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[¶10,205] In the Matter of American Savings Bank, White Plains, New York, Docket No. FDIC-91-101b (3-26-91).
Bank to cease and desist from operating with inadequate capital; failing to provide and adequate reserve for loan losses; operating with an excessive level of poor quality assets; operating so as not to produce stable operating earnings; failing to follow adequate loan policies and procedures; operating with an excessive imbalance of rate sensitive liabilities; and operating with an excessive reliance on collateralized wholesale funding sources and brokered deposits. (This order was terminated by order of the FDIC dated 6-23-92; see ¶ 15,471.)
[.1] Capital—Capital Ratio—Increase—Written Plan Required
[.2] Capital Plan—Progress Report
[.3] Dividends—Restricted
[.4] Business Plan—Written Plan—Minimum Requirements—Review
[.5] Real Estate Activities—Appraisals Required
[.6] Assets—Adversely Classified—Reduce/Eliminate—Schedule
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[.7] Loan Loss Reserve—Compute/Maintain—Report
[.8] Loans—Extensions of Credit—Existing Borrowers—Curtail
[.9] Problem Assets—Individual Written Plans Required
[.10] Problem Assets—Review by Investment Committee
[.11] Loans—Documentation—Review
[.12] Brokered Deposits—Reduction—Written Plan—Minimum
[.13] Funds Management Policy—Requirements—Review
[.14] Management—Qualifications
[.15] Board of Directors—Committee to Review Compliance—Cease and Desist Order
[.16] Shareholders—Disclosure—Cease and Desist Order
[.17] Compliance—Progress Reports—Frequency
In the Matter of
AMERICAN SAVINGS BANK
WHITE PLAINS, NEW YORK
(Insured State Savings Bank)
ORDER TO CEASE AND DESIST
American Savings Bank, White Plains, New York ("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) of the Federal Deposit Insurance Act ("Act"), 12 U.S.C. § 1818(b), 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 March 26, 1991, whereby, solely for the purpose of this proceeding and without admitting or denying the alleged charges of 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, including the Report of Examination of the Bank by the FDIC as of March 31, 1990, 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 American Savings Bank, White Plains, New York, its successors, assigns, directors, officers, employees, agents, and other "institution-affiliated parties", as 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 the Bank with capital which is inadequate in relation to the kind and quality of its assets;
(b) Failing to provide an adequate reserve for loan losses;
(c) Operating the Bank with an excessive level of poor quality assets;
(d) Operating the Bank in such a manner so as not to produce stable operating earnings;
(e) Failing to follow adequate loan policies and procedures;
(f) Operating the Bank with an excessive imbalance of rate sensitive liabilities in relation to rate sensitive assets; and,
(g) Operating the Bank with an excessive reliance on collateralized wholesale funding sources and brokered deposits.
IT IS FURTHER ORDERED, that American Savings Bank, White Plains, New York, its successors, assigns, directors, officers, employees, agents, and other institution-affiliated parties, take AFFIRMATIVE action as follows:
[.1] 1. Within 90 days from the effective date of this ORDER, the Bank shall submit a capital plan to the Regional Director of the New York Regional Office of the FDIC ("Regional Director") and the Superintendent of Banks ("Superintendent") of the New
{{5-31-91 p.C-908}} York State Banking Department ("Department"), which provides for:
(a) recapitalizing the Bank so as to increase the ratio of its Tier 1 capital to its total assets to not less than 4 ½ percent by March 31, 1992, and 5 percent by March 31, 1993, and thereafter maintain that ratio; the ratio requirements set forth in this paragraph 1(a) are dependent upon the Bank achieving compliance with the ratio requirements of paragraph 6(b) of this ORDER. Therefore, notwithstanding the requirements set forth in this paragraph 1(a), if the Bank is not in compliance with the requirements of paragraph 6(b) of this ORDER as of March 31, 1993, the Bank shall be required to achieve a greater ratio of Tier 1 capital to total assets. Such additional capital requirements shall be determined by the FDIC, giving consideration to the asset quality and condition of the Bank at such time as the Bank is not in compliance with the requirements of paragraph 6(b) of this ORDER;
(b) exploring all methods and opportunities for achieving the capital ratio levels set forth in subparagraph (a) above, including, but not limited to, conversion of the Bank's outstanding preferred stock to a security that constitutes Tier 1 capital, asset sales, downsizing of the Bank, the sale of subsidiaries, income retention, the sale of portions of the deposit franchise, overhead reduction, the sale of preferred and/or common stock, with a willingness to incur the level of dilution necessary to attract the requisite capital, merger or consolidation, and private investor acquisition or investment.
