Reviewing Loans Modified/Paid Off
Some adversely classified assets, subsequently brought current or paid off, may have warranted
further review to determine the integrity of the transactions. Some examiners we interviewed
told us that it was not unusual for them to classify an asset at the bank and at the next
examination discover that the asset had been paid off or restructured. Examiners told us that
they generally do not review assets that have been repaid and are no longer on the bank’s books.
We found one line of credit totaling $9.4 million and representing over 138 percent of capital
that raises many questions, including the source of payment and whether loans in the line of
credit were in fact repaid. Renewing or restructuring non-performing loans can make a bank’s
condition appear better than it is and forestall regulatory actions.