Orion failed because its Board of Directors and management did not control the risks associated
with rapid growth and an extremely high concentration in commercial real estate (CRE) and, in
particular, acquisition, development, and construction (ADC) loans. Under the direction of the
CEO, who had a dominant role in the bank and held a controlling interest in the parent bank
holding company, Orion aggressively expanded its CRE and ADC loan portfolios in the south
Florida market from 2004 through 2006. A subsequent rapid decline in the Florida real estate
market led to deteriorating asset quality and significant losses, particularly in the ADC portfolio.
Bank management failed to acknowledge the extent of the real estate market downturn and was
slow in recognizing and mitigating credit risk exposure. Mounting loan losses eliminated the
bank’s earnings, depleted capital, and ultimately led the State to close Orion and appoint the
FDIC as receiver on November 13, 2009.