Risk Management Manual of Examination Policies - FDIC

More documents

Recommendations

Info

Parallel-Owned Banking Organization (PBO) 99999 DISCLAIMER: This information is provided for illustrative purposes of a complex PBO. It does not correspond to the ownership/control information provided in the Bank of Anytown. List the following information for the bank(s) and/or bank holding company(s) in the PBO. U.S. Name: Demo International Bank 1 City, Country: Miami, FL Number of Outstanding Shares: 1,000,000 Foreign Name: Demo International, C.A. City, Country: Caracas, Venezuela Number of Outstanding Shares: 50,000 Foreign Name: Demo Bank Venezuela 2 Foreign Name: Demo Bank Brazil 3 City, Country: Caracas, Venezuela City, Country: Rio de Janeiro, Brazil Foreign Name: Demo Bank Mexico City, Country: Mexico City, Mexico Number of Outstanding Shares: 100,000 1 Of the ten entities that comprise the PBO, only the three foreign banks and the foreign bank holding company that actively engage in transactions with Demo International Bank, Miami, Florida are detailed above. The remaining five entities within the PBO structure include: JMM Holdings, Caracas, Venezuela which whollyowns Demo Bank International, Panama City, Panama; Mendosa Finance Company, Caracas, Venezuela which wholly-owns Demo Bank International, Cartegena, Colombia and Demo Bank International, Bogota, Colombia. 2 Wholly-Owned subsidiary of Demo International, C.A., Caracus, Venezuela. 3 Wholly-Owned subsidiary of Demo Bank Venezuela, Caracas, Venezuela. Detail the stock owned by the beneficial owner(s) whose direct/indirect control forms the nexus of the PBO. Number Percent Type of U.S. Name: Demo International Bank of Shares Owned Control Beneficial Owner: Mendosa Family Trust (Jose Mendosa controls 100%) 750,000 75.00% Direct Beneficial Owner: Rivera Family Trust (Juan Rivera controls 100%) 250,000 25.00% Direct Number Percent Type of Foreign Name: Demo International, C.A. of Shares Owned Control 1 Beneficial Owner: Jose M. Mendosa 5,000 10.00% Direct Beneficial Owner: Carlita S. Mendosa 12,500 25.00% Direct Beneficial Owner: Paco M. Mendosa 7,500 15.00% Direct Beneficial Owner: Juan H. Rivera 12,500 25.00% Direct Beneficial Owner: Mendosa Family Members 12,500 25.00% Direct 1 Mr. Jose M. Mendosa has indirect control of the shares owned by his wife, Ms. Carlita S. Mendosa. Number Percent Type of Foreign Name: Demo Bank Mexico of Shares Owned Control 1 Beneficial Owner: Jose M. Mendosa 50,000 50.00% Direct Beneficial Owner: Carlita S. Mendosa 25,000 25.00% Direct 1 Mr. Jose M. Mendosa has indirect control of the shares owned by his wife, Ms. Carlita S. Mendosa. 20
Parallel-Owned Banking Organization (PBO) (Continued) 99999 Discuss the factor(s) or combination of the attributes (besides or in addition to common stock ownership) that was considered in determining that sufficient control is exercised to conclude that a PBO relationship exists, including whether the individual, family or group of persons acting in concert: 1) Constitutes a quorum or a significant presence on the Board of Directors of both the U.S. depository institution and the foreign bank or the foreign bank holding company. The members of the Mendosa family listed above serve as the chairman, vice chairman or director for the five foreign entities except that none of them are on the Board of Demo Bank Guatemala. Their membership does not constitute a quorum on any of the three foreign or the U.S. banks’ Board, but does constitute a quorum on the Board of the foreign bank holding company, Demo International, C.A. 2) Controls, in any manner, the election of a majority of the directors of the U.S. depository institution and the foreign bank or the foreign bank holding company. The minutes of the shareholder meeting for the election of the directorate for Demo Bank Venezuela were not available for review. However, it is believed that Mr. Jose Mendosa and his family members controlled the election through their ability to vote a majority of the holding company’s stock. Mr. Jose Mendosa’s ability to vote the majority of Demo International Bank’s stock indicates that he controlled the election of its directorate. 