Based on our review of CRA workpapers and follow-up discussions with the EIC and the
Review Examiner, we did not find convincing evidence to support the "Satisfactory" CRA rating
assigned. The rating appears to be based solely on the bank's projected performance and not on
its actual performance during the time period under review. As a result, the rating may not
have been an appropriate one on which to base the approval of the bank's merger application to
acquire MTB Bank.