Each depositor insured to at least $250,000 per insured bank



Home > Regulation & Examinations > Bank Examinations > FDIC Enforcement Decisions and Orders




FDIC Enforcement Decisions and Orders

ED&O Home | Search Form | Text Search | ED&O Help


{{6-30-03 p.C-4893}}
   [¶:11,697] In the Matter of Highland Community Bank, Chicago, Illinois, Docket No. 99-128c&b (3-3-00)

   A cease and desist order was issued, based on findings by the FDIC that it had reason to believe that respondent had engaged in unsafe and unsound practices.

(This order terminated by order of the FDIC issued 4-30-03; see ¶16,335.)    [.1] Bank Records—Restore to Complete and Accurate State
   [.2] Management—Qualifications Specified
   [.3] Data Processing Center—Adequate Staffing Required
{{6-30-03 p.C-4894}}
   [.4] Management—Management Plan Required
   [.5] Bank Operations—Expansion Restricted
   [.6] Software—Resolution of Foreign Currency Program Required
   [.7] Capital—Increase Required
   [.8] Dividends—Dividends Restricted
   [.9] Funds Management and Liquidity—Preparation or Revision of Fund Management Policy Required
   [.10] Brokered Deposits—Notice to FDIC
   [.11] Liquidity—Establish Procedures to Monitor
   [.12] Assets—Adversely Classified Assets—Reduction Required
   [.13] Strategic Plan—Preparation of Required
   [.14] Audit—Required
   [.15] Violations of Law—Correction of Violations Required
   [.16] Board of Directors—Review Investment Policies
   [.17] Board of Directors—Review Management Actions
   [.18] Bank Operations—Information Systems and Internal Reporting Requirements
   [.19] Software—Standards Required
   [.20] Board of Directors—Committee to Review Compliance with Cease and Desist Order Required
   [.21] Shareholders—Disclosure of Cease and Desist Order Required

In the Matter of

HIGHLAND COMMUNITY BANK
CHICAGO, ILLINOIS
(Insured State Nonmember Bank)
ORDER TO CEASE AND DESIST
FDIC-99-128c&b

   The Federal Deposit Insurance Corporation ("FDIC"), on December 13, 1999, issued to Highland Community Bank ("Bank"), a NOTICE OF CHARGES AND OF HEARING ("NOTICE") pursuant to section 8(b) of the Federal Deposit Insurance Act ("Act"), 12 U.S.C. § 1818(b) and a Temporary Order to Cease and Desist ("TEMPORARY ORDER") pursuant to sections 8(c)(1) and (3) of the Act, 12 U.S.C. §§ 1818(c)(1) and (3). The NOTICE charged the Bank with having engaged in unsafe or unsound banking practices. The Bank and counsel for the FDIC and the Assistant Commissioner of the Office of Banks and Real Estate ("Assistant Commissioner") thereafter executed a STIPULATION AND CONSENT TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST ("CONSENT AGREEMENT"), dated March 2, 2000, whereby, solely for the purpose of this proceeding and without admitting or denying the allegations in the NOTICE, the Bank consented to the issuance of an ORDER TO CEASE AND DESIST ("ORDER") by the FDIC.
   The FDIC and Assistant Commissioner considered the matter and determined that they had reason to believe that the Bank had engaged in unsafe or unsound banking practices. The FDIC and Assistant Commissioner, therefore, accepted the CONSENT AGREEMENT and the FDIC 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:
   A. Operating with a board of directors which has failed to provide adequate supervision over and direction to management.
   B. Operating with management whose policies and practices are detrimental to the Bank and which jeopardize the safety of its deposits.
   C. Failing to keep accurate books and records.
   D. Operating with inadequate liquidity in light of the Bank's assets and liability mix.
{{5-31-00 p.C-4895}}
   E. Operating with inadequate internal routines and controls for the Bank and the Bank's data center and information systems.
   F. Operating with an inadequate audit program.
   G. Operating with an excessive amount of interest rate risk.
   H. Operating with an inadequate level of capital protection for the risk profile of the Bank, the kind and quality of assets held, and the potential for additional liabilities.
   I. Operating with poor lending and lax collection practices.
   J. Violating law or regulation, including:
   The requirements of section 103.22(a) of the Treasury Department's Financial Recordkeeping and Reporting of Currency and Foreign Transactions Regulation, 31 C.F.R. § 103.22(a);
   Section 326.8(b) of the FDIC Rules and Regulations, 12 C.F.R. § 326.8(b);
   Section 304.4 of the FDIC Rules and Regulations, 12 C.F.R. § 304.4;    Sections 349.3(a) and (b) of the FDIC Rules and Regulations, 12 C.F.R. § 349.3(a) and (b); and
   Section 323(a)(5)(ii) of the FDIC Rules and Regulations, 12 C.F.R. § 323(a)(5)(ii).
   IT IS FURTHER ORDERED, that the Bank, its institution-affiliated parties, and its successors and assigns, take affirmative action as follows:

