In May 2007, FRB Chicago conducted a full scope examination that resulted in Elmwood again receiving a CAMELS composite 2 rating.5 Examiners downgraded earnings to 3 and cited loan loss provision and personnel expenses that “remain above peer group averages.” Additionally, the July 2007 examination report highlighted credit administration deficiencies, such as inadequate monitoring of out-of-market CRE participation loans, incomplete financial data on borrowers and projects, and weak loan underwriting standards. Examiners maintained the bank’s asset quality component 2 rating despite a significant increase in classified assets and a corresponding rise in past due and non-accrual loans. Three months after the examination report was issued, FRB Chicago increased off-site monitoring of Elmwood due to a deterioration in the bank’s loan portfolio, a rapid increase in past due and non-accrual loans, and earnings levels that were insufficient to augment capital.