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[11,406] In the Matter of United Bank and Trust Company, New Orleans, Louisiana, Docket No. FDIC 97-032b (5-1-97)
Respondent agrees to cease and desist from unsafe and unsound banking practices such as engaging in hazardous lending and lax collection practices; operating with inadequate capital in relation to the kind and quality of assets held by the bank; operating with a large volume of poor-quality loans; operating with an inadequate loan valuation reserve; operating in such a manner as to produce operating losses; operating with management whose policies and practices may be detrimental to the bank and jeopardize the safety of its deposits; and operating with a board of directors which may fail to provide adequate supervision over and direction to the active management of the bank. (This order was terminated by order of the FDIC dated 12-5-00; see ¶16,271.)
[.1] Management—Qualifications Specified
[.2] Board of Directors—Reconstitute—Outside Directors
[.3] Management—Report Required—Written Plan of Implementation
[.4] Management—Business Plan Required
[.5] Capital—Tier 1—Increase/Maintain
[.6] Loan and Lease Losses—Adequate Allowance—Maintain
[.7] Assets—Substandard—Eliminate
[.8] Loans—Review Program—Develop/Implement
[.9] ESOP—Review/Properly Administer
[.10] Shareholders—Cease and Desist Order—Disclosure
[.11] Cease and Desist Order—Compliance Reports Required
In the Matter of
UNITED BANK AND TRUST
COMPANY
NEW ORLEANS, LOUISIANA
Insured State Nonmember Bank
ORDER TO CEASE AND DESIST
FDIC-97-032b
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United Bank and Trust Company, New Orleans, Louisiana ("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)(1) of the Federal Deposit Insurance Act ("Act"), 12 U.S.C. § 1818(b)(1), and having waived those rights, entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST ("CONSENT AGREEMENT") with counsel for the Federal Deposit Insurance Corporation ("FDIC"), dated April 21, 1997, 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 directors, officers, employees, agents, successors, assigns, and other institution-affiliated parties of the Bank, cease and desist from any of the following unsafe or unsound banking practices and violations:
(a) engaging in hazardous lending and lax collection practices;
(b) operating with inadequate capital in relation to the kind and quality of assets held by the Bank;
(c) operating with a large volume of poor-quality loans;
(d) operating with an inadequate loan valuation reserve;
(e) operating in such a manner as to produce operating losses;
(f) operating in violation of section 22(h) of the Federal Reserve Act, as amended, 12. U.S.C. § 375b, and section 215.4(a) of Regulation O of the Board of Governors of the Federal Reserve System, 12 C.F.R. §§ 215.4(a) made applicable to state nonmember banks by section 18(j)(2) of the Act, 12 U.S.C. § 1828(j)(2) and section 23A of the Federal Reserve Act, 12 U.S.C. § 371c, made applicable to state nonmember banks by section 18(j)(1) of the Act, 12 U.S.C. § 1828(j)(1);
(g) operating with management whose policies and practices may be detrimental to the Bank and jeopardize the safety of its deposits; and
(h) operating with a board of directors which may fail to provide adequate su-
{{7-31-97 p.C-4347}}pervision over and direction to the active management of the Bank.
IT IS FURTHER ORDERED that the Bank take affirmative action as follows:
[.1] 1. (a) During the life of this ORDER, the Bank shall have management qualified to restore the Bank to a sound condition. Such management shall include chief executive officer and an experienced senior lending officer responsible for supervising the Bank's overall lending function.
(b) Present management, which includes the Bank's board of directors, shall be assessed on its ability to:
(i) Comply with the requirements of this ORDER;
(ii) Improve and thereafter maintain the Bank in a safe and sound condition, including asset quality, capital adequacy, liquidity adequacy, and earnings adequacy; and
(iii) Comply with all applicable State and Federal laws and regulations.
