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Failed Bank Information
Question and Answer Guide for Silverton Bank, N.A., Atlanta, GA
FDIC Call Center
Toll free number 1-800-523-0640
Hours of Operation – Eastern Time
Friday, May 1, 2009:   Until 9:00 p.m.
Saturday, May 2, 2009:   9:00 a.m. – 6:00 p.m.
Sunday, May 3, 2009:   Noon – 6:00 p.m.
Thereafter:   8:00 a.m. – 8:00 p.m.

GENERAL QUESTIONS

Silverton failed: Why did Silverton, N.A. fail?

Silverton failed due to significant loan losses which eroded its capital position and reduced its ability to maintain adequate liquidity. Problem assets centered in Acquisition, Development, and Construction loans and non-owner occupied Consumer Real Estate loans. Silverton's efforts to raise capital were unsuccessful.

Bridge Bank: What is bridge bank, how does it?

A bridge bank is a new national bank chartered by the Office of the Comptroller of the Currency (OCC) and controlled by the FDIC in accordance with section 11(n) of the Federal Deposit Insurance Act.

 

Creating a bridge bank permits parallel functions to continue. First, the bridge bank allows client banks to maintain their correspondent banking relationship with the least amount of disruption. The Silverton Bridge Bank, N.A. will be the name of the bridge bank. Secondly, operating a bridge bank allows FDIC's preexisting efforts to market the bank to continue. Thirdly, operating the bridge bank allows time for the failed bank to be liquidated in an orderly fashion if marketing efforts are unsuccessful.

Bridge Bank closed: How long will the bridge bank be operational and what happens when it is closed? Will it be it liquidated?

Silverton Bridge Bank, N.A. will be operational for a period of time sufficient to allow client banks to transition correspondent services. When the bridge bank is ultimately terminated, no additional services will be offered by Silverton Bridge Bank, N.A. Current asset portfolios will be serviced, managed, and marketed through the receivership.

Level of Service: Will my bank continue to operate at the same level of services as provided before? Will you continue to provide these services as expected by my customers?

Silverton Bridge Bank, N.A. will continue to operate correspondent services in a business as usual manner. However, loans and other assets will be handled by the Receiver as per FDIC policies.

Communication Plan: How do you plan to communicate with the client banks about the status of this closing?

The FDIC’s plan to communicate with Silverton’s client banks is as follows:

  1. A press release (www.fdic.gov/news/news/press/2009/pr09061.html) has been prepared to discuss the closing of Silverton Bank, N.A.
  2. A conference call is scheduled for Saturday, May 2, 2009, at 3:00pm EST. The affected customers have been notified of the number to call. Please refer to the Silverton Bank, N.A. Conference Call Agenda for details.
  3. If you were unable to dial-in, a replay of the call can be accessed by calling 1-800-867-1927. The replay will be available 1 hour after the conclusion of the conference call. The 1-800-867-1927 number will be operable until 3:00pm EST May 8, 2009.  This is a call for clients of Silverton Bank and is not meant for the media. If representatives of the press access this replay, there should be no attribution or use of this information in any of your reporting. If you have any questions regarding media issues, please contact David Barr at (202) 898-6992 at dbarr@fdic.gov."  A written transcript is also available.
  4. We have created a web site where you may submit questions at any time. You may submit your questions by clicking the following link: https://fdicsurvey.inquisiteasp.com/surveys/N229ux/.

Silverton's failures impact on other banker's bank: What impact, if any, do you think Silverton's failure will have on the remaining banker's banks?


Since the FDIC created the bridge bank to take over Silverton Bank operations, there is not expected to be any meaningful impact on Silverton’s clients or the other banker’s banks. While FDIC continues to market Silverton, operating the bridge bank allows correspondent services provided to client banks to continue without disruption.

Subordinated debt: What will happen to the holders of subordinated debentures issued by Silverton Bank?  What will happen to my investment in Silverton stock?