   [.1]1. The Bank shall immediately allocate the necessary resources to return the Bank's books and records to a complete and accurate state. By the effective date of this ORDER, the Bank shall restore its books and records to a complete and accurate state and shall continue to maintain accurate books and records. All accounts that are presently unreconciled or out of balance must be corrected and written documentation of the correction or reconciliation shall be retained for future regulatory review. All account differences originating prior to October 5, 1999 that are not reconciled and balanced by January 31, 2000 shall be charged off from the Bank's books. During the life of this ORDER, all accounting differences for entries dated subsequent to October 5, 1999 shall be charged off from the Bank's books if not reconciled and balanced within 90 days of the date of entry.

   [.2]2. (a) During the life of this ORDER, the Bank shall have and thereafter retain a qualified chief executive officer. Within 45 days from the effective date of this ORDER, the Bank shall have and thereafter retain a qualified chief operating officer, a qualified manager of the Information Systems area, and a qualified manager of the lending department. 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:

       (i) comply with the requirements of this ORDER;
       (ii) operate the Bank in a safe and sound manner;
       (iii) comply with applicable laws and regulations;
       (iv) ensure that the Bank's electronic or automated information systems result in the Bank's books and records being in and remaining in a complete and accurate state; and
       (v) restore all aspects of the bank to a safe and sound condition, including asset quality, capital adequacy, earnings, management effectiveness, interest rate risk, and liquidity.
   (b) During the life of this ORDER, the Bank shall notify the Regional Director of the Chicago Regional Office of the FDIC ("Regional Director") and the Assistant 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 303.101 of the FDIC Rules and Regulations, 12 C.F.R. § 303.101. 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 303.102 of the FDIC Rules and Regulations, 12 C.F.R. § 303.102.

   [.3]3. By the effective date of this ORDER, the Bank must provide for and maintain adequate staffing and oversight of the Bank's Date Processing Center. The adequacy of staffing will be assessed on:

       (i) management depth and succession;
       (ii) the ability to appropriately review daily reports; and
    {{5-31-00 p.C-4896}}
       (iii) experience in the types of computer systems used by the Bank.

   [.4]4. (a) Within 30 days from the effective date of this ORDER, the Bank shall retain a bank consultant who 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. Within 60 days from the effective date of this ORDER, the Management Plan shall be completed and submitted to the Regional Director and Assistant Commissioner for review and comment. 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 active 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 and other qualifications to fill those officer or staff member positions identified by this paragraph of this ORDER.
   (b) Within 30 days from the receipt of all such comments from the Regional Director and Assistant Commissioner, and after consideration of all such comments, the Bank shall approve the plan, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter, the Bank shall implement and follow the plan.

   [.5]5. The Bank shall not, without the prior approval of the Regional Director and Assistant Commissioner, establish or acquire any additional branch office or engage in any new line of business, including but not limited to, the providing of depository services for the City of Chicago relating to its parking facilities at O'Hare International Airport and the providing of depository services for vendors at O'Hare International Airport.

   [.6]6. By the effective date of this ORDER, the Bank's foreign currency software programming problems as discussed in the September 20, 1999 FDIC Report of Examination must be resolved and appropriate adjustments posted to the Bank's general ledger. By the effective date of this ORDER, the Bank must develop an action plan to reflect Bank management's strategies to prevent similar problems from occurring.

