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FDIC Enforcement Decisions and Orders

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* Any increase in the loans should be fully explained in the PRESENT STATUS section.

{{7-31-92 p.C-745}}
   [10,163] In the Matter of Bank of Stamford, Stamford, Connecticut, Docket No. FDIC-91-3b (1-10-91).

   Bank to cease and desist from operating with an excessive volume of adversely classified assets; engaging in hazardous lending and lax collection practices; operating with an inordinate volume of overdue loans; operating with an undue concentration of loans; operating with inadequate primary capital; operating with management whose policies and practices are detrimental to the Bank; operating with deficient loan documentation; engaging in practices which produce inadequate income and excessive losses; failing to provide adequate supervision over the Bank's affairs; operating with inadequate allowance for loan and lease losses; operating with over-dependency on volatile liabilities; and operating with inadequate written investment policy. (This order was terminated by order of the FDIC dated 5-13-92; see ¶15,446.)

   [.1] Management—Qualifications—Review
   [.2] Management—Management Plan—Minimum Requirements—Review
   [.3] Board of Directors—Committee to Review Compliance—Cease and Desist Order
   [.4] Board of Directors—Election—Independent Directors
   [.5] Board of Directors—Meetings—Frequency—Written Records Required
   [.6] Assets—Adversely Classified—Reduce/Eliminate
   [.7] Capital—Primary Capital—Increase/Maintain
   [.8] Allowance for Loan and Lease Losses—Maintain—Report
   [.9] Loans—Risk Position—Written Plan—Minimum Requirements-Review
   [.10] Loans—Extensions of Credit—Existing Borrowers—Curtail
   [.11] Loans—Accrual of Interest
   [.12] Loans—Overdue—Collection Procedures—Establish
   [.13] Loan Policy—Review Required
   [.14] Profit Plan—Written Plan—Minimum Requirements—Review

{{7-31-92 p.C-746}}
   [.15] Funds Management—Written Policy—Minimum Requirements— Review
   [.16] Investments—Written Policy—Minimum Requirements—Review
   [.17] Dividends—Restricted
   [.18] Shareholders—Disclosure—Cease and Desist Order
   [.19] Technical Exceptions—Correct
   [.20] Loans—Concentrations—Reduce
   [.21] Loans—Special Mention
   [.22] Compliance—Progress Reports—Frequency

In the Matter of

BANK OF STAMFORD
STAMFORD, CONNECTICUT
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST

   Bank of Stamford, Stamford, Connecticut, ("Bank") having been advised of its right to a Notice of Charges and of Hearing detailing the unsafe or unsound banking practices alleged to have been committed by the Bank and of its right to a hearing on such alleged charges under section 8(b)(1) of the Federal Deposit Insurance Act ("Act"), 12 U.S.C. § 1818(b) (1), and having waived those rights, entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST ("CONSENT AGREEMENT") with counsel for the Federal Deposit Insurance Corporation ("FDIC") dated December 27, 1990, whereby solely for the purpose of this proceeding and without admitting or denying any unsafe or unsound banking practices, the Bank consented to the issuance of an ORDER TO CEASE AND DESIST ("ORDER") by the FDIC.
   The FDIC considered the matter and determined that it had reason to believe that the Bank had engaged in unsafe or unsound banking practices. The FDIC, therefore, accepted the CONSENT AGREEMENT and issued the following:

ORDER TO CEASE AND DESIST

   IT IS HEREBY ORDERED, that the Bank and its institution-affiliated parties, as that term is defined in section 3(u) of the Act, 12 U.S.C. § 1813(u), cease and desist from the following unsafe or unsound banking practices:

       (a) operating with an excessive volume of adversely classified assets;
       (b) engaging in hazardous lending and lax collection practices, including maintaining an excessive volume of adversely classified loans;
       (c) operating with an inordinate volume of overdue loans;
       (d) operating with an undue concentration of bank funds loaned to certain borrowers and their related interests;
       (e) operating with inadequate primary capital for the kind and quality of assets held;
       (f) operating with management whose policies and practices are detrimental to the Bank;
       (g) operating with deficient or inadequate loan documentation, including but not limited to current financial statements, insurance coverage, title searches or legal opinions, and appraisals;
       (h) engaging in practices which produce inadequate operating income and excessive loan losses;
       (i) failing to provide adequate supervision and direction over the affairs of the Bank to prevent unsafe or unsound practices;
       (j) operating with an inadequate allowance for loan and lease losses for the volume, kind and quality of loans held;
       (k) operating with an over-dependency on volatile liabilities for funding purposes; and
       (l) operating with an inadequate written investment policy.
   IT IS FURTHER ORDERED, that the Bank and its institution-affiliated parties take affirmative action as follows:

   [.1] 1. (a) The Bank shall have and retain qualified management. At a minimum, such management shall include a chief executive officer and a senior loan officer with proven ability in managing a bank of comparable size and experience in upgrading a low quality loan portfolio. Such persons shall be provided the necessary writ- {{3-31-91 p.C-747}}ten authority to implement the provisions of this ORDER. The qualifications of management shall be assessed on its ability to:

       (i) comply with the requirements of this ORDER,
       (ii) operate the Bank in a safe and sound manner,
       (iii) comply with applicable laws and regulations, and
       (iv) restore all aspects of the Bank to a safe and sound condition, including asset quality, adequate risk diversification, capital adequacy, earnings, liquidity and management effectiveness.
   During the life of this ORDER, the Bank shall notify the Regional Director of the Boston Regional Office ("Regional Director") and the Banking Commissioner for the State of Connecticut ("Banking Commissioner") in writing of any changes in management. The notification must include the names and background of any replacement personnel and must be provided at least thirty (30) days prior to the individual's assuming the new position.

   [.2] (b) Towards this end, within thirty (30) days from the effective date of this ORDER, the Board of Directors shall develop a written analysis and assessment of the Bank's management and staffing needs ("management plan") which shall include, at a minimum:

       (i) identification of both the type and number of officer positions needed to manage and supervise properly the affairs of the Bank;
       (ii) identification and establishment or reorganization of such Bank committees as are needed to provide guidance and oversight to active management;
       (iii) evaluation of each Bank officer, and in particular the chief executive officer, and staff member to determine whether these individuals possess the ability, experience and other qualifications required to perform present and anticipated duties, including adherence to the Bank's established policies and practices, and maintenance of the Bank in a safe and sound condition; and
       (iv) a plan of action to recruit and hire any additional or replacement personnel with the requisite ability, experience and other qualifications, which the Board of Directors determines are necessary to fill Bank officer or staff member positions consistent with the Board's analysis, evaluation and assessment as provided in paragraphs 1(b)(i) and 1(b) (iii) of this ORDER.
   (c) The written management plan shall be submitted to the Regional Director and the Banking Commissioner for review and comment. No sooner than thirty (30) days, but under no circumstances more than forty-five (45) days after such submission, the Board of Directors shall approve the written management plan, taking into consideration any regulatory comments, and such approval shall be recorded in the minutes of the Board of Directors. Subsequent modifications to the written management plan may be made only after giving the Regional Director and the Banking Commissioner written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Banking Commissioner within thirty (30) days from their receipt of the notice of proposed modification. No such modification shall become effective until approved by the Board of Directors, and such approval shall be recorded in the minutes of the Board of Directors. The Bank, its directors, officers and employees shall implement and follow the written management plan and/or any subsequent modification thereto.

   [.3] (d) (i) The written management plan shall also include the requirement that the Board of Directors of the Bank, or a committee thereof consisting of not less than a majority of Board members who are independent with respect to the Bank, provide supervision over lending, investment and operating policies of the Bank sufficient to ensure that the Bank complies with the provisions of this ORDER.

