Further, related to the application review, the FDIC did not adequately validate and review the
financial status of the Chairman of the Board–the source of the capital injection required for the
Purchase and Assumption. While the FDIC’s Statement of Policy on Bank Merger Transactions
and the Case Managers Procedures Manual require the assessment of the financial resources of
the existing and proposed institutions, there is no requirement to validate the financial capability
of a would-be investor. As a result, the FDIC did not verify the financial information submitted
regarding the source of the capital injection and, accordingly, had no assurance that the principal
shareholder was, in fact, injecting the required amount of capital from his personal assets as
agreed to with the regulators