Audit Report 

OIG-11-067

SAFETY AND SOUNDNESS: Material Loss Review 

of Flagship National Bank 

May 3, 2011 

Office of 

Inspector General 

Department of the Treasury 
 
Contents 

Material Loss Review of Flagship National Bank Page i 

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Audit Report

 Causes of Flagship’s Failure ........................................................................ 2 

 High Concentration of CRE-Related Loans ................................................ 3 

 Inadequate Risk Management, Underwriting, and Credit Administration ....... 4 

 

 OCC’s Supervision of Flagship .................................................................... 5 

 OCC Did Not Take Timely Action to Address Flagship’s CRE Concentration... 6 

OCC Did Not Promptly Report Flagship’s Poor Risk Management, 

 Underwriting, and Credit Administration ............................................. 6 

 OCC Appropriately Used PCA ................................................................. 7 

 

Recommendations ..................................................................................... 8 

Appendices

 Appendix 1: Objectives, Scope, and Methodology ....................................10 

 Appendix 2: Background ........................................................................12 

 Appendix 3: Management Response ......................................................14 

 Appendix 4: Major Contributors to This Report ........................................16 

 Appendix 5: Report Distribution .............................................................17 

 

Abbreviations 

 

CRE commercial real estate 

 FDIC Federal Deposit Insurance Corporation 

 Flagship Flagship National Bank 

MLR material loss review 

 OIG Department of the Treasury Office of Inspector General 

 OCC Office of the Comptroller of the Currency 

 PCA prompt corrective action 

 ROE report of examination 
OIG Audit

Report

The Department of the Treasury 

Office of Inspector General 

Material Loss Review of Flagship National Bank Page 1 

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 May 3, 2011 

 John G. Walsh 

Acting Comptroller of the Currency 

This report presents the results of our review of the failure of 

Flagship National Bank (Flagship), of Bradenton, Florida, and of the 

Office of the Comptroller of the Currency’s (OCC) supervision of 

the institution. OCC closed Flagship and appointed the Federal 

Deposit Insurance Corporation (FDIC) as receiver on October 23, 

2009. This review was mandated by section 38(k) of the Federal 

Deposit Insurance Act because of the magnitude of Flagship’s 

estimated loss to the Deposit Insurance Fund.1

 As of March 31, 

2011, FDIC estimated the loss to be $66.8 million. 

Our objectives were to determine the causes of Flagship’s failure; 

assess OCC’s supervision of the bank, including implementation of 

the prompt corrective action (PCA) provisions of section 38; and 

make recommendations for preventing such a loss in the future. To 

accomplish these objectives, we reviewed the supervisory files and 

interviewed OCC and FDIC officials. We conducted our fieldwork 

from May 2010 through July 2010. Appendix 1 contains a more 

detailed description of our review objectives, scope, and 

methodology. Appendix 2 contains background information on 

Flagship’s history and OCC’s assessment fees and examination 

hours. Certain terms that are underlined when first used in this 

report, are defined in, Safety and Soundness: Material Loss Review 

Glossary, OIG-11-065 (April 11, 2011). That document is available 

on the Treasury Office of Inspector General’s (OIG) website at 

http://www.treasury.gov/about/organizationalstructure/ig/Pages/by-date-2011.aspx. 

 

1

 At the time of Flagship’s failure, section 38(k) defined a loss as material if it exceeded the greater of 

$25 million or 2 percent of the institution’s total assets. Effective July 21, 2010, section 38(k) defines 

a loss as material if it exceeds $200 million for calendar years 2010 and 2011, $150 million for 

calendar years 2012 and 2013, and $50 million for calendar years 2014 and thereafter (with a 

provision that the threshold can be raised temporarily to $75 million if certain conditions are met). 
Material Loss Review of Flagship National Bank Page 2 

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In brief, Flagship failed primarily because it had a high 

concentration in commercial real estate (CRE)-related loans2

 and 

inadequate credit risk management, underwriting, and credit 

administration. Regarding supervision, OCC examiners did not take 

timely action to address Flagship’s CRE concentration or bring to 

management’s attention the bank’s inadequate risk management, 

underwriting, and credit administration. However, we determined 

that OCC appropriately used its authority under PCA. As Flagship’s 

capital levels deteriorated, OCC acted timely to impose PCA 

restrictions on the bank. 

