fair value

Foreclosed assets remeasured subsequent to initial recognition:
Carrying value of foreclosed assets prior to remeasurement
Write-downs included in other non-interest expense

Fair value

$

$

$

$

1,348
(76)
1,272

$

$

— $
—
— $

2,899
—
2,899

1,823
(473)
1,350

$

$

$

$

279
—
279

89
(16)
73

Charge-offs recognized upon loan foreclosures are generally offset by general or specific allocations of the allowance 
for loan losses and generally do not, and did not during the reported periods, significantly impact our provision for loan 
losses. Regulatory guidelines require us to reevaluate the fair value of other real estate owned on at least an annual 
basis. While our policy is to comply with the regulatory guidelines, our general practice is to reevaluate the fair value 
of collateral supporting impaired collateral dependent loans on a quarterly basis. Thus, appraisals are generally not 
considered to be outdated, and we typically do not make any adjustments to the appraised values.

ASC  Topic 825,  “Financial  Instruments,”  requires  disclosure  of  the  fair  value  of  financial  assets  and  financial 
liabilities, including those financial assets and financial liabilities that are not measured and reported at fair value on 
a  recurring  basis  or  non-recurring  basis.  The  estimated  fair  value  approximates  carrying  value  for  cash  and  cash 
equivalents,  accrued  interest  and  the  cash  surrender  value  of  life  insurance  policies. The  methodologies  for  other 
financial assets and financial liabilities that are not measured and reported at fair value on a recurring basis or non-
recurring basis are discussed below:

Loans. The estimated fair value approximates carrying value for variable-rate loans that reprice frequently and with 
no significant change in credit risk. The fair value of fixed-rate loans and variable-rate loans which reprice on an 
infrequent basis is estimated by discounting future cash flows using the current interest rates at which similar loans 
with similar terms would be made to borrowers of similar credit quality. An overall valuation adjustment is made for 
specific credit risks as well as general portfolio credit risk.

122

Deposits. The estimated fair value approximates carrying value for demand deposits. The fair value of fixed-rate 
deposit liabilities with defined maturities is estimated by discounting future cash flows using the interest rates currently 
offered for deposits of similar remaining maturities. The estimated fair value of deposits does not take into account the 
value of our long-term relationships with depositors, commonly known as core deposit intangibles, which are separate 
intangible assets, and not considered financial instruments. Nonetheless, we would likely realize a core deposit premium 
if our deposit portfolio were sold in the principal market for such deposits.

Borrowed Funds. The estimated fair value approximates carrying value for short-term borrowings. The fair value 
of long-term fixed-rate borrowings is estimated using quoted market prices, if available, or by discounting future cash 
flows using current interest rates for similar financial instruments. The estimated fair value approximates carrying value 
for variable-rate junior subordinated deferrable interest debentures that reprice quarterly.

Loan Commitments, Standby and Commercial Letters of Credit. Our lending commitments have variable interest 
rates and “escape” clauses if the customer’s credit quality deteriorates. Therefore, the fair values of these items are not 
significant and are not included in the following table.

The estimated fair values of financial instruments that are reported at amortized cost in our consolidated balance 
sheets, segregated by the level of valuation inputs within the fair value hierarchy utilized to measure fair value, were 
as follows:

December 31, 2019

December 31, 2018

Carrying
Amount

Estimated
Fair Value

Carrying
Amount

Estimated
Fair Value

Financial assets:
Level 2 inputs:

Cash and cash equivalents
Securities held to maturity
Cash surrender value of life insurance policies
Accrued interest receivable

$ 3,788,181
2,030,005
187,156
183,850

$ 3,788,181
2,048,675
187,156
183,850

$ 3,955,779
1,106,057
183,473
188,989

$ 3,955,779
1,116,953
183,473
188,989

Level 3 inputs:
Loans, net

Financial liabilities:
Level 2 inputs:

14,618,165

14,654,615

13,967,601

13,933,239

Deposits
Federal funds purchased and repurchase agreements
Junior subordinated deferrable interest debentures
Subordinated notes payable and other borrowings
Accrued interest payable

27,639,564
1,695,342
136,299
98,865
12,393

27,641,255
1,695,342
137,115
89,077
12,393

27,149,204
1,367,548
136,242
98,708
7,394

27,143,572
1,367,548
137,115
98,458
7,394

Under ASC Topic 825, entities may choose to measure eligible financial instruments at fair value at specified election 
dates. The fair value measurement option (i) may be applied instrument by instrument, with certain exceptions, (ii) is 
generally irrevocable and (iii) is applied only to entire instruments and not to portions of instruments. Unrealized gains 
and losses on items for which the fair value measurement option has been elected must be reported in earnings at each 
subsequent reporting date. During the reported periods, we had no financial instruments measured at fair value under 
the fair value measurement option.

123

Note 18 - Operating Segments

We are managed under a matrix organizational structure whereby our two primary operating segments, Banking and 
Frost Wealth Advisors, overlap a regional reporting structure. The regions are primarily based upon geographic location 
and include Austin, Corpus Christi, Dallas, Fort Worth, Houston, Permian Basin, Rio Grande Valley, San Antonio and 
Statewide. We are primarily managed based on the line of business structure. In that regard, all regions have the same 
lines of business, which have the same product and service offerings, have similar types and classes of customers and 
utilize similar service delivery methods. Pricing guidelines for products and services are the same across all regions. 
The regional reporting structure is primarily a means to scale the lines of business to provide a local, community focus 
for customer relations and business development.

Banking and Frost Wealth Advisors are delineated by the products and services that each segment offers. The Banking 
operating segment includes both commercial and consumer banking services and Frost Insurance Agency. Commercial 
banking services are provided to corporations and other business clients and include a wide array of lending and cash 
management products. Consumer banking services include direct lending and depository services. Frost Insurance 
Agency provides insurance brokerage services to individuals and businesses covering corporate and personal property 
and casualty products, as well as group health and life insurance products. The Frost Wealth Advisors operating segment 
includes fee-based services within private trust, retirement services, and financial management services, including 
personal wealth management and securities brokerage services. A third operating segment, Non-Banks, is for the most 
part the parent holding company, as well as certain other insignificant non-bank subsidiaries of the parent that, for the 
most part, have little or no activity. The parent company’s principal activities include the direct and indirect ownership 
of our banking and non-banking subsidiaries and the issuance of debt and equity. Our principal source of revenue is 
dividends from our subsidiaries.

