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{{7-31-95 p.C-2856}}
   [10,672] In the Matter of The Ramapo Bank, Wayne, New Jersey, Docket No. FDIC-92-330b (11-18-92).

   Bank to cease and desist from such unsafe or unsound practices as following hazardous lending and lax collection practices; operating with inadequate capital; operating with an excessive level of poor quality assets; operating with inadequate allowance for loan and lease losses; engaging in practices which produce inadequate earnings; operating in violation of applicable laws or regulations; operating with management whose policies are detrimental to the Bank; and failing to provide adequate supervision over the Bank's affairs. (This order was terminated by order of the FDIC dated 5-26-95. See ¶16,006.)

   [.1] Management—Qualifications—Review
   [.2] Capital—Tier 1 Capital—Increase/Maintain—Methods
   [.3] Allowance for Loan and Lease Losses—Establish/Maintain
   [.4] Budget and Earnings Plan—Preparation Required
   [.5] Assets—Adversely Classified—Eliminate/Reduce
   [.6] Assets—Adversely Classified—Eliminate/Reduce—Timetable
   [.7] Loans—Extensions of Credit—Existing Borrowers—Curtail
   [.8] Assets—Problem Assets—Individual Written Plans
   [.9] Lending and Collection Policy—Minimum Requirements
   [.10] Loan Portfolio—Review and Grading System Required
   [.11] Loan Portfolio—Diversification Required
   [.12] Violations of Law—Eliminate/Correct
   [.13] Bank Holding Company—Relations with—Written Policy Required
   [.14] Loans—Special Mention—Correct Deficiencies
   [.15] Dividends—Restricted
   [.16] Shareholders—Disclosure—Cease and Desist Order
   [.17] Board of Directors—Committee to Review Compliance with Cease and Desist Order

In the Matter of

THE RAMAPO BANK
WAYNE, NEW JERSEY
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST
FDIC-92-330b

   The Ramapo Bank, Wayne, New Jersey ("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 and of its right to a hearing on the 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 November 18, 1992, whereby solely for the purpose of this proceeding and without admitting or denying the alleged charges of unsafe or unsound banking practices and violations of law and/or 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 law 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, 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 {{1-31-93 p.C-2857}}AND DESIST from the following unsafe or unsound banking practices and violations:
   (a) Engaging in hazardous lending and lax collection practices;
   (b) Operating the Bank with inadequate capital in relation to the kind and quality of assets held by the Bank;
   (c) Operating the Bank with an excessive volume of poor quality assets;
   (d) Operating the Bank with an inadequate allowance for loan and lease losses;
   (e) Operating the Bank in such a manner as to produce unsatisfactory earnings;
   (f) Engaging in violations of applicable Federal and State laws and regulations, as more fully set forth on pages 6-a through 6-a-6 of the Report of Examination of the Bank by the FDIC as of April 6, 1992.
   (g) Operating the Bank with management whose policies and practices are detrimental to the Bank; and
   (h) Operating the Bank with a board of directors which has failed to provide adequate supervision over and direction to the operating management of the Bank.
   IT IS FURTHER ORDERED that the Bank take AFFIRMATIVE action as follows:

[.1] 1. (a) The Bank shall have and retain qualified management. Each member of management shall have qualifications and experience commensurate with his or her duties and responsibilities at the Bank. The qualifications of management shall be assessed on its ability to:

       (i) comply with the requirement of this ORDER;
       (ii) operate the Bank in a safe and sound manner;
       (iii) comply with all applicable laws and regulations; and
       (iv) restore all aspects of the Bank to a safe and sound condition, including capital adequacy, asset quality, management effectiveness, earnings and liquidity.
    (b) (i) During the life of this ORDER, the Bank shall notify the Regional Director of the New York Regional Office of the FDIC ("Regional Director") and the Commissioner of Banking for the State of New Jersey ("Commissioner") in writing of any resignations and/or terminations of any members of its board of directors and/or any of its officers.
       (ii) The Bank shall comply with section 32 of the Act, 12 U.S.C. § 1831i, which includes a requirement that the Bank shall notify the Regional Director and the Commissioner in writing at least 30 days prior to any individual assuming a new position as a senior executive officer or any additions to its board of directors.
   (c) To facilitate having and retaining qualified management, the Bank's board of directors shall, within 15 days from the effective date of this ORDER, appoint a committee with at least three members, composed of directors who are not now, and never have been, involved in the daily operations of the Bank ("Outside Directors"), and whose composition is acceptable to the Regional Director and the Commissioner (the "Committee"). The Committee shall, immediately upon being appointed, undertake an in-depth analysis of the Bank's managerial requirements. This analysis shall include a review of the composition, policies, and practices of the Bank's current operating management, and consideration of whether current operating management should be changed, or the terms and conditions under which current operating management should be continued. As part of this review, the Committee shall evaluate each Bank 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.
   (d) Within 90 days from the effective date of this ORDER, the Committee shall prepare and present to the board of directors of the Bank a written report of its findings and recommendations. The board of directors of the Bank shall review the Committee's report and evaluate its current operating management in light of such report, and shall take whatever action is necessary to implement its determinations. A copy of the Committee's report, as well as the board of directors' evaluation, determinations, and implementing actions, shall be submitted to the Regional Director and the Commissioner within 120 {{1-31-93 p.C-2858}}days from the effective date of this ORDER.