   [.4] (ii) At the next meeting of the shareholders of the Bank, and at each succeeding meeting of the shareholders at which Bank directors are to be elected, the members of the Board of Directors who are also shareholders shall nominate and support the election of candidates to the Board of Directors who are independent with respect to the Bank, in such number as is necessary to cause a majority of the Board of Direc- {{3-31-91 p.C-748}}tors to be and to remain independent with respect to the Bank.
   (iii) For purposes of this ORDER, an individual who is "independent with respect to the Bank" shall be any individual (1) who is not an officer of the Bank or any of its affiliated organizations and who does not own more than five (5.0) percent of the outstanding shares of the Bank, (2) who is not related by blood, marriage or common financial interest to an officer of the Bank or to any stockholder owning more than five (5.0) percent of the Bank's outstanding shares, and (3) who is not indebted to the Bank, directly or indirectly (including the indebtedness of any entity in which the individual has a substantial financial interest), in an amount exceeding five (5.0) percent of the Bank's total equity capital and allowance for loan and lease losses.
   (e) Each member of the Bank's loan committee shall have the qualifications and experience necessary to effectively carry out his or her duties and responsibilities as a committee member.

   [.5] (f) The Bank's Board of Directors shall meet at least monthly. The Board shall prepare in advance and shall follow a detailed written agenda at each meeting, which shall include consideration of actions of any committees. A chronological file of all written agendas shall be maintained. Notwithstanding the foregoing, the Board shall not be precluded from considering matters other than those contained in the agenda. Detailed written minutes of all Board meetings shall be maintained and recorded on a timely basis.

   [.6] 2. Within ten (10) days from the effective date of this ORDER, the Bank: (1) shall eliminate from its books, by charge-off or collection, all assets or portions of assets classified "Loss" as of April 12, 1990; and (2) shall either (A) eliminate from its books by charge-off or collection, or (B) if the asset is an extension of credit or lease, increase its allowance for loan and lease losses by an amount equal to, fifty (50.0) percent of those assets or portions of assets classified "Doubtful" as of April 12, 1990, which have not been previously collected or charged off. Reduction of these assets through use of proceeds of loans made by the Bank does not constitute "collection" or "elimination" for the purpose of this paragraph.

   [.7] 3. (a) Within one hundred eighty (180) days from the effective date of this ORDER, the Bank shall have primary capital at or in excess of eight (8.0) percent of the Bank's total assets ("primary capital ratio") and shall continue to maintain its primary capital ratio at or in excess of such level as calculated herein while this ORDER is in effect. Toward this end, the Bank shall develop a Capital Plan which will be submitted to the Regional Director and the Banking Commissioner for approval with sixty (60) days from the effective date of this ORDER. The Capital Plan should address both internal and external sources of capital augmentation, including capital infusions, retention of earnings, restrictions of asset growth and asset sales.
   (b) For the purposes of calculating the primary capital ratio required by paragraph 3 of this ORDER, the terms "primary capital" and "total assets" shall have the same meanings ascribed to them in Part 325 of the FDIC's Rules and Regulations, 12 C.F.R. Part 325.
   (c) If, after having reached the eight (8.0) percent primary capital ratio required by paragraph 3(a), such ratio thereafter declines below eight (8.0) percent, the Bank, within thirty (30) days after the date on which the said ratio so declined, shall submit a written plan to the Regional Director and the Banking Commissioner for increasing such ratio up to or in excess of eight (8.0) percent within sixty (60) days after the written plan is implemented. Thereafter, the Bank shall continue to maintain its primary capital ratio at or in excess of such level as calculated herein while this ORDER is in effect. Upon approval by the Regional Director and the Banking Commissioner, the Bank shall immediately implement the written plan.
   (d) The Bank's Board of Directors shall maintain in its minutes a written record of all actions taken by the Bank to comply with the capital requirements of paragraphs 3(a) through 3(c) of this ORDER.

   [.8] 4. (a) Within thirty (30) days from the effective date of this ORDER, the Bank shall increase its allowance for loan and lease losses existing as of April 12, 1990 by $3,200,000 at a minimum. Thereafter, {{3-31-91 p.C-749}}the Bank shall maintain an allowance for loan and lease losses in accordance with the prevailing requirements of the Instructions for the Reports of Condition and Income ("Instructions"), but in no case shall the allowance for loan and lease losses be less than one (1) percent of the total loans and leases on the Bank's books.
   (b) Reports of Condition and Income required to be submitted by the Bank as of each Report date, as that term is used in the Instructions, between and including September 30, 1990, and the effective date of this ORDER, shall, at a minimum, reflect an allowance for loan and lease losses that should have been maintained in accordance with the Instructions. If necessary to comply with this paragraph 4(b), the Bank shall file amended Reports of Condition and Income within ten (10) days from the effective date of this ORDER.
   (c) Prior to the submission of any Report of Condition or Report of Income required to be filed by the Bank after the effective date of this ORDER, the Board of Directors of the Bank shall: (1) review the adequacy of the Bank's allowance for loan and lease losses, (2) provide for an adequate allowance, and (3) accurately report the allowance in any such Report of Condition and Income. The minutes of the Board meeting at which such review is undertaken shall indicate the results of the review, including any increases in the allowance, and the basis for determining the amount of allowance provided.

