Control and Relationships
Any Company, Inc., a one-bank holding company, continues to own 100 percent of the common stock. Bank directors own or control a combined 908,584 shares or 56 percent of holding company stock. President Lincoln is the largest individual stockholder, controlling 500,326 shares or 31 percent of the outstanding stock. Any Time, Inc., is a subsidiary of the bank and holds title to ORE. Any Body, Inc., is an on-premise insurance agency owned by President Lincoln and Director Killingbird. President Lincoln stated that no ownership or management changes are planned.
The examination scope was expanded from the pre-exam planning (PEP) memo in the following areas:
- Construction Lending – Expanded due to administrative problems identified in the original loan sample. Ten additional construction loans serviced by the two construction lenders and originated in 2004 were reviewed.
- BSA Review – Expanded to include a review of all CTRs filed in 2004 due to indications that they were being filed late.
- Call Reports Review – Expanded to include year-end 2003 in response to the volume of errors noted with our original review.
As a result, examination hours, totaling 760, are 150 over budget (25 percent). Other examination procedures were not modified from those identified in the PEP memo.
BSA Review Scope
Examiners reviewed the bank’s compliance with the Bank Secrecy Act and financial recordkeeping regulations. Core analysis procedures of the Examination Documentation module were completed, as well as expanded procedures related to timely CTR filings, to summarize the findings of this review. Examiners compared bank records with information on the FinCEN CTR filing data report for October through December 2003, and year-to-date 2004. FinCEN 314(a) requests are being received and checked by management. BSA examination findings were discussed during the examination with President Lincoln and BSA Officer Donna Ludlow. Findings were also discussed with the bank’s Board of Directors at its September 18, 2004, meeting.
BSA Sharp Number: 67890
| Loan Penetration
| Asset review date:
| Number of relationships reviewed:
| Total $ of credit extensions reviewed / % of Total
|| $28,148M / 52%
| Total $ of non-homogenous credit extensions reviewed / % of Total
|| $27,635M / 60%
| Credit extension cutoff review point:
REMINDERS – The loan penetration comment can include a breakdown of credit extensions by major loan types, location, officer, etc., as appropriate. The information can be effectively presented in chart form.
Invitations for the bank’s directors to participate in examination discussions were extended during the pre-exam and on-site portions of the examination. Outside director involvement was limited to the Board meeting.
Suggestions for Future Examinations
- There is sufficient working space for seven examiners.
- Management accommodated working hours of 7:30am to 5:00pm.
- The FDIC phone line is in place in the basement boardroom.
- The examination crew should contain at least one examiner with construction loan analysis experience.
- ALERT data can only be provided in fixed-width format.