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Enforcement Action: Coconut Grove Bk/FedRes Atlanta -- 25-MAR-10

Enforcement Action: Coconut Grove Bk/FedRes Atlanta -- 25-MAR-10

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Published by: FloridaHoss on Apr 02, 2010
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04/02/2010

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UNITED STATES OF AMERICABEFORE THEBOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEMWASHINGTON, D.C.STATE OF FLORIDAOFFICE OF FINANCIAL REGULATIONTALLAHASSEE, FLORIDAWritten Agreement by and betweenCOCONUT GROVE BANKMiami, FloridaFEDERAL RESERVE BANK OFATLANTAAtlanta, GeorgiaandSTATE OF FLORIDAOFFICE OF FINANCIAL REGULATIONTallahassee, FloridaDocket No. 10-010-WA/RB-SMOFR AdministrativeFile No. 0720-FI-02/10WHEREAS, in recognition of their common goal to maintain the financial soundness of Coconut Grove Bank (the “Bank”), a state member bank, the Bank, the Federal Reserve Bank oAtlanta (the “Reserve Bank”), and the State of Florida Office of Financial Regulation (the“OFR”) have mutually agreed to enter into this Written Agreement (the “Agreement”); andWHEREAS, on March 17, 2010, the board of directors of the Bank, at a duly constitutedmeeting, adopted a resolution authorizing and directing Robert H. Coords to enter into thisAgreement on behalf of the Bank, and consenting to compliance with each and every provisionof this Agreement by the Bank and its institution-affiliated parties, as defined in section 3(u) othe Federal Deposit Insurance Act, as amended (the “FDI Act”)[Page Break]
 
Page 2(12 U.S.C. § 1813(u)), and Section 655.005(1)(i), Florida Statutes.NOW, THEREFORE, the Bank and the Reserve Bank agree as follows:
Board Oversight
1. Within 60 days of this Agreement, the board of directors of the Bank shall submitto the Reserve Bank and the OFR a written plan to strengthen board oversight of the managementand operations of the Bank. The plan shall, at a minimum, address, consider, and include:(a) The actions that the board of directors will take to improve the Bank’scondition and maintain effective control over, and supervision of, the Bank’s major operationsand activities, including but not limited to, credit risk management, lending, creditadministration, processes to mitigate risks associated with credit concentrations, investmentportfolio management, liquidity, and earnings;(b) the responsibility of the board of directors to monitor management’sadherence to approved Bank policies and procedures and to require management to documentexceptions thereto;(c) the establishment of measures to ensure Bank staff’s adherence toapproved policies and procedures;(d) the maintenance of adequate and complete minutes of all board andcommittee meetings, approval of such minutes, and their retention for supervisory review; and(e) a description of the information and reports that will be regularly reviewedby the board of directors in its oversight of the operations and management of the Bank, includinginformation on the Bank’s adversely classified assets, concentrations of credits, allowance for loanand lease losses, capital, investment management, liquidity, and earnings.[Page Break]
 
Page 3
Credit Risk Management
2.
Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank andthe OFR an acceptable written plan to strengthen credit risk management practices. The planshall, at a minimum, address, consider, and include:(a) Policies and procedures to periodically review and revise risk exposurelimits to address changes in market conditions;(b) policies and procedures to ensure the appropriate risk rating of loans, thetimely recognition of losses, and the adherence to such policies and procedures;(c) procedures to enhance the outsourced credit review function;(d) strategies to minimize credit losses and reduce the level of problem assets;and(e) procedures to identify, limit, and manage commercial real estateconcentrations that are consistent with the Interagency Guidance on Concentrations inCommercial Real Estate Lending, Sound Risk Management Practices, dated December 12, 2006(SR 07-1).
Credit Administration
3.
Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank andthe OFR an acceptable credit administration program that shall, at a minimum, address, considerand include:(a) Procedures that provide for the periodic analyses, during the term of theloan, of the borrower’s repayment sources, global cash flow, and overall debt service ability; and[Page Break]

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