We are not making any new recommendations in this report, but 

are reaffirming two recommendations made in our previous material 

loss reviews (MLR) of OCC-regulated banks,3

 where we identified 

similar causes of failure and reported similar findings regarding 

OCC’s supervision of the banks. 

In a written response, OCC agreed with our reaffirmed 

recommendations and has taken action or is continuing various 

actions. OCC noted that in interagency forums, it proposed a group 

to study the issue of CRE concentrations. The proposal was not 

acted upon so OCC convened an internal group to study it and 

develop proposed solutions. CRE concentrations have been a 

common element in a number of bank failures and we support 

OCC’s efforts to address this issue. OCC’s full response is provided 

in Appendix 3. 

Causes of Flagship’s Failure

The primary cause of Flagship’s failure was its high concentrations 

in CRE-related loans. The CRE concentration exceeded 300 percent 

of its total risk-based capital for the entire period of our review—

June 2005 through October 2009. Flagship’s board and 

management failed to implement risk-management practices 

commensurate with the risks associated with the large CRE-related 

 

2

 Construction and land development loans, nonfarm/nonresidential real estate loans, and multifamily 

residential real estate loans collectively constitute CRE-related loans. 3 Safety and Soundness: Material Loss Review of Union Bank, National Association, OIG-CA-10-009 

(May 11, 2010), and Safety and Soundness: Material Loss Review of TeamBank, National Association,

OIG-10-001 (Oct. 7, 2009). 
Material Loss Review of Flagship National Bank Page 3 

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loan portfolio. The bank’s liberal loan underwriting and inadequate 

credit administration led to rapid asset quality deterioration and 

substantial loan losses when the local real estate market declined. 

High Concentration of CRE-Related Loans 

OCC broadly defines concentrations as groups or classes of credit 

exposures that share common risk characteristics or sensitivities to 

economic, financial, or business developments. According to OCC, 

a concentration exists when the common credit exposures exceed 

25 percent of the bank’s capital structure. Figure 1 shows 

Flagship’s CRE-related loan growth from 2005 to 2009. 

Figure 1: Flagship’s CRE-Related Loan Growth and Concentration as a 

Percentage of Risk-Based Capital, March 2005–September 2009 (millions) 

Source: OIG analysis of Flagship call reports. 

303%

372%

332% 302%

360%

388%

414%

472%

610%

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

Mar‐05 Sep‐05 Mar‐06 Sep‐06 Mar‐07 Sep‐07 Mar‐08 Sep‐08 Mar‐09 Sep‐09

Note: A concentration percent for the third quarter of 2009 is not shown because Flagship was in a 

negative capital position. 

Flagship’s CRE-related loan portfolio grew steadily from 2005, 

reaching more than $80 million in March 2008. Although the 

portfolio decreased after March 2008, Flagship’s concentration of 

CRE-related loans continued to increase because the bank’s capital 

levels declined more rapidly.

CRE-related loans pose significant risk to a bank when they are 

speculative in nature, and the risk is increased when a bank 
Material Loss Review of Flagship National Bank Page 4 

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maintains a high concentration of such loans. From our analysis of 

loan samples taken by OCC examiners, we found that Flagship’s 

CRE-related loans were mostly speculative. In addition, we found 

loans that were approved without developers’ securing enough 

tenants or buyers for the properties in question and loans that were 

processed without sufficient documentation or thorough evaluation 

of borrowers’ loan repayment abilities. 

The risk associated with speculative lending became apparent 

when Florida’s housing market started declining during the 

economic crisis that began in 2007. The quality of Flagship’s CRErelated loans deteriorated rapidly during this time. Flagship’s

nonperforming CRE-related loans increased from $130,000 as of 

March 31, 2007, to $15.4 million as of March 31, 2009. During 

that period, Flagship recognized extensive loan losses and had to 

make large provisions to its allowance for loan and lease losses, 

which eroded capital and caused the bank to become unprofitable. 

Flagship reported a $7.1 million loss for 2008 and a $32.1 million 

loss for the first three quarters of 2009. 

