Rebecca Wright - Page 7




                                        - 7 -                                         
               Each year, Bank of America conducted a review of its trust             
          accounts.  Petitioner prepared the reports for Mrs. Millyard's              
          trust accounts.  One item on the report is the total amount                 
          withdrawn or distributed from the trust during a given year.  On            
          the report for the period April 1993 through April 1994,                    
          petitioner falsely reported the amount transferred from Mrs.                
          Millyard's trust.  During the period April 1993 through April               
          1994, Mrs. Millyard withdrew substantial amounts from her trusts,           
          e.g., $23,500 on May 5, 1993, $35,000 on July 1, 1993, $10,000 on           
          November 10, 1993, and $23,500 on February 2, 1994.  Petitioner             
          reported that Mrs. Millyard withdrew only $23,500 from the trust.           
          Bank of America would have been concerned had it seen that                  
          approximately $100,000 had been taken from the trust.  Another              
          item on the annual trust report inquired whether the trust                  
          officer faced any potential conflict of interest or legal                   
          noncompliance.  Petitioner wrote "non-applicable" on the report,            
          but he knew that accepting money from Mrs. Millyard presented a             
          potential conflict of interest.                                             
               Petitioner knowingly engaged in a scheme to obtain money               
          from a federally insured bank by making false statements or                 


          (...continued)                                                              
          8/4/94    1765           Rebecca Wright                1,000                
          9/21/94   1996           Rebecca Wright                1,000                





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