The accounting policies of each reportable segment are the same as those of our consolidated entity except for the 
following items, which impact the Banking and Frost Wealth Advisors segments: (i) expenses for consolidated back-
office operations and general overhead-type expenses such as executive administration, accounting and internal audit 
are allocated to operating segments based on estimated uses of those services, (ii) income tax expense for the individual 
segments is calculated essentially at the statutory rate, and (iii) the parent company records the tax expense or benefit 
necessary to reconcile to the consolidated total.

We use a match-funded transfer pricing process to assess operating segment performance. The process helps us to 
(i) identify the cost or opportunity value of funds within each business segment, (ii) measure the profitability of a 
particular business segment by relating appropriate costs to revenues, (iii) evaluate each business segment in a manner 
consistent with its economic impact on consolidated earnings, and (iv) enhance asset and liability pricing decisions.

Financial results by operating segment are detailed below. Certain prior period amounts have been reclassified to 
conform to the current presentation. Frost Wealth Advisors excludes off balance sheet managed and custody assets with 
a total fair value of $37.8 billion, $33.3 billion and $32.8 billion at December 31, 2019, 2018 and 2017.

Banking

Frost
Wealth
Advisors

Non-Banks

Consolidated

2019
Net interest income (expense)
Provision for loan losses
Non-interest income
Non-interest expense
Income (loss) before income taxes
Income tax expense (benefit)
Net income (loss)
Preferred stock dividends
Net income (loss) available to common shareholders $
Revenues from (expenses to) external customers

$ 1,010,368
33,758
218,447
703,121
491,936
55,520
436,416
—
436,416
$ 1,228,815

Average assets (in millions)

$

32,019

$

$
$

$

4,001
1
145,905
124,622
25,283
5,308
19,975
—
19,975
149,906

56

$

$
$

$

(10,364) $ 1,004,005
33,759
—
(450)
363,902
834,679
6,936
(17,750)
499,469
(4,958)
55,870
(12,792)
443,599
8,063
8,063
(20,855) $
435,536
(10,814) $ 1,367,907

11

$

32,086

124

Banking

Frost
Wealth
Advisors

Non-Banks

Consolidated

2018
Net interest income (expense)
Provision for loan losses
Non-interest income
Non-interest expense
Income (loss) before income taxes
Income tax expense (benefit)
Net income (loss)
Preferred stock dividends
Net income (loss) available to common shareholders $
Revenues from (expenses to) external customers
Average assets (in millions)
2017
Net interest income (expense)
Provision for loan losses
Non-interest income
Non-interest expense
Income (loss) before income taxes
Income tax expense (benefit)
Net income (loss)
Preferred stock dividends
Net income (loss) available to common shareholders $
Revenues from (expenses to) external customers
Average assets (in millions)

$

$

963,757
21,613
213,763
657,448
498,459
52,928
445,531
—
445,531
$ 1,177,520
30,964
$

856,593
35,460
207,810
644,072
384,871
37,837
347,034
—
347,034
$ 1,064,403
30,391
$

$

$
$
$

$

$
$
$

4,083
—
138,045
114,166
27,962
5,872
22,090
—
22,090
142,128
54

17,644
—
128,819
108,931
37,532
13,137
24,395
—
24,395
146,463
43

$

$
$
$

$

$
$
$

(9,948) $
957,892
21,613
—
(522)
351,286
778,884
7,270
(17,740)
508,681
(5,037)
53,763
(12,703)
454,918
8,063
8,063
(20,766) $
446,855
(10,470) $ 1,309,178
31,030
$

12

(7,815) $
866,422
35,460
—
(159)
336,470
759,069
6,066
(14,040)
408,363
(6,760)
44,214
(7,280)
364,149
8,063
8,063
(15,343) $
356,086
(7,974) $ 1,202,892
30,450

16

$

Note 19 - Condensed Financial Statements of Parent Company

Condensed financial statements pertaining only to Cullen/Frost Bankers, Inc. are presented below. Investments in 

subsidiaries are stated using the equity method of accounting.

Condensed Balance Sheets

Assets:
Cash
Resell agreements

Total cash and cash equivalents

Investment in subsidiaries
Accrued interest receivable and other assets

Total assets

Liabilities:

Junior subordinated deferrable interest debentures, net of unamortized issuance
costs
Subordinated notes, net of unamortized issuance costs
Accrued interest payable and other liabilities

Total liabilities
Shareholders’ Equity

Total liabilities and shareholders’ equity

125

December 31,

2019

2018

$

$

$

$

9,116
258,000
267,116
3,896,962
2,545
4,166,623

136,299
98,865
19,791
254,955
3,911,668
4,166,623

$

$

$

$

11,397
225,000
236,397
3,362,474
9,122
3,607,993

136,242
98,708
4,126
239,076
3,368,917
3,607,993

Condensed Statements of Income

Income:

Dividend income paid by Frost Bank
Dividend income paid by non-banks
Interest and other income

Total income

Expenses:

Interest expense
Salaries and employee benefits
Other

Total expenses

$

Income before income taxes and equity in undistributed

earnings of subsidiaries

Income tax benefit
Equity in undistributed earnings of subsidiaries
Net income

Preferred stock dividends

Net income available to common shareholders

$

Condensed Statements of Cash Flows

Year Ended December 31,

2019

2018

2017

234,531
1,822
2,868
239,221

10,363
1,551
7,033
18,947

220,274
5,135
218,190
443,599
8,063
435,536

$

$

223,371
953
1,828
226,152

9,948
1,973
7,016
18,937

207,215
5,218
242,485
454,918
8,063
446,855

$

$

149,671
915
421
151,007

7,815
1,202
6,373
15,390

135,617
7,092
221,440
364,149
8,063
356,086

Operating Activities:

