FRB Minneapolis did not conclude that a formal enforcement action was necessary until the
2007 target examination. Upon reaching that conclusion, it took five months to issue the formal
enforcement action. We believe that the time taken to issue the enforcement action was unduly
prolonged, but likely did not have a material impact. The critical juncture to uncover and
forcefully address BankFirst‟s loan growth and pervasive control deficiencies was in 2005 and
2006.