[.2] 2. (a) By not later than June 30, 1993, the Bank shall have adjusted Tier 1 capital equal to or greater than 6.0 percent of the Bank's adjusted Part 325 total assets and qualifying total capital equal to or greater than 8.0 percent of risk-weighted assets. Thereafter, during the life of this ORDER, the Bank shall maintain adjusted Tier 1 capital equal to or greater than 6.0 percent of the Bank's adjusted Part 325 total assets and qualifying total capital equal to or greater than 8.0 percent of risk-weighted assets.
   (b) Any increase in Tier 1 capital necessary to meet the ratio required by paragraph 2(a) of this ORDER may be accomplished by the following:

       (i) the sale of new securities in the form of common stock or non-cumulative perpetual preferred stock; or
       (ii) the direct contribution of cash by the directors or parent bank holding company of the Bank; or
       (iii) any combination of the above or other method acceptable to the FDIC.
   (c) If all or part of the increase in Tier 1 capital required by paragraph 2(a) of this ORDER is accomplished by the sale of new securities, the board of directors of the Bank shall forthwith adopt and implement a plan for the sale of such additional securities, including the voting of any shares owned or proxies held or controlled by them in favor of the plan. Should the implementation of the plan involve a public distribution of Bank securities (including a distribution limited only to the Bank's existing shareholders), the Bank shall prepare offering materials fully describing the securities being offered, including an accurate description of the financial condition of the Bank and the circumstances giving rise to the offering, and any other material disclosures necessary to comply with Federal and State securities laws. Prior to the implementation of the plan and, in any event, not less than 20 days prior to the dissemination of such materials, the plan and any materials used in the sale of the securities shall be submitted to the FDIC, Registration and Disclosure Section, Washington, D.C. 20429. Any changes requested to be made in the plan or materials by the FDIC shall be made prior to their dissemination.
   (d) In complying with the provisions of paragraph 2 of this ORDER, the Bank shall provide to any subscriber and/or purchaser of Bank securities written notice of any planned or existing development or other changes which are 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 shall be furnished within 10 calendar days from the date such material development or change was planned or occurred, whichever is earlier, and shall be furnished to every subscriber and/or purchaser of Bank securities who received or was tendered the information contained in the Bank's original offering materials.
   (e) For the purposes of this ORDER, the terms "Tier 1 capital" and "Part 325 total assets" shall have the meanings ascribed to them in Part 325 of the FDIC's Rules and Regulations, respectively sections 325.2(m) and 325.2(n) (to be recodified at 12 C.F.R. §§ 325.2(t) and (v), 57 Fed. Reg. 44866, 44899 (1992)), and the terms "qualifying total capital" and "riskweighted assets" shall have the meanings ascribed to them in Appendix A of Part 325 of the FDIC's Rules and Regulations. The "Analysis of Capital" schedule on page 3 of the FDIC Report of Examination provides the method for determining the ratio of adjusted Tier 1 capital to adjusted Part 325 total assets as required by this ORDER.
   (f) The Bank shall not lend funds directly or indirectly, whether secured or unsecured, to any purchaser of Bank stock or to any investor by any other means for any portion of any increase in Tier 1 capital required herein.

