UNITED STATES OF AMERICA

DEPARTMENT OF THE TREASURY

OFFICE OF THE COMPTROLLER OF THE CURRENCY

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| **In the Matter of:**                     | ) | AA-EC-02-03            |
|                                           |   |                        |
| Peoples National Bank                     | ) |                        |
|                                           |   |                        |
| Paris, Texas                              | ) |                        |
|                                           |   |                        |
|                                           | ) |                        |
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**NOTICE OF CHARGES FOR ISSUANCE OF AN ORDER TO CEASE AND DESIST**

TAKE NOTICE that on the \_[**17th**\_\_]{.underline} day of May, 2002,
or such other date as determined by the Administrative Law Judge, a
hearing will commence at 10:00 a.m. in Dallas, Texas, pursuant to 12
U.S.C. § 1818(b), concerning the charges set forth herein, to determine
whether an Order to Cease and Desist should be issued against Peoples
National Bank, Paris, Texas ("Bank"). The hearing afforded the Bank
shall be open to the public unless the agency, in its discretion,
determines that holding an open hearing would be contrary to the public
interest.

After examination into the affairs of the Bank, the Comptroller is of
the opinion that the Bank is engaging or has engaged in violations of
law, rule or regulation; the Bank is engaging or has engaged in unsafe
or unsound practices in conducting the affairs of the Bank; and such
violations and/or unsafe or unsound practices are likely to weaken the
condition of the Bank, and/or prejudice the interests of the Bank's
depositors.

In support of this Notice of Charges ("Notice"), the Comptroller charges
the following:

**Article I**

#### **Jurisdiction**

At all times relevant to the charges set forth below:

1.  The Bank was, and continues to be, a national banking association,
    chartered and examined by the Comptroller, pursuant to the National
    Bank Act of 1864, as amended, 12 U.S.C. §1 *et seq*.

2.  The Bank was, and continues to be, an "insured depository
    institution" within the meaning of 12 U.S.C. §1818(b).

3.  The Comptroller was, and continues to be, the "appropriate Federal
    banking agency" within the meaning of 12 U.S.C. §1813(q)(1) and for
    purposes of 12 U.S.C. §1818(b) to initiate and maintain an
    enforcement proceeding against a national banking association.

##### Article II

#### **Unsafe or Unsound Practices**

4.  Contrary to safe and sound banking practices, from on or about May
    2001, to the present, the Bank has engaged or is engaging in unsafe
    or unsound practices by failing to measure, monitor, and control the
    risks associated with the Bank's operations and lending activities,
    and by failing to meet accepted standards of prudent banking
    operations.

5.  The Bank's unsafe or unsound practices are evidenced by the
    following facts:

    **Absence of the Requisite Policies, Procedures, Systems and
    Controls for Payday Loans**

6.  The Bank initiated a high-risk, subprime Payday loan product without
    first ensuring the presence of the comprehensive array of policies,
    procedures, systems and controls needed to prudently engage in this
    high risk business.

7.  The Bank then grew the Payday lending product rapidly, during which
    time, the Bank still lacked the needed policies, procedures, systems
    and controls to prudently manage the associated risk, thereby
    increasing risk commensurate with the growth of the product.
    Specifically:

    a.  between February 2001, when the product was initiated, and May
        2001, a period of just three months, the Bank exponentially grew
        the product, until it approximated 120% percent of the Bank's
        capital, while failing to have the requisite policies,
        procedures, systems and controls, thereby placing the Bank, its
        depositors, and the federal deposit insurance fund at risk;

    b.  between May 2001, and October 2001, the Bank more than doubled
        the product volume again, until it approximated 240% of the
        Bank's capital, while failing to have the requisite policies,
        procedures, systems and controls, thereby placing the Bank, its
        depositors, and the federal deposit insurance fund at risk;

    c.  from approximately October 2001, until approximately January
        2002, the Bank continued to imprudently permit the Payday loan
        product to approximate 240% or more of the Bank's capital, while
        failing to have all of the necessary policies, procedures,
        systems and controls, thereby placing the Bank, its depositors,
        and the federal deposit insurance fund at risk;

    d.  from approximately January 2002, until the present, the Bank
        continues to imprudently permit the Payday loan product to
        approximate 130% of the Bank\'s capital, while failing to have
        all of the necessary policies, procedures, systems and controls,
        thereby placing the Bank, its depositors, and the federal
        deposit insurance fund at risk; and

    e.  the reduction in concentration to 130% of the Bank\'s capital
        was due in large part to the Bank\'s receipt of proceeds of a
        \$3 million loan made to the Bank\'s parent company by the
        Bank\'s primary third-party vendor for the Payday loan product.
        In the absence of this indirect loan from the Payday loan
        vendor, the Bank\'s Payday loan product would approximate 180%
        of the Bank\'s capital.

