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Risk Management Manual of Examination Policies - FDIC

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INVESTIGATION REPORT CONCLUSIONS AND RECOMMENDATIONS (Continued)<br />

General Character <strong>of</strong> <strong>Management</strong><br />

The general character <strong>of</strong> the proposed management team appears fundamentally sound and consistent with a rating <strong>of</strong> “2” under the<br />

Uniform Financial Institutions Rating System. Proposed management’s aversion for risk is suggested by the concentration <strong>of</strong> less<br />

risky residential real estate during the formative years. While the finding on this factor is favorable, one open supervisory item<br />

remains pending. To date, the Applicant has not submitted any stock benefit plans/agreements on its executive <strong>of</strong>ficers or directors.<br />

In light <strong>of</strong> exceptions taken during the prior proposal on the extent <strong>of</strong> option grants to certain executive <strong>of</strong>ficers, appropriate due<br />

diligence should be accorded prior to chartering.<br />

<strong>Risk</strong> to the Fund<br />

The proposal does not appear to present any undue risk to the insurance fund. This determination is based on the business model’s<br />

strong initial capitalization base, seemingly conservative management team and investment philosophy, as well as, the viable and<br />

multi-faceted branch network strategy. The finding on this factor is favorable.<br />

Convenience and Needs <strong>of</strong> the Community<br />

Given the extent <strong>of</strong> competition and available market share, the Applicant would not adversely impact<br />

competition or the delivery <strong>of</strong> financial services within the market area. The finding on this factor is favorable.<br />

Consistency <strong>of</strong> Corporate Powers<br />

The finding on this factor is favorable.<br />

Recommendation<br />

The Examiner has concluded that all seven statutory factors have been favorably resolved. However, three open supervisory items<br />

remain and should be satisfactorily addressed prior to chartering.<br />

<strong>FDIC</strong> 6510/10 (02-2002) 2<br />

Examiner

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