Risk Management Manual of Examination Policies - FDIC

OTHER PERTINENT INFORMATION
If applicable, provide a summary of comments made by bankers and other interested parties. Address problems with stock offering
circular. For applicants delivering services over electronic channels (such as the Internet or wireless devices) assess the information
systems infrastructure, policies and security.
Summary and Findings
Summary of Banker Comments
Loren Greene, President & CEO – Anybank & Trust, Anytown, Anystate
Mr. Greene stated he knew proposed CEO Hamm by reputation primarily and suggested he was a very conservative banker. He
knows about the proposed bank and opined that the discontinuance of the former delivery channels appeared to be a positive
development. With regard to the operating environment, Mr. Greene stated that loan demand has picked up considerably in the county
since late 2000, particularly in the SBA, commercial and residential real estate sectors. Funding has been relationship driven and
continues to exceed expectations. According to Mr. Greene, the failure of Anybank, which retained a branch directly across from his
bank and subject proposal, will assist in reducing the cost of funding for area banks. This is the case given Anybank’s aggressiveness
with regards to deposit pricing.
Rick Savage, Executive Vice President, Lending – Anybank & Trust, Anytown, Anystate
Mr. Savage served as proposed CEO Hamm’s colleague while at Anybank in Anytown. As a Senior Lending Officer, he worked
closely with Mr. Hamm who retained the title of Chief Credit Officer. Mr. Savage stated that Mr. Hamm had a strong credit and
special assets background. In addition, he stated that Mr. Well (proposed Senior Lending Officer) was also a very competent lender
and proficient in operational matters. Mr. Savage suggested that Mr. Hamm would need strong officer support in the operational areas
of the bank.
James Brown, Chairman & CEO – Anybank, Anytown, Anystate
Anybank is a federally chartered thrift and a second year denovo. It operates a pure internet business model.
Mr. Brown stated that market acceptance over the bank's model had been positive since the bank’s inception. However, according to
him, the growth rate has been purely a function of pricing. He added that premium pricing across all deposit categories is what
attracts the higher net worth Anytown clientele. The institution is currently experiencing a transaction/CD account mix of
approximately 34%/66%. His experience has been that technology for this type of business model was costlier than perceived to be in
the planning stages.
Doug Jones, SVP/Retail and Alternative Delivery – Anybank, Anytown, Anystate
Prior to its acquisition by RegionalBank, Anybank was an established National bank which operated 32 in-store retail branches
throughout Anystate. The in-store branches are hosted within Albertsons Supermarkets.
Mr. Jones stated that Anybank started this program over four years ago. It is expected to be a profit center for the bank but requires
loan production to achieve that goal. Not all locations have been successful thus far. He stated that clientele is very sensitive to
deposit pricing and primarily drawn to the time deposit products. He estimates time deposit/MMDA mixes of up to 60%/20%. Given
the configuration of their in-store facilities, their loan production mainly caters to consumer type products such as auto and HELs. Mr.
Jones stated that customer acquisition becomes a delicate balance of pricing, customer traffic, and marketing abilities of the staff. He
concluded that customer traffic was very important for the success of the in store branch. Their institution currently performs studies
to locate retail stores which achieve average weekly store traffic of 28,000 shoppers.
FDIC 6510/10 (02-2002) 37