Holders of subordinated debt of Silverton Bank, N.A., will need to file a claim with the FDIC as Receiver for Silverton Bank, N.A. 

Silverton Stocks: What will happen to my investment in Silverton Financial Services, Inc.?

All the stock of Silverton Bank, N.A., was owned by the bank holding company, Silverton Financial Services, Inc. Shareholders of equity stock, trust preferred securities, and subordinated debt of Silverton Financial Services, Inc. should direct inquiries to:

 
Chris Maddox
770-867-9111 – Office

Company debt: How will my company's debt, stock loans and/or borrowings be disposed of?

Bank stock loans will be independently reviewed and each borrower will be contacted to determine the various options available to them and the FDIC. The Receiver does not intend to package these loans to sell; however, it will continue to manage them until they are resolved.

The receiver’s role is to maintain integrity and loan values in order to return the loans to the private sector as quickly as possible (with the exception of the bank stock loans). The process includes packaging the loans and offering them for sale. Typically the marketing process is completed several months after a bank’s failure.

UPDATE: The Receiver is charged with winding up the affairs of the failed institution and disposing of the failed institution's assets in a cost-effective and time-efficient manner. 12 U.S.C §1821(c)(2)(A)(ii). After careful consideration, the FDIC, as Receiver of Silverton, is now evaluating final resolution options for this portfolio that may likely include an Asset Marketing initiative and ultimate sale of this portfolio

Continuation of services: Have arrangements been made to provide for a continuation of services and/or disaster recovery sites?

Silverton Bridge Bank, N.A. will continue to provide correspondent services in a business as usual manner. Please continue to use your customary account manager for guidance on how to address your specific needs.

Working with the same Silverton representative: Will we continue to work with the same person we did prior to resolution?

Yes. The bridge bank will continue to employ key personnel during its tenure.

Customer communication: What communication is going to be provided that I can give my customers?

See the answer to question 5 above.

Discontinuing use of Silverton's name: Do we need to discontinue the use of anything bearing Silverton’s name?

You can continue to use anything that bears the Silverton name. Silverton Bridge Bank, N.A. will maintain Silverton Bank ’s routing number.

New correspondent relationships: What guidance is available regarding the procedures and requirements to establish a new correspondent relationship? How do I find out if a particular correspondent may be at risk of resolution?

Guidance on obtaining correspondent services is provided on the Federal Reserve Board’s website (www.federalreserve.gov). The FDIC does not comment on open, insured financial institutions.

PAYMENT SOLUTIONS/DEPOSITS

Bank funds at risk: Are any of our bank funds at risk?

Silverton Bridge Bank, N.A. is a newly chartered institution. The FDIC is the sole shareholder, and insured deposits continue to be fully insured.

Returned deposit items: Will the process I use to receive my RDI Cash Letters (Returned Deposited Items) be changed?

TBB Connect will remain active and processing cash items and return items will remain unchanged. 

Using TBB Connect/ACH origination: If I use TBB Connect today for ACH origination will I continue to use this connection?

TBB Connect will remain active and can be used to initiate ACH transactions. All warehoused and in-process ACH transactions will settle as scheduled.

Routing number change: Will any routing numbers change?

Silverton Bridge Bank, N.A. will use the same ABA routing number as Silverton Bank. Silverton Bridge Bank, N.A.

Continuation of wires: Will Silverton continue to do wires or will member banks need to perform this service now?

During its tenure, Silverton Bridge Bank, N.A. will continue to initiate and process wires.

Clearing account: Do I need to move my clearing account?

During its tenure, the bridge bank will continue to provide this service. At the same time, FDIC is continuing with efforts to market the Silverton Bank N. A. franchise over the next few weeks. If the marketing efforts are unsuccessful, the bridge bank will continue to operate to allow sufficient time for client banks to transition services to another institution in an orderly manner. Currently, client banks can begin evaluating potential providers for correspondent services.

ACH changes: What will change with ACH, ACH settlement, rejects?


During the tenure of the bridge bank there will be no change to ACH processing.

