Examiners identified classified assets totaling $46.3 million, a fivefold increase from the 2007 FRB examination, and noted that non-performing loans tripled. Examiners criticized management’s poor business decisions and inadequate due diligence when implementing its growth strategy. As a result, CRE participation loans and one-to-four family residential loans made to speculative investors constituted the majority of classified assets. Additionally, examiners noted that the ALLL was inadequate because of outdated real estate appraisals, untimely information on CRE loan participations, and outdated borrower financial information.