Net income
Adjustments to reconcile net income to net cash provided by

operating activities:
Equity in undistributed earnings of subsidiaries
Stock-based compensation
Net tax benefit from stock-based compensation
Net change in other assets and other liabilities

Net cash from operating activities

Investing Activities:

Net cash from investing activities

Financing Activities:

Proceeds from issuance of subordinated notes
Principal payments on subordinated notes
Proceeds from stock option exercises
Proceeds from stock-based compensation activities of

subsidiaries

Purchase of treasury stock
Cash dividends paid on preferred stock
Cash dividends paid on common stock
Net cash from financing activities
Net change in cash and cash equivalents
Cash and cash equivalents at beginning of year
Cash and cash equivalents at end of year

$

126

Year Ended December 31,

2019

2018

2017

$

443,599

$

454,918

$

364,149

(218,190)
780
240
22,216
248,645

(242,485)
721
304
(12,709)
200,749

(221,440)
519
318
7,665
151,211

—

—

—

—
—
20,770

15,166
(68,793)
(8,063)
(177,006)
(217,926)
30,719
236,397
267,116

$

—
—
31,647

13,222
(101,010)
(8,063)
(165,449)
(229,653)
(28,904)
265,301
236,397

$

98,434
(100,000)
67,746

12,494
(101,473)
(8,063)
(144,172)
(175,034)
(23,823)
289,124
265,301

Note 20 - Accounting Standards Updates

Accounting  Standards  Update  (“ASU”)  2014-09,  “Revenue  from  Contracts  with  Customers  (Topic  606).” 
ASU 2014-09 implements a common revenue standard that clarifies the principles for recognizing revenue. The core 
principle of ASU 2014-09 is that an entity should recognize revenue to depict the transfer of promised goods or services 
to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those 
goods or services. To achieve that core principle, an entity should apply the following steps: (i) identify the contract(s) 
with  a  customer,  (ii) identify  the  performance  obligations  in  the  contract,  (iii) determine  the  transaction  price, 
(iv) allocate the transaction price to the performance obligations in the contract and (v) recognize revenue when (or 
as) the entity satisfies a performance obligation. We adopted ASU 2014-09 effective January 1, 2018. See Note 1 - 
Summary of Significant Accounting Policies for additional information.

ASU 2016-01, “Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial 
Assets  and  Financial  Liabilities."  ASU 2016-01,  among  other  things,  (i)  requires  equity  investments,  with  certain 
exceptions, to be measured at fair value with changes in fair value recognized in net income, (ii) simplifies the impairment 
assessment of equity investments without readily determinable fair values by requiring a qualitative assessment to 
identify impairment, (iii) eliminates the requirement for public business entities to disclose the methods and significant 
assumptions  used  to  estimate  the  fair  value  that  is  required  to  be  disclosed  for  financial  instruments  measured  at 
amortized cost on the balance sheet, (iv) requires public business entities to use the exit price notion when measuring 
the fair value of financial instruments for disclosure purposes, (v) requires an entity to present separately in other 
comprehensive income the portion of the total change in the fair value of a liability resulting from a change in the 
instrument-specific credit risk when the entity has elected to measure the liability at fair value in accordance with the 
fair value option for financial instruments, (vi) requires separate presentation of financial assets and financial liabilities 
by measurement category and form of financial asset on the balance sheet or the accompanying notes to the financial 
statements and (viii) clarifies that an entity should evaluate the need for a valuation allowance on a deferred tax asset 
related to available-for-sale securities. ASU 2016-01 became effective for us on January 1, 2018 and did not have a 
significant impact on our financial statements.

ASU 2016-02, “Leases (Topic 842).” ASU 2016-02 among other things, requires lessees to recognize a lease liability, 
which is a lessee's obligation to make lease payments arising from a lease, measured on a discounted basis; and a right-
of-use asset, which is an asset that represents the lessee’s right to use, or control the use of, a specified asset for the 
lease  term.  We  adopted ASU  2016-02,  along  with  several  other  subsequent  codification  updates  related  to  lease 
accounting, as of January 1, 2019. See Note 1 - Summary of Significant Accounting Policies for additional information.

ASU 2016-13, “Financial Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial 
Instruments.” ASU 2016-13 along with several other subsequent codification updates related to accounting for credit 
losses, requires the measurement of all expected credit losses for financial assets held at the reporting date based on 
historical experience, current conditions, and reasonable and supportable forecasts and requires enhanced disclosures 
related to the significant estimates and judgments used in estimating credit losses, as well as the credit quality and 
underwriting standards of an organization’s portfolio. In addition, ASU 2016-13 amends the accounting for credit losses 
on available-for-sale debt securities and purchased financial assets with credit deterioration. We currently expect the 
adoption of ASU 2016-13 will result in a combined 20.0% to 35.0% increase in our allowance for loan losses and our 
reserves for unfunded commitments. As we are currently finalizing the execution of our implementation controls and 
processes, the ultimate impact of the adoption of ASU 2016-13 as of January 1, 2020 could differ from our current 
expectation. The expected increase is a result of changing from an “incurred loss” model, which encompasses allowances 
for current known and inherent losses within the portfolio, to an “expected loss” model, which encompasses allowances 
for losses expected to be incurred over the life of the portfolio. Furthermore, ASU 2016-13 will necessitate that we 
establish an allowance for expected credit losses for certain debt securities and other financial assets; however, we do 
not expect these allowances to be significant. The adoption of ASU 2016-13 is not expected to have a significant impact 
on our regulatory capital ratios.

ASU 2016-15, “Statement of Cash Flows (Topic 230) - Classification of Certain Cash Receipts and Cash Payments.”
ASU 2016-15 provides guidance related to certain cash flow issues in order to reduce the current and potential future 
diversity in practice. ASU 2016-15 became effective for us on January 1, 2018 and did not have a significant impact 
on our financial statements.

