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FDIC Enforcement Decisions and Orders

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{{3-31-95 p.C-3916}}
   [11,122] In the Matter of Kent Bank, Kent, Illinois, Docket No. FDIC-94-198b (1-20-95).

   Bank to cease and desist from such unsafe or unsound practices as following hazardous lending and lax collection practices; operating with inadequate capital; operating in violation of applicable laws or regulations; operating with an excessive volume of adversely classified assets; operating with inadequate liquidity; operating with inadequate allowance for loan and lease losses; operating with inadequate level of earnings; operating without adequate policies to monitor and control asset growth; 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 3-12-99; see ¶16,214)

   [.1] Capital—Tier 1 Capital—Increase/Maintain—Methods
   [.2] Management—Qualifications—Review
   [.3] Management—Management Plan—Minimum Requirements
   [.4] Board of Directors—Election—Outside Directors Added
   [.5] Dividends—Restricted
   [.6] Loans—Extensions of Credit—Existing Borrowers—Curtail
   [.7] Assets—Adversely Classified—Eliminate/Reduce
   [.8] Allowance for Loan and Lease Losses—Establish/Maintain
   [.9] Loans—Risk Position—Reduce—Written Plans Required
   [.10] Loans—Special Mention—Correct Deficiencies
   [.11] Technical Exceptions—Eliminate/Correct
   [.12] Collections Policy—Minimum Requirements
   [.13] Loan Committee—Responsibilities

{{3-31-95 p.C-3917}}
   [.14] Loan Policy—Written Revision—Minimum Requirements
   [.15] Assets—Total Assets—Limit on Increase
   [.16] Liquidity and Funds Management—Policy Required
   [.17] Violations of Law—Eliminate/Correct
   [.18] Interest—Rates Paid—Market Average
   [.19] Profit Plan—Minimum Requirements
   [.20] Shareholders—Disclosure—Cease and Desist Order
   [.21] Board of Directors—Committee to Review Compliance with Cease and Desist Order

In the Matter of
KENT BANK
KENT,ILLINOIS
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST
FDIC-94-198b

   Kent Bank, Kent, Illinois ("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 or regulation alleged to have been committed by the Bank, and of its right to a hearing on the 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 January 13, 1995, whereby, solely for the purpose of this proceeding and without admitting or denying the charges of unsafe or unsound banking practices and violations of law or regulation, 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 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 institution-affiliated parties, as that 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 law or regulation:
   A. Engaging in hazardous lending and lax collection practices, including, but not limited to the following:
—The failure to obtain proper loan documentation;
—The failure to establish and monitor collateral margins of secured borrowers;
—The failure to establish and enforce adequate loan repayment programs;
—The failure to obtain current and complete financial information;
—Extending credit beyond the borrower's reasonable ability to repay;
—The failure to adhere to loan policy guidelines'
—The failure to properly identify, monitor and react to problem credits;
—Other poor credit administration practices.
   B. Operating with an inadequate level of capital protection for the kind and quality of assets held.
   C. Violating law or regulation, including:
—The good faith terms and circumstances requirement of section 23B of the Federal Reserve Act ("section 23B"), 12 U.S.C. § 371c-1(a)(1)(B).
—Failure to file a Report of Apparent Crime as required under section 353.1(b)(1) of the FDIC Rules and Regulations, 12 C.F.R. § 353.1(b)(1).
   D. Operating with an excessive level of adversely classified loans and delinquent loans.
   E. Operating with inadequate liquidity in light of the Bank's asset and liability mix.
   F. Operating with an inadequate allowance for loans and lease losses ("ALLL")

{{3-31-95 p.C-3918}}for the volume, kind, and quality of loans and leases held.
   G. Operating with an inadequate level of earnings.
   H. Operating with inadequate policies to monitor and control asset growth.
   I. Operating with management whose policies and practices are detrimental to the Bank and which jeopardize the safety of its deposits.
   J. Operating with a board of directors which has failed to provide adequate supervision over and direction to the management of the Bank to prevent unsafe or unsound banking practices, and violations of law or regulation.
   IT IS FURTHER ORDERED, that the Bank, its institution-affiliated parties, and its successors and assigns, take affirmative action as follows:

[.1] 1. (a) Within 60 days from the effective date of this ORDER, the Bank shall increase its Tier 1 capital by an amount sufficient to increase the level of Tier 1 capital as a percentage of its total assets ("capital ratio") to a minimum of 7 percent.
   (b) Within 30 days from the last day of each calendar quarter following the date of required compliance with paragraph 1(a) of this ORDER, the Bank shall determine from its Report of Condition and Income its level of Tier 1 capital as a percentage of its total assets ("capital ratio") for that calendar quarter. If the capital ratio is less than 7 percent, the Bank shall, within 60 days of that date of the required determination, increase its capital ratio to not less than 7 percent calculated as of the end of that preceding quarterly period. For purposes of this ORDER, Tier 1 capital and total assets shall be calculated in accordance with Part 325 of the FDIC Rules and Regulations ("Part 325"), 12 C.F.R. Part 325.
   (c) Any such increase in Tier 1 capital may be accomplished by the following:

       (i) The sale of common stock and noncumulative perpetual preferred stock constituting Tier 1 capital under Part 325; or
       (ii) The elimination of all or part of the assets classified "Loss" as of March 31, 1994 without loss or liability to the Bank, provided any such collection on a partially charged-off asset shall first be applied to that portion of the asset which was not charged off pursuant to this ORDER;
       (iii) The collection in cash of assets previously charged off; or
       (iv) The direct contribution of cash by the directors and/or the shareholders of the Bank or its holding company; or
       (v) Any other means acceptable to the Regional Director of the Chicago Regional Office of the FDIC ("Regional Director") and the Commissioner of Banks and Trust Companies, State of Illinois ("Commissioner"); or
       (vi) Any combination of the above means.
   (d) If all or part of the increase in capital required by this paragraph is to be accomplished by the sale of new securities, the board of directors of the Bank shall adopt and implement a plan for the sale of such additional securities, including the voting of any shares owned or proxies held by or controlled by them in favor of said plan. Should the implementation of the plan involve public distribution of the Bank securities, including a distribution limited only to the Bank's existing shareholders, the Bank shall prepare detailing 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 the Federal 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 materials used in the sale of the securities shall be submitted to the FDIC, Registration and Disclosure Section, Room F-640, 1776 F-Street, N.W., Washington, D.C., 20429, for its review. Any changes requested to be made in the materials by the FDIC shall be made prior to their dissemination.
   (e) In complying with the provisions of paragraph 1(d) 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 of the

{{3-31-95 p.C-3919}}date any material development or change was planned or occurred, whichever is earlier, and shall be furnished to every purchaser and/or subscriber of the Bank's original offering materials.
   (f) The capital ratio analysis required by this paragraph shall not negate the responsibility of the Bank and its board of directors for maintaining throughout the year an adequate level of capital protection for the kind, quality and degree of market depreciation of assets held by the Bank.

[.2] 2. (a) During the life of this ORDER, the Bank shall have and thereafter retain qualified management. Each member of management shall have the 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:

    (comply with the requirements of this ORDER;
       (ii) operate the Bank in a safe and sound manner;
       (iii) comply with applicable laws and regulations; and
       (iv) restore all aspects of the Bank to a safe and sound condition, including asset quality, capital adequacy, earnings, management effectiveness, and liquidity.
   (b) During the life of this ORDER, the Bank shall notify the Regional Director and Commissioner in writing of any changes in the Bank's management. For purposes of this ORDER, "management" is defined as members of the board of directors and "senior executive officers," as that term is defined in section 32 of the Act ("section 32"), 12 U.S.C. § 1831(i), and section 303.14 of the FDIC Rules and Regulations ("section 303.14"), 12 C.F.R. § 303.14. Prior to the addition of any individual to the board of directors or the employment of any individual as a senior executive officer, the Bank shall comply with the requirements of section 32 and section 303.14.

[.3] 3. (a) Within 10 days from the effective date of this ORDER, the Bank shall retain a bank consultant acceptable to the Regional Director and Commissioner. The consultant shall develop a written analysis and assessment of the Bank's management and staffing needs ("Management Plan") for the purpose of providing qualified management for the Bank. The Management Plan shall be developed within 30 days from the effective date of this ORDER. The Management Plan shall include, at a minimum:

       (i) Identification of both the type and number of officer positions needed to properly manage and supervise the affairs of the Bank;
       (ii) Identification and establishment of such Bank committees as are needed to provide guidance and oversight to action management;
       (iii) Evaluation of all Bank officers and staff members 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 restoration and maintenance of the Bank in a safe and sound condition; and
       (iv) A plan to recruit and hire any additional or replacement personnel with the requisite ability, experience or other qualifications to fill those officer or staff member positions identified by this paragraph of this ORDER.
   (b) The Management Plan and any subsequent modification thereto shall be submitted to the Regional Director and Commissioner for review and comment upon their completion or receipt. Within 30 days from the receipt of any comment from the Regional Director and Commissioner and after the adoption of any recommended changes, the Bank shall approve the Management Plan or any subsequent modifications, which approval shall be recorded in the minutes of the board of directors' meeting. Thereafter, the Bank, its directors, officers, and employees shall implement and follow the Management Plan and/or any subsequent modification.