8.  As of October 2001, 60% or more of the Bank\'s classified assets are
    delinquent Payday loans. Yet, the Bank has failed and fails to
    internally classify delinquent Payday loans, despite the fact that
    the primary source of repayment for these loans (the borrower) has
    failed to perform, and the loans consequently meet the criteria for
    a substandard classification. Failure to classify these loans is
    unacceptable, since the Bank is ultimately the party to bear the
    risk of loss.

    **Disregard of Bank Internal Limits on Payday Loan Volume**

9.  Although the Bank's Board set a loan volume limit of \$2.5 million,
    or 25% of capital when the Bank initiated the Payday lending
    product, the Bank quickly exceeded this self-imposed limit, and the
    Bank, Board and management failed and fail to prudently oversee the
    operations of the Bank, including ensuring adherence to
    Board-imposed limits. Specifically:

    a.  over a period of approximately eight months, the Bank ignored
        its own Board-imposed limit, and increased the product more than
        seven-fold, at all times without the appropriate policies,
        procedures, systems and controls; and

    b.  the Board failed and fails to establish and approve a new
        prudent limit on Payday loan volume, both as a dollar amount,
        and as a percentage of the Bank's capital, thereby subjecting
        the Bank to excessive and unmitigated risk, which is limited
        solely by the Bank\'s ability to fund the loans.

        **Excessive and Unacceptable Concentration of Credit Risk**

10. The Board has failed and continues to fail to set prudent risk
    limits and to establish a comprehensive monitoring process for
    Payday loan volume based on both the dollar volume of loans and as a
    concentration of capital. Specifically:

    a.  from May 2001 until the present, outstanding Payday loans have
        exceeded the Bank\'s capital, and represent an excessive and
        unacceptably high concentration of credit risk, thereby
        subjecting the Bank, its depositors, and the federal deposit
        insurance fund to unacceptable risk.

        **Inadequate Supervision of the Payday Loan Product**

11. The Bank has failed to supervise, or is unwilling or incapable of
    supervising, its Payday loan product appropriately and effectively,
    as evidenced by:

    a.  the implementation of the Payday loan program without a written
        strategic plan designed to address the Bank's increasing risks
        and resource needs of the Payday loan program;

    b.  the implementation of the Payday loan program without the
        appropriate policies, procedures, systems and controls to
        prudently manage risk;

    c.  the implementation and rapid growth of the Payday loan product
        at an excessive concentration of credit risk;

    d.  the implementation and rapid growth of the Payday loan product
        without adequate capital support;

    e.  the implementation and rapid growth of the Payday loan product
        without prudent and adequate underwriting standards for
        successive loans to one borrower;

    f.  the implementation and rapid growth of the Payday loan product
        without obtaining and/or testing the contingency plans of the
        third-party vendors relied upon by the Bank to offer this
        product; and

    g.  the fragmented supervision of its Payday loan program.

12. Prior to initiating the Payday loan product, and after commencing
    Payday loan operations, the Bank failed to establish clear lines of
    authority with one individual responsible for comprehensive
    monitoring of:

    a.  adherence with Board-established policies;

    b.  legal and regulatory requirements;

    c.  adequate financial safeguards, including prudent risk-control
        limits and prudent disaster contingency plans; and

    d.  adequate financial and operational reports that assess risk,
        provide trend analysis, and facilitate monitoring of program
        goals and targets.

13. Furthermore, the Bank has failed to classify delinquent Payday
    loans, and failed to institute a process to effectively manage the
    Bank's capital position and balance sheet.

    **Failure to Implement Prudent Underwriting Standards for Payday
    Loans**

14. The Bank has failed to implement, or is unwilling or incapable of
    implementing, prudent underwriting standards for Payday loans.
    Specifically, the Bank has permitted, and continues to permit,
    successive Payday loans to be extended to borrowers without the
    concurrent update and verification of employment and income with
    each and every extension of credit, despite the extended length of
    time and number of loans that may be made to one borrower.