127

ASU 2016-16, “Income Taxes (Topic 740) - Intra-Entity Transfers of Assets Other Than Inventory.” ASU 2016-16 
provides guidance stating that an entity should recognize the income tax consequences of an intra-entity transfer of an 
asset other than inventory when the transfer occurs. ASU 2016-16 became effective for us on January 1, 2018 and did 
not have a significant impact on our financial statements.

ASU 2016-18, “Statement of Cash Flows (Topic 230) - Restricted Cash.” ASU 2016-18 requires that a statement 
of cash flows explain the change during the period in the total of cash, cash equivalents, and amounts generally described 
as restricted cash or restricted cash equivalents. Therefore, amounts generally described as restricted cash and restricted 
cash equivalents should be included with cash and cash equivalents when reconciling the beginning-of-period and end-
of-period total amounts shown on the statement of cash flows. ASU 2016-18 became effective for us on January 1, 
2018 and did not have a significant impact on our financial statements.

ASU 2017-01, “Business Combinations (Topic 805) - Clarifying the Definition of a Business.” ASU 2017-01 clarifies 
the definition and provides a more robust framework to use in determining when a set of assets and activities constitutes 
a business. ASU 2017-01 is intended to provide guidance when evaluating whether transactions should be accounted 
for as acquisitions (or disposals) of assets or businesses. ASU 2017-01 became effective for us on January 1, 2018 and 
did not have a significant impact on our financial statements.

ASU 2017-04, “Intangibles - Goodwill and Other (Topic 350) - Simplifying the Test for Goodwill Impairment.”
ASU 2017-04 eliminates Step 2 from the goodwill impairment test which required entities to compute the implied fair 
value of goodwill. Under ASU 2017-04, an entity should perform its annual, or interim, goodwill impairment test by 
comparing the fair value of a reporting unit with its carrying amount. An entity should recognize an impairment charge 
for the amount by which the carrying amount exceeds the reporting unit’s fair value; however, the loss recognized 
should not exceed the total amount of goodwill allocated to that reporting unit. ASU 2017-04 will be effective for us 
on January 1, 2020, with earlier adoption permitted and is not expected to have a significant impact on our financial 
statements.

ASU 2017-05, “Other Income - Gains and Losses from the Derecognition of Nonfinancial Assets (Subtopic 610-20) 
- Clarifying the Scope of Asset Derecognition Guidance and Accounting for Partial Sales of Nonfinancial Assets.”
ASU 2017-05 clarifies the scope of Subtopic 610-20 and adds guidance for partial sales of nonfinancial assets, including 
partial sales of real estate. Historically, U.S. GAAP contained several different accounting models to evaluate whether 
the transfer of certain assets qualified for sale treatment. ASU 2017-05 reduces the number of potential accounting 
models that might apply and clarifies which model does apply in various circumstances. ASU 2017-05 became effective 
for us on January 1, 2018 and did not have a significant impact on our financial statements.

ASU 2017-08, “Receivables - Nonrefundable Fees and Other Costs (Subtopic 310-20) - Premium Amortization on 
Purchased Callable Debt Securities.” ASU 2017-08 shortens the amortization period for certain callable debt securities 
held at a premium to require such premiums to be amortized to the earliest call date unless applicable guidance related 
to certain pools of securities is applied to consider estimated prepayments. Under prior guidance, entities were generally 
required  to  amortize  premiums  on  individual,  non-pooled  callable  debt  securities  as  a  yield  adjustment  over  the 
contractual life of the security. ASU 2017-08 does not change the accounting for callable debt securities held at a 
discount. We adopted ASU 2017-08 effective January 1, 2019 and recognized a cumulative effect adjustment reducing 
retained earnings by $14.7 million. See Note 1 - Summary of Significant Accounting Policies for additional information.

ASU  2017-09,  “Compensation  -  Stock  Compensation  (Topic  718)  -  Scope  of  Modification  Accounting.” 
ASU 2017-09 clarifies when changes to the terms or conditions of a share-based payment award must be accounted 
for as modifications. Under ASU 2017-09, an entity will not apply modification accounting to a share-based payment 
award if all of the following are the same immediately before and after the change: (i) the award's fair value, (ii) the 
award's vesting conditions and (iii) the award's classification as an equity or liability instrument. ASU 2017-09 became 
effective for us on January 1, 2018 and did not have a significant impact on our financial statements.

ASU  2017-12,  “Derivatives  and  Hedging  (Topic  815)  -  Targeted  Improvements  to  Accounting  for  Hedging 
Activities.” ASU 2017-12  amends  the  hedge  accounting  recognition  and  presentation  requirements  in ASC  815  to 
improve the transparency and understandability of information conveyed to financial statement users about an entity’s 
risk  management  activities  to  better  align  the  entity’s  financial  reporting  for  hedging  relationships  with  those  risk 
management activities and to reduce the complexity of and simplify the application of hedge accounting. ASU 2017-12 
became effective for us on January 1, 2019 and did not have a significant impact on our financial statements. 

128

ASU 2018-02, “Income Statement - Reporting Comprehensive Income (Topic 220) - Reclassification of Certain Tax 
Effects from Accumulated Other Comprehensive Income.” Under ASU 2018-02, entities may elect to reclassify certain 
income tax effects related to the change in the U.S. statutory federal income tax rate under the Tax Cuts and Jobs Act, 
which  was  enacted  on  December 22,  2017,  from  accumulated  other  comprehensive  income  to  retained  earnings. 
ASU 2018-02 also requires certain accounting policy disclosures. We elected to adopt the provisions of ASU 2018-02 
as of January 1, 2018 in advance of the required application date of January 1, 2019. See Note 1 - Summary of Significant 
Accounting Policies for additional information.