   [.7]7. (a) By the effective date of this ORDER, the Bank shall have formulated a capital plan to increase the Bank's Tier 1 leverage capital to at least 7.0 percent of total assets, exclusive of a fully funded Allowance for Loan and Lease Losses ("ALLL"). A copy of the capital plan shall be submitted to the Regional Director and the Assistant Commissioner. For purposes of this ORDER, Tier 1 leverage 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.
   (b) Within 60 days from the effective date of this ORDER, the Bank will increase its Tier 1 leverage capital to at least 7.0 percent of total assets, exclusive of a fully funded ALLL.
   (c) Within 10 days from the last day of each month and following the effective date of paragraph 7(b), above, the Bank shall determine its level of Tier 1 leverage capital as a percentage of its total assets ("capital ratio") for that month end. If the capital ratio is less than 7.0 percent, the Bank shall, within 30 days of the date of the required determination, increase its capital ratio to not less than 7.0 percent calculated as of the end of that preceding period.
   (d) Any increase in Tier 1 leverage capital required by this paragraph 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 September 20, 1999 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; or
       (iii) The collection in cash of assets previously charged off; or
    {{5-31-00 p.C-4897}}
       (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 and Assistant Commissioner; or
       (vi) Any combination of the above means.
   (e) 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 detailed 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 in Washington, D.C., for its review. Any changes requested to be made in the materials by the FDIC shall be made prior to their dissemination.
   (f) In complying with the provisions of paragraph 7(e) 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 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.
   (g) 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.

   [.8]8. As of the effective date of this ORDER, the Bank shall pay no cash dividends that would result in a Tier 1 leverage capital ratio of less than 7.0 percent, without the prior written consent of the Regional Director and Assistant Commissioner.

   [.9]9. Within 30 days from the effective date of this ORDER, the Bank shall formulate, and submit to the Regional Director and Assistant Commissioner for review and comment, a written plan addressing liquidity and the Bank's relationship of volatile liabilities to temporary investments, rate sensitivity objectives, and an asset/liability management policy. Within 30 days from the receipt of all such comments from the Regional Director and the Assistant Commissioner, and after consideration of all such comments, the Bank shall approve the plan, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter, the Bank shall implement the plan. 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 to maintain adequate provisions to meet the Bank's liquidity needs. The initial plan shall include, at a minimum, provisions:

       (i) Establishing a desirable range for net non-core funding dependence ("volatile liability dependency ratio") as defined in the User's Guide for the Uniform Bank Performance Report;
       (ii) Identifying the source and use of borrowed and/or volatile funds;
       (iii) Establishing appropriate lines of credit that would allow the Bank to borrow funds to meet depositor demands if the Bank's other provisions for liquidity are inadequate;
       (iv) Requiring the retention of securities and/or other identified categories of investments that can be liquidated within one day in amounts sufficient (as a percentage of the Bank's total assets) to ensure the maintenance of the Bank's liquidity posture at a level consistent with short- and long-term liquidity objectives;
       (v) Establishing a minimum liquidity ratio and defining how the ratio is to be calculated;
       (vii) Establishing plans to improve li- {{5-31-00 p.C-4898}}quidity to the level established in the Bank's liquidity policy.

   [.10]10. During the life of this ORDER, the Bank shall not renew brokered deposits or obtain new brokered deposits without the prior written approval of the Regional Director and Assistant Commissioner. Any request for approval to renew brokered deposits or obtain new brokered deposits shall be made in accordance with the waiver provision of Section 337.6(c) of the FDIC Rules and Regulations, 12 C.F.R. § 337.6(c). For purposes of this ORDER, brokered deposits are defined as described in section 337.6(a) of the FDIC Rules and Regulations, 12 C.F.R. § 337.6(a).

   [.11]11. (a) Within 60 days from the effective date of this ORDER, the Bank shall develop and submit to the Regional Director and Assistant Commissioner for review and comment:

       (i) an adequate model for managing and monitoring the Bank's sensitivity to market risk; and
       (ii) a formal plan for reducing the imbalance between rate sensitive assets and liabilities.
   (b) Within 30 days from the receipt of all such comments from the Regional Director and Assistant Commissioner and after consideration of all such comments, the Bank shall approve the plans, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter, the Bank shall implement and follow the plans.

