Our review of the FDIC’s analysis of the application found no mention of the fact that the bank
had a history of poor management as evidenced by risky lending, insufficient loan
administration, concentrations of credit risk, questionable compliance with banking laws, and
insufficient responsiveness to examiner recommendations. It appears that the analysis was
focused more on the condition of the bank and the Chairman’s reported wealth and prior
willingness to inject substantial capital into the institution. In our opinion, the history of
management deficiencies at the bank raises doubts about the FDIC’s decision to approve CBC’s
acquisition of MTB Bank.