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FDIC Enforcement Decisions and Orders

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{{8-31-93 p.C-1079}}
   [10,262] In the Matter of Peoples Heritage Savings Bank, Portland, Maine, Docket No. FDIC-91-156b (6-13-91).

   Bank to cease and desist from such unsafe or unsound practices as operating with excessive volumes of adversely classified assets; following hazardous lending and lax collection practices; operating with inadequate capital; operating in violation of applicable laws or regulations; operating with policies detrimental to the Bank; engaging in practices which produce inadequate operating income; failing to prevent unsafe or unsound practices and violations of law; failing to submit Reports of Condition and Income as required; operating with inadequate {{8-31-93 p.C-1080}}routine and controls policies; and operating without adequate investment and liquidity and funds management policies. (This order was terminated by order of the FDIC dated 6-14-93; see ¶ 15,686.)

   [.1] Management—Qualifications—Review

   [.2] Management—Management Plan—Minimum Requirements

   [.3] Board of Directors—Election—Outside Directors Added

   [.4] Loans—Loan Review Department—Progress Report Required

   [.5] Loans—Workout Department—Progress Report Required

   [.6] Assets—Adversely Classified—Eliminate/Reduce

   [.7] Loan Loss Reserve—Maintain—Review Required

   [.8] Capital—Tier 1 Capital—Increase/Maintain—Methods

   [.9] Loans—Risk Position—Reduction Required

   [.10] Loans—Extensions of Credit—Existing Borrowers—Curtail

   [.11] Loan Policy—Written Revision—Minimum Requirements

   [.12] Liquidity and Funds Management—Written Policy Required

   [.13] Investment Policy—Revision—Minimum Requirements

   [.14] Dividends—Restricted

   [.15] Loans—Special Mention—Correct Deficiencies

   [.16] Violations of Law—Eliminate/Correct

   [.17] Compliance Reports—Frequency

In the Matter of

PEOPLES HERITAGE SAVINGS
BANK

PORTLAND, MAINE
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST

   Peoples Heritage Savings Bank, Portland, Maine ("Bank"), having been advised of its right to a Notice of Charges and of Hearing detailing the unsafe or unsound banking practices and violations of law and/or regulations alleged to have been committed by the Bank (the "Charges") and of its right to a hearing on such 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 June 3, 1991, whereby solely for the purpose of this proceeding and without admitting or denying any Charges or any other grounds for issuance of an Order under section 8(b) of the Act 12 U.S.C. § 1818(b), 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 and had violated laws and/or regulations. 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. section 1813(u), cease and desist from the following unsafe or unsound banking practices and violations of law and/or regulations:

       (a) operating with an excessive volume of adversely classified assets;
       (b) engaging in deficient lending and collection practices, including maintaining an excessive volume of adversely classified loans, 100% financing of real estate projects, lack of satisfactory appraisals and feasibility studies, and lending on out of area projects;
       (c) operating with an inadequate volume of Tier 1 capital for the kind and quality of assets held;
       (d) engaging in violations of section 23A of the Federal Reserve Act, 12 U.S.C.
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    section 371c, and section 215.4(b) of Federal Reserve Regulation O, 12 C.F.R. § 215.4(b), as set forth in the FDIC's Report of Examination of the Bank as of September 24, 1990 (the "Report of Examination");
       (e) operating with management with certain policies and practices which are detrimental to the Bank;
       (f) engaging in practices which produce inadequate operating income and excessive loan losses;
       (g) failure by the Board of Directors to prevent unsafe or unsound practices and violations of the above-referenced laws and/or regulations;
       (h) failing to submit Reports of Condition and Income in accordance with prevailing instructions;
       (i) operating without adequate internal routines and controls; and
       (j) operating without adequate investment and liquidity and funds management policies.
   IT IS FURTHER ORDERED, that the Bank and its institution-affiliated parties take affirmative action as set forth below. Solely for purposes of enforcement of this Order under Section 8(i) of the Act, 12 U.S.C. § 1818(i), the Bank and its institution-affiliated parties will not be deemed to be in violation of paragraphs (a) through (j) above, except to the extent that the Bank is not in material compliance with the following provisions:

       [.1] 1. (a) Within one hundred and twenty (120) days from the effective date of this ORDER, the Bank shall assess the qualifications of senior management. Each member of senior management shall have qualifications and experience commensurate with his or her duties and responsibilities at the Bank. The qualifications of senior 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) operate all aspects of the Bank in a safe and sound condition, including asset quality, capital adequacy, earnings, management effectiveness and liquidity.
       During the life of this ORDER, the Bank shall notify the Regional Director of the FDIC's Boston Regional Office ("Regional Director") and the Superintendent of the Maine Bureau of Banking ("Superintendent") in writing of any changes in management at the level of senior vice president or above or, in the case of the Commercial Loan, Credit Policy, and Loan Review Areas, at the level of vice president and above. The notification must include the names and background of any replacement personnel and must be provided prior to the individual's assuming the new position.

   [.2] (b) In order to have qualified management, within ninety (90) days from the effective date of this ORDER, the Board of Directors shall develop, with such assistance from the Bank's executive officers as it deems appropriate, a written analysis and assessment of the Bank's management needs ("management plan"), which shall include, at a minimum:
       (i) identification of both the type and number of officer positions at the level of senior vice president and above, needed to manage and supervise properly the affairs of the Bank, and officer positions at the level of vice president or above needed to manage and supervise properly the Commercial Loan, Credit Policy, and Loan Review areas of the Bank.
       (ii) identification and establishment of such Bank committees as are needed to provide guidance and oversight to active management;
       (iii) evaluation of each Bank officer occupying a position identified in paragraph 1(b)(i) above to determine whether these individuals posses 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 is 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 may determine is necessary to ensure that the Bank has {{8-31-91 p.C-1082}}qualified management 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 Superintendent 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 received within said thirty (30) day period, 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 a majority of whose members 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.

       (ii) 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 or any of its affiliated organizations' 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.

   [.4] (e) Within ninety (90) days of the effective date of this ORDER, the progress of the Loan Review Department shall be reviewed and a written report of the findings submitted to the Regional Director and the Superintendent. The review should include, at a minimum, staffing adequacy, comparison of commercial loan ratings recommended by the Loan Review Department to those of lending officers, percentage of loans reviewed (total portfolio and general types of loans), and adequacy of the scope of loan review (evaluation of loan policy compliance, etc.).

   [.5] (f) Within ninety (90) days of the effective date of this ORDER, the progress of the Workout Department shall be evaluated and a written report of findings submitted to the Regional Director and the Superintendent. The review should include staffing adequacy, effectiveness of general workout strategies, timing of transfer of loans to workout, and continued involvement of initiating loan officers.

   [.6] 2. (a) The Bank: (1) shall eliminate from its books, by charge-off or collection, all assets or portions of assets classified "Loss" in the Report of Examination; 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 or reserve for loan and lease losses ("Reserve") by an amount equal to fifty (50.0) percent of those assets of portions of assets classified "Doubtful" in the Examination, which have not been previously collected or charged off. Reduction of these assets through use of proceeds of loans made by the Bank, other than loans to qualified third party borrowers, does not constitute "collection" or "elimination" for the purpose of this paragraph.

