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FDIC Enforcement Decisions and Orders

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{{11-30-94 p.C-2167}}
   [10,513] In the Matter of Suburban Bank, Lake Worth, Florida, Docket No. FDIC-92-76b (4-17-92).

   Bank to cease and desist from such unsafe or unsound practices as failing to provide adequate supervision over the Bank's affairs; operating with management whose policies are detrimental to the Bank; operating with excessive volumes of adversely classified assets; following hazardous lending and lax collection practices; operating with inadequate capital; engaging in practices which produce inadequate operating income; operating with inadequate allowance for loan and lease losses; operating in violation of applicable laws or regulations; and relying on an excessive amount of volatile liabilities. (This order was terminated by order of the FDIC dated 9-27-94; see ¶15,916.)

   [.1] Management—Qualifications—Review
   [.2] Capital—Tier 1 Capital—Increase/Maintain—Methods
   [.3] Allowance for Loan and Lease Losses—Establish/Maintain
   [.4] Assets—Adversely Classified—Eliminate/Reduce
   [.5] Loans—Extensions of Credit—Existing Borrowers—Curtail
   [.6] Loans—Overdue—Accrual of Interest
   [.7] Loan Policy—Written Revision—Minimum Requirements
   [.8] Loans—Documentation—System Required
   [.9] Loans—Acquisition, Development, Construction—Reduce Risk Exposure
   [.10] Loans—Special Mention—Correct Deficiencies
   [.11] Budget and Earnings Forecast—Preparation Required
   [.12] Dividends—Restricted
   [.13] Violations of Law—Eliminate/Correct
   [.14] Liabilities—Volatile—Reduction Required
   [.15] Institution-Affiliated Parties—Transactions With—Restricted
   [.16] Shareholders—Disclosure—Cease and Desist Order
   [.17] Compliance Reports—Frequency

{{11-30-94 p.C-2168}}
In the Matter of

SUBURBAN BANK
LAKE WORTH, FLORIDA
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST
FDIC-92-76b

   The Suburban Bank, Lake Worth, Palm Beach County, Florida ("Bank"), having been advised of its right to a written Notice of Charges and of Hearing detailing unsafe or unsound banking practices and violations of applicable laws and regulations alleged to have been committed by the Bank and of its right to a hearing regarding 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 a representative of the Legal Division of the Federal Deposit Insurance Corporation ("FDIC"), dated March 18, 1992, whereby solely for the purpose of this proceeding and without admitting or denying any of the alleged charges of unsafe or unsound banking practices and violations of applicable laws and regulations, 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 committed violations of applicable laws and regulations.
   The FDIC, therefore, accepted the CONSENT AGREEMENT and issued the following:

ORDER TO CEASE AND DESIST

   IT IS HEREBY ORDERED, that the Bank, its institution-affiliated parties, as such term is defined in section 3(u) of the Act, 12 U.S.C. § 1813(u), and its successors and assigns cease and desist from the following unsafe or unsound banking practices and violations of laws and regulations:
   A. Failing to provide adequate supervision and direction over the affairs of the Bank by the board of directors of the Bank to prevent unsafe or unsound practices and violations of laws and regulations;
   B. Operating the Bank with management whose policies and practices are detrimental to the Bank and jeopardize the safety of its deposits;
   C. Operating the Bank with an excessive volume of adversely classified assets;
   D. Engaging in hazardous lending and ineffective and lax collection practices, including but not limited to: (i) failing to establish and enforce repayment programs; (ii) failing to provide adequate diversification of risk by allowing an excessive concentration of real estate commercial, acquisition, development and construction loans; (iii) continuing to accrue interest on loans that are 90 days or more delinquent in principal or interest payments and which are not both well secured and in the process of collection; (iv) advancing funds on lines of credit in order to pay accrued interest on delinquent or non-performing loans; and (v) extending credit with inadequate financial information to support the extensions of credit;
   E. Operating the Bank with equity capital that is inadequate for the kind and quality of assets held by the Bank;
   F. Engaging in practices which produce inadequate operating income and excessive loan losses;
   G. Failing to provide and maintain an adequate allowance for loan and lease losses for the volume, kind and quality of loans held by the Bank;
   H. Engaging in violations of applicable Federal and state laws and regulations, as more fully described on pages 6-b through 6-b-1 of the FDIC's Report of Examination of the Bank as of June 17, 1991; and
   I. Engaging in unsafe and unsound funds management practices by funding long-term assets with an excessive amount of volatile liabilities.
   IT IS FURTHER ORDERED that the Bank and its successors and assigns take affirmative action as follows:

   [.1] 1. (a) Within ninety (90) days from the effective date of this ORDER, the Bank shall have and retain qualified management. At a minimum, such management shall include a chief executive officer with proven ability in managing a bank of comparable size and a qualified senior loan officer. Such persons shall be provided the necessary written 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
{{6-30-92 p.C-2169}}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, capital adequacy, earnings, management effectiveness, and liquidity. As long as this ORDER remains in effect, the Bank shall notify the Regional Director of the FDIC's Atlanta Regional Office ("Regional Director") and the Florida State Comptroller ("Comptroller") in writing of any changes in management. Such notification shall be in addition to any application and prior approval requirements established by section 32 of the Act, 12 U.S.C. § 1831i, and implementing regulations; must include the names and qualifications of any replacement personnel; and must be provided at lease thirty (30) days prior to the individual's assuming the new position.
   (b) To facilitate compliance with paragraph 1(a) of this ORDER, the Bank's board of directors shall, within no more than thirty (30) days from the effective date of this ORDER, appoint an individual or a committee of individuals who are independent with respect to the Bank to develop, within no more than ninety (90) days from the effective date of this ORDER, 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 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, 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 analysis, evaluation and assessment as provided in paragraph 1(b)(i) and 1(b)(iii) of this ORDER.
   (c) The written Management Plan and all subsequent modifications to the Management Plan shall be submitted to the Regional Director and to the Comptroller for review and comment. Not more than thirty (30) days from receipt of any comment from the Regional Director or from the Comptroller, the board of directors shall, after consideration of such comment, approve the Management Plan which approval shall be recorded in the minutes of the board of directors' meeting. Thereafter, the Bank and its successors and assigns shall implement and follow the Management Plan and shall implement and follow any modifications to the Management Plan as such modifications may be made from time to time.
   (d) 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 or director of the Bank or any of its affiliated organizations and who does not own more than five (5) percent of the outstanding shares of the Bank or any of its affiliated organizations, (2) who is not related by blood, marriage or common financial interest to an officer or director of the Bank or to any stockholder owning more than five (5) percent of the outstanding shares of the Bank or any of its affiliated organizations, 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) percent of the Banks' total equity capital and allowance for loan and lease losses.

   [.2] 2. (a) Within one hundred-eighty (180) days from the effective date of this ORDER, the Bank shall increase its Tier 1 capital by not less than one million five hundred thousand dollars ($1,500,000). Such increase in Tier 1 capital may be accomplished by any one or more of the following:

       (i) The sale of new securities in the form of common stock;
       (ii) The collection in cash of all or
    {{6-30-92 p.C-2170}}part of the assets other than loans classified "Loss" or "Doubtful" as of June 17, 1991, and charged off in accordance with paragraph 4 of this ORDER;
       (iii) The direct contribution of cash by the directors and shareholders of the Bank;
       (iv) The collection in cash of assets other than loans previously charged off; or
       (v) Any other means acceptable to the Regional Director and the Comptroller.
       (b) (i) If all or part of the increase in the Bank's Tier 1 capital required under paragraph 2(a) of this ORDER involves a public distribution of the Bank's securities (including a distribution limited to the Bank's existing shareholders), the Bank shall prepare detailed offering materials fully describing the securities being offered, including an accurate description of the financial condition of the Bank and of this ORDER as well as the circumstances giving rise to the offering, and any other material disclosures necessary to comply with applicable Federal securities laws. Prior to the sale of such 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, and to the Comptroller for review. All changes requested by the FDIC or by the Comptroller to be made in such offering materials shall be made prior to their dissemination.
       (ii) In complying with the provisions of paragraph 2(b)(i) of this ORDER, the Bank shall provide to each subscriber and/or purchaser of Bank securities 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. The written notice required by this paragraph 2(b)(ii) shall be furnished within ten (10) calendar days from the date that such material development or change was planned or occurred, whichever is earlier, and shall be furnished to each purchaser and/or subscriber of Bank securities who received or was tendered the information obtained in the Bank's original offering materials.
   (c) Within thirty (30) days from the effective date of this ORDER, and within thirty (30) days after the end of each calendar quarter thereafter while this ORDER remains in effect, the Bank shall calculate it's Tier 1 capital as a percentage of its total assets (the resulting percentage shall be referred to as the Bank's "capital ratio") as of the nearest preceding March 31, June 30, September 30 or December 31 date. If such capital ratio is less than six percent (6.0%), then, within ninety (90) days from the fate of such calculation, the Bank shall increase its Tier 1 capital by an amount sufficient to raise its capital ratio to not less than six percent (6.0%) as of the nearest preceding March 31, June 30, September 30, or December 31 date.
   (d) For the purposes of this ORDER, the terms "Tier 1 capital" and "total assets" shall have the meanings ascribed to them in sections 325.2(m) and 325.2(n), respectively, of the FDIC's Rules and Regulations, 56 Fed. Reg. 10161 (March 11, 1991) (to be codified at 12 C.F.R. §§ 325.2(m) and (n)), effective April 10, 1991.
   (e) In addition to the requirements of paragraphs 2(a) and 2(c) of the ORDER, for as long as this ORDER remains in effect, the Bank shall meet the minimum ratio requirements established for "risk-based capital" by the deadlines set out in Appendix A of Part 325 of the FDIC's Rules and Regulations, 12 C.F.R. Part 325, which Appendix A is entitled "Statement of Policy on Risk-Based Capital," as such minimum ratio requirements and deadlines may be modified from time to time by amendments to the FDIC's Rules and Regulations.