Inadequate Risk Management, Underwriting, and Credit 

Administration

Flagship’s risk management practices were inadequate, and its 

underwriting and credit administration were inappropriate. In OCC’s 

2008 report of examination (ROE), examiners reported that the 

bank’s credit administration was weak, its underwriting had been 

superficial, and its credit risk management was deficient for the 

size and complexity of its portfolio. Also included in the ROE was 

that Flagship management did not implement risk management 

practices commensurate with a large CRE-related portfolio. 

The loan samples taken by OCC examiners revealed that Flagship 

management did not gather sufficient information on its borrowers 

and was not fully aware of borrowers’ outside debts and payment 

responsibilities. The examiners also found that Flagship 

management approved loans for borrowers with severe financial 

weaknesses that were identified prior to loan approval, including 

• unverified stated outside liquidity (assets held outside of 

Flagship); 
Material Loss Review of Flagship National Bank Page 5 

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• incomes heavily concentrated in speculative real estate; 

• poor credit histories at Flagship, with numerous overdrafts; and 

• credit reports showing low credit scores, numerous late 

payments, and foreclosures. 

OCC’s Supervision of Flagship 

OCC performed timely examinations of Flagship in accordance with 

examination guidelines but did not report or take actions to address 

the bank’s CRE concentrations or its inadequate credit risk 

management, liberal underwriting, and poor credit administration 

until the 2008 examination. These conditions had existed before—

from 2005 through 2007—but OCC did not address them during 

the earlier examinations. 

Summary of OCC’s Flagship Supervisory Actions 

Table 1 summarizes OCC’s examinations of Flagship and related 

enforcement actions from June 2005 to August 2009. 

Table 1: OCC Examinations of Flagship (June 2005–August 2009)

Date started/ 

Type of 

examination 

Assets 

(millions) 

Examination Results 

CAMELS

rating 

Number 

of 

matters 

requiring 

attention 

(MRA) 

Number of 

recommendations 

Formal enforcement 

action 

6/27/2005 

(full-scope 

examination) 

$126 2/222222 0 0 None 

2/5/2007 

(full-scope 

examination) 

$203 2/222222 0 2 None 

7/28/2008 

(full-scope 

examination) 

$226 4/444432 5 5 11/20/2008

Formal agreement 

3/16/2009 

(joint visit 

with FDIC) 

$209 4/454542 4 0 Formal agreement (in 

place) 

8/17/2009 

(review) 

$194 5/555555 0 0 Formal agreement (in 

place) 

Source: OCC ROEs and PCA directive. 
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OCC Did Not Take Timely Action to Address Flagship’s CRE 

Concentration 

According to interagency guidance on CRE concentration risk, an 

institution whose CRE loans represent 300 percent or more of its 

total capital may be identified for further supervisory analysis to 

assess the nature and risk posed by the concentration. The 

guidance also provides a framework for supervisory monitoring of 

the concentrations.4

As shown in figure 1, Flagship’s CRE-related loans grew steadily 

from 2005, reaching 388 percent of total risk-based capital in 

September 2007. OCC’s 2007 examination did not report on 

Flagship’s CRE-related credit concentration and did not mention or 

follow the new interagency guidance, which was released in 

December 2006. In this regard, OCC examiners did not assess the 

nature and risk posed by the concentration and did not assess the 

bank’s risk management practices until the 2008 examination. 

OCC Did Not Promptly Report Flagship’s Poor Risk Management, 

Underwriting, and Credit Administration 

In the 2008 ROE, OCC examiners identified previously unreported 

problems with Flagship’s loans. They discovered problems with the 

bank’s underwriting of new and renewed loans, several instances 

of indefinite or liberal repayment programs, inadequate financial 

analyses, inappropriate interest reserves, and underperforming 

loans approved for speculative purposes. These problems were not 

reported in the 2005 ROE or the 2007 ROE. 