Upon receipt of a written approval or statement of nonobjection from the Regional Director and the Superintendent, the revised capital plan shall forthwith be adopted and implemented. For purposes of this ORDER, the terms "Tier 1 capital" and "total assets," shall be defined as those terms are defined in the amendments to Part 325 of the FDIC's Rules and Regulations ("Regulations"), which were adopted by the Board of Directors of the FDIC on February 28, 1991 (to be codified at 12 C.F.R. Part 325), with the exception that goodwill attendant to the acquisitions of United Mutual Savings Bank and Riverhead Savings Bank, FSB, will not be deducted in such computation which shall be performed on a wholly consolidated basis.
[.2] 2. By the fifteenth day of each calendar quarter, the Bank shall provide the Regional Director and the Superintendent with a progress report, in form and content acceptable to the Regional Director, discussing in detail all capital-raising alternatives explored pursuant to paragraph 1 of this ORDER. The progress report shall include, but not be limited to, information about third parties contacted, and attendant information which would assist the FDIC and the Department in evaluating the Bank's actions and progress in achieving the capital ratio levels set forth in paragraph 1 of this ORDER.
[.3] 3. While this ORDER is in effect, the Bank shall not declare or pay any dividend either directly or indirectly, whether in cash, stock, or otherwise, on any class of its stock, unless (i) the Bank is at the time of any such declaration and payment in full compliance with the requirements of paragraph 1 of this ORDER, and (ii) the declaration and payment of any such dividend has received the specific prior written consent of the Regional Director and the Superintendent.
[.4] 4. Within 90 days from the effective date of this ORDER, the Bank shall submit a business plan to the Regional Director and the Superintendent consistent with the provisions of paragraph 1 of this ORDER, such plan to be implemented upon receipt of the written approval or statement of non objection pursuant to paragraph 1(b) of this ORDER and which shall provide for the following:
(a) the Bank shall not engage in nor shall it permit any subsidiary to engage in any new construction lending other than (i) fulfilling legally binding commitments which are outstanding on the effective date of this ORDER and (ii) constructing one-to-four family units which are already subject to a legally binding contract of sale on the date of the commitment;
(b) the Bank shall not engage in nor shall it permit any subsidiary to engage in any new real estate investment of any kind, including but not limited to debt or equity investments, joint venture arrangements, full ownership by the Bank or any subsidiary, indirectly through profit sharing arrangements, or otherwise, other than any
{{5-31-91 p.C-909}} such real estate investments acquired as a result of debts previously contracted or as to which the Bank is subject to a legally binding commitment which is outstanding on the effective date of this ORDER, it being understood that "real estate investments" shall not include loans secured by mortgages on real property made by the Bank in the ordinary course of its business;
(c) the Bank shall not engage in nor shall it permit any subsidiary to engage in any new commercial business lending which is related to real estate development activities, other than any such commercial business lending as to which the Bank is subject to a legally binding commitment which is outstanding on the effective date of this ORDER, provided that this paragraph (c) shall not apply to secured lending by the Bank's Westchester Community Lending Division where the security for such loan consists of property or assets the value of which is not dependent on the completion or success of any real estate development activity engaged in by the borrower;
(d) the Bank shall not engage in nor shall it permit any subsidiary to engage in any new "highly leveraged transactions", as that term is defined in Financial Institution Letter FIL-18-89, issued November 20, 1989, of any kind, other than any such highly leveraged transaction as to which the Bank is subject to a legally binding commitment which is outstanding on the effective date of this ORDER;
(e) the Bank shall reduce all wholesale funding sources, both short and long term, to less than 20 percent of its total funding liabilities and, except as specifically referenced in the business plan pursuant to this paragraph 4 as approved by the Regional Director and the Superintendent, maintain them at or below that level thereafter; and
(f) the Bank shall submit, in conjunction with the business plan pursuant to paragraph 4, financial projections for a period covering at least 2 years, computed under current, positive, and negative interest rate scenarios covering a range of plus 200 basis points to minus 200 basis points. Additionally, by the thirtieth day of each subsequent quarter, the Bank shall provide to the Regional Director and the Superintendent a detailed analysis of the extent to which the Bank has achieved the submitted projections and the reasons therefor, together with appropriate supporting documentation. By January 31 of each year while this ORDER remains in effect, the Bank shall submit updated financial projections for the ensuing 2 year period.