Silverton reports: How do I get reports and other output previously provided by Silverton?

Account Information reporting will continue to be accessible via TBB Connect. Daily, weekly and monthly Account Summary statements will be available. Customized Cash Letter Availability Reports will continue to be available to all clearing customers via TBB Connect. Silverton Bridge Bank, N.A. will provide balance confirmations as needed for your financial institution’s internal and external audit needs.

Customer changes: What changes will my customers see (statements, notices, etc.)?

There should be no change since Silverton Bridge Bank, N.A. will continue to operate all systems of Silverton Bank.

Pass-through reserves: Will my pass-through reserves for the current week be credited?

Yes. The bridge bank enables the FDIC to continue providing this service to client banks.

Originating credit/debit: Through Silverton Bank, I am an originator of credit/debit ACH services for clients. Will those occur on a timely basis on Monday?

Yes. Silverton Bridge Bank, N.A., operations will continue to operate these services business as usual.

Deposit broker: I am a deposit broker or I have brokered deposits. What do I need to do?

Depository Trust & Clearing Company (DTCC) brokered deposits will be paid out directly by the FDIC. Brokers will not need to provide documentation to the FDIC. If you are a DTCC participant broker, you must contact DTCC with any questions. If you are a customer who has a Silverton Bank, N.A. deposit through a broker, you must contact your broker with any questions.

CAPITAL MARKETS

How will Fed Funds be paid: How will I be paid for the Federal Funds sold to Silverton Bank (as principal)? Will this include interest through repayment date?

Silverton Bank terminated purchasing unsecured Federal Funds for internal use effective April 28, 2009. Any Federal Funds purchased remaining on Silverton Bank's books was deposited into the client bank's DDA on April 29, 2009. Silverton Bridge Bank, N.A. will not re-offer this product.


Silverton Bridge Bank, N.A. will continue accepting Federal Funds from client banks and selling those funds to your approved upstream purchasing banks.

Federal Reserve arrangements: If I am not paid immediately for my Federal Funds sold, have any arrangements been made with the Federal Reserve for short term borrowings by the respondent banks?

No. All monies, including interest have been deposited by Silverton Bank, N.A. into your account on April 29, 2009.

Purchasing Fed Funds: Will I be able to purchase Federal Funds and how? Will my agent Federal Funds continue with interest? On Monday, will my Federal Funds credit line be available?

Silverton Bridge Bank, N.A. will not purchase Federal Funds from client banks. However, we will continue to sell funds to clients who have established lines of credit from the former Silverton Bank, N.A. We discontinued the agent agreement effective April 28, 2009.

Honoring purchase/sale commitments: I have a pending purchase/sale of securities that are to be settled on Monday. How will the commitment be honored? Will we continue to buy bonds the same way after resolution?

If securities trades have not yet settled, we expect to complete the settlement of those trades. Also, at present we do not anticipate any changes in the way trades are settled. If a customer needs to put on new trades, we expect to do so as needed, during tenure of the bridge bank.

SAFEKEEPING AND BOND ACCOUNTING

Length of bond accounting and safekeeping services: How long will the bridge bank provide bond accounting services and safekeeping services?

All accounting and correspondent services will be business as usual during the tenure of the bridge bank.

COMMERCIAL BANKING

Payments on participating loans: Will investors continue to receive their share of payments collected on participated loans?

Silverton Bridge Bank, N.A. will continue to service participated loans and provide the downstream payments to the participants using the client banks' clearing account. Investors will receive their share of the payments without interruption.

Advances on loans: Will advances be allowed (and under what circumstances) for any loans (personal or non-personal)?

All requests for the advance of funds will be reviewed individually to determine the current status of each loan, the reason for the advance, determine if all inspections have been completed to verify work performed as billed, and all necessary documentation is current.

Proportionate share on advances: If advances are allowed, will the proportionate share be requested from an investor in that loan?

Yes, the Receiver will only address any unfunded portion that was a commitment on the part of Silverton.