Upon reviewing the workpapers of the loan sample reviews 

conducted by OCC during the 2005 and 2007 examinations, we 

found that the examiners had identified many of the same 

deficiencies reported on in the 2008 ROE. For example, the 

examiners were aware that Flagship management did not gather 

sufficient information on its borrowers and was not fully aware of 

borrowers’ outside debts and payment responsibilities. The 

examiners were also aware that Flagship management approved 

loans for borrowers with severe financial weaknesses that were 

4

 OCC Bulletin 2006-46, Interagency Guidance on CRE Concentration Risk Management (Dec. 6, 2006).
Material Loss Review of Flagship National Bank Page 7 

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identified prior to loan approval. But these deficiencies were not 

reported in OCC’s 2005 or 2007 ROE. 

An examiner who worked on the 2005 examination told us that 

Flagship had no underwriting issues as of 2005. An examiner who 

worked on the 2007 examination told us that Flagship had several 

underwriting exceptions but that he did not see that as a problem. 

On the other hand, an examiner who worked on the 2008 

examination told us that Flagship’s loan problems were systemic. 

OCC Appropriately Used PCA

Although we determined that OCC should have acted more 

forcefully and sooner to address the unsafe and unsound practices 

with Flagship, we concluded that OCC appropriately used its 

authority under PCA. As Flagship’s capital levels deteriorated, OCC 

acted timely to impose PCA restrictions on the bank. 

The purpose of PCA is to resolve problems of insured depository 

institutions with the least possible long-term loss to the Deposit 

Insurance Fund. PCA requires federal banking agencies to take 

certain actions when an institution’s capital drops to certain levels. 

PCA also gives regulators flexibility to discipline institutions based 

on criteria other than capital levels to help reduce deposit insurance 

losses caused by unsafe and unsound practices. 

OCC took the following key actions related to Flagship: 

• On November 20, 2008, OCC entered into a formal agreement 

with Flagship that required the bank to achieve by March 31, 

2009, and thereafter maintain, a Tier 1 leverage capital ratio of 

at least 9 percent and a total risk-based capital ratio of at least 

13 percent. The formal agreement also required the bank to 

submit a 3-year capital plan and take steps to address excessive 

CRE-related concentrations, problem loan management, and 

inadequate credit administration. 

• Flagship submitted a capital plan on March 31, 2009, and a 

revised capital plan on June 23, 2009, but OCC rejected both 

on the grounds that they failed to identify the sources, timing, 

and terms of potential capital needed to comply with the 

minimum capital requirements. 
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• By the second quarter of 2009, Flagship became significantly 

undercapitalized. OCC required the bank to submit a capital 

restoration plan no later than September 13, 2009. OCC also 

restricted the bank from accepting, renewing, or rolling over 

brokered deposits and restricted the yield that the bank could 

offer on deposits. 

• On September 17, 2009, OCC notified the bank that it was 

critically undercapitalized and that it disapproved the bank’s 

capital restoration plan. On October 23, 2009, OCC closed 

Flagship and appointed FDIC as receiver.

Recommendations 

We are not making any new recommendations in this report, but 

are reaffirming two recommendations made in our previous MLRs 

of OCC-regulated banks. 

In our May 2010 MLR report on Union Bank,5 we reported that the 

bank failed primarily because of high CRE concentrations and 

stated that a strong supervisory response by OCC was warranted 

to address the high CRE concentrations. We recommended that 

OCC work with its regulatory partners to determine whether to 

propose legislation and/or change regulatory guidance to establish 

limits or other controls for concentrations that pose an 

unacceptable safety and soundness risk and determine an 

appropriate range of examiner response to high-risk concentrations. 

The failure of Flagship was another case in which a bank failed 

primarily because it had a high concentration in CRE loans that 

warranted a strong supervisory response by OCC. Therefore, we 

reaffirm the recommendation made in the Union Bank MLR. 

In our October 2009 MLR report on TeamBank,6

 we also reported 

that the bank failed due to its high-risk concentration in CRE loans 

 

5 Safety and Soundness: Material Loss Review of Union Bank, National Association, OIG-CA-10-009 

(May 11, 2010). The review of Union Bank was performed by Mayer Hoffman McCann P.C., an 

independent certified public accounting firm, under the supervision of OIG. 