    **Three Million Dollar Loan from Third-Party Vendor to Reduce
    Concentration**

15. The Bank obtained an indirect \$3 million loan from its primary
    third-party vendor for the Payday loan product, to bolster capital
    and reduce the concentration of Payday loans, though this loan
    increased risk to the Bank.

16. The proceeds from this loan were obtained by the Bank\'s parent
    company from the Payday loan third-party vendor and injected into
    the Bank.

17. The loan has a rapidly escalating interest rate and provides strong
    incentive for the Bank to maintain its Payday loan volume at an
    excessive level, or even increase this volume, in order for the Bank
    to have earnings sufficient to pay increasingly large dividends to
    the Bank\'s parent company, so that the parent company can repay the
    third-party vendor loan as contractually agreed.

18. The Bank\'s indirect receipt of loan proceeds from its primary
    third-party vendor for the Payday loan product underscores the undue
    level of Bank reliance placed upon the Bank\'s third-party vendor,
    to wit, for marketing, underwriting, originating, disbursing,
    servicing and collecting these loans.

    **Failure to Obtain or Test Vendor Disaster Recovery Plans**

19. In offering the Payday loan product, the Bank exposed and continues
    to expose all of its capital, by relying on two third-party vendors
    in order to market, underwrite, originate, disburse, service and
    collect these loans, while failing to assure itself that these
    third-party vendors will be able to contractually perform as
    promised.

20. The Bank failed to obtain the contingency plans of its Payday loan
    third-party vendors, and thus failed to assure itself of continuity
    of operations in the event of any unforeseen contingency(ies).

21. The Bank failed to assure itself that its primary Payday loan
    third-party vendor possessed a comprehensive contingency plan.

22. The Bank's primary third-party vendor failed to have a comprehensive
    contingency plan.

23. After obtaining the third-party vendors' contingency plans, and/or
    requiring the primary third-party vendor to draft a comprehensive
    contingency plan, the Bank failed and continues to fail to test
    these contingency plans.

    **Inadequate Strategic Plan**

24. The Bank's strategic plan is inadequate because it fails to
    appropriately:

    a.  consider or incorporate the Payday loan product;

    b.  address the increasing risks and resource requirements of the
        Payday loan product, including the needed policies, procedures,
        systems and controls to engage in prudent Payday lending
        operations;

    c.  project the amount of equity capital needed to support the
        Payday loan product, and appropriate sources for such capital;
        and

    d.  address and limit concentration of Payday loans.

        **Significant Flaws in the Allowance for Loan Lease Losses
        Methodology**

25. The Bank\'s methodology for ensuring the adequacy of the Allowance
    for Loan Lease Losses (\"ALLL\") was significantly flawed, and
    resulted in an underfunded ALLL account, as detailed in the Bank\'s
    most recent Report of Examination. Among other things, the Bank
    failed to:

    a.  appropriately revise the ALLL process to ensure compliance with
        relevant OCC guidance and instructions for filing Consolidated
        Reports of Condition and Income ("Call Reports"); and

    b.  allocate appropriate reserves for the Payday loan portfolio
        commensurate with recent Payday loan loss trends.

        **Inadequate and Unacceptable Audit Function**

26. The Bank's audit function is unacceptable, and as set forth further
    below in Article III, this has resulted in a violation of a law,
    rule or regulation.

27. Internal audit was not independent from external audit, since some
    of the staff of the Bank\'s audit firm were responsible for
    conducting both the internal and external audits, essentially
    reviewing and attesting to their own work, thereby compromising
    auditor independence.

28. Auditors\' lines of reporting to the Board are compromised, since
    audit reports are reviewed and responded to by an officer of the
    Bank before the Board is made privy to the audit findings, thereby
    compromising auditor independence.

29. The Bank\'s audit firm determines the audit scope and sample
    criteria without consulting the Board, or receiving prior Board
    approval.

    **Inadequate Management Information Systems**

30. The Bank failed to obtain, or is unwilling or incapable of
    obtaining, all reports necessary to measure, monitor, and control
    the risks associated with the Payday loan program, and/or to confirm
    the accuracy and reliability of such reports.