(c) (i) During the life of this ORDER, the Bank shall notify the Regional Director of the Memphis Regional Office ("Regional Director") and the Commissioner of Financial Institutions for the State of Louisiana ("Commissioner") in writing of any resignations and/or terminations of any members of its board of directors and/or any of its officer(s) within 15 days of the event.
(ii) The Bank shall comply with section 32 of the Act, 12 U.S.C. § 1831i.
(d) Within 60 days of the effective date of this ORDER, the Bank's board of directors shall develop and adopt an educational program for each member of the board. The educational program shall include, at a minimum:
(i) specific training in the areas of lending, operations, and compliance with laws, rules and regulations applicable to FDIC insured depository institutions;
(ii) specific training in the duties and responsibilities of the board of directors in connection with the safe and sound operation of the Bank; and
(iii) provision for periodic training.
The training should ensure that the board of directors is provided with the most current and up-to-date information. The educational program shall be submitted to the Regional Director and the Commissioner within 90 days of the effective date of this ORDER for review and comment. Within 30 days from receipt of any comment, and after consideration of such comment, the board of directors shall implement the educational program. The board of directors shall document the training activities in the minutes of the next meeting following completion of the training. The board's actions as required by this paragraph shall be satisfactory to the Regional Director and the Commissioner as determined at subsequent examinations or visitations.
[.2] (e) Within 30 days from the effective date of this ORDER, the board of directors shall establish a committee of the board of directors with the responsibility to ensure that the Bank complies with the provisions of this ORDER. At least two-thirds of the members of such committee shall be independent, outside directors as defined herein. The committee shall report monthly to the entire board of directors, and a copy of the report and any discussion relating to the report or the ORDER shall be included in the minutes of the board of directors. Nothing contained herein shall diminish the responsibility of the entire board of directors to ensure compliance with the provisions of this ORDER.
(f) For the purpose of this ORDER, an "outside director" shall be an individual:
(i) Who shall not be employed, in any capacity, by the Bank or its affiliates other than as a director of the Bank or an affiliate;
(ii) Who shall not own or control more than 5 percent of the voting stock of the Bank or its holding company;
(iii) Who shall not be indebted to the Bank or any of its affiliates in an amount greater than 5 percent of the Bank's equity capital and reserves;
(iv) Who shall not be related to any directors, principal shareholders or the Bank or affiliates of the Bank; and
(v) Who shall be a resident of, or engage in business in, the Bank's trade area.
[.3] 2. (a) Within 60 days from the date of this ORDER, the board of directors shall review and make a written report ("Management Report") on the Bank's management needs in the lending area. Special emphasis shall be placed on the Bank's Special Lending Department. For purposes of this
{{7-31-97 p.C-4348}}ORDER, "Special Lending" shall have the meaning ascribed to it in the Bank's written loan policy as of September 30, 1996, which includes secured loans to finance used cars. The Management Report shall incorporate an analysis of the Bank's management and staffing requirements and shall, at a minimum:
(i) Identify both the number and type of positions needed to properly supervise the Bank's lending functions, giving appropriate consideration to the Bank's loan volume, customer base and the number of problem credits.
(ii) Provide a clear and concise description of the general duties and responsibilities for lending officers and their support staff.
(iii) Identify the skills, experience and pay required for each position.
(iv) Provide an evaluation of the Bank's senior management and lending officials, indicating whether bank officials possess the necessary lending and collection experience and qualifications required to adequately perform present and anticipated duties.
(v) Establish a plan to recruit, hire and/or replace personnel based on ability and experience.
(vi) Establish a plan providing for periodic evaluation of each individual's job performance.
(vii) Provide for periodic review of Bank's management and updating of lending policies and procedures.
(b) The board of directors shall obtain the services of an outside consultant(s), acceptable to the Regional Director and the Commissioner, who is knowledgeable in the area of lending, collections and personnel evaluation to assist the board of directors in reviewing the Bank's management needs and preparing the Management Report. The acceptability of the consultant(s) shall be based on the consultant's ability to advise the Bank in each of the areas identified in Paragraph 2(a).
