Finally, the FDIC implemented PCA in accordance with the requirements of section 38 of
the FDI Act; however, PCA was not fully effective due to improper asset valuations that
overstated CBC’s capital for several years. Because CBC masked the true nature of certain
financial transactions, examiners did not determine the actual financial condition of CBC until a
full investigation was performed subsequent to the March 2001 examination. Once the loan
schemes were uncovered, the examiners concluded that bank was critically undercapitalized. As
a result, enforcement actions, including those available under PCA, were not fully effective at
minimizing the loss to the insurance fund.
This report contains five recommendations designed to help improve the bank supervision process
and to promote the safety and soundness of FDIC-regulated institutions.