   [.3] 3. (a) Within thirty (30) days from the effective date of this ORDER, and concurrently with compliance with the requirements of paragraph 4 of this ORDER, the Bank shall establish and thereafter continually maintain an adequate allowance for loan and lease losses in accordance with the prevailing requirements of the Instructions for the Reports of Condition and Income, by charges against current operating income. In com- {{6-30-92 p.C-2171}}plying with the requirements of this paragraph 3(a) of the ORDER, the Bank's board of directors shall, at a minimum, review the adequacy of the Bank's allowance for loan and lease losses prior to the end of each calendar quarter. The review shall include consideration of loans internally classified during the bank's loan review process, loans adversely classified at FDIC or Florida State Department of Banking examinations, and delinquent non-performing loans. The minutes of the board meeting at which such review is undertaken shall indicate the results of the review, the amount of any recommended increases in the allowance, and the basis for determining the amount of allowance provided.
   (b) Reports of Condition and Income required to be filed by the Bank prior to the effective date of this ORDER and subsequent to June 17, 1991, shall reflect a provision for the allowance for loan and lease losses necessary to comply with paragraph 3(a) of this ORDER. If necessary to comply with this paragraph 3(b) of the ORDER, the Bank shall file amended Reports of Condition and Income within thirty (30) days from the effective date of this ORDER.

   [.4] 4. Within thirty (30) days from the effective date of this ORDER, the Bank shall eliminate from its books, by collection, charge-off or other proper entries, all assets or portions of assets classified "Loss" and one-half of all assets or portions of assets classified "Doubtful" by the FDIC as a result of its examination of the Bank as of June 17, 1991, which have not been previously collected or charged off, unless otherwise approved in writing by the Regional Director and the Comptroller.
   5. (a) Within one hundred eighty (180) days from the effective date of this ORDER, the Bank shall reduce the aggregate dollar volume of all remaining assets classified "Substandard" and "Doubtful" in the FDIC's Report of Examination of the Bank as of June 17, 1991, to not more than sixteen million five hundred thousand dollars ($16,500,000); within three hundred sixty (360) days from the effective date of this ORDER, the Bank shall reduce such aggregate total to not more than thirteen million dollars ($13,000,000); within five hundred forty (540) days from the effective date of this ORDER, the Bank shall reduce such aggregate total to not more than nine million dollars ($9,000,000); and within seven hundred twenty (720) days from the effective date of this ORDER, the Bank shall reduce such aggregate total to not more than four million dollars ($4,000,000). The requirements of this paragraph 5(a) of the ORDER shall not be construed to establish a standard for future operations of the Bank.
   (b) Within sixty (60) days from the effective date of this ORDER, the Bank shall submit to the Regional Director and the Comptroller a written plan of action to reduce each line of credit which was adversely classified by the FDIC as of June 17, 1991, and which aggregated five hundred thousand dollars ($500,000) or more as of that date. Such plan of action shall thereafter be implemented by the Bank and monitored, and progress reports shall be submitted by the Bank to the Regional Director and the Comptroller concurrently with the other reporting requirements set forth in paragraph 18 of this ORDER.
   (c) As used in this paragraph 5 of the ORDER, "reduce" means to (i) collect, (ii) charge off, or (iii) improve the quality of such assets sufficiently to warrant removal of any adverse classification by the FDIC.