(c) Within 90 days of the effective date of this ORDER, the board of directors, with the assistance of the outside consultant(s), shall prepare a written plan of implementation ("Plan") addressing the findings of the Management Report. The plan shall specify the actions to be taken by the board of directors and the time frames for each action.
(d) Within 90 days of the effective date of this ORDER, the board of directors shall prepare a written report ("Written Report") which shall (1) contain a recitation identifying the recommendations made by the outside consultants(s) which have been incorporated in the Management Report and Plan, (2) a recitation identifying the recommendations made by the outside consultant(s) which were not incorporated in the Management Report and Plan and the reasons for not including such recommendations, and (3) a copy of any report(s) prepared by the outside consultant(s).
(e) A copy of the Management Report, Plan, and Written Report shall be submitted to the Regional Director and the Commissioner for review and comment. Within 30 days from receipt of any comment, and after consideration of such comment, the board of directors shall approve the Management Report and Plan of implementation which approval shall be recorded in the minutes of the meeting of the board of directors. It shall remain the responsibility of the board to fully implement the plan within the specified time frames. In the event the Plan, or any portion thereof, is not implemented, the board shall immediately advise the Regional Director, in writing, of specific reasons for deviating from the Plan.
[.4] 3. (a) Within 90 days from the effective date of this ORDER, the board of directors of the Bank shall develop and submit to the Regional Director and the Commissioner a business plan that contains, at a minimum:
(i) a statement of the board's general business philosophy;
(ii) defines the board's business vision and goals;
(iii) details the board's long term (within one to three years) and short term (within six months) objectives and strategies as to anticipated activities, asset/liability mix, loan and deposit pricing, and growth; and
(iv) contains projections as to growth, capital, deposit sources, and general investment plans.
(b) The business plan shall incorporate a written profit plan which shall, at a minimum, address:
(i) identification of the major areas in, and means by, which the board of directors will seek to improve the Bank's operating performance;
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(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; and
(v) Periodic salary review.
(c) A copy of the business plan shall be submitted to the Regional Director and the Commissioner for review and comment. Within 30 days from receipt of any comment, and after consideration of such comment, the board of directors shall approve the business plan which approval shall be recorded in the minutes of the meeting of the board of directors. It shall remain the responsibility of the board to fully implement the business plan within the specified time frames. In the event the business plan or any portion thereof is not implemented, the board shall immediately advise the Regional Director and the Commissioner, in writing, of specific reasons for deviating from the business plan.
(d) The board shall assess, on at least a quarterly basis, the Bank's performance in relation to its business plan, shall determine the cause and implications of any substantial deviations therefrom, and shall amend the business plan on an ongoing basis as appropriate. The results of the board's assessment shall be recorded in the minutes of the meeting of the board of directors.
4. Within 60 days from the effective date of this ORDER, the Bank shall develop, adopt and implement a written ethics policy and procedure with regard to the ethical conduct and other standards of conduct and responsibilities for its directors, officers, employees, agents and other persons participating in the conduct of the affairs of the Bank. ("Ethics Program") At a minimum, the Ethics Program shall address the following:
(a) Ethical and other conduct and responsibilities of individuals in the acceptance of gifts, entertainment, favors and loans; in the case of the use of official information; employment of relatives; use of Bank property; travel expenses; and indebtedness to the Bank or any other financial institution.
(b) The financial interests and obligations of individuals that appear to conflict with that individual's duties and responsibilities such as:
(i) Participating in any manner in any transaction or loan in which the individual, his spouse, child, partner, or organization is involved; or in which the individual serves as an officer, director, trustee, partner, or employee, or has a financial interest;
(ii) Purchasing of Bank property;
(iii) Providing goods or services to the Bank; and
(iv) Outside employment and other activities.
(c) A periodic written method of reporting each individual's compliance with the Ethics Program to an Ethics Counselor and/or committee who shall review compliance with the Ethics Program and report his findings to the board of directors.