ASU 2018-05, “Income Taxes (Topic 740) - Amendments to SEC Paragraphs Pursuant to SEC Staff Accounting 
Bulletin (SAB) No. 118.” ASU 2018-05 amends the Accounting Standards Codification to incorporate various SEC 
paragraphs pursuant to the issuance of SAB 118. SAB 118 addresses the application of generally accepted accounting 
principles in situations when a registrant does not have the necessary information available, prepared, or analyzed 
(including computations) in reasonable detail to complete the accounting for certain income tax effects of the Tax Cuts 
and Jobs Act. See Note 13 - Income Taxes.

ASU  2018-13, “Fair  Value  Measurement  (Topic  820)  -  Disclosure  Framework-Changes  to  the  Disclosure 
Requirements  for  Fair  Value  Measurement.”  ASU 2018-13  modifies  the  disclosure  requirements  on  fair  value 
measurements in Topic 820. The amendments in this update remove disclosures that no longer are considered cost 
beneficial, modify/clarify the specific requirements of certain disclosures, and add disclosure requirements identified 
as relevant. ASU 2018-13 will be effective for us on January 1, 2020, with early adoption permitted, and is not expected 
to have a significant impact on our financial statements.

ASU  2018-14,  “Compensation  -  Retirement  Benefits-Defined  Benefit  Plans-General  (Subtopic  715-20).” 
ASU 2018-14 amends and modifies the disclosure requirements for employers that sponsor defined benefit pension or 
other post-retirement plans. The amendments in this update remove disclosures that no longer are considered cost 
beneficial,  clarify  the  specific  requirements  of  disclosures,  and  add  disclosure  requirements  identified  as  relevant. 
ASU 2018-14 will be effective for us on January 1, 2021, with early adoption permitted, and is not expected to have a 
significant impact on our financial statements.

ASU 2018-15,  “Intangibles  -  Goodwill  and  Other  -  Internal-Use  Software  (Subtopic  350-40)  -  Customer’s 
Accounting  for  Implementation  Costs  Incurred  in  a  Cloud  Computing  Arrangement  That  Is  a  Service  Contract.” 
ASU 2018-15 clarifies certain aspects of ASU 2015-05, “Customer’s Accounting for Fees Paid in a Cloud Computing 
Arrangement,” which was issued in April 2015. Specifically, ASU 2018-15 aligns the requirements for capitalizing 
implementation costs incurred in a hosting arrangement that is a service contract with the requirements for capitalizing 
implementation costs incurred to develop or obtain internal-use software (and hosting arrangements that include an 
internal-use  software  license). ASU 2018-15  does  not  affect  the  accounting  for  the  service  element  of  a  hosting 
arrangement that is a service contract. ASU 2018-15 will be effective for us on January 1, 2020, with early adoption 
permitted, and is not expected to have a significant impact on our financial statements.

ASU 2018-16, “Derivatives and Hedging (Topic 815) - Inclusion of the Secured Overnight Financing Rate (SOFR) 
Overnight Index Swap (OIS) Rate as a Benchmark Interest Rate for Hedge Accounting Purposes.” The amendments 
in this update permit use of the OIS rate based on SOFR as a U.S. benchmark interest rate for hedge accounting purposes 
under Topic 815 in addition to the interest rates on direct U.S. Treasury obligations, the LIBOR swap rate, the OIS rate 
based  on  the  Fed  Funds  Effective  Rate  and  the  Securities  Industry  and  Financial  Markets Association  (SIFMA) 
Municipal Swap Rate. ASU 2018-16 was effective for us on January 1, 2019 and did not have a significant impact on 
our financial statements.

ASU 2019-12, “Income Taxes (Topic 740) - Simplifying the Accounting for Income Taxes.” The guidance issued in 
this update simplifies the accounting for income taxes by eliminating certain exceptions to the guidance in ASC 740 
related to the approach for intraperiod tax allocation, the methodology for calculating income taxes in an interim period 
and the recognition for deferred tax liabilities for outside basis differences. ASU 2019-12 also simplifies aspects of the 
accounting for franchise taxes and enacted changes in tax laws or rates and clarifies the accounting for transactions 
that result in a step-up in the tax basis of goodwill. ASU 2019-12 will be effective for us on January 1, 2021, with early 
adoption permitted, and is not expected to have a significant impact on our financial statements.

129

Cullen/Frost Bankers, Inc.
Consolidated Average Balance Sheets
(Dollars in thousands - tax-equivalent basis)

The following unaudited schedule is presented for additional information and analysis.

Year Ended December 31,

2019

Interest
Income/
Expense

Average
Balance

Yield
/Cost

Average
Balance

2018

Interest
Income/
Expense

Yield
/Cost

$ 1,616,896

$

35,590

2.20% $ 2,951,128

$

56,968

1.93%

245,613

5,524

2.25

265,085

5,500

2.07

Assets:
Interest-bearing deposits
Federal funds sold and resell agreements
Securities:
Taxable
Tax-exempt

Total securities

Loans, net of unearned discount

5,048,552

8,248,812

13,297,364

14,440,549

117,082

325,058

442,140

747,112

Total earning assets and average rate earned

29,600,422

1,230,366

Cash and due from banks
Allowance for loan losses
Premises and equipment, net
Accrued interest receivable and other assets

Total assets

Liabilities:
Non-interest-bearing demand deposits:

Commercial and individual
Correspondent banks
Public funds

Total non-interest-bearing demand deposits

Interest-bearing deposits:

Private accounts:

Savings and interest checking
Money market deposit accounts
Time accounts

Public funds

Total interest-bearing deposits
Total deposits

Federal funds purchased and repurchase agreements
Junior subordinated deferrable interest debentures
Subordinated notes payable and other notes

503,929

(135,928)

876,442

1,240,986

$ 32,085,851

$ 9,829,635

213,442

315,339

10,358,416

6,777,473

7,738,654

989,907

548,827

16,054,861

26,413,277

1,283,381

136,272

98,792

4,650

71,584

16,298

7,210

99,742

19,675

5,706

4,657

Total interest-bearing liabilities and average rate paid

17,573,306

129,780

Accrued interest payable and other liabilities

Total liabilities

Shareholders’ equity

Total liabilities and shareholders’ equity

Net interest income
Net interest spread
Net interest income to total average earning assets

