Lessons Learned
BankFirst‟s failure offers important lessons learned for Federal Reserve examiners and
managers. First, heightened supervisory attention is vital when banks implement a new business
strategy featuring growth in high-risk lending outside of the institution‟s traditional market area.
In addition, BankFirst‟s failure demonstrates the importance of confirming that new business
activities operate within an effective internal control infrastructure. The failure also highlights
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the need for immediate, aggressive, and forceful supervisory action when (1) management
deviates from business plan projections or (2) examiners detect corporate governance
deficiencies that blur the barriers between affiliated entities.