[.3] 3. (a) Within 30 days from the effective date of this ORDER, the board of directors of the Bank shall review the adequacy of the Bank's allowance for loan and lease losses. This review shall focus particular attention upon: (i) results of the Bank's internal loan review; (ii) loan loss experience; (iii) an estimate of potential loss exposure on each significant credit; (iv) concentrations of credit in the Bank; and (v) present and prospective economic conditions.
   (b) Immediately upon completing the review required by paragraph 3(a) of this ORDER, the Bank's board of directors {{1-31-93 p.C-2859}}shall adopt a method of computing the balance of the Bank's allowance for loan and lease 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, including, but not limited to, the factors referenced in paragraph 3(a). Thereafter, the Bank's board of directors shall, during the first month of each quarter, reevaluate the allowance for loan and lease losses and make such additional provisions for loan and lease losses that are necessary to maintain the allowance at an adequate level relative to the volume of risk in the Bank's loan portfolio. All such additional provisions for loan and lease losses shall be made in the first month of the calendar quarter in which the deficiency in the allowance 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 the calendar quarter in which the deficiency is identified 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 allowance shall be maintained for future regulatory review.
   (c) All increases in the allowance for loan and lease losses, with the exception of recoveries credited directly to the allowance, shall be accomplished by charges to operating earnings through the provision for loan and lease losses.

[.4] 4. (a) Within 60 days from the effective date of this ORDER, and within the first 30 days of each calendar year thereafter, the board of directors of the Bank shall develop a written earnings plan consisting of goals and strategies for improving the earnings of the Bank for each calendar year. The written earnings plan shall include, at a minimum:

       (i) identification of the major areas in, and means by, which the board of directors will seek to improve the Bank's operating performance;
       (ii) realistic and comprehensive budgets;
       (iii) a budget review process to monitor the income and expenses of the Bank to compare actual figures with budgetary projections on not less than a quarterly basis; and
       (iv) a description of the operating assumptions that form the basis for, and adequately support, major projected income and expense components.
   (b) Such written earnings plan and any subsequent modification thereto shall be submitted to the Regional Director and the Commissioner for review and comment. Within 30 days after the receipt of any comment from the Regional Director and the Commissioner, the board of directors shall approve the written earnings plan, which approval shall be recorded in the minutes of the meeting of the board of directors of the Bank. Thereafter, the Bank shall follow the written earnings plan and/or any subsequent modification thereto.

   [.5] 5. Within 10 days from the effective date of this ORDER, the Bank shall eliminate from its books, by collection or charge-off, all assets or portions of assets classified "Loss" and 50 percent of all assets or portions of assets classified "Doubtful" by the FDIC as a result of its examination of the Bank as of April 6, 1992, which have not been previously charged off or collected, provided, however, that prior to the effective date of this ORDER, the Bank may submit to the Regional Director and the Commissioner a list of those assets or portions of assets classified "Doubtful" which it believes should not be charged off and a comprehensive discussion of the circumstances surrounding each such asset or portion of an asset. The Bank shall eliminate from its books all or said listed assets or portions of assets not later than 30 days from the effective date of this ORDER, unless the Regional Director and Commissioner both issue written statements of nonobjection to the Bank's retaining any such asset or portion thereof, in which case the Bank may, subject to such conditions and limitations as the Regional Director or the Commissioner require, retain any such asset or portion of an asset on its books. In addition, and so long as this ORDER remains in effect, the Bank shall, within 30 days from the receipt of any subsequent Report of Examination of the Bank from the FDIC or the Commissioner, eliminate from its books, by collection or charge-off, all assets or portions of assets classified "Doubtful" in said Reports {{1-31-93 p.C-2860}}of Examination. Elimination of these assets through the use of the proceeds of loans or other extensions of credit made by the Bank does not constitute collection for the purposes of this ORDER.

[.6] 6. (a) Within 360 days from the effective date of this ORDER, 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 April 6, 1992, to not more than 150 percent of Tier 1 capital plus the allowance for loan and lease losses, and, within 540 days from the effective date of this ORDER, the Bank shall reduce the remaining total of such assets to not more than 100 percent of Tier 1 capital plus the allowance for loan and lease losses. The requirements of this paragraph 6(a) shall not be construed as a standard for future operations of the Bank. In addition to accomplishing the foregoing schedule of reductions, the Bank shall eventually reduce all adversely classified assets of the Bank.
   (b) As used in this ORDER, the word "reduce" means (i) to collect, (ii) to charge off, or (iii) to improve the quality of adversely classified assets sufficiently to warrant removing any adverse classification, as determined by the FDIC and the New Jersey Department of Banking ("Department"). Reduction of these assets through the use of the proceeds of loans or other extensions of credit made by the Bank does not constitute collection for the purposes of this ORDER.