452,090

28,383,812

3,702,039

$ 32,085,851

2.33

4.06

3.40

5.17

4.20

4,222,688

7,842,737

12,065,425

13,617,940

86,370

322,855

409,225

674,177

28,899,578

1,145,870

2.03

4.11

3.38

4.95

3.96

496,418

(149,315)

536,056

1,247,113

$ 31,029,850

$ 10,164,396

205,727

386,685

10,756,808

6,667,695

7,645,624

800,096

418,843

15,532,258

26,289,066

1,054,915

136,215

98,635

5,369

59,175

6,441

4,352

75,337

8,021

5,291

4,657

16,822,023

93,306

166,643

27,745,474

3,284,376

$ 31,029,850

0.07

0.93

1.65

1.31

0.62

1.53

4.19

4.71

0.74

0.08

0.77

0.81

1.04

0.49

0.76

3.88

4.72

0.55

$ 1,100,586

$ 1,052,564

3.46%  

3.75%  

3.41%

3.64%

For these computations: (i) average balances are presented on a daily average basis, (ii) information is shown on a taxable-equivalent 
basis assuming a 21% tax rate in 2019 and 2018 and a 35% tax rate for prior years, (iii) average loans include loans on non-accrual status, 
and (iv) average securities include unrealized gains and losses on securities available for sale, while yields are based on average amortized 
cost.

130

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2017

Interest
Income/
Expense

Average
Balance

Yield
/Cost

Average
Balance

Year Ended December 31,

2016

Interest
Income/
Expense

Yield
/Cost

Average
Balance

2015

Interest
Income/
Expense

Yield
/Cost

Average
Balance

2014

Interest
Income/
Expense

Yield
/Cost

$ 3,579,737

$

41,608

1.16% $ 3,062,189

$

16,103

0.53% $ 3,047,515

$

8,123

0.27% $ 4,189,110

$

10,725

0.26%

73,140

936

1.28

42,361

272

0.64

24,695

107

0.43

19,683

83

0.42

103,025

369,335

472,360

463,299

952,034

2.01

5.57

4.02

4.01

3.60

112,601

340,417

453,018

439,651

900,899

2.11

5.59

3.97

3.90

3.50

93,087

271,543

364,630

447,036

822,474

2.14

5.58

3.96

4.34

3.47

5,251,192

6,806,448

12,057,640

11,554,823

26,717,013

513,441

(151,901)

562,875

1,190,665

$28,832,093

$ 9,215,962

310,445

507,912

10,034,319

5,745,385

7,466,252

811,102

454,786

14,477,525

24,511,844

770,942

136,100

99,933

4,892,827

7,353,279

12,246,106

12,460,148

92,979

391,730

484,709

542,703

28,359,131

1,069,956

1.92

5.37

3.99

4.36

3.79

505,611

(153,505)

522,625

1,216,345

$30,450,207

$10,155,502

245,759

418,165

10,819,426

6,376,855

7,502,494

775,940

430,203

15,085,492

25,904,918

978,571

136,157

90,037

1,303

12,721

1,764

1,400

17,188

1,522

3,955

3,860

16,290,257

26,525

167,260

27,276,943

3,173,264

$30,450,207

0.02

0.17

0.23

0.33

0.11

0.16

2.90

4.29

0.16

5,438,973

6,175,925

11,614,898

11,267,402

25,954,510

531,534

(107,799)

513,624

1,168,757

$28,060,626

$ 9,334,604

353,766

491,440

10,179,810

4,831,927

7,715,890

874,368

438,763

13,860,948

24,040,758

648,851

136,042

99,814

4,439,993

4,929,665

9,369,658

10,299,025

23,877,476

554,439

(97,932)

363,790

1,068,528

$25,766,301

$ 8,384,376

351,803

388,851

9,125,030

4,211,336

7,342,967

966,420

407,006

12,927,729

22,052,759

560,841

130,477

99,693

1,054

4,673

1,331

190

7,248

204

3,281

1,343

0.02

0.06

0.16

0.04

0.05

0.03

2.41

1.34

0.08

996

6,418

1,473

137

9,024

167

2,725

948

0.02

0.08

0.17

0.03

0.07

0.03

2.00

0.95

0.09

924

7,852

2,053

193

11,022

134

2,488

893

0.02

0.11

0.21

0.05

0.09

0.02

1.89

0.89

0.11

15,484,500

12,076

254,378

25,773,197

3,058,896

$28,832,093

14,745,655

12,864

239,969

25,165,434

2,895,192

$28,060,626

13,718,740

14,537

210,305

23,054,075

2,712,226

$25,766,301

$1,043,431

$ 939,958

$ 888,035

$ 807,937

3.63%  

3.69%  

3.52%  

3.56%  

3.41%  

3.45%  

3.36%

3.41%

131

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ITEM 9.  CHANGES  IN  AND  DISAGREEMENTS  WITH  ACCOUNTANTS  ON  ACCOUNTING  AND 
FINANCIAL DISCLOSURE

None

ITEM 9A. CONTROLS AND PROCEDURES

As of the end of the period covered by this Annual Report on Form 10-K, an evaluation was carried out by our 
management, with the participation of our Chief Executive Officer and Chief Financial Officer, of the effectiveness of 
our disclosure controls and procedures (as defined in Rule 13a-15(e) under the Securities Exchange Act of 1934). Based 
upon that evaluation, the Chief Executive Officer and Chief Financial Officer concluded that the disclosure controls 
and procedures were effective as of the end of the period covered by this report. No changes were made to our internal 
control over financial reporting (as defined in Rule 13a-15(f) under the Securities Exchange Act of 1934) during the 
last fiscal quarter that materially affected, or are reasonably likely to materially affect, our internal control over financial 
reporting.

