The FDIC did not fully consider the past performance of bank management before approving the
application to acquire MTB Bank. This happened, in part, because FDIC guidance addressing the
review of management in conjunction with a merger or acquisition is vague and as such, there was
no requirement to assess certain specific attributes of management’s past performance. The bank
had a history of poor management, risky lending, insufficient loan administration, concentrations of
credit risk, and questionable compliance with banking laws. These deficiencies were not addressed
in the analysis of the application. In total, these management deficiencies raise doubts regarding the
FDIC’s decision to approve CBC’s application to acquire MTB Bank