   [.5] 6. (a) Effective the date of this ORDER, the Bank shall not extend, directly or indirectly, any additional 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" or "Doubtful", and is uncollected.
   (b) Effective the date of this ORDER, the Bank shall not extend, directly or indirectly, any additional credit to or for the benefit of any borrower who has a loan or other extension of credit with the Bank that has been classified, in whole or in part, "Substandard", and is uncollected, unless a majority of the Bank's board of directors first: (i) determines that such advance is in the best interest of the Bank, (ii) determines that the Bank has satisfied the requirements set out in paragraph 5(b) of this ORDER as to such borrower, and (iii) approves such advance. A written record of the board of directors' determi- {{6-30-92 p.C-2172}}nation and approval of any advance under this paragraph 6(b) of the ORDER shall be maintained in the credit files of each affected borrower as well as in the minutes of the board of directors.
   (c) The requirements of this paragraph 6 of the ORDER shall not prohibit the Bank from renewing or extending the maturity of any credit already extended to the borrower, provided such action is in accordance with both Federal and state laws, rules and regulations, and further provided that all interest due at the time of such renewal or extension is collected in cash from the borrower.

   [.6] 7. (a) Within thirty (30) days from the effective date of this ORDER, and in accordance with the Instructions for the Reports of Condition and Income, the Bank shall reverse on its books all accrued and unpaid interest on any loan that is ninety (90) days or more delinquent in principal or interest payments and is not both well secured and in the process of collection.
   (b) Effective the date of this ORDER, the Bank shall not: (i) accrue interest on any loan that is, or becomes, ninety (90) days or more delinquent in principal or interest payments unless the loan is both well secured and in the process of collection; (ii) add uncollected interest to the unpaid principal balance of any loan on which interest is due unless such addition is supported by additional tangible collateral which adequately and completely secures the loan; (iii) extend credit by means of a new note for uncollected interest due on any loan unless such new extension of credit is supported by additional tangible collateral which adequately and completely secures the loan; or (iv) book uncollected interest by any other means in contravention of the Instructions for Reports of Condition and Income.
   (c) For purposes of this paragraph 7 of the ORDER, "well secured" and "in the process of collection" shall have the same meanings as those terms have in the prevailing Instructions for the Reports of Condition and Income.

   [.7] 8. (a) Within sixty (60) days from the effective date of this ORDER, the Bank shall review and revise its lending practices to provide for the safe and sound administration of all aspects of the Bank's lending function. The Bank's lending practices shall, at a minimum, be revised to address the deficiencies described on pages 1 and 6-a of the FDIC's Report of Examination of the Bank as of June 17, 1991.
   (b) The Bank's board of directors shall implement procedures to ensure that the Bank's loan policy and all subsequent modification to the Bank's loan policy are implemented and strictly enforced.

   [.8] 9. Within sixty (60) days from the effective date of this ORDER, the Bank shall establish an effective system of loan documentation and shall ensure that all necessary loan documentation, or evidence of loan documentation, is obtained and evaluated before any credit is extended by the Bank.

   [.9] 10. Within ninety (90) days from the effective date of this ORDER, the Bank shall establish a system for identifying its total risk exposure related to real estate commercial, acquisition, development, and construction lending, including, but not limited to, funded extensions of credit, unfunded commitments, and in-substance foreclosures. Further, within 90 days from the effective date of this ORDER, the Bank shall develop, submit to the Regional Director and the Comptroller for review and comment, and thereafter implement a plan to reduce such risk exposure to a prudent and reasonable level. Such plan need not require that the Bank refuse to extend or renew credit to creditworthy borrowers, consistent with safe and sound banking practices.

   [.10] 11. Within ninety (90) days from the effective date of this ORDER, the Bank shall correct the cited deficiencies in the assets listed for "Special Mention" on pages 2-d of the FDIC's Report of Examination of the Bank as of June 17, 1991. Thereafter, the Bank shall service these loans in accordance with its written loan policy and in accordance with safe and sound banking practices.

   [.11] 12. (a) Within thirty (30) days after the effective date of this Order, the Bank shall prepare a realistic and comprehensive budget and earnings forecast for calendar year 1992 and shall submit this budget and earnings forecast to the Regional Director and the Comptroller for review and comment.
   (b) As long as this ORDER remains in effect, the Bank shall annually prepare realistic and comprehensive calendar year budgets and earnings forecasts on a consolidated basis as of January 1 of each
{{6-30-92 p.C-2173}}year subsequent to 1992 and shall submit these budgets and earnings forecasts to the Regional Director and the Comptroller for review and comment no later than January 31 of each year.
   (c) In preparing the budgets and earnings forecasts required by this paragraph 12 of the ORDER, the Bank shall, at a minimum:

       (i) Identify the major areas in, and means by, which the board of directors will seek to improve the Bank's operating performance; and
       (ii) Describe the operating assumptions that form the basis for, and adequately support, major projected income and expense components.
   (d) Progress reports comparing the Bank's actual income and expense performance with budgetary projections shall be submitted to the Regional Director and the Comptroller concurrently with the other reporting requirements set forth in paragraph 18 of this ORDER. The Bank's board of directors shall meet and review such progress reports, which review shall be recorded in the minutes of the board of directors.