[.5] (a) (i) No later than September 30, 1997, the Bank shall achieve and maintain Tier 1 capital equal to or greater than six (6.0) percent of the Bank's adjusted Part 325 total assets.
(ii) No later than March 31, 1998, the Bank shall achieve and maintain Tier 1 capital equal to or greater than six and one-half (6.5) percent of the bank's adjusted Part 325 total assets.
(iii) No later than September 30, 1998, the Bank shall have Tier 1 capital equal to or greater than seven and one-half (7.5) percent of the Bank's adjusted Part 325 total assets.
(iv) Thereafter, during the life of this ORDER, the Bank shall maintain Tier 1 capital equal to seven and one-half (7.5) percent of the Bank's adjusted Part 325 total assets.
(b) Any increase in Tier 1 capital necessary to meet the ratio required by Paragraph 5(a) of this ORDER may be accomplished by the following:
(i) The sale of new securities in the form of common stock; or
(ii) The direct contribution of cash by the directors, shareholders, or parent bank holding company of the Bank; or
(iii) Any other method acceptable to the FDIC and the Commissioner.
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(c) If all or part of the increase in Tier 1 capital required by Paragraph 5(a) of this ORDER is 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 or controlled by them in favor of the plan. Should the implementation of the plan involve a public distribution of the Bank's 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 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 plan and any materials used in the sale of the securities shall be submitted to the FDIC, Registration and Disclosure Unit, 550 17th Street, N.W., Room F-250, Washington, D.C. 20429 and the Commissioner for review. Any changes requested to be made in the plan or materials by the FDIC shall be made prior to their dissemination. If the Regional Director allows any part of the increase in Tier 1 capital to be provided by the sale of noncumulative perpetual preferred stock, than all terms and conditions of the issue, including but not limited to those terms and conditions relative to the interest rate and any convertibility factor, shall be presented to the Regional Director for prior approval.
(d) In complying with the provisions of Paragraph 5 of this ORDER, the Bank shall provide to any subscriber and/or purchaser of the Bank's 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 days from the date such material development or change was planned or occured, whichever is earlier, and shall be furnished to every subscriber and/or purchaser of the Bank's securities who received or was tendered the information contained in the Bank's original offering materials.
(e) For 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 subsections 325.2(t), and 325.2(v), 12 C.F.R. § § 325.2(t) and (v). The "Capital Calculations" schedule on page 4.2 of the Joint Report of Examination provides the method for determining the ratio of 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.
[.6] Within 30 days from the effective date of this ORDER, the Bank shall establish and shall thereafter maintain, through charges to current operating income, an adequate valuation reserve for loan and lease losses. In determining the adequacy of the valuation reserve for loan and lease losses, the board of directors of the Bank shall at a minimum consider the following:
(i) Prevailing instructions contained in the Federal Financial Institutions Examination Council booklet entitled "Instructions—Consolidated Reports of Condition and Income";
(ii) The volume and mix of the existing loan portfolio, including the volume and severity of nonperforming loans and adversely classified credits, as well as an analysis of net charge-offs experienced on previously adversely classified loans;
(iii) The extent to which loan renewals and extensions are used to maintain loans on a current basis and the degree of risk associated with such loans;
(iv) The trend in loan growth, including any rapid increase in loan volume within a relatively short time period;
(v) General and local economic conditions affecting the collectibility of the Bank's loans;
(vi) Previous loan loss experience by loan type, including the trend of net chargeoffs as a percent of average loans over the past several years;
(vii) Off balance sheet credit risks;
(viii) The overall risk associated with each concentration of credit together with the degree of risk associated with each related individual borrower; and
(ix) Any other factors appropriate in determining future valuation reserves.
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(b) Prior to the submission of any Report of Condition or Report of Income, the board of directors of the Bank shall review the adequacy of the Bank's valuation reserve for loan and lease losses. The minutes of the board meetings at which each review is undertaken shall indicate the results of the review, the amount of any increase to the reserve, and the basis for the amount of the valuation reserve. The criteria for the review shall be as set forth in Paragraph 6(a).