[.5] 5. (a) Within 30 days from the effective date of this ORDER, the Bank shall submit a schedule, which shall be subject to the approval of the Regional Director and the Superintendent, showing each loan, real estate development investment, and parcel of other real estate in excess of $5,000,000 which, in the view of management of the Bank, does not require a new full scope appraisal by an independent appraiser.
(b) Within 30 days from the effective date of this ORDER, the Bank shall schedule a full scope appraisal of each loan, real estate development investment, and parcel of other real estate in excess of $5,000,000 not listed in the schedule referenced in paragraph 5(a), to be performed by an independent, outside appraiser who is qualified by education and experience to appraise property of the size and complexity involved, to be performed within 12 months of the effective date of this ORDER. Thereafter, the Bank shall have a revaluation of such assets performed at least once in every 12 months, or more often, if changed market conditions appear to warrant it. The revaluation may be performed by either internal or outside appraisers. Any appraisal or revaluation performed pursuant to this paragraph 5 shall, at a minimum, comply in all respects with the appraisal standards set forth in section 323.4(a) of the FDIC's Rules and Regulations, 12 C.F.R. § 323.4(a). Furthermore, immediately upon the effective date of this ORDER, the Bank shall review all of its appraisals and revaluations on loans and real estate development investments which are equal to or less than $5,000,000, and shall commission appraisals and revaluations, as necessary, to ensure prompt compliance, at a minimum, with the appraisal standards set forth in section 323.4(a) of the FDIC's Rules and Regulations, 12 C.F.R. § 323.4(a).
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[.6] 6. (a) Within 10 days from the effective date of this ORDER, the Bank shall eliminate from its books, by collection, charge-off, or other proper entry, all assets or portions of all assets which have been classified "Loss" and 50 percent of all assets or portions of all assets which have been classified "Loss" and 50 percent of all assets or portions of all assets classified "Doubtful" by the FDIC as a result of its examination of the Bank as of March 31, 1990, which have not been previously charged off or collected. In addition, and so long as this ORDER remains in effect, the Bank shall, within 10 days from the receipt of any subsequent Report of Examination of the Bank from the FDIC or the Superintendent, eliminate from its books, by collection, charge-off, or other proper entry, all such assets or portions of such assets classified "Loss" and 50 percent of all such assets of portions of such assets classified "Doubtful" in said Report of Examination. Reduction of these assets through proceeds of loans or other extensions of credit made by the Bank is not considered "collection" for the purpose of this paragraph.
(b) The Bank shall reduce the remaining total of all assets classified "Doubtful" and "Substandard" by the FDIC as a result of its examination of the Bank as of March 31, 1990, to not more than 75 percent of equity capital and reserves by March 31, 1992, and subsequently, the Bank shall reduce the total of such assets to not more than 50 percent of equity capital and reserves by March 31, 1993. For the purposes of this paragraph, those assets held as of the March 31, 1990 examination by any wholly owned depository institution, which would not be subject to consolidation under the Instructions for the preparation of Reports of Condition and Income, shall be excluded.
(c) The requirements of this paragraph 6 of this ORDER shall not be construed as a standard for future operations of the Bank. In addition to accomplishing the foregoing schedule, the Bank shall use best efforts to further reduce all nonaccrual loans, past-due loans, and adversely classified assets of the Bank.