   [.12] 13. As of the effective date of this ORDER, the Bank shall not pay any cash or property dividends without the prior written consent of the Regional Director and the Comptroller.

   [.13] 14. Within thirty (30) days from the effective date of this ORDER, the Bank shall eliminate or correct all violations of law and regulations committed by the Bank, as described on pages 6-b through 6-b-1 of the FDIC's Report of Examination of the Bank as of June 17, 1991. In addition, the Bank shall adopt appropriate procedures to ensure the Bank's future compliance with all applicable laws and regulations.

   [.14] 15. Within sixty (60) days from the effective date of this ORDER, the Bank shall develop written goals and strategies for managing and reducing the Bank's dependence on volatile liabilities to fund long-term assets, for reducing the ratio of total loans to total deposits, and for reducing the ratio of total loans to total assets. The Bank's board of directors shall periodically review and monitor the Bank's performance in achieving these goals and strategies, which review shall be recorded in the minutes of the board of directors.

   [.15] 16. (a) Within sixty (60) days from the effective date of this ORDER, the Bank shall develop, adopt and implement written policies and procedures which, at a minimum, require that prior to every instance in which the Bank extends credit to or engages in any other transaction with a Bank insider, the Bank's board of directors must formally approve each such extension of credit or other transaction. At a minimum the Bank's policies and procedures must require that prior to the board's approval of any such extension of credit or other transaction, the following information must be revealed to each member of the Bank's board of directors: (1) the identity of each affected Bank insider; (2) the nature of each affected Bank insider's involvement in the extension of credit or transaction; (3) the nature of any potential or actual conflict arising between the interests of the Bank and interests of each Bank insider due to the extension of credit or other transaction; and (4) if the transaction is other than an extension of credit, an analysis of reasonable alternative transactions, sufficient to enable an informed, objective business decision on the transaction to be made.
   (b) At a minimum the Bank's policies and procedures pursuant to paragraph 16(a) of this ORDER must require that the minutes of any board meeting approving extensions of credit or other transactions with Bank insiders reflect: (1) that every affected Bank insider abstained from voting on the extension of credit or other transaction; (2) that the extension of credit or other transaction was either approved or disapproved by a majority of the members of the board of directors; (3) the results of the board of directors' deliberations regarding actual or potential conflicts between the interests of each Bank insider and the interests of the Bank; and (4) the identification of each director voting to approve and the identification of each director voting to disapprove the extension of credit or other transaction.
   (c) For purposes of this paragraph 16 of the ORDER: (i) the term "Bank insider" shall mean any director, executive officer, or principal shareholder of the Bank, any related interest of any such person,
{{6-30-92 p.C-2174}}and any person related by blood, marriage, or common financial interest to any of the foregoing; and (ii) the term "related interest" shall have the meaning ascribed to this term in section 215.2(k) of Regulation O of the Board of Governors of the Federal Reserve System, 12 C.F.R. § 215.2(k).

   [.16] 17. Following the effective date of this ORDER, the Bank shall send to its shareholders or otherwise furnish 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 this 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, and to the Comptroller, for review at least 20 days prior to dissemination to shareholders. Any changes requested to be made by the FDIC or the Comptroller shall be made prior to dissemination of the description, communication, notice or statement.

   [.17] 18. Within ninety (90) days from the effective date of this ORDER, and within thirty (30) days following the end of each calendar quarter thereafter while this ORDER is in effect, the Bank shall furnish written progress reports to the Regional Director and to the Comptroller detailing the form and manner of all actions taken to secure compliance with this ORDER and the results of such actions. Such reports may be discontinued when the corrections required by this ORDER have been accomplished and the Regional Director and the Comptroller have released the Bank in writing from making further reports. 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 appropriate board meeting.
   19. The provisions of this ORDER shall become effective ten (10) days from the date of its issuance and shall be binding upon the Bank, its institution-affiliated parties, and its successors and assigns. Further, 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.
   Dated at Atlanta, Georgia, this 17th day of April, 1992.
   Pursuant to delegated authority.

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