   [.12]12. (a) 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" as of September 20, 1999 that have not been previously collected or charged off. Any such charged-off asset shall not be rebooked without the prior written consent of the Regional Director and Assistant Commissioner. 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.
   (b) Within 60 days from the effective date of this ORDER, the Bank shall develop a formal risk identification program that includes procedures for loan and lease review, loan and lease risk rating, the placing of loans and leases on the Watch List, and timely recognition of loss.

   [.13]13. (a) Within 90 days from the effective date of this ORDER, the Bank shall formulate, and submit to the Regional Director and Assistant Commissioner for review and comment, a written formal strategic plan to address the direction and goals of the Bank. The strategic plan shall include a detailed assessment of the Bank's present and anticipated future market area(s) as well as personnel and financial resources and operating circumstances unique to the Bank. The strategic plan should also consider the Information Systems area, including an adequate contingency plan. Further, the strategic plan should include a realistic profit plan and comprehensive budget. The written profit plan shall address, at a minimum, the following:

       (i) realistic asset growth and margin assumptions;
       (ii) realistic core deposit growth projections and strategies associated therewith;
       (iii) realistic funding strategies associated with the use of brokered deposits that address, among other things, limitations on the total amount of brokered deposits that the Bank can use in relation to total deposits, and sufficient documentation to show that the Bank's use of brokered deposits will have a positive impact upon earnings, liquidity and interest rate risk;
       (iv) maintenance of an adequate ALLL;
       (v) clear assignments of responsibility for implementing these plans.
   (b) Within 30 days from the receipt of all such comments from the Regional Director and Assistant Commissioner, and after consideration of all such comments, the Bank shall approve the strategic plan, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter, the Bank shall implement and follow the strategic plan. The strategic plan shall be reviewed by the Bank's board of directors periodically and revised as appropriate.
   (c) At 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 evaluations, and any actions taken by the Bank, in the minutes of the board of directors' meeting at which such evaluation is undertaken.

   [.14]14. (a) Within 90 days from the effective date of this ORDER, the Bank's board of directors shall adopt and implement a comprehensive written audit program, which shall include the Bank's Information Systems area. {{5-31-00 p.C-4899}}The Bank shall thereafter implement and enforce an effective system of internal and external audits. The internal auditor shall make written monthly reports of audit findings directly to the Bank's board of directors. The minutes of the meetings of the board of directors shall reflect consideration of these reports and describe any action taken as a result thereof. A copy of the audit program should be submitted to the Regional Director and Assistant Commissioner upon its completion.
   (b) Within 60 days from the effective date of this ORDER, the Bank shall provide for an external audit of its financial statements and operating procedures, including the Bank's Information Systems area, to be performed by an independent public accounting firm.
   (c) During the life of this ORDER, the Bank shall forward copies of any external audit reports required by this paragraph to the Regional Director and Assistant Commissioner within 10 days from the Bank's receipt of such reports.

   [.15]15. (a) Within 30 days from the effective date of this ORDER, the Bank shall correct all violations of law and/or regulations listed on pages 51–55 of the September 20, 1999 FDIC Report. With regard to past violations of Part 323, 12 C.F.R. Part 323, relating to appraisals, the Bank shall implement procedures to prevent future violations.
   (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.

   [.16]16. (a) Within 90 days from the effective date of this ORDER, and annually thereafter, the bank's board of directors shall review the Bank's investment policy and practices for adequacy and, based upon this review, shall make appropriate revisions in the policy which are necessary to strengthen the Bank's investment procedures.
   (b) The Bank's policy, when revised as required by this paragraph, shall be submitted to the Regional Director and Assistant Commissioner for review and comment. Within 30 days from the receipt of all such comments from the Regional Director and Assistant Commissioner, and after consideration of such comments, the Bank shall approve the policy, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter the Bank shall implement and follow the policy.