6 Safety and Soundness: Material Loss Review of TeamBank, National Association, OIG-10-001 (Oct. 7, 

2009). 
Material Loss Review of Flagship National Bank Page 9 

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coupled with deficient underwriting and credit administration. We 

recommended that OCC emphasize to examiners that MRAs are to 

be issued in ROEs in accordance with the criteria regarding 

deviations from sound management and noncompliance with laws 

or policies listed in the Comptroller’s Handbook. Flagship’s high 

concentration in CRE-related loans was a deviation from sound 

management and warranted a proper supervisory action. Therefore, 

we reaffirm the recommendation made in the TeamBank MLR. 

Management Response 

OCC responded that in interagency forums it proposed a group to 

study the issue of CRE concentrations. The proposal was not acted 

upon so it convened an internal group to study it and develop 

proposed solutions. OCC said its policy for utilizing MRAs is clearly 

stated within the Comptroller’s Handbook. In addition, it distributed 

a MRA Reference Guide in July 2010, to further emphasize 

expectations for proactive supervision, clear and assertive 

communication of concerns to the Board of Directors, and prompt 

follow-up on commitments for corrective action. Training was also 

conducted on the Guide in all field offices in 2010. 

OIG Comment 

OCC’s actions meet the intent of our prior MLR recommendations. 

 *****

We appreciate the courtesies and cooperation provided to our staff 

during the audit. If you wish to discuss the report, you may 

contact me at (202) 927-6512 or Myung G. Han, Audit Manager, 

at (202) 927-4878. Major contributors to this report are listed in 

appendix 4. 

Michael J. Maloney /s/ 

Audit Director 
Appendix 1 

Objectives, Scope, and Methodology 

Material Loss Review of Flagship National Bank Page 10 

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We conducted this material loss review of Flagship National Bank 

(Flagship) of Bradenton, Florida, in response to our mandate under 

section 38(k) of the Federal Deposit Insurance Act.7

 This section 

provides that if the Deposit Insurance Fund incurs a material loss 

with respect to an insured depository institution, the inspector 

general for the appropriate federal banking agency is to prepare a 

report to the agency that 

• ascertains why the institution’s problems resulted in a material 

loss to the insurance fund; 

• reviews the agency’s supervision of the institution, including its 

implementation of the prompt corrective action provisions of 

section 38; and 

• makes recommendations for preventing any such loss in the 

future. 

At the time of Flagship’s failure, on October 23, 2009, section 

38(k) defined a loss as material if it exceeded the greater of 

$25 million or 2 percent of the institution’s total assets. We 

initiated a material loss review of Flagship based on the loss 

estimate by the Federal Deposit Insurance Corporation (FDIC), 

which on the date of failure was $58.2 million. As of March 31, 

2011, FDIC estimated that the loss to the Deposit Insurance Fund 

from Flagship’s failure would be $66.8 million. 

Our objectives were to determine the causes of Flagship’s failure 

and assess the Office of the Comptroller of the Currency’s (OCC) 

supervision of the bank. To accomplish our review, we conducted 

fieldwork at OCC headquarters in Washington, D.C., and its field 

office in Jacksonville, Florida. We interviewed headquarters and 

field office personnel. We performed work at FDIC’s Division of 

Resolutions and Receiverships in Jacksonville, Florida, and 

interviewed personnel involved in Flagship’s closing and 

receivership. We also interviewed personnel from FDIC’s Division of 

Supervision and Consumer Protection via teleconference. We 

conducted our fieldwork from May 2010 through July 2010. 

To assess the adequacy of OCC’s supervision of Flagship, we 

performed the following work. 

7

 12 U.S.C. § 1831o(k). 
Appendix 1 

Objectives, Scope, and Methodology 

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• We reviewed OCC’s supervisory files and records for Flagship 

from 2005 through 2009. We analyzed examination reports, 

supporting workpapers, and related supervisory correspondence 

to gain an understanding of the problems identified, the 

approach and methodology OCC used to assess the bank’s 

condition, and the regulatory action OCC used to compel bank 

management to address deficient conditions. 

• We interviewed and discussed various aspects of the 

supervision of Flagship with OCC officials and examiners to 

obtain their perspective on the bank’s condition and the scope 

of the examinations. We also interviewed FDIC officials 

responsible for monitoring Flagship for federal deposit insurance 

purposes. 

• We interviewed personnel from FDIC’s Division of Resolutions 

and Receiverships involved in the receivership process, which 

was conducted before and after Flagship’s closure and 

appointment of a receiver. 