3) Constitutes a quorum or a significant portion of the executive management of both the U.S. depository institution and the foreign bank or the foreign bank holding company. The members of the Mendosa family listed above serve as the president, vice president or cashier of Demo International Bank, Demo International, C.A. and at the four foreign banks except Demo Bank Guatemala. Their positions constitute a quorum of the executive management at Demo International, C.A., but not at the three foreign banks or at the U.S. bank. However, they occupy critical positions on those teams. 4) Exercises a controlling influence over the management and/or policies of both organizations. Mr. Jose Mendosa’s position as chairman of Demo International Bank and as president of Demo Bank Venezuela enables him to exert a controlling influence over the management and policies of both organizations. 5) Engages in an unusually high level of reciprocal correspondent banking and/or other transactions or facilities between the U.S. depository institution and the foreign bank. The institutions primarily engage in correspondent bank services, dollar clearings, letters of credit, and trade related transactions. Fee income from transactions with the three foreign banks accounts for slightly over 40 percent of the total fee income generated by Demo International Bank, Miami, Florida in 2003. The U.S. bank also extended a $5 million line of credit secured by a $5 million certificate of deposit to Demo Bank Venezuela, Caracus, Venezuela. 6) Obtains financing to purchase the stock of either the U.S. depository institution or the foreign bank or the foreign bank holding company from, or arranged by, the foreign bank, especially if the shares of the U.S. depository institution are collateral for the stock-purchase loan. None noted. 21
Page 1 and 2:
DSC Risk Management Manual of Exami
Page 3 and 4:
INDEX Section 0.1 Policies, Procedu
Page 5 and 6:
INDEX Section 0.1 Liquidity Managem
Page 7 and 8:
INDEX Section 0.1 Introduction 14.1
Page 9 and 10:
BASIC EXAMINATION CONCEPTS AND GUID
Page 11 and 12:
Page 13 and 14:
Page 15 and 16:
Page 17 and 18:
Page 19 and 20:
Page 21 and 22:
Page 23 and 24:
Page 25 and 26:
Page 27 and 28:
Page 29 and 30:
CAPITAL Section 2.1 INTRODUCTION Pu
Page 31 and 32:
CAPITAL Section 2.1 Interests in As
Page 33 and 34:
CAPITAL Section 2.1 the holder prio
Page 35 and 36:
CAPITAL Section 2.1 • Qualifying
Page 37 and 38:
CAPITAL Section 2.1 application sub
Page 39 and 40:
CAPITAL Section 2.1 may leave the b
Page 41 and 42:
CAPITAL Section 2.1 procedures empl
Page 43 and 44:
CAPITAL Section 2.1 growth and rema
Page 45 and 46:
ASSET QUALITY Section 3.1 INTRODUCT
Page 47 and 48:
LOANS Section 3.2 INTRODUCTION The
Page 49 and 50:
LOANS Section 3.2 Qualifications of
Page 51 and 52:
LOANS Section 3.2 to the ALLL), an
Page 53 and 54:
LOANS Section 3.2 PORTFOLIO COMPOSI
Page 55 and 56:
LOANS Section 3.2 • Require reaso
Page 57 and 58:
LOANS Section 3.2 Internal Controls
Page 59 and 60:
LOANS Section 3.2 continue to suppo
Page 61 and 62:
LOANS Section 3.2 board of director
Page 63 and 64:
LOANS Section 3.2 the institution's
Page 65 and 66:
LOANS Section 3.2 such as for lives
Page 67 and 68:
LOANS Section 3.2 Classification Gu
Page 69 and 70:
LOANS Section 3.2 checks; terms in
Page 71 and 72:
LOANS Section 3.2 • Sublicensee B
