TCB failed primarily because its Board and management did not effectively manage the risks
associated with loan growth; exposure to large, complex borrower relationships; and
concentrations in economically sensitive and specialized segments of the commercial and
industrial (C&I) market. Lax oversight of the lending and credit administration functions
contributed to asset quality weaknesses. In addition, TCB did not maintain capital at levels that
were commensurate with its increasing risk profile. TCB also relied on capital injections from
the holding company and non-core funding sources to support loan growth. By September 2011,
TCB’s loan portfolio had significantly deteriorated, requiring increases to the allowance for loan
and lease losses that depleted earnings, eroded capital, and strained liquidity. TCB was unable to
raise additional capital to sustain safe and sound operations.