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EXCEL - IDEA: XBRL DOCUMENT - COMMUNITY FIRST INCFinancial_Report.xls
EX-21.1 - EX-21.1 - COMMUNITY FIRST INCd837441dex211.htm
EX-31.2 - EX-31.2 - COMMUNITY FIRST INCd837441dex312.htm
EX-23.1 - EX-23.1 - COMMUNITY FIRST INCd837441dex231.htm
EX-32.1 - EX-32.1 - COMMUNITY FIRST INCd837441dex321.htm
EX-99.1 - EX-99.1 - COMMUNITY FIRST INCd837441dex991.htm
EX-31.1 - EX-31.1 - COMMUNITY FIRST INCd837441dex311.htm
EX-32.2 - EX-32.2 - COMMUNITY FIRST INCd837441dex322.htm
10-K - FORM 10-K - COMMUNITY FIRST INCd837441d10k.htm

Exhibit 99.2

CERTIFICATION OF CHIEF FINANCIAL OFFICER

UNDER SECTION 111(B)4 OF EESA

I, Jon Thompson, Chief Financial Officer, of Community First, Inc. (the “Company”), certify, based on my knowledge, that:

(i) The compensation committee of the Company has discussed, reviewed, and evaluated with the senior risk officer at least every six months during any part of the most recently completed fiscal year that was a TARP period (January 1, 2014 through April 14, 2014, such period the “applicable period”), senior executive officer (SEO) compensation plans and employee compensation plans and the risk these plans pose to the Company;

(ii) The compensation committee of the Company has identified and limited during the applicable period any features of the SEO compensation plans that could lead SEOs to take unnecessary and excessive risks that could threaten the value of the Company and has identified any features of the employee compensation plans that pose risks to the Company and has limited those features to ensure that the Company is not unnecessarily exposed to risks;

(iii) The compensation committee has reviewed, at least every six months during the applicable period ending April 3, 2014, the terms of each employee compensation plan and identified any features of the plan that could encourage the manipulation of reported earnings of the Company to enhance the compensation of an employee, and has limited any such features;

(iv) The compensation committee of the Company will certify to the reviews of the SEO compensation plans and employee compensation plans required under (i) and (iii) above;

(v) The compensation committee of the Company will provide a narrative description of how it limited during the applicable period the features in:

 

  (A) SEO compensation plans that could lead SEOs to take unnecessary and excessive risks that could threaten the value of the Company;

 

  (B) Employee compensation plans that unnecessarily expose the Company to risks; and

 

  (C) Employee compensation plans that could encourage the manipulation of reported earnings of the Company to enhance the compensation of an employee;

(vi) The Company has required that bonus payments to SEOs or any of the next twenty most highly compensated employees, as defined in the regulations and guidance established under section 111 of EESA (bonus payments), be subject to a recovery of “clawback” provision during the applicable period if the bonus payments were based on materially inaccurate financial statements or any other materially inaccurate performance metric criteria;


(vii) The Company has prohibited any golden parachute payment, as defined in the regulations and guidance established under section 111 of EESA, to a SEO or any of the next five most highly compensated employees during the applicable period;

(viii) The Company has limited bonus payments to its applicable employees in accordance with section 111 of EESA and the regulations and guidance established thereunder during the applicable period;

(ix) The Company and its employees have complied with the excessive or luxury expenditures policy, as defined in the regulations and guidance established under section 111 of EESA, during the applicable period; and any expenses that, pursuant to the policy, required approval of the board of directors, a committee of the board of directors, an SEO, or an executive officer with a similar level of responsibility were properly approved;

(x) The Company will permit a non-binding shareholder resolution in compliance with any applicable Federal securities rules and regulations on the disclosures provided under the Federal securities laws related to SEO compensation paid or accrued during the applicable period;

(xi) The Company will disclose the amount, nature, and justification for the offering during the applicable period of any perquisites, as defined in the regulations and guidance established under section 111 of EESA whose total value exceeds $25,000 for any employee who is subject to the bonus payment limitations identified in paragraph (viii);

(xii) The Company will disclose whether the Company, the board of directors of the Company, or the compensation committee of the Company has engaged during the applicable period, a compensation consultant; and the services the compensation consultant or any affiliate of the compensation consultant provided during this period;

(xiii) The Company has prohibited the payment of any gross-ups, as defined in the regulations and guidance established under section 111 of EESA, to the SEOs and the next twenty most highly compensated employees during the applicable period;

(xiv) The Company has substantially complied with all other requirements related to employee compensation that are provided in the agreement between the Company and Treasury, including any amendments;

(xv) On April 14, 2014, the U.S. Department of the Treasury completed its sale of the Company preferred stock that it held as a result of the Company’s participation in the TARP Capital Purchase Program. Therefore, the standard referred to in paragraph (xv) of the Model Certification for Years Following First Year Certification set forth in the regulations and guidance established under section 111 of EESA, was not required to be met by the Company;


(xvi) I understand that a knowing and willful false or fraudulent statement made in connection with this certification may be punished by fine, imprisonment, or both. (See, for example, 18 USC 1001).

 

Date: February 27, 2015

/s/ Jon Thompson

Jon Thompson,
Chief Financial Officer