   [.17]17. Within 45 days from the effective date of this ORDER, the Board shall have the Bank's attorneys perform a review of past management actions to determine whether the Bank has acted in contravention of Medicare agreements and whether any contingencies or losses could result. Upon completion, the Bank shall submit the assessment to the Regional Director and Assistant Commissioner.

   [.18]18. Within 45 days from the effective date of this ORDER, the Bank shall establish appropriate oversight of the Information System ("IS") area. At a minimum, this shall include:

       (a) Activating the IS Steering Committee;
       (b) Requiring the IS Steering Committee to maintain minutes and submit regular formal reports to the Bank;
       (c) Requiring the IS Steering Committee to receive regular reports from the Management Information System department;
       (d) Requiring the IS Steering Committee to review and approval all personnel, hardware, and software changes in the IS area;
       (e) Reviewing and tracking, to final resolution, all audit and examination report recommendations relating to the IS area;
       (f) Reviewing and approving, at least annually, all IS policies.
   19. (a) Within 60 days from the effective date of this ORDER, the Bank shall assess its IS activities. This assessment shall accomplish the following objectives:
       (i) Determine if the Bank would be best served by continuing to operate an in-house computer system, outsource its IS activities, or use a combination of in-house processing and outsourcing; and
       (ii) Determine the proper controls and procedures to be employed by the Bank's IS department, including all hardware and software controls.
   (b) If the Bank determines to continue processing in-house, the Bank shall continue to maintain adequate staffing and oversight of the data processing function.
   20. Within 90 days from the effective date of this ORDER, the Bank shall establish ad- {{5-31-00 p.C-4900}}equate IS security procedures and settings by reviewing, revising, and approving those procedures and settings that cover the Operating System of the AS400, the Application System Programs used in the IS area, and all related Utility System Programs. At a minimum, the Bank shall:
       (a) Appoint or retain a qualified and independent security officer for the IS area and the local area network;
       (b) Provide adequate training and supervision for the security officer;
       (c) Implement procedures to monitor security activities on a daily basis;
       (d) Remove the security functions from the system programmer and provide for adequate separation of duties in computer operations.
   21. Within 90 days from the effective date of this ORDER, the Bank shall complete a review of all system user security profiles and provide the users with appropriate security access that is necessary for the completion of their job functions, which shall include limiting access to compiler and utility programs.

   [.19]22. Within 90 days from the effective date of this ORDER, the Bank shall develop standards for software development and modifications, including procedures for programmer duties and for placing new or modified software into production, and shall submit the standards to the Regional Director and Assistant Commissioner for review and comment. Within 30 days from the receipt of all such comments from the Regional Director and Assistant Commissioner and after consideration of all such comments, the Bank shall approve the standards, which approval shall be recorded in the minutes of a board of directors' meeting. Thereafter, the Bank shall implement and follow the standards.

   [.20]23. During the life of this ORDER, the Bank shall establish and maintain a compliance committee comprised of at least four directors who are not officers of the Bank. The committee shall meet bi-weekly, maintain formal written minutes of record, and monitor the Bank's compliance with this ORDER. The committee shall submit to the Bank's Board of Directors, for consideration at the Board's regular 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. The establishment and maintenance of the compliance committee does not in any way diminish the responsibility of the entire Board of Directors for ensuring compliance with the provisions of this ORDER. During the life of this ORDER, regular Board of Director meetings shall be held at least bi-weekly.
   24. Within 45 days following the date of issuance of this ORDER, and within 10 days after each calendar quarter end thereafter, the Bank shall furnish to the Regional Director and Assistant Commissioner written progress reports, signed by each member of the Bank's board of directors, detailing the form and manner of any actions taken to secure compliance with this ORDER. Such reports may be discontinued when the corrections required by this ORDER have been accomplished and the Regional Director and Assistant Commissioner have, in writing, released the Bank from making further reports.

   [.21]25. 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 in Washington, D.C. 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.
   The effective date of this ORDER shall be 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.
   Pursuant to delegated authority.
   Dated: March 3, 2000.

ED&O Home | Search Form | Text Search | ED&O Help

Last Updated 6/17/2003 legal@fdic.gov