Complaint 4 26 13 Final - OakBridge Insurance Services

Case 3:13-cv-01328-CCC Document 1 Filed 04/26/13 Page 27 of 31
d. Approving multiple increases, extensions and/or renewals of delinquent and
defaulted Loss Loans in order to fund interest reserves and continue to derive short term income
and profits at the expense of the safety and soundness of federally insured depositor funds, and in
order to give the false appearance that the Bank was performing better than it was; and
e. Failing to heed examiner and auditor warnings of deficiencies in lending and loan
administration, failing to correct those deficiencies, and approving, increasing, extending, and/or
renewing Loss Loans despite those warnings.
f. Failing to inform themselves and each other of the true condition of the assets and
liabilities of Eurobank and the nature of its loan portfolio, or to review and inquire adequately
into Eurobank’s loan transactions;
g. Failing to adhere to the Bank’s Loan Policy prescribing the conditions and
limitations under which loans could be made and the underwriting and record-keeping which
should be undertaken on loans, resulting in hazardous lending;
h. Causing or permitting approval of loans with excessive LTV ratios that exceeded
allowable LTV ratios pursuant to Loan Policy and Interagency Guidelines and/or relying upon
deficient, outdated, incomplete, or non-existent appraisals;
i. Failing to establish or adhere to policies responsive to the numerous and repeated
warnings and criticisms of federal and state banking authorities and regulators;
j. Failing to inform themselves and each other of the nature, viability, legality and
prudence of loans presented for their review, analysis, approval or ratification;
k. Failing to require adequate loan documentation;
l. Failing to exercise independent judgment and to act in the best interest of
Eurobank in approving and ratifying loans;
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