(c) Notwithstanding the provisions of Paragraph 6(a) and 6(b) above, as of the effective date of this ORDER, the Bank shall have achieved, a valuation reserve for loan and lease losses, as of September 30, 1996, after charge-off of loans classified "Loss" as required in Paragraph 7(a) below, of not less than $450,000.
(d) In the event that the Regional Director and/or the Commissioner determine, at subsequent examinations and/or visitations, that the Bank's valuation reserve for loan and lease losses is inadequate, the Bank shall amend its Consolidated Reports of Condition and Income.
(e) The requirements of Paragraph 6(c) above are not to be construed as a standard for future operations.
7. (a) Within 10 days from the effective date of this ORDER, the Bank shall eliminate from its books, by charge-off or collection, all assets classified "Loss" as of September 30, 1996, that have not been previously collected or charged-off. Reduction of these assets through proceeds of other loans made by the Bank is not considered collection for the purpose of this paragraph.
[.7] (b) Within 90 days from the effective date of this ORDER, the Bank shall have reduced the assets classified "Substandard" as of September 30, 1996, to not more than $800,000.
(c) Within 180 days from the effective date of this ORDER, the Bank shall have reduced the assets classified "Substandard" as of September 30, 1996, to not more than $725,000.
(d) Within 270 days from the effective date of this ORDER, the Bank shall have reduced the assets classified "Substandard" as of September 30, 1996, to not more than $650,000.
(e) Within 360 days from the effective date of this ORDER, the Bank shall have reduced the assets classified "Substandard" as of September 30, 1996, to not more than $575,000.
(f) The requirements of Paragraphs 7(a), 7(b), 7(c), 7(d), and 7(e) are not to be construed as standards for future operations and, in addition to the foregoing, the Bank shall eventually reduce the total of all adversely classified assets. As used in Paragraphs 7(b), 7(c), 7(d), 7(e), and 7(f) the word "reduce" means (i) to collect, (ii) to charge-off, or (iii) to sufficiently improve the quality of assets adversely classified to warrant removing any adverse classification, as determined by the FDIC and the Commissioner.
8. (a) Beginning with 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 has a loan or other extension of credit with the Bank that has been charged off or classified, in whole or in part, "Loss" and is uncollected. The requirements of this paragraph shall not prohibit the Bank from renewing (after collection in cash of interest due from the borrower) any credit already extended to any borrower.
(b) Beginning with the effective date of this ORDER, the Bank shall not make any further extensions of credit, directly or indirectly, to any borrower whose loans are adversely classified "Substandard" as of September 30, 1996, without prior approval by the Bank's board of directors after the board's affirmative determination, as reflected in the minutes of the meeting that the extension of credit is in full compliance with the Bank's loan policy, that the extension of credit is necessary to protect the Bank's interest or is adequately secured, that credit analysis has determined the customer to be creditworthy, and that all necessary loan documentation is on file, including current financial and cash flow information and satisfactory appraisal, title and lien documents.
9. (a) Within 60 days from the effective date of this ORDER, the Bank shall revise, adopt, and implement written lending and collection policies to provide effective guidance and control over the Bank's lending function with emphasis on the Bank's Special Lending Department. At a minimum, the revised policies shall address acquisition of dealer financial information limits for any one dealer's paper, dealer reserves and charge-backs, delinquency notification and
{{7-31-97 p.C-4352}}follow-up, charge-offs, and collections. Such policies and their implementation shall be in a form and manner acceptable to the Regional Director and the Commissioner as determined at subsequent examinations and/or visitations.
