Elmwood failed because its Board of Directors and management pursued a risky loan
growth strategy that featured new loan products and out-of-market lending without developing
adequate credit risk management controls. The bank pursued this strategy even though its
modest earnings and capital position did not provide adequate support to withstand possible asset
quality deterioration. The growth strategy, coupled with insufficient credit risk management
controls, resulted in poorly underwritten loans. Bank management’s inability to adequately
address loan portfolio weaknesses led to asset quality deterioration and significant losses.
Mounting losses eliminated earnings, depleted capital, and strained liquidity. The State closed
Elmwood and appointed the FDIC as receiver after the bank failed to meet a regulatory deadline