Collection efforts: For any litigation efforts Silverton is currently involved in, will those efforts continue and under what name?

Any current or pending litigation actions initiated by Silverton Bank, N.A., may be stayed for up to 90 days.  This will allow time to review each situation on a case-by-case basis.

Maturing loans: On loans reaching maturity that have a good pay record, and that we have agreed to renew in the past – what process do we follow for them?

The Receiver will independently review any request for an extension at maturity.

Promissory note with different pricing scenarios: If a promissory note states that a client can convert part of their note to a different pricing scenario, i.e. variable to fixed under certain terms, do we honor such requests or is there a process to follow to process the requests?

The Receiver and Silverton Bridge Bank, N.A. will maintain the same process established by the bank with respect to adjustments to rates if the terms of the note allow for the adjustments and all other terms of the note have been maintained in a current status.

Credit bureau reporting: Will credit bureau reporting continue and if so, under what entity?

The Receiver does not report to credit bureaus. However, Silverton Bridge Bank, N.A, will continue to report to credit bureaus.

Silverton Bank, N.A. participation: Will Silverton Bridge Bank, N.A. honor a commitment that Silverton Bank had on a loan participation that will close soon?

Each transaction will require independent review; however, it is likely that if a loan has not been booked on the records of Silverton Bank, N.A., prior to closing the Receiver will not advance funds for any new loans.

Funding for unfunded loan portion: Will funding continue on the unfunded portion of a client bank's loan?

Requests for additional funding will be addressed immediately. FDIC will conduct a thorough analysis and may require additional information to perform its analysis and make a fact-based decision. Such information can include current financial statements and recent tax returns from borrowers and guarantors, and third party reports such as feasibility studies, market analyses, and appraisals. All requests will be reviewed individually to determine the loan status, the reason for the advance, and whether the funding is in the best interest of the receivership. FDIC will discuss funding decisions with participants.

CARDS SERVICES

Card program customer service: Who will perform Customer Service support for my Card program?

There will be no changes to customer service support. Employees will continue to field customer service calls 8am – 6pm, and service partners will continue to provide customer service during non-banking hours.

Card program incentives: Will monthly/quarterly incentives on the card program continue as normal?

Yes. There will be no changes to incentives.

Card program feature changes: Will any of the card program features change (e.g. rewards)?

There will be no immediate changes to card program features. Program features will be reviewed by the FDIC as Receiver. There may be changes once the card program is sold to another card issuer.

Contact for card program accounts: Who will credit card clients contact for questions about my credit card program/accounts?

Continue to use the contact information previously provided.

Market the credit cards: Can client banks continue to market the credit cards to new customers?

Yes, you may continue to market cards to your customers.

Re-issuing cards: Will client banks need to re-issue anything?

There is no need to re-issue cards at this time. The FDIC plans to sell the portfolio and the next issuer will then issue new cards.

Visa/MasterCard sponsor: Silverton Bank, N.A. was my principal sponsor for MasterCard or Visa. Will the cards continue to work?

Yes. The FDIC has made arrangements with MasterCard and Visa to ensure that the cards will continue to function.

Gift cards/travel cards value: Will the cards that I have issued to customers (gift cards, travel cards) still have value?

Prepaid cards will continue to have value.

Outstanding card stock: What should be done with the outstanding card stock that I have on hand that has not been sold?

Continue to secure the card stock using previously established guidelines. Once a final determination is made on the prepaid program additional information will be provided.

Continue to sell cards: Can the client banks continue to sell cards?

Yes, you may continue to sell cards and forward the funds as previously established.

Ordering more cards: Can more cards be ordered and has the process changed?

Yes. The credit card program will continue to operate business as usual.

Card issuer going forward: Who will the issuer of cards be going forward?

The process is just beginning, so we have no information at this time.

Replacing existing cards: Will any existing cards in customer hands require replacement?

No. Expired cards will be replaced through the normal process.





Last Updated 08/17/2012 Customer Service