31. In approximately February 2001, the Bank failed to establish the
    type and frequency of MIS reports needed to supervise the Payday
    loan product in advance of implementing Payday lending.

32. As the product was greatly expanded over the next eight months, the
    Bank continued to fail to establish the type and frequency of MIS
    reports needed to prudently supervise the Payday loan product,
    despite the greatly increased risk to the Bank with the increase in
    loan volume, concentration of credit risk, and lack of capital
    support.

33. Despite the ongoing risk to the Bank, the Bank only proceeded to
    develop additional MIS reports upon the OCC\'s examination, and even
    this additional MIS was insufficient.

34. Specifically, the Bank has failed to develop MIS for trend analysis
    and to provide data for risk control and adequate monitoring of
    Payday loan program goals and targets, including the following:

    a.  an aging of past due accounts;

    b.  a cumulative historical summary of delinquencies and losses;

    c.  an analysis of customer complaints received, resolved, or in the
        process of resolution;

    d.  the number of consecutive advances compared to default
        probability;

    e.  the percentage of delinquent loans that become losses, by period
        originated;

    f.  a listing of borrowers sorted by number of consecutive
        borrowings;

    g.  a listing of borrowers sorted by number of borrowings during the
        past 12 months;

    h.  the recovery percentage based on days of delinquency (to support
        charge-off timing);

    i.  the number of customers stratified by number of consecutive
        advances; and

    j.  applicant credit scores and other ancillary information
        correlated against average credit extended, loss rates, and
        renewal ratios.

35. The failure, unwillingness or incapability of the Bank to meet the
    accepted standards of prudent banking operations, enumerated above,
    collectively and individually results in abnormal risk of loss to
    the Bank, and is likely to weaken the condition of the Bank, and/or
    prejudice the interests of the Bank's depositors.

    **Unsafe or Unsound Capital Levels**

36. Contrary to safe and sound banking practices, the Bank's capital is
    deficient in relation to the Bank's extremely high risk exposures,
    as further set forth in the Bank's most recent Report of
    Examination.

37. The failure of the Bank to maintain appropriate capital at a level
    that is adequate to support the high levels of concentration,
    credit, transaction, compliance, reputation, legal and strategic
    risks results in abnormal risk of loss to the Bank, and is likely to
    weaken the condition of the Bank, and/or prejudice the interests of
    the Bank's depositors.

    **Article III**

#### **Violations of Law, Rule or Regulation Regarding Standards for Safety and Soundness**

38. From on or about February 21, 2001, to the present, the Bank has
    caused, brought about, participated in, counseled or aided or
    abetted violations of law, rule or regulation when the Bank failed
    to comply with the Standards for Safety and Soundness promulgated at
    12 C.F.R. Part 30 Appendix A (II). The facts supporting these
    violations are described below.

39. As detailed in 12 C.F.R. Part 30 Appendix A (II)(A), the Bank has
    failed to have internal controls and information systems that are
    appropriate to the size of the institution and the nature, scope and
    risk of its activities, including effective risk assessment, and
    adequate procedures to safeguard and manage assets, as evidenced by
    the Bank's failure to:

    a.  have an updated strategic plan:

        i.  considering or incorporating the Payday loan product;

        ii. addressing the increasing risks and resource requirements of
            the Payday loan product, including the needed policies,
            procedures, systems and controls to engage in prudent Payday
            lending operations; and

        iii. projecting equity capital needed to support the Payday loan
             product, and appropriate sources for such capital;

    b.  prudently underwrite successive Payday loans to one borrower;

    c.  eliminate fragmented supervision of its Payday loan program;

    d.  maintain its Payday loans at a level at or below its own
        established concentration limit of the lesser of \$2.5 million
        in Payday loans, or 25% of the Bank\'s capital;

    e.  obtain and test the contingency plans of the Payday loan
        third-party vendors in the event the third-party vendors are
        unable to continue to perform Payday loan services for the Bank;
        and

    f.  obtain all reports necessary to measure, monitor, and control
        the risks associated with the Payday loan program.

