TCB failed primarily because its board of directors (Board) and management did not
effectively manage the risks associated with the bank’s sustained high growth in C&I
lending. Notably, TCB had a significant concentration in an economically sensitive and
specialized segment of the C&I market pertaining to the transportation industry. TCB’s
lending in this area included loans to leasing companies and lease brokers for the
financing of trucks, buses, and other commercial use vehicles. However, TCB’s
underwriting, administration, monitoring, and collection procedures for these and other
C&I loans was not adequate. Contributing to the bank’s credit risk exposure were large
and complex borrowing relationships that were not effectively managed. Further, TCB’s
funding strategy for sustaining loan growth and maintaining liquidity involved heavy
reliance on non-core funding sources, such as Internet and brokered deposits, and capital
injections from its holding company. Finally, TCB did not maintain capital at levels that
were commensurate with its risk profile.
In 2007, TCB began to experience problems with its loans in the transportation industry
due to the bank’s lax lending practices and a softening economy. The credit quality of
TCB’s loan portfolio continued to decline in 2008 and accelerated as the economy
deteriorated. However, TCB continued its high growth strategy, reporting that it
originated over $90 million in new loans during the first quarter of 2009. In total, TCB
originated or renewed about $400 million in loans from 2009 until its failure. The bank
ultimately charged off about $64 million of the $400 million amount as loss. TCB’s
Board and management failed to recognize problems and losses in the bank’s loan
portfolio in a timely manner or to take appropriate action to address problems as they
developed. TCB also engaged in unusual lending practices, such as insurance premium
financing, and made a number of particularly risky loans to individuals in the banking
sector that were secured by the stock of other banks in the years before its failure. These
loans contributed to the bank’s losses.