Page 73 and 74:
LOANS Section 3.2 similar propertie
Page 75 and 76:
LOANS Section 3.2 policies and proc
Page 77 and 78:
LOANS Section 3.2 Moreover, since t
Page 79 and 80:
LOANS Section 3.2 generally should
Page 81 and 82:
LOANS Section 3.2 exercise control
Page 83 and 84:
LOANS Section 3.2 Problems in this
Page 85 and 86:
LOANS Section 3.2 that reveal other
Page 87 and 88:
LOANS Section 3.2 Other loans of qu
Page 89 and 90:
LOANS Section 3.2 be determined whe
Page 91 and 92:
LOANS Section 3.2 time period elaps
Page 93 and 94:
LOANS Section 3.2 individual apprai
Page 95 and 96:
LOANS Section 3.2 controls over its
Page 97 and 98:
LOANS Section 3.2 consistent with t
Page 99 and 100:
LOANS Section 3.2 such funds, the m
Page 101 and 102:
LOANS Section 3.2 security interest
Page 103 and 104:
LOANS Section 3.2 unambiguous terms
Page 105 and 106:
LOANS Section 3.2 Trustees are sele
Page 107 and 108:
LOANS Section 3.2 be valid but cert
Page 109 and 110:
LOANS Section 3.2 Overview of the S
Page 111 and 112:
LOANS Section 3.2 Although some ins
Page 113 and 114:
LOANS Section 3.2 • Portfolio gro
Page 115 and 116:
LOANS Section 3.2 pricing decisions
Page 117 and 118:
LOANS Section 3.2 trends, condition
Page 119 and 120:
LOANS Section 3.2 provide additiona
Page 121 and 122:
SECURITIES AND DERIVATIVES Section
Page 123 and 124:
Page 125 and 126:
Page 127 and 128:
Page 129 and 130:
Page 131 and 132:
Page 133 and 134:
Page 135 and 136:
Page 137 and 138:
Page 139 and 140:
Page 141 and 142:
Page 143 and 144:
Page 145 and 146:
CASH AND DUE FROM BANKS Section 3.4
Page 147 and 148:
CASH AND DUE FROM BANKS Section 3.4
Page 149 and 150:
PREMISES AND EQUIPMENT Section 3.5
Page 151 and 152:
PREMISES AND EQUIPMENT Section 3.5
Page 153 and 154:
OTHER REAL ESTATE Section 3.6 Under
Page 155 and 156:
OTHER ASSETS AND LIABILITIES Sectio
Page 157 and 158:
Page 159 and 160:
Page 161 and 162:
Page 163 and 164:
Page 165 and 166:
OFF-BALANCE SHEET ACTIVITIES Sectio
Page 167 and 168:
Page 169 and 170:
Page 171 and 172:
MANAGEMENT Section 4.1 INTRODUCTION
Page 173 and 174:
MANAGEMENT Section 4.1 consequently
Page 175 and 176:
MANAGEMENT Section 4.1 overdue, ren
Page 177 and 178:
MANAGEMENT Section 4.1 money launde
Page 179 and 180:
MANAGEMENT Section 4.1 management l
Page 181 and 182:
MANAGEMENT Section 4.1 • An adequ
Page 183 and 184:
MANAGEMENT Section 4.1 • Troubled
Page 185 and 186:
MANAGEMENT Section 4.1 management i
Page 187 and 188:
INTERNAL ROUTINE AND CONTROLS Secti
Page 189 and 190:
Page 191 and 192:
Page 193 and 194:
Page 195 and 196:
Page 197 and 198:
Page 199 and 200:
Page 201 and 202:
Page 203 and 204:
Page 205 and 206:
Page 207 and 208:
Page 209 and 210:
Page 211 and 212:
RELATED ORGANIZATIONS Section 4.3
Page 213 and 214:
RELATED ORGANIZATIONS Section 4.3 c
Page 215 and 216:
RELATED ORGANIZATIONS Section 4.3 U
Page 217 and 218:
RELATED ORGANIZATIONS Section 4.3 i
Page 219 and 220:
RELATED ORGANIZATIONS Section 4.3 A
Page 221 and 222:
RELATED ORGANIZATIONS Section 4.3 c
Page 223 and 224:
RELATED ORGANIZATIONS Section 4.3 S
Page 225 and 226:
RELATED ORGANIZATIONS Section 4.3 w
Page 227 and 228:
RELATED ORGANIZATIONS Section 4.3 r
Page 229 and 230:
RELATED ORGANIZATIONS Section 4.3 A
Page 231 and 232:
FIDELITY AND OTHER INDEMNITY PROTEC
Page 233 and 234:
Page 235 and 236:
Page 237 and 238:
Page 239 and 240:
VIOLATIONS OF LAWS AND REGULATIONS
Page 241 and 242:
VIOLATIONS OF LAWS AND REGULATIONS
Page 243 and 244:
MISCELLANEOUS BANKING ACTIVITIES Se
Page 245 and 246:
EARNINGS Section 5.1 structure will
Page 247 and 248:
EARNINGS Section 5.1 demand is low)
Page 249 and 250:
EARNINGS Section 5.1 2. Certain dir
Page 251 and 252:
EARNINGS Section 5.1 capital and al
Page 253 and 254:
LIQUIDITY AND FUNDS MANAGEMENT Sect
Page 255 and 256:
Page 257 and 258:
Page 259 and 260:
Page 261 and 262:
Page 263 and 264:
Page 265 and 266:
Page 267 and 268:
Page 269 and 270:
SENSITIVITY TO MARKET RISK Section
Page 271 and 272:
Page 273 and 274:
Page 275 and 276:
Page 277 and 278:
Page 279 and 280:
Page 281 and 282:
Page 283 and 284:
Page 285 and 286:
Page 287 and 288:
Page 289 and 290:
BANK SECRECY ACT, ANTI-MONEY LAUNDE
Page 291 and 292:
Page 293 and 294:
Page 295 and 296:
Page 297 and 298:
Page 299 and 300:
Page 301 and 302:
Page 303 and 304:
Page 305 and 306:
Page 307 and 308:
Page 309 and 310:
Page 311 and 312:
Page 313 and 314:
Page 315 and 316:
Page 317 and 318:
Page 319 and 320:
Page 321 and 322:
Page 323 and 324:
Page 325 and 326:
Page 327 and 328:
Page 329 and 330:
Page 331 and 332:
Page 333 and 334:
Page 335 and 336:
Page 337 and 338:
Page 339 and 340:
Page 341 and 342:
Page 343 and 344:
BANK FRAUD AND INSIDER ABUSE Sectio
Page 345 and 346:
Page 347 and 348:
Page 349 and 350:
Page 351 and 352:
Page 353 and 354:
Page 355 and 356:
Page 357 and 358:
Page 359 and 360:
Page 361 and 362:
SUSPICIOUS ACTIVITY AND CRIMINAL VI
Page 363 and 364:
Page 365 and 366:
Page 367 and 368:
Page 369 and 370:
Page 371 and 372:
INTERNATIONAL BANKING Section 11.1
Page 373 and 374:
Page 375 and 376:
Page 377 and 378:
Page 379 and 380:
Page 381 and 382:
Page 383 and 384:
Page 385 and 386:
Page 387 and 388:
Page 389 and 390:
Page 391 and 392:
Page 393 and 394:
Page 395 and 396:
Page 397 and 398:
Page 399 and 400:
Page 401 and 402:
Page 403 and 404:
Page 405 and 406:
Page 407 and 408:
Page 409 and 410:
Page 411 and 412:
Page 413 and 414:
Page 415 and 416:
Page 417 and 418:
Page 419 and 420:
APPLICATIONS Section 12.1 Effective
Page 421 and 422:
APPLICATIONS Section 12.1 for compa
Page 423 and 424:
APPLICATIONS Section 12.1 be tantam
Page 425 and 426:
APPLICATIONS Section 12.1 accept sh
Page 427 and 428:
APPLICATIONS Section 12.1 consideri
Page 429 and 430:
APPLICATIONS Section 12.1 accepted
Page 431 and 432:
APPLICATIONS Section 12.1 The FDIC
Page 433 and 434:
APPLICATIONS Section 12.1 employee
Page 435 and 436:
APPLICATIONS Section 12.1 including
Page 437 and 438:
APPLICATIONS Section 12.1 Branch cl
Page 439 and 440:
APPLICATIONS Section 12.1 its accep
Page 441 and 442:
APPLICATIONS Section 12.1 examinati
Page 443 and 444:
MEMORANDUMS OF UNDERSTANDING Sectio
Page 445 and 446:
CIVIL MONEY PENALTIES Section 14.1
Page 447 and 448:
Page 449 and 450:
Page 451 and 452:
CMP MATRIX (Continued) Points Sugge
Page 453 and 454:
FORMAL ADMINISTRATIVE ACTIONS Secti
Page 455 and 456:
Page 457 and 458:
Page 459 and 460:
Page 461 and 462:
Page 463 and 464:
Page 465 and 466:
REPORT OF EXAMINATION INSTRUCTIONS
Page 467 and 468:
Page 469 and 470:
Page 471 and 472:
Page 473 and 474:
Page 475 and 476:
Page 477 and 478:
Page 479 and 480:
Page 481 and 482:
Page 483 and 484:
Page 485 and 486:
Page 487 and 488:
Page 489 and 490:
Page 491 and 492:
Page 493 and 494:
Page 495 and 496:
Page 497 and 498:
Page 499 and 500:
Page 501 and 502:
Page 503 and 504:
Page 505 and 506:
Page 507 and 508:
Page 509 and 510:
Page 511 and 512:
Page 513 and 514:
Page 515 and 516:
Page 517 and 518:
Page 519 and 520:
Page 521 and 522:
Page 523 and 524:
Page 525 and 526:
Page 527 and 528:
Page 529 and 530:
Page 531 and 532:
Page 533 and 534:
Page 535 and 536:
Page 537 and 538:
Page 539 and 540:
Page 541 and 542:
Page 543 and 544:
Page 545 and 546:
Page 547 and 548:
Page 549 and 550:
Page 551 and 552:
Page 553 and 554:
Page 555 and 556:
Page 557 and 558:
Page 559 and 560:
Page 561 and 562:
BANK OF ANYTOWN ANYTOWN ANY COUNTY
Page 563 and 564:
Examination Conclusions and Comment
Page 565 and 566:
Page 567 and 568:
Page 569 and 570: Examination Conclusions and Comment
Page 571 and 572: Risk Management Assessment 99999 1.