   [.4] 4. Within 120 days from the effective date of this ORDER, the Bank shall add to its board of directors two new members who are independent directors. For purposes of this ORDER, a person who is an independent director shall be any individual (a) who is not an officer of the Bank; (b) who does not own more than 5 percent of the outstanding

{{3-31-95 p.C-3920}}shares of the Bank; (c) who is not related by blood or marriage to an officer of or director of the Bank or to any shareholder owning more than 5 percent of the Bank's outstanding shares, and who does not otherwise share a common financial interest with such officer, director or shareholder; and (d) who is not indebted to the Bank directly or indirectly by blood, marriage or common financial interest, including the indebtedness of any entity in which the individual has a substantial financial interest in an amount exceeding 5 percent of the Bank's total Tier 1 capital and allowance for loan and lease losses. The addition of any new Bank directors required by this paragraph may be accomplished, to the extent permissible by state statute or the Bank's bylaws, by means of appointment or by election at a regular or special meeting of the Bank's shareholders.

   [.5] 5. As of the effective date of this ORDER, the Bank shall not declare or pay any cash dividend without the prior written consent of the Regional Director and Commissioner.

    [.6] 6. (a) As of the effective date of this ORDER, the Bank shall not extend, directly or indirectly, any additional credit to, or for the benefit of, any borrower who is already obligated in any manner to the Bank on any extensions of credit (including any portion thereof) that has been charged off the books of the Bank or classified "Loss" so long as such credit remains uncollected.
       (b) As of the effective date of this ORDER, the Bank shall not extend, directly or indirectly, any additional credit it, or for the benefit of, any borrower whose loan or other credit has been classified "Substandard," or is listed for "Special Mention" and is uncollected unless the Bank's board of directors has adopted, prior to such extension of credit, a detailed written statement giving the reasons why such extension of credit is in the best interest of the Bank. A copy of the statement shall be placed in the appropriate loan file and shall be incorporated in the minutes of the applicable board of directors' meeting.

   [.7] 7. As of the effective date of this ORDER, the Bank shall eliminate from its books, by charge-off or collection, all assets or portions of assets classified "Loss" within the Reports of Examination of the FDIC and Commissioner, as of March 31, 1994 and October 31, 1994, respectively, that have not been previously collected or charged off. Elimination or reduction of these assets with the proceeds of other Bank extensions of credit is not considered collection for the purpose of this paragraph.

    [.8] 8. (a) Prior to submission or publication of all Reports of Condition and Income required by the FDIC after the effective date of this ORDER, the board of directors of the Bank shall review the adequacy of the Bank's ALLL, provide for an adequate ALLL, and accurately report the same. The minutes of the board meeting at which such review is undertaken shall indicate the findings of the review, the amount of increase in the reserve recommended, if any, and the basis for determination of the amount of ALLL provided. In making these determinations, the board of directors shall consider the Federal Financial Institutions Examination Council's Instructions for the Reports of Condition and Income and any analysis of the Bank's ALLL provided by the FDIC.
       (b) While this ORDER is in effect, the Bank shall submit to the Regional Director and Commissioner the analysis supporting the determination of the adequacy of its ALLL. These submissions may be made at such times as the Bank files the progress reports otherwise required by the ORDER.
       (c) ALLL entries required by this Paragraph shall be made prior to any Tier 1 capital determinations required by this ORDER.

    [.9] 9. (a) Within 60 days from the effective date of this ORDER, the Bank shall adopt and implement a written plan to reduce the Bank's risk position in each asset in excess of $40,000 which is classified "Substandard" in the Reports of Examination of the FDIC and Commissioner, as of March 31, 1994 and October 31, 1994, respectively. A copy of the written plan shall be submitted to the Regional Director and Commissioner upon its completion. In developing such plan, the Bank shall, at a minimum:
         (i) Review the financial position of each such borrower, including source of repayment, repayment ability, and alternative repayment sources; and
         (ii) Evaluate the available collateral for each such credit, including possible {{3-31-95 p.C-3921}}actions to improve the Bank's collateral position.
       (b) Such plan shall include, but not be limited to, the following:

         (i) Dollar levels to which the Bank shall reduce each asset within 12 months from the effective date of this ORDER; and

         (ii) Provisions for the submission of monthly written progress reports to the Bank's board of directors for review and notation in minutes of the meetings of the board of directors.

    (c) As used in this paragraph, "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.