Management’s Report on Internal Control Over Financial Reporting

The management of Cullen/Frost Bankers, Inc. is responsible for establishing and maintaining adequate internal 
control over financial reporting. Our internal control over financial reporting is a process designed under the supervision 
of our Chief Executive Officer and Chief Financial Officer to provide reasonable assurance regarding the reliability of 
financial reporting and the preparation of our financial statements for external purposes in accordance with generally 
accepted accounting principles.

As of December 31, 2019, management assessed the effectiveness of our internal control over financial reporting 
based on the criteria for effective internal control over financial reporting established in “Internal Control - Integrated 
Framework,” issued by the Committee of Sponsoring Organizations (“COSO”) of the Treadway Commission (“2013 
framework”). Based on the assessment, management determined that we maintained effective internal control over 
financial reporting as of December 31, 2019, based on those criteria.

Ernst & Young  LLP,  the  independent  registered  public  accounting  firm  that  audited  our  consolidated  financial 
statements included in this Annual Report on Form 10-K, has issued an attestation report on the effectiveness of our 
internal control over financial reporting as of December 31, 2019. The report, which expresses an unqualified opinion 
on the effectiveness of our internal control over financial reporting as of December 31, 2019, is included in this Item 
under the heading “Attestation Report of Independent Registered Public Accounting Firm.”

Attestation Report of Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm 

To the Shareholders and the Board of Directors of 
Cullen/Frost Bankers, Incorporated

Opinion on Internal Control over Financial Reporting

We have audited Cullen/Frost Bankers, Inc.’s internal control over financial reporting as of December 31, 2019, 
based  on  criteria  established  in  Internal  Control  -  Integrated  Framework  issued  by  the  Committee  of  Sponsoring 
Organizations  of  the  Treadway  Commission  (2013  framework)  (the  COSO  criteria).  In  our  opinion,  Cullen/Frost 
Bankers, Inc. (the Company) maintained, in all material respects, effective internal control over financial reporting as 
of December 31, 2019, based on the COSO criteria. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United 
States) (PCAOB), the consolidated balance sheets of the Company as of December 31, 2019 and 2018, and the related 
consolidated statements of income, comprehensive income, changes in shareholders’ equity and cash flows for each 
of the three years in the period ended December 31, 2019, and the related notes and our report dated February 4, 2020
expressed an unqualified opinion thereon.

132

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and 
for  its  assessment  of  the  effectiveness  of  internal  control  over  financial  reporting  included  in  the  accompanying 
Management’s Report on Internal Control Over Financial Reporting. Our responsibility is to express an opinion on the 
Company’s internal control over financial reporting based on our audit. We are a public accounting firm registered with 
the  PCAOB  and  are  required  to  be  independent  with  respect  to  the  Company  in  accordance  with  the  U.S.  federal 
securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and 
perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was 
maintained in all material respects. 

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a 
material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the 
assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that 
our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding 
the reliability of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles. A company’s internal control over financial reporting includes those 
policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly 
reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions 
are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting 
principles, and that receipts and expenditures of the company are being made only in accordance with authorizations 
of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely 
detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on 
the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. 
Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become 
inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may 
deteriorate.

San Antonio, Texas
February 4, 2020

ITEM 9B. OTHER INFORMATION

None

133

PART III

ITEM 10. DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

Certain information regarding executive officers is included under the section captioned “Executive Officers of the 
Registrant” in Part I, Item 1, elsewhere in this Annual Report on Form 10-K. Other information required by this Item 
is incorporated herein by reference to our Proxy Statement (Schedule 14A) for our 2020 Annual Meeting of Shareholders 
to be filed with the SEC within 120 days of our fiscal year-end.

ITEM 11. EXECUTIVE COMPENSATION

The information required by this Item is incorporated herein by reference to our Proxy Statement (Schedule 14A) 

for our 2020 Annual Meeting of Shareholders to be filed with the SEC within 120 days of our fiscal year-end.

ITEM 12.  SECURITY  OWNERSHIP  OF  CERTAIN  BENEFICIAL  OWNERS AND  MANAGEMENT AND 
RELATED STOCKHOLDER MATTERS

Certain information regarding securities authorized for issuance under our equity compensation plans is included 
under the section captioned “Stock-Based Compensation Plans” in Part II, Item 5, elsewhere in this Annual Report on 
Form  10-K.  Other  information  required  by  this  Item  is  incorporated  herein  by  reference  to  our  Proxy  Statement 
(Schedule 14A) for our 2020 Annual Meeting of Shareholders to be filed with the SEC within 120 days of our fiscal 
year-end.

ITEM 13.  CERTAIN  RELATIONSHIPS  AND  RELATED  TRANSACTIONS,  AND  DIRECTOR 
INDEPENDENCE

The information required by this Item is incorporated herein by reference to our Proxy Statement (Schedule 14A) 

for our 2020 Annual Meeting of Shareholders to be filed with the SEC within 120 days of our fiscal year-end.

ITEM 14. PRINCIPAL ACCOUNTING FEES AND SERVICES

The information required by this Item is incorporated herein by reference to our Proxy Statement (Schedule 14A) 

for our 2020 Annual Meeting of Shareholders to be filed with the SEC within 120 days of our fiscal year-end.

134

ITEM 15. EXHIBITS, FINANCIAL STATEMENT SCHEDULES
(a) 

The following documents are filed as part of this Annual Report on Form 10-K:

PART IV

1.  Consolidated Financial Statements. Reference is made to Part II, Item 8, of this Annual Report on Form 10-K.

2.  Consolidated Financial Statement Schedules. These schedules are omitted as the required information is inapplicable 

or the information is presented in the consolidated financial statements or related notes.

3. 

Exhibits. The exhibits to this Annual Report on Form 10-K listed below have been included only with the copy of 
this report filed with the Securities and Exchange Commission.

