SARC-99-05 (September 13, 1999)

On September 8, 1999, the Supervision Appeals Review Committee (“Committee”) of the Federal Deposit Insurance Corporation (“FDIC”) considered the appeal by [Bank] (“Bank”), of the Community Reinvestment Act (“CRA”) rating resulting from the FDIC’s examination of the Bank on October 13, 1998.

After carefully considering the issues raised in your appeal package dated July 2, 1999, the Committee concluded that the CRA rating of “Needs to Improve” should be affirmed.

The Committee concluded that the Bank’s deteriorating loan volume relative to other local institutions as well as its own capacity to lend are not indicative of “Satisfactory” performance under the Community Reinvestment Act. Additionally, the Committee concurs with findings indicating that the significant reductions in both the dollar volume of gross loans and the loan-to-deposit ratio since the last examination cannot be attributed to local economic and/or demographic conditions, but instead are due in large part to factors under management’s control.

This decision is considered a final supervisory determination by the FDIC.

By direction of the Supervision Appeals Review Committee of the Federal Deposit Insurance Corporation.