Examination reports from 1996 through 2002 cited the following matters for CBC management's attention:
FDIC Report of Examination - December 30, 1996:
Credit Administration--on-going review, monitoring, and management of the commercial loan portfolio needed improvement. The loan review process was almost nonexistent; documentation required as part of loan agreements was not being received or requested; financial information needed to monitor credits was not being obtained.
Management--Principal shareholder and Chairman of the Board dominated and controlled CBC’s management. This raised issues regarding risk tolerance; loans to entities affiliated with the Chairman or one of his related interests; and the appropriate role for the principal shareholder in the daily operations of CBC.
FDIC Report of Examination - October 20, 1997:
Asset Quality--the volume of adversely classified assets remained excessive and the past due ratio escalated to an alarming level.
Asset Administration--documentation, analysis support, and monitoring of assets in the Accounts Receivable Purchase Facility program was inadequate. Two assets were cited for Special Mention. The volume of technical deficiencies in credit files remained high.
Management--although management and the Board had taken appropriate steps to correct prior deficiencies, substantial weaknesses in other areas were noted. The new deficiencies reflected poorly on management's ability to prevent further problems. In addition, the lack of a strategic plan and budget for 1998 raised questions regarding management's ability to plan and provide critical direction to CBC.
FDIC Report of Examination - October 26, 1998:
Asset Quality--volume of adversely classified items remained excessive. Efforts to reduce this level were hampered by new classifications. The return of CBC to a satisfactory condition was dependent on efforts to improve overall asset quality.
Concentrations of Credit--constituted over 400 percent of capital, exposing CBC to a high degree of diversification risk. Management should have implemented a process to adequately identify, measure, and monitor the risks inherent in these types of relationships.
Management--CBC was operating without a President. Despite this vacancy, senior management took steps toward improving the condition of the institution. However, additional efforts were needed to stabilize earnings performance, reduce problem assets, monitor and administer credit concentrations, and improve internal routine and controls. Also, two directors were noted for having poor attendance at Board meetings.
FDIC and State of Connecticut Department of Banking Report of Examination - December 27, 1999:
Asset Quality--while improved, remained a concern. Management implemented procedures to strengthen loan administration; however, additional efforts to correct deficiencies were necessary.
Concentrations of Credit--continued to represent over 400 percent of capital, exposing CBC to a high degree of diversification risk.
Management--took several appropriate steps to address regulatory concerns. Additional efforts to correct deficiencies in the administration of the loan and lease portfolio and Accounts Receivable Purchase Facility program were necessary.
FDIC and State of Connecticut Department of Banking Report of Examination - March 5, 2001:
The report noted that recommendations from prior examinations had not been satisfactorily addressed. The report stated: "loan administration weaknesses that were noted at the past several examinations still remain outstanding." Also, the report noted deficiencies from the prior two examinations pertaining to the loan loss reserve methodology, internal audit function, and review of the interest rate risk model that had not been fully addressed by management. Further, examiners had concerns in the following areas:
Asset Quality--the volume and severity of items adversely classified increased substantially since the previous examination. Adversely classified items were an unacceptable 90 percent of Tier 1 Capital and reserves. There was $35 million in assets listed for Special Mention.
Credit Administration--numerous loans reviewed during the examination contained severe underwriting, credit, and collateral deficiencies. In addition, a substantial number of loan policy exceptions were noted. Numerous imprudent lending practices were identified in loans associated with insiders. There were numerous discrepancies between management’s internal risk ratings and the examiners’ classifications. Also, there were increases in concentrations of credit.
Management--the Board’s oversight of management was deficient in the loan and compliance areas as well as risk management practices.
FDIC draft Examination Summary Report - April 1, 2002:
Asset Quality--management and the Board had not appropriately overseen the loan portfolio and loan administration. Loan relationships were not properly monitored, warning signs were not appropriately researched, and loan officers had not been held accountable for their actions. Since the previous examination, management still could not provide meaningful information on many of the numerous credit relationships and had not rectified many of the noted deficiencies.
Credit Administration and Loan Underwriting--weaknesses remained problematic due to a lack of management oversight, lack of an effective credit policy, and lack of an effective risk assessment.
Management--the Board and management took action on some previous recommendations; however, the majority of deficiencies were not addressed. The volume of deficiencies identified in the loan portfolio was overwhelming. Loans were not appropriately risk rated, over-advances on factoring lines were prevalent, and appropriate ongoing analysis and monitoring of many credits was not performed.