Exhibit
Number

Exhibit Description

3.1
3.2
3.3

Restated Articles of Incorporation of Cullen/Frost Bankers, Inc.
Amended and Restated Bylaws of Cullen/Frost Bankers, Inc.
Certificate of Designations of 5.375% Non-Cumulative Perpetual

Preferred Stock, Series A

4.1
4.2P(1)
10.1(2)
10.2(2)
10.3(2)

10.4(2)
10.5(2)
10.6(2)
10.7(2)
10.8(2)
10.9(2)
10.10(2)
10.11(2)
10.12(2)
10.13(2)

Description of Registrant's Securities
Instruments Defining the Rights of Holders of Long-Term Debt
Cullen/Frost Bankers, Inc. Restoration Plan
Amendment No. 1 to the Cullen/Frost Bankers, Inc. Restoration Plan
Thrift Incentive Stock Purchase Plan for Certain Employees of Cullen/

Frost Bankers, Inc.

Cullen/Frost Restoration Profit Sharing Plan
Amendment No. 1 to the Cullen/Frost Restoration Profit Sharing Plan
2005 Omnibus Incentive Plan
2007 Outside Director Incentive Plan
2015 Omnibus Incentive Plan
Amendment to the 2015 Omnibus Incentive Plan
Deferred Stock Unit Award Agreement with 12 Directors
Change-In-Control Agreements with 2 Executive Officers
Change-In-Control Agreements with 5 Executive Officers
Amendment to Change-In-Control Agreements with 7 Executive

Officers

21.1
23.1
24.1
31.1
31.2
32.1(3)
32.2(3)
101.INS(4)
101.SCH
101.CAL
101.DEF
101.LAB
101.PRE
104(5)

Subsidiaries of Cullen/Frost Bankers, Inc.
Consent of Independent Registered Public Accounting Firm
Power of Attorney
Rule 13a-14(a) Certification of the Chief Executive Officer
Rule 13a-14(a) Certification of the Chief Financial Officer
Section 1350 Certification of the Chief Executive Officer
Section 1350 Certification of the Chief Financial Officer
Inline XBRL Instance Document
Inline XBRL Taxonomy Extension Schema Document
Inline XBRL Taxonomy Extension Calculation Linkbase Document
Inline XBRL Taxonomy Extension Definition Linkbase Document
InlineXBRL Taxonomy Extension Label Linkbase Document
Inline XBRL Taxonomy Extension Presentation Linkbase Document
Cover Page Interactive Data File

_________________________

Incorporated by Reference

Filed
Herewith

Form

File No.

Exhibit

10-Q
8-K

8-A

10-K
10-K

10-K

10-K
10-K
DEF 14A
S-8
DEF 14A
10-K

001-13221
001-13221

001-13221

001-3221
001-3221

001-3221

001-3221
001-3221
001-13221
333-143397
001-13221
001-13221

3.1
3.2

3.3

10.1
10.2

10.3

10.7
10.8
Annex A
4.4
Annex A
10.12

Filing
Date

7/26/2006
1/28/2016

2/15/2013

2/6/2019
2/6/2019

2/6/2019

2/6/2019
2/6/2019
3/20/2013
5/31/2007
3/23/2015
2/3/2017

10-K

001-13221

10.4

2/6/2019

X

X

X

X

X
X
X
X
X
X
X
X
X
X
X
X
X

(1)  We agree to furnish to the SEC, upon request, copies of any such instruments.
(2)  Management contract or compensatory plan or arrangement.
(3)  This exhibit shall not be deemed “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, or otherwise subject to 
the liability of that section, and shall not be deemed to be incorporated by reference into any filing under the Securities Act of 1933 
or the Securities Exchange Act of 1934.

(4)  The instance document does not appear in the interactive data file because its XBRL tags are embedded within the Inline XBRL 

document.

(5)  Formatted as Inline XBRL and contained within the Inline XBRL Instance Document in Exhibit 101.

(b)  Exhibits - See exhibit index included in Item 15(a)3 of this Annual Report on Form 10-K.

(c)  Financial Statement Schedules - See Item 15(a)2 of this Annual Report on Form 10-K.

135

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ITEM 16. FORM 10-K SUMMARY

None

136

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused 

this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: February 4, 2020

CULLEN/FROST BANKERS, INC.
(Registrant)

By:

/s/  JERRY SALINAS
Jerry Salinas
Group Executive Vice President and Chief Financial Officer

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed by the following 

persons on behalf of the registrant and in the capacities and on the dates indicated.

Signature

Title

Date

/s/  PHILLIP D. GREEN*
Phillip D. Green

/s/  JERRY SALINAS
Jerry Salinas

/s/  CARLOS ALVAREZ*
Carlos Alvarez

/s/  CHRIS AVERY*
Chris Avery

/s/ CYNTHIA COMPARIN*
Cynthia Comparin

/s/ SAM DAWSON*
Sam Dawson

/s/ CRAWFORD H. EDWARDS*
Crawford H. Edwards

/s/  PATRICK B. FROST*
Patrick B. Frost

/s/  DAVID J. HAEMISEGGER*
David J. Haemisegger

/s/  KAREN E. JENNINGS*
Karen E. Jennings

/s/  RICHARD M. KLEBERG, III*
Richard M. Kleberg, III

/s/  CHARLES W. MATTHEWS*
Charles W. Matthews

/s/  IDA CLEMENT STEEN*
Ida Clement Steen

/s/  GRAHAM WESTON*
Graham Weston

/s/  HORACE WILKINS, JR.*
Horace Wilkins, Jr.

Chairman of the Board, Director and Chief
Executive Officer (Principal Executive Officer)

February 4, 2020

Group Executive Vice President and Chief
Financial Officer (Principal Financial Officer
and Principal Accounting Officer)

Director

Director

Director

Director

Director

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

Director and President of Frost Bank

February 4, 2020

Director

Director

Director

Director

Director

Director

Director

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

February 4, 2020

*By: /s/  JERRY SALINAS
Jerry Salinas
As attorney-in-fact for the persons indicated

Group Executive Vice President and Chief
Financial Officer (Principal Financial Officer
and Principal Accounting Officer)

February 4, 2020

137

NOTES

NOTES

NOTES