40. As detailed in 12 C.F.R. Part 30 Appendix A (II)(B), the Bank has
    failed to have an internal audit system that is appropriate to the
    size of the Bank and the nature and scope of its activities, which
    provides for adequate monitoring of the system of internal controls
    through an internal audit function, and independence and
    objectivity, as evidenced by the Bank's failure to:

    a.  ensure internal audit was independent from external audit;

    b.  ensure auditors\' lines of reporting to the Board were and are
        not compromised; and

    c.  ensure the Bank\'s audit firm determined and determines the
        audit scope and sample criteria after consulting the Board,
        and/or receiving prior Board approval.

41. As detailed in 12 C.F.R. Part 30 Appendix A (II)(D), the Bank has
    failed to establish and maintain prudent credit underwriting
    practices that, among other things, are commensurate with the types
    of loans the institution will make and consider the terms and
    conditions under which they will be made; provide for consideration,
    prior to credit commitment, of the borrower's overall financial
    condition and resources, character, and willingness to repay as
    agreed; and take adequate account of concentration of credit risk.
    This is evidenced by the Bank's failure to:

    a.  maintain its Payday loans at a level at or below its own
        internally-established concentration limit of the lesser of
        \$2.5 million or 25% of capital;

    b.  restrain its current concentration of credit, which far exceeds
        100% of capital; and

    c.  ensure adherence to prudent underwriting standards for
        successive Payday loans to one borrower, including:

        i.  underwriting standards requiring the complete
            re-underwriting of successive Payday loans, such as
            obtaining documentation of employment or other source(s) of
            income, and bank statement, for each and every extension of
            credit; and

        ii. underwriting standards for successive Payday loans requiring
            the borrower\'s specific reason why the loan has been
            requested, identifying the source(s) of funds used to repay
            the preceding loan(s), if any, including whether these prior
            loan(s) have been repaid using other sources of credit, such
            as payday loans from different lender(s), and then the
            Bank\'s determination about the borrower\'s present ability
            to repay the Payday loan being sought without using borrowed
            funds.

42. As detailed in 12 C.F.R. Part 30 Appendix A (II)(F), the Bank has
    failed to have asset growth that is prudent and considers the effect
    of growth on the Bank\'s capital, as evidenced by the Bank's:

    a.  significantly increased volume of Payday loans without a
        corresponding increase in the level or quality of Bank resources
        to manage the Payday lending program, such as the appropriate
        policies, procedures, systems and controls;

    b.  significantly increased volume of Payday loans without the
        requisite increase in the amount of capital needed; and

    c.  significantly increased volume of Payday loans and consequent
        increase in the concentration of credit risk.

43. As detailed in 12 C.F.R. Part 30 Appendix A (II)(G), the Bank has
    failed to have an asset quality system that is commensurate with the
    Bank's size and the nature and scope of its operations, as evidenced
    by the Bank's failure to:

    a.  internally classify delinquent Payday loans;

    b.  ensure the adequacy of the ALLL methodology, including:

        i.  appropriately revise the ALLL process to ensure compliance
            with relevant OCC guidance, and instructions for filing Call
            Reports; and

        ii. allocate appropriate reserves for the Payday loan portfolio
            commensurate with recent Payday loan loss trends;

    c.  obtain updated collateral valuations on problematic assets;

    d.  maintain its Payday loans at a level at or below its own
        internally-established concentration limit of the lesser of
        \$2.5 million or 25% of capital;

    e.  obtain all reports necessary to measure, monitor, and control
        the risks associated with the Payday loan program; and

    f.  consider the size and potential risks of material asset
        concentrations.

44. The Bank's repeated failures, enumerated above, demonstrate that the
    Bank has violated the Standards set forth in 12 C.F.R. Part 30
    Appendix A(II).

    **Article IV**

###### Violation of Law and Unsafe or Unsound Banking Practices 

###### Inaccurate and Material Misrepresentations of Financial Condition

45. All national banks are required to file accurate Call Reports
    pursuant to 12 U.S.C. § 161. Call Reports must be filed 30 days
    after the close of each calendar quarter.

46. The Bank caused, brought about, participated in, counseled or aided
    or abetted violations of 12 U.S.C. § 161 when the Bank filed
    inaccurate Call Reports for the quarters ending December 31, 2000,
    and March 31, 2001, as described below.

47. Generally Accepted Accounting Principles ("GAAP") require financial
    institutions to account for certain investments in limited
    partnerships using the equity method of accounting.