[.7] 7. (a) Within 30 days from the effective date of this ORDER, the Bank's board of directors shall adopt a method of computing the balance of the Bank's reserve for loan losses that gives consideration to the volume and composition of the loan portfolio not subject to criticism, as well as to the volume and composition of criticized loans. Thereafter, the Bank's board of directors shall, during the first month of each quarter, reevaluate the reserve for loan losses and make such additional provisions for loan losses that are necessary to maintain the reserve at an adequate level relative to the volume of risk in the Bank's loan portfolio. All such additional provisions for loan losses shall be made in the first month of the calendar quarter in which the deficiency in the reserve is identified, but as of the end of the preceding calendar quarter, and shall be reflected in the Report of Condition and the Report of Income filed in such calendar quarter with respect to the preceding calendar quarter. The minutes of the board of directors of the Bank shall reflect that such reevaluation has been performed, and documentary proof of the method employed in determining the level of the reserve shall be maintained for future regulatory review.
(b) All increases in the valuation reserves, with the exception of recoveries credited directly to the reserve, shall be accomplished by charges to operating earnings through the provision for loan losses or other operating expenses, as appropriate.
[.8] 8. (a) Immediately upon the effective date of this ORDER, and notwithstanding any other provision of this ORDER, the Bank shall not extend, either directly or indirectly, any new or additional credit (which, for the purposes of this ORDER, shall include the granting of renewals or extensions, or the capitalizing of accrued interest) to, or for the benefit of, any borrower who is obligated in any manner to the Bank on any extension of credit, or portion thereof, which has been charged off the books of the Bank in whole or in part, or to any affiliate of, or related interest of, any such borrower, so long as any portion of such extension of credit, whether or not that portion was charged off, remains uncollected, except that in the case of work-outs, the Bank shall be permitted to extend any new or additional credit which may be prohibited by this paragraph provided that the bank shall have received the prior approval of the Regional Director and the Superintendent. The prohibitions of this para-
{{5-31-91 p.C-911}}graph 8(a) shall not apply to the advance of funds by the Bank for the sole purpose of maintaining or protecting the Bank's collateral for any extension of credit, up to a maximum amount of $100,000 in the aggregate for all such advances, in respect of any single extension of credit. The Bank shall provide written notification to the Regional Director and the Superintendent immediately after each such advance, including the specific reasons therefor.
(b) Immediately upon the effective date of this ORDER, the Bank shall not extend, directly or indirectly, any new or additional credit to, or for the benefit of, any borrower who is obligated in any manner to the Bank on any loan or other extension of credit that has been adversely classified, in whole or in part, by the FDIC as a result of its examination of the Bank as of March 31, 1990 or as a result of any subsequent examination of the Bank by the FDIC or the Department ("classified borrower"), so long as such loan or other extension of credit remains classified or is uncollected. This paragraph 8(b) shall not prohibit the Bank from renewing all or any part of, or granting an extension with respect to, an extension of credit to a classified borrower who is not subject to the prohibitions of paragraph 8(a) of this ORDER, after collection in cash of interest due on the entire extension of credit. The prohibitions of this paragraph 8(b) shall not apply to any extension of credit to a classified borrower who is not subject to the prohibitions of paragraph 8(a) of this ORDER, if:
(i) the Bank's failure to extend further credit to a classified borrower would be substantially detrimental to the best interests of the Bank;
(ii) a comparison with the written program adopted pursuant to paragraph 9 of this ORDER shows that the Bank's formal program to eliminate the basis of criticism of said criticized asset is not compromised; and
(iii) with respect to any adversely classified loan or extension of credit in excess of $250,000, prior to extending any new of additional credit, a majority of the full Investment Committee of the Board of Directors approves such new or additional credit and the minutes of the meeting of the Investment Committee at which such action is taken specify the reasons why failure to so act would be detrimental to the best interest of the Bank. A copy of appropriate excerpts from such minutes shall be placed in the credit file of the respective classified borrowers. A copy of the complete minutes of each Investment Committee meeting at which any such action is taken shall be submitted to, and the action taken therein ratified by, the full Board of Directors, and shall also be submitted promptly to the Regional Director and the Superintendent.
