For many of the issues, the bank, which reportedly has $1.2billion in assets, has agreed in a document signed March 8 andreleased by the Fed today that it would submit improvement planswithin the next 60 days. These plans will include, according to thedocument, "an acceptable written plan to strengthen the bank'smanagement of commercial real estate concentrations, includingsteps to reduce or mitigate the risk of concentrations in light ofcurrent market conditions."The bank also agreed to submit a plan"designed to improve the bank's position through repayment,amortization, liquidation, additional collateral, or other means oneach loan, relationship or other asset in excess of $500,000,including other real estate owned that is past due as to principalor interest more than 90 days as of the date of (the) agreement, ison the bank's problem loan list, or was adversely classified in theReport of Examination."


According to the agreement, the Report of Examination referencedwas filed by the Fed and the state on June 22, 2009. The bank"shall not, directly or indirectly, extend, renew or restructureany credit to or for the benefit of any borrower, including anyrelated interest of the borrower, whose loans or other extensionsof credit are criticized in the report," according to theagreement. Both Fed and state officials refused to discuss theagreement or the report. "We would not make that report public," afederal spokeswoman tells Bank officials did notreturn calls for comment.


The bank also agreed to submit plans to maintain sufficientcapital and improve the bank's liquidity position and fundsmanagement practices, and to reduce, and not accept any new,brokered deposits. Also, the bank is not allowed to declare or payany dividends without the state and Fed giving permission.

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