   [.7] (b) The Bank shall continue to maintain its Reserve in accordance with the prevailing requirements of the Instructions for the Reports of Condition and Income ("Instructions"). Toward this end, within sixty (60) days from the effective date of this ORDER, the Bank's Board of Directors shall review its policy for determining the adequacy of the Bank's Reserve. The policy shall provide for a review of the Reserve at least once each calendar quarter. The review should focus on the results of the Bank's internal loan review, loan loss experience, trends of delinquent and non-accrual loans, an estimate of potential loss exposure on significant credits, concentrations of credit, and present and prospective economic conditions. Review of other real estate and exposure therein shall be undertaken along {{8-31-91 p.C-1083}}the same lines as the aforementioned loan portfolio review.
   (c) The adequacy of the Reserve in relation to the loss potential in the loan portfolio will continue to be reviewed by the Board of Directors and adjustments to the Reserve will be made accordingly. Details of these reviews will be incorporated into the minutes of the Board of Directors, including the methodology used to determine the adjustments made.
   (d) 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 shall, at a minimum, continue to reflect a Reserve that should be maintained in accordance with the Instructions.
   (e) 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 Reserve, (2) provide for an adequate Reserve, and (3) accurately report the Reserve 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 Reserve, and the basis for determining the amount of allowance provided.
   [.8] 3. (a) (i) The Bank shall have Tier 1 capital at or in excess of four and one-half (4 1/2) percent of the Bank's total assets by December 31, 1991, five (5) percent of the Bank's total assets by June 30, 1992, and six (6) percent of the Bank's total assets by June 30, 1993 ("Tier 1 leverage capital ratio") and shall continue to maintain its Tier 1 leverage 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 Superintendent for approval within 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.

       (ii) For purposes of this ORDER, the term "Tier 1 capital" shall have the meaning set forth in section 325.2(m) of the FDIC's Rules and Regulations, 12 C.F.R. § 325.2(m).
       (iii) For purposes of this ORDER, the term "total assets" shall have the meaning set forth in section 325.2(n) of the FDIC's Rules and Regulations, 12 C.F.R. § 325.2(n).
   (b) In calculating the Bank's Tier 1 leverage capital ratio under paragraph 3(a) initially, the Bank shall first comply fully with paragraphs 2(a) and (b) of this ORDER. Thereafter, such ratio and its component parts shall be determined only after the Bank has made such additions to its Reserve so as to bring the Reserve into compliance with the prevailing requirements of the Instructions and charged off any losses identified subsequent to the Examination.
   (c) Any increase in the Tier 1 leverage capital ratio made by the Bank in order to meet the requirements of paragraph 3(a) of this ORDER may be accomplished by:
       (i) the sale of common stock and/or non-cumulative perpetual preferred stock;
       (ii) the retention of earnings;
       (iii) the collection of all or part of assets classified "Loss" within the Examinations without loss or liability to the Bank. Reductions to loans and leases classified "Loss" shall first be credited to the Bank's Reserve and, if the Board of Directors' review of the adequacy of the Reserve required by paragraph 2 of this ORDER indicates that such Reserve has a balance in excess of that required for adequacy, any such excess may be transferred to equity capital through a negative provision to the Reserve:
       (iv) the collection in cash of assets previously charged off;
       (v) any combination of the above means; or
       (vi) any other means acceptable to the Regional Director and the Superintendent.
   (d) Before downsizing the Bank to maintain the target Tier 1 capital ratio described in paragraph 3(a), the Bank shall fully analyze the effect of such action on earnings and liquidity. The Bank shall pro- {{8-31-91 p.C-1084}}vide the Regional Director and the Superintendent with at least ten (10) days notice prior to any sales of assets by the Bank that would result in an aggregate calendar quarterly decrease of more than ten (10) percent of assets.
   (e) In addition to the requirements of paragraphs 3(a)—(d), the Bank shall comply with the FDIC's Statement of Policy on Risk-Based Capital found in Appendix A to Part 325 of the FDIC Rules and Regulations, 12 C.F.R. Part 325, App. A.
   (f) If all or part of any increase in capital made by the Bank in order to meet the requirements of this paragraph 3 involves a public offering, the Bank shall prepare offering materials fully describing the securities being offered, and including an accurate description of the financial condition of the Bank, this ORDER, and the circumstances giving rise to the offering, and any other material disclosures necessary to comply with the applicable Federal and State securities laws. Prior to the sale of the securities, and, in any event not less than twenty (20) days prior to the dissemination of such materials, the materials used in the sale of the securities shall be submitted to the FDIC, Registration and Disclosure Section, Washington, D. C. 20429, for review. Any changes requested to be made in the materials by the FDIC shall be made prior to their dissemination.
   (g) In complying with the provisions of paragraph 3(f) of this ORDER, the Bank shall provide to any subscriber and/or purchaser of Bank stock, written notice of any planned or existing development or other change which is materially different from the information reflected in any offering materials used in connection with the sale of Bank securities, and which occur before completion of the sale of the securities. The written notice required by this paragraph 3(g) shall be furnished within ten (10) calendar days from the date such material development or change was planned or occurred, whichever is earlier, to every purchaser and/or subscriber of Bank stock who received or was tendered the information contained in the Bank's original offering materials.
   (h) 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(g) of this ORDER including, at a minimum, any action to increase its capital by each of the methods specified in paragraphs 3(c)(i) through 3(c)(vi) of this ORDER.