48. The Bank's Call Reports for the quarters ending December 31, 2000,
    and March 31, 2001, contained significant and material errors in
    Schedule RC, Report of Condition. As part of these Call Reports, the
    Bank incorrectly reported the value of Equipment Leasing Associates
    1995-V Limited Partnership ("ELA 95-V").

49. The Bank has a 90% ownership of Peoples Asset Management ("PAM"), a
    consolidated subsidiary. PAM's only asset is a 99% limited partner
    ownership interest in ELA 95-V. Because the limited partner
    ownership interest is more than 3 to 5 percent, this investment in
    ELA 95-V must be accounted for using the equity method of
    accounting. On a GAAP basis, ELA 95-V has a lease receivable and a
    lease obligation of a like amount for various computer equipment.
    Thus, the Bank's investment in ELA 95-V effectively represents an
    intangible asset.

50. The economic substance of the transaction is that the Bank
    ostensibly acquired the right to approximately \$7.4 million in tax
    deductions from 1996 to 2002 in exchange for a cash payment of
    approximately \$887,000 plus approximately \$27,000 in legal
    expenses. In addition to the tax deductions, the Bank is entitled to
    receive contingent cash flows from the potential re-lease of the
    computer equipment.

51. In accordance with GAAP, PAM's investment in ELA 95-V should have
    been accounted for using the equity method of accounting resulting
    in the investment being amortized over the life of the underlying
    lease obligation.

52. The December 31, 2000, balance of the net recorded investment,
    reported at \$772,000, should have been \$209,000. This represents
    an overstatement of \$563,000\--more than 9% of the Bank's Tier 1
    capital.

53. The March 31, 2001, balance of the net recorded investment, reported
    at \$771,000, should have been \$169,000. This represents an
    overstatement of \$602,000\--more than 9% of the Bank's Tier 1
    capital.

54. The Bank became aware during the latter half of 2000 that the
    underlying computer equipment supporting the at-issue lease had been
    substituted for less valuable collateral. This substitution was
    viewed by the Bank as inappropriate, and precipitated a lawsuit by
    the Bank. This event should have also triggered a re-valuation of
    PAM's investment in ELA 95-V by no later than the December 31, 2000,
    Call Report.

55. The Bank's failure to use the equity method of accounting and to
    amortize the PAM investment in ELA 95-V over the life of the
    underlying lease obligation in the December 31, 2000, and March 31,
    2001, Call Reports, resulted in material misrepresentations of the
    Bank's true financial condition, overstating the Bank's assets and
    capital by more than nine percent. Such material misrepresentations
    are both violations of 12 U.S.C. § 161 and constitute unsafe or
    unsound banking practices.

56. The Bank's failure to re-value the underlying asset in the December
    31, 2000, and March 31, 2001, Call Reports, resulted in material
    misrepresentations of the Bank's true financial condition, by
    overstating the Bank's assets and capital. Such material
    misrepresentations are both violations of 12 U.S.C. § 161 and
    constitute unsafe or unsound banking practices.

As evidenced by the Bank\'s actions described in Articles II through IV
above, the Bank has violated laws, rules and regulations and has engaged
in unsafe or unsound practices in conducting the affairs of the Bank.

The Bank is directed to file a written answer to this Notice within
twenty (20) days from the date of service of this Notice in accordance
with 12 C.F.R. § 19.19(a) and (b). The original and one copy of any
answer shall be filed with the Office of Financial Institution
Adjudication, 1700 G Street, N.W., Washington, DC 20552. A copy of any
answer shall also be served with the Hearing Clerk, Office of the Chief
Counsel, Office of the Comptroller of the Currency, Washington, DC 20219
and with the OCC attorney whose name appears on the accompanying
certificate of service. **Failure to answer within this time period
shall constitute a waiver of the right to appear and contest the
allegations contained in this Notice, and shall, upon the OCC\'s motion,
cause the administrative law judge or the Comptroller to find the facts
in this Notice to be as alleged, upon which an appropriate order may be
issued.**

##### PRAYER FOR RELIEF

The Comptroller prays for relief in the form of the issuance of a final
Order Requiring Affirmative and Corrective Action, in substantial form
to the attached proposed Order.

Witness, my hand on behalf of the Office of the Comptroller of the
Currency, given at Washington, DC this \_**[15th]{.underline}**\_day of
March, 2002.

\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Leann Britton

Senior Deputy Comptroller

for Midsize/Community Bank Supervision