23.               RELATED PARTY TRANSACTIONS

At December 31, 2013 and 2012, certain directors, executive officers, principal holders of the Company’s common stock, associates of such persons, and affiliated companies of such persons were indebted, including undrawn commitments to lend, to the Bank in the aggregate amount of $463 thousand and $386 thousand, respectively.

Commitments to lend to related parties as of December 31, 2013 and 2012 were comprised of $4 thousand and $2 thousand, respectively to directors and none to executive officers.  The commitments are in the form of loans and guarantees for various business and personal interests.  This indebtedness was incurred in the ordinary course of business on substantially the same terms, including interest rate and collateral, as those prevailing at the time of comparable transactions with unrelated parties.  This indebtedness does not involve more than the normal risk of repayment or present other unfavorable features.

None of the Company’s affiliates, officers, directors or employees have an interest in or receive remuneration from any special purpose entities or qualified special purpose entities which the Company transacts business.

The Company maintains a written policy and procedures covering related party transactions.  These procedures cover transactions such as employee-stock purchase loans, personal lines of credit, residential secured loans, overdrafts, letter of credit and increases in indebtedness.  Such transactions are subject to the Bank’s normal underwriting and approval policies and procedures.