[.9] 9. Within 45 days from the effective date of this ORDER, the board of directors of the Bank shall adopt and implement a written program for each problem asset. Subsequent to the effective date of this ORDER, within 30 days after any asset becomes a problem asset, the board of directors of the Bank shall adopt and implement a written program for each such program asset. For the purposes of this ORDER, a "problem asset" means any asset (including unfunded commitments) which exceeds $250,000 and:
(a) has been adversely classified or listed for Special Mention by the FDIC as a result of its examination of the Bank as of March 31, 1990 or is adversely classified or listed for Special Mention by either the FDIC or the Department as a result of any subsequent examination of the Bank; or
(b) has been accorded a sub-investment quality rating and/or has been designated a work-out or watch list asset, or some equivalent designation, as the result of an internal asset review and rating procedure performed by the Bank or by another party on behalf of the Bank; or
(c) is past due in excess of 120 days and/or has been placed in either a nonaccrual or non-earning status by the Bank; or
(d) has been partially charged-off.
Such program shall include, at a minimum, an assessment of the status of each problem asset, the proposed action to eliminate the cause or causes of asset's being a problem asset, and the time frame for its accomplishment. Once adopted, a copy of each program shall be forwarded to the Superintendent and the Regional Director.
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[.10] 10. The Bank's Investment Committee shall conduct a review of each program adopted pursuant to paragraph 9 of this ORDER at least once in each month, to determine:
(a) the status of each problem asset;
(b) management's adherence to each written program;
(c) the status and effectiveness of each written program; and
(d) the need to revise each written program and/or take other actions.
The results of such review shall be included in the minutes of Bank's board of directors.
The board shall send quarterly progress reports to the Regional Director and the Superintendent on the status of each problem asset equal to or exceeding $1,500,000 with the progress reports required under paragraph 17 of this ORDER, and shall include in such reports a general summary of the programs for problem assets which do not exceed $1,500,000.
[.11] 11. (a) Within 60 days from the effective date of this ORDER, the Bank shall complete a review of its files for all loans and/or real estate development investments to the same or to related, affiliated, or associated borrowers which total more than $1,000,000 as to any such borrower or related, affiliated, or associated borrowers, to determine whether the documentation and financial statements provided by guarantors and developers to the Bank and upon which the Bank is relying in support of such extensions of credit are comprehensive in all respects, including, to the extent possible, full balance sheets, income statements, cash flow statements, and contingencies, all prepared by a certified public accountant in accordance with generally accepted accounting principles, and which include all financial obligations and information about the developer and/or guarantor and not just a compilation of selected information.
(b) Immediately upon discovering that any of the foregoing required documentation or any other financial information which would support an extension of credit is missing, the Bank shall use its best efforts as documented in applicable credit file, to ensure that such documentation and/or information is forthwith provided to the Bank.
[.12] 12. Immediately upon the effective date of this ORDER, the Bank shall not accept, renew or rollover any "brokered deposits," as defined in section 337.6(a)(1) of the FDIC's Rules and Regulations, 12 C.F.R. § 337.6(a)(1), other than in accordance with the requirements of 12 C.F.R. §§ 337.6-.11. Within 10 days from the effective date of this ORDER, the Bank shall submit to the Regional Director and the Superintendent a written plan for eliminating its reliance on brokered deposits. The plan should contain details as to the current composition of brokered deposits by maturity and explain the means by which such deposits will be reduced or eliminated. The Regional Director or the Superintendent shall have the right to reject the Bank's plan. The submission of any plan which provides for any rollover of brokered deposits shall not be construed as a request for a waiver of the prohibition on acceptance, renewal or rollover of brokered deposits, and the Bank shall submit a written request for any such waiver in accordance with the requirements of 12 C.F.R. §§ 337.6-.11. By the fifteenth day of the quarter, the Bank shall provide a written progress report to the Regional Director and the Superintendent detailing the level, source and use of brokered deposits with specific reference to progress under the Bank's plan.