   [.10] 10. Within 90 days from the effective date of this ORDER, the Bank shall correct all deficiencies in the loans listed for "Special Mention" in the Reports of Examination of the FDIC and Commissioner, as of March 31, 1994 and October 31, 1994, respectively.

   [.11] 11. Within 90 days from the effective date of this ORDER, the Bank shall correct the technical exceptions listed in the Reports of Examination of the FDIC and Commissioner, as of March 31, 1994 and October 31, 1994, respectively.

   [.12] 12. Within 60 days from the effective date of this ORDER, the Bank shall adopt and implement a written plan for the reduction and collection of delinquent loans. Said plan shall include, at a minimum, provisions which: (1) prohibit the extension of required payments without proper verification of the borrower's ability to service the debt; (2) delineate areas of responsibility for supervising and monitoring collection practices within the consumer loan portfolio; and (3) establish acceptable guidelines for the collection of delinquent credits. A copy of the written plan shall be submitted to the Regional Director and Commissioner upon its completion. Such plan shall include, but not be limited to the following:

       (a) Dollar levels to which the Bank shall reduce delinquencies within 6 and 12 months from the effective date of this ORDER; and

       (b) Provisions for the submission of monthly written progress reports to the Bank's board of directors for review and notation in minutes of the meetings of the board of directors. Reductions of delinquent loans with the proceeds of other Bank extensions of credit, or through the granting of unsupported payment extensions or credit renewals will not be considered appropriate for the purpose of this paragraph.

   [.13] 13. (a) As of the effective date of this ORDER, the Bank's loan committee shall, at a minimum, perform the following functions:

       (i) Evaluate, grant, and/or approve loans in accordance with the Bank's loan policy amended to comply with this ORDER. The loan committee shall provide a thorough written explanation of any deviations from the loan policy, which statement shall address how said exceptions are in the Bank's best interest and which shall be reflected in the minutes of the corresponding committee meeting.

       (ii) Review and monitor the status of repayment and collection of overdue and maturing loans, as well as all other loans that were classified "Substandard" in the FDIC's Report of Examination as of March 31, 1994, or that are included on the Bank's internal watch list.

       (iii) Maintain written minutes of the committee meetings which include a record of the review and status of the aforementioned loans.

[.14] 14. (a) Within 30 days from the effective date of this ORDER, and annually thereafter, the board of directors of the Bank shall review the Bank's loan policy and procedures for adequacy and, based upon this review, shall make all appropriate revisions to the policy necessary to strengthen lending procedures and abate additional loan deterioration. The revised written loan policy and any subsequent modifications shall be submitted to the Regional Director and Commissioner for review and comment upon their completion.

   (b) The initial revisions to the Bank's loan policy required by this paragraph, at a minimum, shall address the recommendations setforth on page 8.4 of the FDIC's Report of Examination as of March 31, 1994, as well as the following provisions:
{{3-31-95 p.C-3922}}

       (i) Designating the Bank's normal trade area;

       (ii) Establishing review and monitoring procedures to ensure that all lending personnel are adhering to established lending procedures and that the directorate is receiving timely and fully documented reports on loan activity, including any deviations from established policy;

       (iii) Requiring that all extensions of credit originated or renewed by the Bank be supported by current credit information and collateral documentation, including lien searches and the perfection of security interests; have a clearly defined and stated purpose; and have a predetermined and realistic repayment source and specific amortization program. Credit information and collateral documentation shall include current financial information, profit and loss statements or copies of tax returns, and cash flow projections, and shall be maintained throughout the term of the loan with loan officer notations and comments; and

       (iv) Incorporating limitations on the amount that can be loaned in relation to established collateral values, including the requirement that the source of the valuations be identified and which require that such collateral valuations shall be completed prior to the disbursement of loan proceeds and be performed on a periodic basis over the term of the loan;

   (c) Within 30 days from the receipt of any comments from the Regional Director and Commissioner and after the adoption of any recommended changes, the board of directors shall approve the written loan policy and any subsequent modification thereto, which approvals shall be recorded in the minutes of the board of directors' meeting. Thereafter, the Bank shall implement and follow the written loan policy and any subsequent modifications thereto.

   [.15] 15. During the life of this ORDER, the Bank shall not increase its total assets by more than 4 percent during any consecutive three-month period without providing, at least 30 days prior to its implementation, a growth plan to the Regional Director and Commissioner. Such growth plan shall include the funding source to support the projected growth, as well as the anticipated use of funds. This growth plan shall not be implemented without the prior written consent of the Regional Director and Commissioner. In no event shall the Bank increase its total assets by more than 10 percent annually. For the purpose of this paragraph, "total assets" shall be defined as in the Federal Financial Institutions Examination Council's Instructions for the Consolidated Reports of Condition and Income.