[.7] 7. (a) Immediately upon the effective date 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), other than for taxes, insurance, and routine maintenance, 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 had been charged off the books of the Bank, in whole or in part, or to any affiliate or related interest of, or other person or entity associated with, any such borrower ("charged-off borrower"), so long as any portion of such extension of credit, whether or not that portion was charged off, remains uncollected.
   (b) Immediately upon the effective date of this ORDER, the Bank shall not extend, either directly or indirectly, any new or additional credit, other than for taxes, insurance, and routine maintenance, to or for the benefit of any borrower who is obligated in any manner to the Bank on any 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 April 6, 1992, or as a result of any subsequent examination of the Bank by the FDIC or the Department, or to any affiliate or related interest of, or other person or entity associated with, any such borrower ("classified borrower"), so long as such extension of credit remains classified or uncollected. This paragraph 7(b) shall not prohibit the Bank from renewing all or any part of an extension of credit to a classified borrower, after collection in cash of interest due on the entire extension of credit.
   (c) The prohibitions of paragraph 7(a) and 7(b) shall not apply to any extension of credit to a charged-off or classified borrower, if:

       (i) the Bank's failure to extend further credit to a charged-off or classified borrower would be substantially detrimental to the best interests of the Bank;
       (ii) the extension of credit fully complies with the requirements of the Bank's written lending and collection policies and procedures which have been revised, adopted, and implemented pursuant to paragraph 9 of this ORDER;
       (iii) any extension of credit, regardless of amount, with respect to any problem asset, as defined in paragraph 8 of this ORDER, is supported by a current appraisal which at a minimum complies in all respects with the requirements of Part 323 of the FDIC's Rules and Regulations, 12 C.F.R. Part 323;
       (iv) a comparison with the written program adopted pursuant to paragraph 8 of this ORDER shows that the Bank's formal program to eliminate the basis of criticism of said problem asset is not compromised; and,
       (v) prior to extending any credit to a charged-off borrower, or a classified borrower whose outstanding loans or other extensions of credit exceed $100,000 in the aggregate, a majority of the Bank's full board of directors {{1-31-93 p.C-2861}}approves the extension of credit and certifies, in writing, the specific reasons why failure to so act would be substantially detrimental to the best interests of the Bank. A copy of the board's certification shall be maintained in the credit file of the charged-off or classified borrower, and shall also be submitted promptly to the Regional Director and the Commissioner.

   [.8] 8. Within 30 days from the effective date of this ORDER, the Bank's board of directors 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 of the Bank becomes a problem asset, the board of directors of the Bank shall adopt and implement a written program for each such problem asset. For the purposes of this ORDER, a "problem asset" means any asset (including any unfunded commitment) which exceeds $100,000 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 April 6, 1992, 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 nonearning 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 the 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 Regional Director and the Commissioner.

   [.9] 9. Within 60 days from the effective date of this ORDER, the Bank shall review its written loan and collection policy and make whatever changes may be necessary to provide for the safe and sound administration of all aspects of the lending and collection function. Specific procedures shall be included for prior approval of loans to directors, officers and principal shareholders and their related interests in compliance with applicable laws and regulations. Loan documentation, repayment programs, collection and charge-off procedures and internal loan review shall also be included as a part of the review. The Bank shall adopt changes it considers necessary and appropriate and management shall reaffirm its intent to comply with the policy, as amended. Evidence of management's reaffirmation shall be reduced to writing. The policy and its implementation shall be in a form and manner acceptable to the Regional Director and the Commissioner as determined at subsequent examinations and/or visitations. A copy of the revised loan and collection policy shall accompany the first quarterly progress report furnished pursuant to paragraph 18 of this ORDER. Thereafter, whenever the revised loan and collection policy is further amended, a copy of the revised loan and collection policy as so amended shall accompany the first such quarterly progress report furnished after the adoption of each such amendment.