[.13] 13. Within 60 days from the effective date of this ORDER, the board of directors of the Bank shall review and amend its written funds management policy and submit it to the Regional Director and the Superintendent for review. Upon written notice from the Regional Director and Superintendent, that the submitted plan is not acceptable, the Bank shall, within 30 days of its receipt of such notice, submit amendments to the policy to the Regional Director and Superintendent, which shall give due consideration to the changes requested by them. Upon written notice from the Regional Director and Superintendent that the policy has been accepted, the board of directors of the Bank shall adopt such funds management policy. The Bank shall thereafter immediately initiate measures detailed in the policy to the extent such measures have not previously been initiated. The funds management policy shall, at a minimum, provide:
(a) An asset/liability management strategy to reduce the level of interest rate risk being incurred by the Bank;
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(b) A plan to decrease the reliance of the Bank of short-term, potentially volatile liabilities for funding longer term assets; and
(c) Procedures which will enable the board and management to actively monitor the Bank's liquidity and interest rate risk positions and maintain them at prudent levels.
[.14] 14. The Bank shall have and retain sufficient qualified management and qualified staff. Each member of management and of staff shall have qualifications and experience commensurate with his or her duties and responsibilities at the Bank. The qualifications and sufficiency of management and of staff shall be assessed on their ability, commensurate with their duties and responsibilities, to:
(a) comply with the requirements of this ORDER;
(b) operate the Bank in a safe and sound manner;
(c) comply with applicable laws and regulations; and
(d) restore all aspects of the Bank to a safe and sound condition, including capital adequacy, asset quality, management effectiveness, earnings and liquidity.
While this ORDER is in effect, the Bank shall notify the Regional Director and the Superintendent in writing of any changes in management. For purposes of the ORDER, "management" shall be defined as those individuals occupying the position of senior vice-president or above. Except in the case of any director and any "senior executive officer", as defined by the FDIC in section 303.14(a)(3) of its Regulations, 12 C.F.R. § 303.14(a)(3), promulgated pursuant to section 32 of the Act, 12 U.S.C. § 1831i, the notification must include the names and background of any additional or replacement management personnel and must be provided not less than 15 days prior to the individual assuming the new position. In the case of any addition to, or replacement of any member of, the board of directors of the Bank, or the employment or change in responsibilities of any individual to any position as a senior executive officer, the notification shall be provided in accordance with section 32 of the Act and section 303.14 of the FDIC's Regulations.
[.15] 15. Within 30 days from the effective date of this ORDER, the Bank's board of directors shall appoint a committee composed of three non-officer Directors (the "Committee"), to monitor the Bank's compliance with this ORDER. Within 60 days from the effective date of this ORDER, and at monthly intervals thereafter, such Committee shall prepare and present to the Bank's board of directors a written report of its findings, detailing the form, content, and manner of any action taken to secure compliance with this ORDER and the results thereof, and any recommendations with respect to such compliance. Such progress reports shall be included in the minutes of the Bank's board of directors.
[.16] 16. Following the effective date of this ORDER, the Bank shall send to, or otherwise furnish, its shareholder(s) a description of this ORDER in conjunction with the Bank's next shareholder communication. 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 Disclosure Section, Washington, D.C. 20429, for review at least 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.
[.17] 17. By the fifteenth day of each calendar quarter following the effective date of this ORDER, the Bank shall furnish written progress reports to the Regional Director and the Superintendent detailing the form, content, and manner of any actions taken to secure compliance with this ORDER, and the results thereof. Such reports shall include the Committee reports prepared pursuant to paragraph 15 of this ORDER. Such reports may be discontinued when the corrections required by this ORDER have been accomplished and the Regional Director and the Superintendent have, in writing, released the Bank from making further reports.
The effective date of this ORDER shall be 10 days from the date of its issuance.
The provisions of this ORDER shall be binding upon American Savings Bank, its successors, assigns, directors, officers, em-
{{5-31-94 p.C-914}}ployees, agents, and other institution-affiliated parties.
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.
Date of Issuance: March 26, 1991
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