   [.9] 4. (a) Within sixty (60) days from the effective date of this ORDER, the Board of Directors, or a committee thereof a majority of whose members are independent with respect to the Bank, shall develop a written plan of action to lessen the Bank's risk position with respect to each borrower who or which had outstanding principal debt owing to the Bank in excess of $500,000 which was classified "Substandard" or "Doubtful," in whole or in part, as of September 24, 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;
       (ii) evaluate the available collateral for each such credit, including possible actions to improve the Bank's collateral position; and
       (iii) evaluate the prospects of restructuring such indebtedness in a manner which ultimately could result in it no longer being adversely classified.
Based upon such review and evaluation, the written plan of action shall: (A) establish target dollar levels to which the Bank shall reduce the aggregate dollar volume of each "Substandard" or "Doubtful" classifications within six (6) and twelve (12) months from the effective date of this ORDER; and (B) provide for the submission of written quarterly progress reports to the Bank's Board of Directors for review and notation in the Board minutes. Such progress reports shall be in the form of Exhibit A or in a similar form which includes the information set forth in Exhibit A. 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 Main Bureau of Banking. Payment of loans with the proceeds of other loans made by the Bank, other than loans to qualified third party borrowers, will not constitute "reduction" or "collection" for purposes of this ORDER.
   (b) The written plan of action described {{8-31-91 p.C-1085}}by paragraph 4(a) shall be submitted to the Regional Director and the Superintendent 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 received within said thirty (30) day period, 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 Superintendent written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/ or the Superintendent 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 thereto.

   [.10] 5. Except for legally binding commitments in effect on the effective date of this Order, 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 aggregating $100,000 or more than has been charged off or classified, in whole of in part, "Loss," "Doubtful," or "Substandard," and is uncollected, unless the Bank's Board of Directors, or a committee thereof a majority of whose members are independent with respect to the Bank, 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 4 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 5 shall be maintained in the credit file of the affected borrower(s) as well as the minutes of the Board of Directors.

   [.11] 6. Within sixty (60) days from the effective date of this ORDER, the Bank shall revise the Bank's written loan policy, which revision shall include, at a minimum, provisions designed to address the concerns and recommendations set forth on pages 6 and 6-1 and 6-2 of the Report of Examination. The revised written loan policy shall be submitted to the Regional Director and the Superintendent for review and comment. No sooner than thirty (30) days, but under no circumstances more than sixty (60) days after such submission, the Board of Directors shall approve the revised written loan policy, taking into consideration any regulatory comments received within said 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 revised written loan policies and/or any subsequent modification thereto.

