UNITED

STATES

OF OF

AMERICA
FEDERAL RESERVE SYSTEM

BEFORE

THE

BOARD

OF

GOVERNORS

THE D.C.

WASHINGTON,

In the Matter LOIS A. BRIGHAM

of
1 1 1

Docket

No.

98-009-E-12

An Institution-Affiliated Party of the former Towne Bank Perrysburg, Ohio and Towne Bancorp, Inc. Perrysburg, Ohio

Order of Prohibition Issued Upon Consent the Federal Deposit Act, as Amended

Pursuant to Insurance

1

WHEREAS, Federal Deposit

pursuant

to sections Act, as amended

8(e)

and

(i) (3) of the

Insurance and

(the

"FDI Act") of the this

(12 U.S.C. Federal Order

1818(e)

(i) (3)), (the

the Board

of Governors

Reserve

System

"Board

of Governors") against Lois

issues A. Brigham and 3(u)

of Prohibition former

(the "Order") senior

("Brigham"),

vice-president, as defined 1813(u)

director, in sections and

institution-affiliated 8(b)(3) former bank of the FDI Act Towne was Inc., Bank,

party,

and of the

(12 U.S.C.

1818(b)(3)),

Perrysburg,

Ohio

("Towne"), Reserve

a state-chartered System, a former and Towne

that

a member

of the Federal Ohio

Bancorp, bank

Perrysburg, due

("Bancorp"), alleged

registered in the

holding

company,

to Brigham's or unsound

participation regarding

violations lending

of law and unsafe at Towne;

practices

function

and

2 WHEREAS, has consented by affixing issuance her signature Order rights hereunder, by the Board she might Part Brigham of

to the

of this all and

Governors have

and has waived

any and 1818

otherwise or

pursuant

to 12 U.S.C.

12 C.F.R.

263,

otherwise

(a) to the set

issuance

of a notice Order; respect

of intent

to prohibit for the implied of this in any or (e) to or

on any matter purpose set

forth

in this with

(b) to a hearing to any matter judicial review

of taking in this

evidence Order;

forth

(c) to obtain

Order manner

or any provision the basis,

hereof;

(d) to challenge terms,

or contest

issuance, Order fees

validity,

effectiveness hereof; and

enforceability any and Towne, all

of this claims for

or any provision or expenses Bank, related

to this Ohio arising

Order

its successor, or Bancorp

the Exchange

Luckey, whether

("Exchange") common limited

or its successor, terms law. of any

in but not

law or under to, Ohio

the

statute,

including,

state

NOW, adjudication set forth

THEREFORE,

prior

to the issue

taking

of any

testimony implied an of of

or or

of or finding

on any this made

of fact

or law

herein, of any

and without allegation

Order

constituting

adm5ssion Governors settlement

or implied and solely

by the Board for

in connection of this

herewith, without

the purpose

matter

protracted

or extended

proceedings:

3 IT IS HEREBY (i)(3), and ORDERED, pursuant (12 U.S.C. to sections 1818(e), 8(e), (i) (3), and

(j) of the FDI Act

(j)), that:

1.

Brigham, and,

without where

the prior necessary

written pursuant

approval to

of the

Board section another hereby

of Governors 8(e)(7)(B) federal

of the FDI Act

(12 U.S.C.

1818(e)(7)(B)), agency, is

financial

institution

regulatory

and henceforth

prohibited:

(a)
conduct section

From

participating

in any manner or agency

in the specified in

of the affairs 8(e)(7)(A) but not

of any

institution

of the FDI Act limited to, any

(12 U.S.C. insured

1818(e) (7) (A)),

including, institution,

depository company;

or depository

institution

holding

lb)
attempting consent, any

from

soliciting, voting with

procur

ins,

transferr ,ing, any proxy, rights in

to transfer, or authorization described

or attempting respect

to vote

to any voting

institution

in section

8(e)(7) (A) of the FDI Act:

(cl previously approved

from violating by any federal

any voting banking

agreement or

agency;

(d)
acting

from voting

for a director, party,

or serving in

or

as an institution-affiliated

as defined

4 section employee, 3(u) of the FDI Act, institution such as an officer, in section director or

in any

described

8(e)(7) (A) of

the FDI Act.

2. subject both

Any

violation

of this

Order

shall

separately penalties or

Brigham

to appropriate

criminal

or civil

under

section

8 of the FDI Act

(12 U.S.C.

1818).

3. and shall

This

Order,

and

each

and

every

provision until by

hereof, expressly

is

remain

fully

effective

and

enforceable

stayed,

modified,

terminated

or suspended

in writing

the Board

of Governors.

4. addressed to:

All

communications

regarding

this

Order

shall

be

(a)

Mr. R. Chris Moore Senior Vice President Federal Reserve Bank of Cleveland 1455 East Sixth Street 44101 Cleveland, Ohio Ms. Lois A. Brigham 7027 Coder Road Estates 43537 Maumee, Ohio

(b)

.-

5. or otherwise state agency

The

provisions the Board

of this

Order

shall or any other

not

bar,

estop, or

prevent

of Governors taking any

federal

or department

from

action

affecting

5

Brigham,

Towne,

Exchange,

Bancorp

or any

former

or current

institution-affiliated

parties

thereof.

By order /3* day

of the Board

of Governors 1998.

effective

this

of&*_,

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

Secretary

of the Board