ATTACHMENT C

# CHAIN GROUP SUMMARY ANALYSIS

## PURPOSE

The primary purpose of this analysis is to provide meaningful
information about the chain banking group to the OCC that is not
detailed or summarized in the commercial examination reports of the
group\'s banks. The analysis should emphasize the adequacy and
effectiveness of the chain group\'s plans, policies and internal
monitoring mechanisms. The analysis will give the overall financial
condition of the consolidated group. Examiners are urged to be creative,
analytical and forward looking in the presentation of the consolidated
examination results. The areas that should be addressed are described
below.

## SCOPE OF EXAMINATION

-   Consolidated chain group and individual entities or subsidiaries -
    Summarize the overall scope of the examination of the significant
    member entities, non-significant and nonbank entities. Summarize the
    scope and the degree of coordination between the OCC and the
    regulatory agencies in conducting the coordinated examination.

## OVERALL CONCLUSIONS

-   Financial condition - Summarize the condition of the consolidated
    chain group.

-   Significant problems - Identify areas of concern which are
    significant and affect several or all of the chain system\'s
    organizations. Indicate management\'s commitments for corrective
    action. Problems which concern only one or a few banks or entities
    should be discussed in the reports of examination for the affected
    banks.

## MANAGEMENT AND SUPERVISION

-   Evaluate any controlling ownership influence over the chain group.

-   Evaluate the style of controlling management and supervision of the
    system.

-   Evaluate the competence, effectiveness and continuity of management
    personnel.

-   Evaluate the reporting systems and internal monitoring mechanisms.

[LIQUIDITY AND FUNDS MANAGEMENT]{.underline}

-   Analysis of policies, procedures and objectives.

-   Evaluate liability composition.

-   Evaluate the group\'s capacity to acquire funds including
    contingency plans, e.g., downstream/upstream correspondents,
    commercial paper, etc.

-   Evaluate rate sensitivity of assets and liabilities.

ASSETS (if centralized)

-   Analysis of policies, procedures and objectives.

-   Evaluate loan portfolio management.

-   Evaluate the internal loan review system.

-   Evaluate investment portfolio management.

## EARNINGS AND CAPITAL

-   Analysis of policies, procedures and objectives.

-   Summarize past earnings.

-   Evaluate current earnings.

-   Evaluate ability to maintain capital adequacy.

-   Evaluate management/service fees.

-   Evaluate debt service capabilities.

-   Evaluate budget process.

[AUDIT PROGRAM]{.underline} (if centralized)

-   Evaluate the adequacy, scope and frequency of the audit program.

-   Evaluate the independence of the auditor.

-   Laws and Regulations - Comment on the extent to which the audit
    function checks for compliance with laws and regulations.

-   Comment on the extent of audit of internal management reports.

## FUTURE PLANS AND STRATEGIES

-   Image - Summarize the image and posture the control group wants to
    project to the public and industry and describe any expected
    changes.

-   Plans and objectives - Summarize goals and objectives for capital
    planning, loan and investment decisions, marketing, auditing, etc.
    State the plans for the future as expressed by management and
    controlling owner, operating plans, capital plans and other
    projections. Evaluate ability to meet future projections.

-   Strategy formulation - Describe the techniques used to develop
    strategies and evaluate achievement in attaining goals.

-   Acquisition plans - Describe plans to acquire banks or other
    affiliated entities.

[LITIGATION]{.underline} (Optional)

-   Lawsuits - List any significant lawsuits in which the controlling
    parties or organizations are defendants.

## INTERCOMPANY TRANSACTIONS

-   Significant transactions - Discuss any significant transactions,
    such as, loan participations or sales; insider and related interest
    loans or transactions; BHC or bank stock loans, correspondent or
    interbank transfers; contractual obligations; purchases or sales of
    securities or other assets.

## CHAIN BANKS AND RATINGS

-   List the individual chain banks in the group, total assets and
    CAMEL/ composite ratings from the most recent examination.