       [.12] 7. (a) Within ninety (90) days from the effective date of this ORDER, the Bank shall adopt a more comprehensive liquidity and funds management policy. At a minimum, this policy should address the following:
         (i) standards of risk for liquid assets to deposits and funding liabilities (liquidity ratio):
         (ii) standards of risk for volatile liability dependence;
         (iii) parameters for the type and source of funding diversification;
         (iv) parameters for general asset diversification;
         (v) standards of risk for interest rate risk exposure;
         (vi) managerial responsibility for planning and day to day funds management; and
         (vii) management reporting and control systems.
       (b) Within ninety (90) days of the effective date of this ORDER, the Bank, in conjunction with Peoples Heritage Financial Group, Inc. shall develop and implement a contingency liquidity plan. The plan should address how the Bank may address unexpected funding outflows and/ or asset funding requirements and identify events, such as quarterly earnings announcements, which may precipitate unexpected liquidity demands upon the Bank.
       [.13] 8. (a) Within ninety (90) days from the effective date of this ORDER, the Bank
{{8-31-91 p.C-1086}}
    shall develop a more comprehensive investment policy, which shall include, at a minimum:
         (i) the Bank's investment needs and plans for ensuring that such needs are met on an ongoing basis;
         (ii) guidelines and limitations for the Bank's trading activities;
         (iii) general risk diversification parameters; and
         (iv) managerial responsibility for planning and investment decisions.
       (b) The written investment policy shall be submitted to the Regional Director and the Superintendent 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 policy, taking into consideration any regulatory comments received within said thirty (30) day period, and such approval shall be recorded in the minutes of the Board of Directors. Subsequent modifications to the written investment policy may be made only after giving the Regional Director and the Superintendent written notice of the proposed modification, and after consideration of any responsive comments submitted by the Regional Director and/or the Superintendent 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 policy and/or any subsequent modification thereto.

   [.14] 9. The Bank shall not declare or pay any dividends unless:
       (a) such declarations and payments are made in accordance with applicable State and Federal laws and regulations;
       (b) after payment of such dividends, the Tier 1 capital ratio specified in paragraph 3(a)(i) shall not be less than six (6) percent and the Bank's allowance for loan and lease losses shall be adequate as described in paragraph 2 of this ORDER;
       (c) such declaration and payment of dividends shall be approved in advance by the Board of Directors of the Bank; and
       (d) such declaration and payment of dividends shall be approved in advance, in writing, by the Regional Director and the Superintendent.

   [.15] 10. Within (60) days from the effective date of this ORDER, the Bank shall correct the remediable deficiencies in the loans listed for "Special Mention" on pages 2-c of the Report of Examination.

   [.16] 11. To the extent not already done so by the Bank, the Bank shall, within sixty (60) days from the effective date of this ORDER, eliminate and/or correct all violations of law and regulations committed by the Bank as described on pages 6-2 and 6-2-a of the Report of Examination.

   [.17] 12. Within thirty (30) days from the end of the calendar quarter ending on June 30, 1991, and, thereafter, within thirty (30) days from the end of each subsequent calendar quarter, the Bank shall furnish written progress reports to the Regional Director and the Superintendent detailing the form and manner of any action taken to secure compliance with this ORDER and the results thereof. In addition, the Bank shall furnish such reports on request of either the Regional Director or the Superintendent. 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. Such reports may be discontinued in whole or in part when the corrections required by this ORDER have been accomplished and the Regional Director and the Superintendent have released the Bank, in writing, from making further reports in whole or in part.
   13. The ORDER is not intended to constitute an adjudication of any factual issue encompassed herein, or have any res judi- cata, collateral estoppel, or other estoppel effect in any other action or proceeding. This paragraph is not intended to inhibit, bar, estop, or otherwise prevent the FDIC from undertaking any action with respect to this ORDER pursuant to section 8 of the Act, 12 U.S.C. § 1818, or to have any effect with respect to any such proceeding.
   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 as defined in section 3(u) of the Act, 12 U.S.C. section 1813(u).
   The provisions of this ORDER shall remain effective an enforceable except to the extent that, and until such time as any pro- {{6-30-92 p.C-1087}}visions of this ORDER shall have been modified, terminated, suspended, or set aside by the FDIC.
   Dated at Needham, Massachusetts this 13th day of June, 1991.
   Pursuant to delegated authority.

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