With respect to supervision, FRB Richmond complied with the applicable
examination frequency guidelines, conducted regular offsite monitoring, and
implemented applicable prompt corrective action provisions during the time frame
under review—2006 through 2014. FRB Richmond’s supervisory activity during this
period included formal enforcement actions in the form of a written agreement and a
prompt corrective action directive. Our review of FRB Richmond’s supervision of
NBRS Financial revealed that FRB Richmond took strong supervisory action in 2009
and seized an opportunity to take even stronger supervisory action in 2012. Our
review resulted in one finding related to the potential fraud and insider abuse risks
that dominant management officials can present. We observed this theme with NBRS
Financial and reported on it in prior failed bank reviews.