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Enforcement Action: 1st Comm Bk of FL, Orlando/FedRes Atlanta -- 7-Apr-10

Enforcement Action: 1st Comm Bk of FL, Orlando/FedRes Atlanta -- 7-Apr-10

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Published by: FloridaHoss on Apr 08, 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 amongFCB FLORIDA BANCORPORATION, INC.Orlando, FloridaFIRST COMMERCIAL BANK OF FLORIDAOrlando, FloridaFEDERAL RESERVE BANKOF ATLANTAAtlanta, GeorgiaandSTATE OF FLORIDAOFFICE OF FINANCIAL REGULATIONTallahassee, FloridaDocket Nos. 10-038-WA/RB-HC10-038-WA/RB-SMOFR Administrative File No.0723-FL-02/10WHEREAS, in recognition of their common goal to maintain the financial soundness of FCB Florida Bancorporation, Inc., Orlando, Florida (“Bancorp”), a registered bank holdingcompany, and its subsidiary, First Commercial Bank of Florida, Orlando, Florida (the “Bank”), astate chartered bank that is a member of the Federal Reserve System, Bancorp, the Bank, theFederal Reserve Bank of Atlanta (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”); and
2WHEREAS, on March 22, 2010, the boards of directors of Bancorp and the Bank, at dulyconstituted meetings, adopted resolutions authorizing and directing Alan Rowe, President andChief Executive Officer, to enter into this Agreement on behalf of Bancorp and the Bank, andconsenting to compliance with each and every applicable provision of this Agreement by Bancorpand the Bank, and their institution-affiliated parties, as defined in Sections 3(u) and 8(b)(3) of theFederal Deposit Insurance Act, as amended (the “FDI Act”) (12 U.S.C. §§ 1813(u) and1818(b)(3)) and Section 655.005(1), Florida Statutes.NOW, THEREFORE, Bancorp, the Bank, the Reserve Bank, and the OFR agree asfollows:
Credit Risk Management
 1. 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) The responsibility of the board of directors to establish appropriate risk tolerance guidelines and risk limits;(b) periodic review and revision of risk exposure limits to address changes inmarket conditions;(c) timely and accurate identification and quantification of credit risk withinthe loan portfolio;(d) enhanced stress testing of individual loans during the underwritingprocess; and(e) strategies to minimize credit losses and reduce the level of problem assets.
Concentrations of Credit
2. Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank andthe OFR an acceptable written plan to strengthen the Bank’s management of commercial realestate (“CRE”) concentrations, including steps to reduce the risk of concentrations. The planshall, at a minimum, include:(a) Procedures to identify, limit, and manage concentrations of credit that areconsistent with the Interagency Guidance on Concentrations in Commercial Real Estate Lending,Sound Risk Management Practices, dated December 12, 2006 (SR 07-1); and(b) a schedule for reducing and the means by which the Bank will reduce thelevel of CRE concentrations, and timeframes for achieving the reduced levels.
Asset Improvement
3. The Bank shall not, directly or indirectly, extend, renew, or restructure any creditto or for the benefit of any borrower, including any related interest of the borrower, whose loansor other extensions of credit are criticized in the report of examination of the Bank conducted bythe Reserve Bank that commenced on July 13, 2009 (the “Report of Examination”) or in anysubsequent report of examination, without the prior approval of a majority of the full board of directors or a designated committee thereof. The board of directors or its committee shalldocument in writing the reasons for the extension of credit, renewal, or restructuring,specifically certifying that: (i) the Bank’s risk management policies and practices for loanworkout activity are acceptable; (ii) the extension of credit is necessary to improve and protectthe Bank’s interest in the ultimate collection of the credit already granted and maximize itspotential for collection; (iii) the extension of credit reflects prudent underwriting based onreasonable repayment terms and is adequately secured; and all necessary loan documentation has

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