[.8] (b) Within 60 days after the effective date of this ORDER, the board of directors shall establish a loan review committee to periodically review the Bank's loan portfolio and identify and categorize problem credits. At least 50 percent of the members of the loan review committee shall be directors not employed in any capacity by the bank other than as a director. The committee shall file a report with the board of directors. This report shall include the following information:
(i) The overall quality of the loan portfolio;
(ii) The identification, by type and amount, of each problem or delinquent loan;
(iii) The identification of all loans not in conformance with the Bank's lending policy; and
(iv) The identification of all loans to officers, directors, principal shareholders or their related interests.
10. Within 180 days from the effective date of this ORDER (unless within 60 days an alternative timetable or proposal is submitted by the Bank and approved in writing by the Regional Director and the Commissioner), the Bank shall reduce the concentration as of September 30, 1996, of loans in the Specialized Lending Department, which are secured by used automobiles, to an amount which shall be less than 100 percent of the Bank's Tier 1 capital.
11. Within 60 days from the effective date of this ORDER, the Bank shall eliminate and/or correct all violations of law which are set out on pages 8.10 and 8.11 of the Joint Report of Examination of the Bank as of September 30, 1996. In addition, the Bank shall henceforth comply with all applicable laws and regulations.
[.9] 12. (a) Within 30 days from the effective date of this ORDER, the Bank's board of directors shall authorize a comprehensive review of the Bancshares Employee Stock Ownership Plan and take appropriate measures to ensure that the ESOP has been and is administered solely for the benefit of the ESOP participants and is being conducted as an employee benefit plan qualified under the Internal Revenue Code for federal income tax exemption and in accordance with appropriate laws, rules and regulations and in a manner consistent with sound fiduciary principles. The results of the comprehensive review and any measures adopted by the board of directors to ensure proper administration of the ESOP shall be recorded in the minutes of the meeting of the board.
(b) The Bank shall not make any payments or contributions to the ESOP unless:
(i) the board of directors has conducted an independent review of the action which includes, at a minimum, an assessment of:
(A) the effect of such contribution on the Bank's earnings performance and its relation to overall personnel expense; and
(B) the Bank's ability to continue to meet minimum capital requirements of Paragraph 5 above.
(ii) the board of directors has determined that it is advantageous for the Bank to engage in such action after such independent review;
(iii) the board of directors has determined that the Bank's contribution complies with all applicable laws, rules and regulations, including Regulation O of the Federal Reserve Act, the Employee Retirement Income Security Act, and the Internal Revenue Code.
(iv) the board of directors has received from the ESOP trustee, a signed statement in the specific use of the proposed contribution;
(v) the board of directors has given the Regional Director and the commissioner thirty days' prior notice of the Bank's proposed contribution to the ESOP.
(vi) the board of directors has recorded the results of its review in the minutes of the meeting of the board of directors.
13.While this ORDER is in effect, the Bank shall not declare or pay any cash dividend on its capital stock without the prior written approval of the Regional Director and the Commissioner.
[.10] 14. 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
{{7-31-97 p.C-4353}}fully describe the ORDER in all material respects. The description and any accompanying communication, statement, or notice shall be sent to the FDIC, Division of Supervision, Registration and Disclosure Unit, 550 17th Street, N.W., Room F-250, Washington, D.C. 2042, 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.
[.11] 15. On the fifteenth day of the second month following the effective date of this ORDER, and on the fifteenth day of every third month thereafter, the Bank shall furnish written progress reports to the Regional Director detailing the form and manner of any actions taken to secure compliance with this ORDER and the results thereof. Such reports may be discontinued when the corrections required by this ORDER have been accomplished and the Regional Director has released the Bank in writing from making further reports.
The provisions of this ORDER shall be binding upon the Bank, its directors, officers, employees, agents, successors, assigns, and other institution-affiliated parties of the Bank.
This ORDER shall become effective 10 days from the date of its issuance.
The provisions of this ORDER shall remain effective and enforceable except to the extent that, and until such time as, any provisions of this ORDER shall have been modified, terminated, suspended, or set aside by the FDIC.
Pursuant to delegated authority.
Dated: 5/1/97
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