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application was signed by petitioner and notarized on July 3,
1991. Petitioner named Cable Leon as his employer, stating that
he had been employed there since 1954 and that he was the main
stockholder and president of the board. Information that
petitioner provided on his individual financial statement
included total assets of $14,831,800, a portion of which was
represented by $7,500,000 in "notes and accounts receivable
considered good and payable".
To substantiate to the Texas Department of Banking that
petitioner had adequate assets with which to purchase the bank,
petitioner had his family members, his five children and his
wife, draw up promissory notes. The notes obligated each child
to pay to petitioner $1,250,000 and his wife to pay to petitioner
$1,875,000 over a period of 15 years. Petitioner's accountant,
Dan Boldt (Boldt), prepared a document titled "Ernesto H. Monroy
M., Personal Financial Statement as of February 28, 1991". The
financial statement listed the same business interests as were
listed in the 1990 financial statement, except that the total
market value of the business interests was increased to
$7.5 million. The financial statement represented that
petitioner was holding the stock of certain corporations, valued
at $7.5 million, as collateral for the promissory notes; that
each child owned a 15-percent interest in the stock; and that his
wife owned a 25-percent interest in the stock. After receiving
the application to purchase the bank, the Texas Department of
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