    [.16] 16. (a) Within 60 days from the effective date of this ORDER, the Bank shall adopt and implement a written plan addressing liquidity and the Bank's relationship of volatile liabilities to temporary investments and rate sensitivity objectives. Annually thereafter during the life of this ORDER, the Bank shall review this plan for adequacy and, based upon such review, shall make appropriate revisions in the plan that are necessary to strengthen funds management procedures and maintain adequate provisions to meet the Bank's liquidity needs. A copy of the revised plan shall also be submitted to the Regional Director and Commissioner, for their review and comment. The initial plan shall include, at a minimum, provisions which:

         (i) establish adequate recordkeeping systems to identify and track the volume of core deposits and volatile deposits;

         (ii) establish a desirable range for liquidity and volatile liability dependency ratios as computed in FDIC Reports, and require that monthly calculations of the liquidity and dependency ratios be provided to the board of directors for review, with such review noted in the board minutes;

         (iii) establish a range of acceptable loans-to-deposit and loans-to-asset ratios;

         (iv) establish contingency plans to improve liquidity to the level established in the Bank's liquidity policy; and,

         (v) establish a funds-management committee to meet at least monthly to determine how best to allocate the Bank's available funding sources among various asset categories after reviewing: (1) the Bank's liquidity position, (2) outstanding loan commitments and letters of credit, (3) upcoming deposit maturities, and (4) the Bank's ratesensitivity position and net interest margin.

{{11-30-97 p.C-3923}}

    [.17] 17. (a) Within 10 days from the effective date of this ORDER, the Bank shall eliminate and/or correct all violations of law and/or regulations listed on pages 8.23 and 8.24 of the FDIC's Report of Examination as of March 31, 1994.

       (b) Within 30 days from the effective date of this ORDER, the Bank shall implement procedures to ensure future compliance with all applicable laws and regulations.

   [.18] 18. As of the effective date of this ORDER, the Bank shall develop appropriate measures to assure that the rates offered by the bank on any of its interest bearing deposits are within 75 basis points of the average rate paid for similar type deposits by banks within the normal market area or the national rate paid on similar type deposits for deposits solicited outside the bank's normal market area.

       [.19] 19. (a) Within 60 days from the effective date of this ORDER, the Bank shall adopt and implement a written profit plan and a realistic, comprehensive budget for all categories of income and expense for calendar year 1995. The plan required by this paragraph shall contain formal goals and strategies, consistent with sound banking practices, to reduce discretionary expenses and to improve the Bank's overall earnings, and shall contain a description of the operating assumptions that form the basis for major projected income and expense components. A copy of the plan shall be submitted to the Regional Director and Commissioner upon its completion.

       (b) Prior to the end of each calendar quarter, the Bank's board of directors shall evaluate the Bank's actual performance in relation to the plan and budget required by this paragraph and record the results of the evaluation, and any actions taken by the Bank, in the minutes of the board of directors' meeting at which such evaluation is undertaken.

       [.20] 20. 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 (2) in conjunction with its notice or proxy statement preceding the Bank's next shareholder meeting. The description shall fully describe the ORDER in all material respects. The description and any accompanying communication, notice, or statement shall be sent to the FDIC, Registration and Disclosure Section, Room F-640, 1776 F-Street, N.W., 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.

   [.21] 21. Within 60 days from the effective date of this ORDER, the Bank shall establish a compliance committee comprised of at least three directors. The committee shall monitor compliance with this ORDER, and, within 90 days from the effective date of this ORDER, and every 90 days thereafter, shall submit to the board of directors for consideration at its regular monthly meeting a written report detailing the Bank's compliance with this ORDER. The compliance report shall be incorporated in the minutes of the board of directors' meeting. Establishment of this committee does not in any way diminish the responsibility of the entire board of directors for ensuring compliance with the provisions of this ORDER.

   22. Within 30 days of the end of each calendar quarter following the effective date of this ORDER, the Bank shall furnish to the Regional Director and Commissioner written progress reports signed by each member of the Bank's board of directors, detailing the actions taken to secure compliance with the ORDER and the results thereof. Such reports may be discontinued when the corrections required by this ORDER have been accomplished and the Regional Director and Commissioner have, in writing, released the Bank from making further reports. The effective date of this ORDER shall be a 10 days after its issuance by the FDIC.

   The provisions of this ORDER shall be binding upon the Bank, its institution-affiliated parties, and any successors and assigns thereof.

   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: January 20, 1995.
   Pursuant to delegated authority.

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