In February 2009, FRB Chicago and the State conducted a target examination that focused on asset quality, credit risk, and liquidity. The May 2009 report downgraded the bank to a composite 5 rating. Banks in this group exhibit extremely unsafe and unsound practices or conditions and pose a significant risk to the DIF because failure is highly probable. Examiners expressed concern with poor credit risk management and loan administration and an inadequate loan rating system. According to examiners, Elmwood’s unacceptable credit risk and asset quality resulted from management’s lax underwriting, insufficient credit analysis, and excessive loan policy exceptions.