   [.9] 5. (a) Within ninety (90) days from the effective date of this ORDER, the Board of Directors shall develop a written plan of action to lessen the Bank's risk position in each extension of credit aggregating $100,000 or more which was classified "Substandard" or "Doubtful" as of April 12, 1990. In developing such plan, the Bank shall, at a minimum:

       (i) review the financial position of each such borrower, including source of repayment, repayment ability, and alternative repayment sources; and
       (ii) evaluate the available collateral for each such credit, including possible actions to improve the Bank's collateral position.
   Based upon such review and evaluation, the written plan of action shall also: (A) establish target dollar levels at six (6) month intervals to which the Bank shall reduce the aggregate dollar volume of "Substandard" or "Doubtful" classifications to forty (40) percent of primary capital within twenty-four (24) months from the effective date of this ORDER; and (B) provide for the submission of written monthly progress reports thereon to the Bank's Board of Directors for review and notation in the Board minutes. Exhibit A provides the form for the progress report. As used in this paragraph 5, "reduce" means to (1) collect, (2) charge off, or (3) improve the quality of such assets so as to warrant removal of any adverse classification by the FDIC and the State banking department. Payment of loans with the proceeds of the other loans made by the Bank will not constitute "reduction" or "collection" for purposes of this ORDER.
   (b) The written plan of action described by paragraph 5(a) shall be submitted to the Regional Director and the Banking Commissioner for review and comment. No sooner than thirty (30) days, but under no circumstances more than forty-five (45) days after such submission, the Board of Directors shall approve the written plan of action, taking into consideration any regulatory comments, and such approval shall be recorded in the minutes of the Board of Directors. Subsequent modifications to the written plan may be made only after giving the Regional Director and the Banking Commissioner written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Banking Commissioner within thirty (30) days from their receipt of the notice of proposed modification. No such modification shall become effective until approved by the Board of Directors, and such approval shall be recorded in the minutes of the Board of Directors. The Bank, its directors, officers and employees shall follow the written plan of action and/or any subsequent modification.

   [.10] 6. The Bank shall not extend or renew, directly or indirectly, credit to, or for the benefit of, any borrower who has a loan or other extension of credit with the Bank that has been charged off or classified, in whole or in part, "Loss," "Doubtful," or "Substandard," and is uncollected, unless a {{3-31-91 p.C-750}}majority of the Bank's Board of Directors first (1) determines that such advance is in the best interest of the Bank, (2) determines that the Bank has satisfied the requirements set out in paragraph 5 of this ORDER as to such borrower, and (3) approves such advance. A written record of the Board of Directors' determination and approval of any advance under the terms of this paragraph 6 shall be maintained in the credit file of the affected borrower(s) as well as the minutes of the Board of Directors.

   [.11] 7. The Bank shall not accrue interest on any loan that is, or becomes, ninety (90) days or more delinquent as to principal or interest, unless the loan is both well secured and in the process of collection. For purposes of this paragraph 7, "well secured" and "in the process of collection" shall have the same meaning as those terms have in the prevailing Instructions for the Reports of Condition and Income ("Instructions"). The Bank shall reverse on its books all previously accrued but uncollected interest on any loan that has ceased to accrue interest pursuant to this provision.

   [.12] 8. The Board shall establish prudent collection procedures with the goal of reducing the ratio of past due and nonaccrual loans to total loans to under six (6.0) percent within three hundred sixty (360) days from the effective date of this ORDER through cash collections or the equivalent, and to endeavor to further reduce loans in a manner consistent with the best interest of the Bank. The six (6.0) percent level should not be construed as a standard for future operations. The terms "past due loans" and nonaccrual loans" shall have the same meanings as is given those terms in the Instructions.

