The Bank Engaged in High-Risk Activities Without Proper Risk Management Processes
A review of examination reports and related records shows that the bank had a history of
engaging in high-risk activities without proper risk management policies and procedures in
place. Also, the bank routinely engaged in out-of-territory lending. In 1999, more than 45
percent of CBC’s loan portfolio involved companies operating outside of the State of
Connecticut and sometimes outside of the United States. According to examiners, some of the
lending by the bank appeared to be more representative of lending by venture capital companies
as opposed to an FDIC-insured bank. This type of lending without a proper risk identification
system is a direct result of the bank’s directors and management failing to fulfill their
responsibilities to run the bank in a safe and sound manner.
In guidance to examiners, the DSC Examination Documentation Modules state that Boards of
Directors should establish adequate lending policies, procedures, and operating strategies.
Inadequate lending policies and procedures may expose banks to greater risk. Bank management
should conduct risk assessments to identify key business risks and should adhere to reasonable
risk-taking practices.
CBC’s Chairman directed the bank to engage in risky out-of-area lending without the benefit of
proper guidelines or documented support for the transactions. Aggressive and uncontrolled
risk-taking by the bank led to an increase in the bank's exposure to risk. Our review of
examination reports indicates that the bank continually assumed high levels of risk in its loan
portfolio without adequate processes to identify, measure, monitor, and control these risks. The
December 1996 FDIC examination report noted that much of the bank’s new commercial
lending was in leases or purchases of receivables, and was out of state. Examiners were
concerned that this type of lending requires “special technical expertise, close monitoring, and
hands-on management.” The report also indicated that the bank was already understaffed in its
commercial loan department. Also, the examination report noted that the loan review process
was almost nonexistent, documentation required as part of loan agreements was not being
received or requested, and financial information to monitor credits was not being obtained.
Subsequent examination reports noted similar deficiencies. The 1999 examination report found
that more than 45 percent of the bank’s loan portfolio was made to companies doing business
outside the state of Connecticut, including in Central and South America and Canada. The bank
did not have policies in place for controlling risk in foreign countries. Also, the examination
report identified that the bank was modifying and restructuring loans without current financial
information. The 2001 examination report, under Matters Requiring Board Attention, noted that
“risk management practices are severely deficient relative to the institution's size, complexity,
and risk profile.” The report further noted that “Sound underwriting standards need to be
adopted and enforced." Based on examination reports, loan underwriting improved prior to, and
deteriorated soon after, the acquisition of MTB Bank.
Weaknesses in risk management were exacerbated after the Purchase and Assumption of MTB
Bank. With over $214 million of additional deposits acquired from MTB Bank, CBC funded
tens of millions of dollars in high-risk lending and speculative ventures dealing with accounts
receivable purchase financing, coal mining and oil exploration, and casino gambling. Many of
these loans were to borrowers out of state and/or out of the country.