Page 573 and 574: Violations of Laws and Regulations
Page 575 and 576: Information Technology Assessment (
Page 577 and 578: Fiduciary Activities Assessment (Co
Page 579 and 580: Comparative Statements of Financial
Page 581 and 582: Recapitulation of Securities 99999
Page 583 and 584: Items Subject to Adverse Classifica
Page 585 and 586: Analysis of Loans Subject to Advers
Page 587 and 588: Assets with Credit Data or Collater
Page 589 and 590: Capital Calculations 99999 Tier 1 C
Page 591 and 592: Comparative Statements of Income an
Page 593 and 594: Extensions of Credit to Directors/T
Page 595 and 596: Confidential - Supervisory Section
Page 597 and 598: In-House Information Technology 999
Page 599 and 600: Directors/Trustees and Officers 999
Page 601 and 602: INTERNATIONAL REPORT PAGES AND WORK
Page 603 and 604: Analysis of the Country Exposure Ma
Page 605 and 606: International Loans, Acceptances, a
Page 607 and 608: International Loans, Acceptances, a
Page 609 and 610: Foreign Exchange Activities 99999 N
Page 611 and 612: Position Analysis - Other Currencie
Page 613 and 614: Revaluation and Income/Loss Analysi
Page 615 and 616: Policy and Procedures 99999 1. (a)
Page 617 and 618: Policy and Procedures (Continued) 9
Page 619: Audit and Internal Controls - Inter
Page 623 and 624: REPORT OF INVESTIGATION INSTRUCTION
Page 645 and 646: FDIC Report of Investigation THIS R
Page 647 and 648: Description of the Transaction INVE
Page 649 and 650: FINANCIAL HISTORY AND CONDITION Ass
Page 651 and 652: FINANCIAL HISTORY AND CONDITION (Co
Page 657 and 658: ADEQUACY OF THE CAPITAL STRUCTURE G
Page 659 and 660: ADEQUACY OF THE CAPITAL STRUCTURE (
Page 661 and 662: FUTURE EARNINGS PROSPECTS Assess th
Page 663 and 664: FUTURE EARNINGS PROSPECTS (Continue
Page 665 and 666: GENERAL CHARACTER OF THE MANAGEMENT
Page 667 and 668: GENERAL CHARACTER OF THE MANAGEMENT
Page 669 and 670: IV. GENERAL CHARACTER OF THE MANAGE
Page 671 and 672:
Interview Comments IV. GENERAL CHAR
Page 673 and 674:
IV. GENERAL CHARACTER OF THE MANAGE
Page 675 and 676:
IV. GENERAL CHARACTER OF THE MANAGE
Page 677 and 678:
GENERAL CHARACTER OF THE MANAGEMENT
Page 679 and 680:
RISK TO THE FUNDS As a general matt
Page 681 and 682:
VI. CONVENIENCE AND NEEDS OF THE CO
Page 683 and 684:
OTHER PERTINENT INFORMATION If appl
Page 685 and 686:
Source: Application for Federal Dep
Page 687 and 688:
Service Continuity & Monitoring OTH
show all

Risk Management Manual of Examination Policies - FDIC

Create successful ePaper yourself

Delete template?

Save as template?