[.10] 10. (a) Within 30 days from the effective date of this ORDER, the board of directors of the Bank shall adopt and implement an internal loan review and grading system for periodically reviewing the Bank's loan portfolio and identifying and categorizing problem credits ("System"). At a minimum, the System shall provide for:

       (i) identifying the overall quality of the loan portfolio;
       (ii) the identification and amount of each delinquent loan;
       (iii) an identification or grouping of loans that warrant the special attention of management;
       (iv) for each loan identified, a statement of the amount and an indication of the degree of risk that the loan will not be fully repaid according to its terms and the reasons why the particular loan merits special attention;
       (v) an identification of credit and collateral documentation exceptions;
       (vi) the identification and status of {{1-31-93 p.C-2862}}each violation of law, rule or regulation;
       (vii) an identification of loans not in conformance with the Bank's lending policy, and exceptions to the Bank's lending policy;
       (viii) an identification of insider loan transactions; and
       (ix) a mechanism for reporting periodically, but in any event no less than quarterly, to the board of directors on the status of each loan identified and the actions taken by operating management.
   (b) A copy of each report submitted to the board, as well as documentation of the actions taken by the Bank to collect or strengthen assets identified as problem credits, shall be kept with the minutes of the board of directors.
   (c) All references to loans in this ORDER shall be deemed to include all other forms of extensions of credit.

   [.11] 11. Within 30 days from the effective date of this ORDER, the Bank's board of directors shall adopt and implement a plan to increase the diversification of the Bank's asset portfolio. Such plan shall address measures to be taken, target ratios to be met, and time frames for reducing the concentrations of credit which are detailed on pages 2-b and 2-b-1 of the Report of Examination of the Bank by the FDIC as of April 6, 1992.

   [.12] 12. Within 60 days from the effective date of this ORDER, the Bank shall eliminate and/or correct all violations of law and regulations, as described on pages 6-a through 6-a-6 of the Report of Examination of the Bank by the FDIC as of April 6, 1992. In addition, the Bank shall take all steps necessary to ensure future compliance with all applicable Federal and State laws and regulations.

   [.13] 13. Within 60 days from the effective date of this ORDER, the Bank shall develop, adopt, and implement a written policy satisfactory to the Regional Director and the Commissioner, which policy shall govern the relationship between the Bank and its holding company, and shall limit the payment of any management, consulting, or other fees or funds of any nature, directly or indirectly, to or for the benefit of the Bank's holding company to only those fees or funds paid in connection with services performed by the Bank's holding company on behalf of or for the benefit of the Bank.

   [.14] 14. Within 60 days from the effective date of this ORDER, the Bank shall take all necessary steps to eliminate all deficiencies noted in all assets scheduled as "Special Mention" by the FDIC as a result of its examination of the Bank as of April 6, 1992, and within 60 days from the receipt of any subsequent Report of Examination from the FDIC or the Department, the Bank shall take the necessary steps to eliminate all deficiencies noted in all assets scheduled as "Special Mention" in each such Report.

   [.15] 15. While this ORDER is in effect, the Bank shall not declare or pay either directly or indirectly any dividends, whether in cash, stock, or otherwise, on any class of its stock, without the prior written consent of the Regional Director and the Commissioner.

   [.16] 16. Following the effective date of this ORDER, the Bank shall send to its shareholders or otherwise furnish a description of this ORDER (i) in conjunction with the Bank's next shareholder communication, and also (ii) in conjunction with its notice or proxy statement preceding the Bank's next shareholder meeting. The description shall fully describe the ORDER in all material respects. The description and any accompanying communication, statement, or notice shall be send 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. The Bank's board of directors shall appoint a committee composed of at least three Outside Directors, as defined in paragraph 1(c) of this ORDER, and whose composition is acceptable to the Regional Director and the Commissioner (the "Compliance Committee"), to monitor the Bank's compliance with this ORDER. Within 30 days from the effective date of this ORDER, and at monthly intervals thereafter, such Compliance Committee shall prepare and present to he 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 min- {{1-31-93 p.C-2863}}utes of the meeting of the Bank's board of directors.

   18. By the 30th day after the end of the calendar quarter in which this ORDER is issued, and by the 30th day after the end of every calendar quarter thereafter, the Bank shall furnish written progress reports to the Regional Director and the Commissioner detailing the form, content, and manner of any actions taken to secure compliance with this ORDER, and the results thereof.
   The effective date of this ORDER shall be 10 days from the date of issuance.
   The provisions of this ORDER shall be binding upon the Bank, its successors, assigns, directors, officers, employees, 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.
   Dated: November 18, 1992.
   Pursuant to delegated authority.

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