   [.13] 9. Within thirty (30) days from the effective date of this ORDER, the Bank shall review the Bank's written loan policy and shall record the results of such review in the Board of Directors' minutes. The Board of Directors shall take steps to insure the Bank's future compliance with its written loan policy.

   [.14] 10. (a) Within thirty (30) days from the effective date of this ORDER, the Bank shall develop a written profit plan consisting of goals and strategies for improving the earnings of the Bank, which written profit plan shall include, at a minimum:

       (i) identification of the major areas in, and means by, which the Board of Directors will seek to improve the Bank's operating performance;
       (ii) realistic and comprehensive budgets;
       (iii) a budget review process to monitor the income and expenses of the Bank to compare actual figures with budgetary projections; and
       (iv) a description of the operating assumptions that form the basis for, and adequately support, major projected income and expense components.
   (b) The written profit plan shall be submitted to the Regional Director and the Banking Commissioner for review and comment. No sooner than thirty (30) days, but under no circumstances more than forty-five (45) days after such submission, the Board of Directors shall approve the written profit plan, taking into consideration any regulatory comments, and such approval shall be recorded in the minutes of the Board of Directors. Subsequent modifications to the written profit plan may be made only after giving the Regional Director and the Banking Commissioner written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Banking Commissioner within thirty (30) days from their receipt of the notice of proposed modification. No such modification shall become effective until approved by the Board of Directors, and such approval shall be recorded in the minutes of the Board of Directors. The Bank, its directors, officers, and employees shall follow the written profit plan and/or any subsequent modification thereto.

   [.15] 11. (a) Within thirty (30) days from the effective date of this ORDER, the Bank shall develop a written funds management policy which shall include, at a minimum:

       (i) the Bank's liquidity needs and plans for ensuring that such needs are met on an ongoing basis;
       (ii) goals and strategies for managing and/or improving the Bank's interest rate risk exposure;
       (iii) monitoring of the interest rate sensitivity of present investments and deposits, and projections of the types of investments and deposits to improve such interest rate sensitivity position {{3-31-91 p.C-751}}with the objective of achieving and maintaining a ratio of rate sensitive assets to rate sensitive liabilities within a range of 85% to 115% for prospective six (6) and twelve (12) month time frames; and
       (iv) coordination of the Bank's loan, investment, operating, and budget and profit planning policies with the written funds management policy.
   (b) The written funds management policy shall be submitted to the Regional Director and the Banking Commissioner for review and comment. No sooner than thirty (30) days, but under no circumstances more than forty-five (45) days after such submission, the Board of Directors shall approve the written funds management policy, taking into consideration any regulatory comments, and such approval shall be recorded in the minutes of the Board of Directors. Subsequent modifications to the written funds management policy may be made only after giving the Regional Director and the Banking Commissioner written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Banking Commissioner within thirty (30) days from their receipt of the notice of proposed modification. No such modification shall become effective until approved by the Board of Directors, and such approval shall be recorded in the minutes of the Board of Directors. The Bank, its directors, officers and employees shall follow the written funds management policy and/or any subsequent modification thereto.

   [.16] 12. Within thirty (30) days from the effective date of this ORDER, the Bank shall develop a written investment policy consisting of goals and strategies for improving the quality of the Bank's investment portfolio. The written investment policy shall be submitted to the Regional Director and the Banking Commissioner for review and comment. No sooner than thirty (30) days, but under no circumstances more than forty-five (45) days after such submission, the Board of Directors shall approve the written investment plan, taking into consideration any regulatory comments, and such approval shall be recorded in the minutes of the board. Subsequent modifications to the written investment policy may be made only after giving the Regional Director and the Banking Commissioner written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Banking Commissioner within thirty (30) days from their receipt of the notice of proposed modification. No such modification shall become effective until approved by the Board of Directors, and such approval shall be recorded in the minutes of the Board of Directors. The Bank, its directors, officers and employees shall follow the written investment plan and/or any subsequent modification thereto.

   [.17] 13. The Bank shall not pay or declare any dividends without the prior written consent of the Regional Director and the Banking Commissioner.

