From 2007 to 2012, the FDIC and the Tennessee Department of Financial Institutions (TDFI)
conducted five onsite risk management examinations, three onsite visitations, and offsite
monitoring. Examiners identified key risks in TCB’s operations, brought these to the attention of
the Board and management, and made recommendations for improvement. However, TCB’s
Board and management did not take adequate steps to address the weaknesses. In 2009,
examiners downgraded TCB and proposed a Memorandum of Understanding (MOU), which
TCB’s Board refused to sign. Although TCB adopted a Board Resolution instead, the key
objectives and goals of the proposed MOU were not addressed. The 2011 joint examination
noted that all areas of the bank had become critically deficient, at which point examiners further
downgraded TCB and secured a stipulation by the Board to a Consent Order.