Federal Deposit
Insurance Corporation

By letter dated June 26, 2001, you requested a change to the assessment risk classification assigned to [Bank] (“Bank”), for the second semiannual assessment period, which began on July 1, 2001.

At its meeting held on November 19, 2001, the Federal Deposit Insurance Corporation’s (“FDIC”) Assessment Appeals Committee (“Committee”) considered your request and determined that it should be granted. Based upon your letter and additional information provided by the Bank at staff’s request, the Committee determined that the Bank should be treated as, in substance, a de novo institution as a result of the acquisition and merger that occurred on May 17, 2001. Specifically, as a result of the acquisition and merger:

1. A new management team was installed;
2. A new strategic plan was implemented;
3. A substantial capital infusion and balance sheet restructuring occurred; and
4. New parent companies committed to maintain the Bank as a well capitalized and well managed institution.

Therefore, the risk classification assigned to the Bank will be changed from “3C” to “1A” for the semiannual assessment period beginning July 1, 2001.

You may contact Ms. Cheryl Timmons, Chief, Assessment Operations Section of the FDIC’s Division of Finance at (202) 416-7546 with questions on the method and timing of any refunds or credits that result from this action.

By direction of the Assessment Appeals Committee.