   [.18] 14. Following the effective date of this ORDER, the Bank shall send to its shareholders a description of this ORDER, (1) in conjunction with the Bank's next shareholder communication, and also (2) in conjunction with its notice or proxy statement preceding the Bank's next shareholder meeting. The description shall fully describe the ORDER in all material respects. The description and any accompanying communication, statement, or notice shall be sent to the FDIC, Registration and Disclore Section, Washington, D.C. 20429, for review at least twenty (20) days prior to dissemination to shareholders. Any changes requested to be made by the FDIC shall be made prior to dissemination of the description, communication, notice, or statement.

   [.19] 15. (a) Within sixty (60) days from the effective date of this ORDER, the Bank shall correct the technical exceptions on loans noted on pages 2-c of the State Report of Examination of the Bank as of April 12, 1990.

   [.20] (b) Within (60) days from the effective date of this ORDER, the Bank shall formulate and implement a plan to reduce, as noted on page 2-b of the State Report of Examination of the Bank as of April 12, 1990, the "Borrower Concentration" to less than fifteen (15.0) percent of total equity capital and allowance for loan and lease losses.

   [.21] (c) Within (60) days from the effective date of this ORDER, the Bank shall correct the cited deficiencies in the loans {{3-31-91 p.C-752}}listed for "Special Mention" on page 2-d of the State Report of Examination of the Bank as of April 12, 1990.

   [.22] 16. Within forty-five (45) days from December 31, 1990 and, thereafter, within forty-five (45) days from the end of each calendar quarter, the Bank shall furnish written progress reports to the Regional Director and the Banking Commissioner detailing the form and manner of any action taken to secure compliance with this ORDER and the results thereof. Such progress reports shall also include copies of the currently due FDIC Reports of Condition and Income. In addition, the Bank shall furnish such reports on request of either the Regional Director or the Banking Commissioner. All progress reports and other written responses to this ORDER shall be reviewed by the Board of Directors of the Bank and made a part of the minutes of the Board meeting.
   This ORDER shall become effective ten (10) days from the date of its issuance.
   The provisions of this ORDER shall be binding upon the Bank and its institution-affiliated parties.
   This ORDER has been reviewed and concurred in by the Banking Commissioner for the State of Connecticut.
   The provisions of this ORDER shall remain effective and enforceable except to the extent that, and until such time as, any provisions of this ORDER shall have been modified, terminated, suspended, or set aside by the FDIC.
   Pursuant to delegated authority.
   Dated at Needham, Massachusetts this 10th day of January, 1991.

BANK OF STAMFORD
STAMFORD, CONNECTICUT

CRITICIZED ASSET REPORT
AS OF: _____
__________________________________________________________________________
BORROWER(S):
__________________________________________________________________________
LOAN BALANCE(S) AND RATING CRITICISM (SPECIAL MENTION, SUBSTANDARD, DOUBTFUL OR LOSS):
CLASSIFIED LOAN BALANCE(S): $ _____
PRESENT LOAN BALANCE(S): $ _____
CRITICISM _____
AMOUNT CHARGED OFF TO DATE _____ FUTURE POTENTIAL CHARGE-OFF _____
__________________________________________________________________________
PRESENT STATUS*(Include past due status, nonaccrual, significant progress of collection, deterioration, etc.):
__________________________________________________________________________
FINANCIAL AND/OR COLLATERAL SUPPORT (Include brief summary of most current financial info, appraised value of collateral and/or estimated value and date thereof, bank's lien position and amount of available equity, if any, guarantor(s) info, etc.):
__________________________________________________________________________
PROPOSED PLAN OF ACTION TO ELIMINATE ASSET CRITICISM(S) AND TIME FRAME FOR ITS ACCOMPLISHMENT:
__________________________________________________________________________
IDENTIFIED SOURCE OF REPAYMENT AND DEFINED REPAYMENT PROGRAM (Repayment program should coincide with source of repayment):
__________________________________________________________________________
Use this form for reporting each criticized asset which exceeds one hundred thousand dollars ($100,000) and retain the original in the credit file for review by the examiners. Submit your reports quarterly, in writing, until notified otherwise by the FDIC Regional Director and the Banking Commissioner.

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