Background 2
Causes of Failure and Material Loss 2
Board and Management Planning and Oversight 3
CRE and ADC Loan Concentrations 5
Credit Risk Management Practices for CRE and ADC Lending 9
Commercial and Industrial Loans and Related Practices 10
Allowance for Loan and Lease Losses 11
Additional Events That Negatively Impacted FSB’s Capital Position 12
The FDIC’s Supervision of FSB 13
Supervisory History 14
Supervisory Oversight of FSB’s Board and Management 16
Supervisory Approach to CRE and ADC Concentrations 18
Implementation of PCA 21
Corporation Comments 23
Appendices
1. Objectives, Scope, and Methodology 24
2. Glossary of Terms 27
3. Acronyms 29
4. Corporation Comments 30
Tables
1. Financial Condition of FSB 2
2. FSB’s Examination History, 2003 to 2009 14
3. FSB’s Capital Ratios Relative to PCA Thresholds for Well
Capitalized Banks
22
4. FSB’s PCA Notifications Provided by the FDIC 22
Figures
1. FSB’s Annual Asset Growth Compared to Peers 4
2. FSB’s Loan Portfolio Composition and Growth 5
3. FSB’s ADC Loan Concentration as a Percent of Total Capital
Compared to Peers
6
4. FSB’s CRE Loan Concentration as a Percent of Total Capital
Compared to Peers