Estate of James Waldo Hendrickson - Page 26




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          "problem bank" designation, Peoples was subjected to a very high             
          level of scrutiny in future examinations by the FDIC;                        
          examinations were conducted more frequently; greater                         
          correspondence between Peoples and the FDIC was required; and                
          Peoples could have been prohibited from any merger, acquisition,             
          divestiture, or expansion activity.  Designation as a "problem               
          bank" also excluded Peoples from bidding on the assets of failed             
          financial institutions.  Continued failure to comply with the CRA            
          could have resulted in a cease-and-desist order by the FDIC, with            
          the ultimate sanction of forced closure.                                     
               Peoples' CRA compliance costs were significant for a bank               
          its size.  In addition to the additional demands on management               
          imposed by the CRA requirements, Peoples was forced to hire two              
          full-time attorneys to oversee its CRA compliance.  In February              
          1993, shortly after hiring Mr. Krochta, Peoples hired Tony                   
          Aylsworth, another local attorney as an assistant vice president             
          and assistant compliance officer.  Mr. Aylsworth's first                     
          assignment at Peoples was "scrubbing" the loan files.                        
          "Scrubbing" as used in this context, refers to the process of                
          reviewing loan files to see if they contain adequate                         
          documentation, and correcting any documentation problems                     
          discovered, such as missing documents or signatures.  Inadequate             
          loan documentation was a contributing factor in Peoples' CRA                 
          compliance difficulties, because Peoples was unable to show why              
          and where it was denying certain loans.  Until decedent's death              




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