• We assessed OCC’s actions based on its internal guidance and 

requirements of the Federal Deposit Insurance Act (12 U.S.C. § 

1811 et seq.). 

We conducted this performance audit in accordance with generally 

accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix 2 

Background 

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History of Flagship National Bank 

Flagship National Bank (Flagship) was a federally chartered national 

bank. It was established as a community bank in 1999 and had no 

holding company or affiliates. Flagship’s main office was in 

Bradenton, Florida, and the bank had three branches in Sarasota, 

Florida. 

OCC Assessments Paid by Flagship 

OCC funds its operations in part through semiannual assessments 

on national banks. OCC publishes annual fee schedules, which 

include general assessments to be paid by each institution based 

on the institution’s total assets. If the institution is a problem bank 

(i.e., it has a CAMELS composite rating of 3, 4, or 5), OCC also 

applies a surcharge to the institution’s assessment to cover 

additional supervisory costs. These surcharges are calculated by 

multiplying the sum of the general assessment by 50 percent for 3-

rated institutions or by 100 percent for 4- and 5-rated institutions. 

Table 2 shows the assessments that Flagship paid to OCC from 

2005 through 2009 and their share of the total assessments paid 

by OCC-regulated banks. 

Table 2: Assessments Paid by Flagship to OCC, 2005–2009 

Billing Period Exam Rating 

Source: OCC $MART database. 

Amount Paid % of Total Collection

1/1/2005–6/30/2005 2 $26,060 0.009% 

7/1/2005–12/31/2005 2 $27,614 0.009% 

1/1/2006–6/30/2006 2 $30,521 0.010% 

7/1/2006–12/31/2006 2 $31,704 0.010% 

1/1/2007–6/30/2007 2 $36,247 0.011% 

7/1/2007–12/31/2007 2 $38,563 0.011% 

1/1/2008–6/30/2008 2 $36,475 0.010% 

7/1/2008–12/31/2008 4 $36,877 0.010% 

1/1/2009–6/30/2009 4 $72,292 0.019% 

7/1/2009–12/31/2009 5 $68,818 0.018% 
Appendix 2 

Background 

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Number of OCC Staff Hours Spent Examining Flagship 

Table 3 shows the number of OCC staff hours spent examining 

Flagship from 2005 to 2009. 

Table 3: Number of OCC Hours Spent on Examining Flagship, 2005–2009 

Examination Start 

Date 

Number of 

Examination Hours 

6/27/2005 355 

2/5/2007 311 

7/28/2008 750 

3/16/2009 406 

8/17/2009 875 

Source: OCC Examiner View. 

Note: Examination hours are totaled for safety and soundness examinations, information 

technology examinations, and compliance examinations. They do not include time spent 

performing off-site monitoring. 
Appendix 3 

Management Response 

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Appendix 3 

Management Response 

Material Loss Review of Flagship National Bank Page 15 

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Appendix 4 

Major Contributors to This Report 

Material Loss Review of Flagship National Bank Page 16 

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Michael J. Maloney, Director, Fiscal Service Audits 

Myung G. Han, Audit Manager 

Shaneasha Edwards, Analyst-in-Charge 

Michelle C. Ruff, Auditor 

John B. Gauthier, Auditor 

Annie Y. Wong, Auditor 

Benjamin J. Frank, Analyst 

Katherine E. Johnson, Referencer 
Appendix 5 

Report Distribution 

Material Loss Review of Flagship National Bank Page 17 

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Department of the Treasury

 Deputy Secretary 

Office of Strategic Planning and Performance Management 

 Office of Accounting and Internal Control 

 

Office of the Comptroller of the Currency 

 Acting Comptroller of the Currency 

 Liaison Officer 

 

Office of Management and Budget

 OIG Budget Examiner 

Federal Deposit Insurance Corporation

 Chairman 

 Inspector General 

U.S. Senate

Chairman and Ranking Member, 

Committee on Banking, Housing and Urban Affairs 

Chairman and Ranking Member, 

Committee on Finance 

U.S. House of Representatives

Chairman and Ranking Member, 

 Committee on Financial Services 

U.S. Government Accountability Office

 Comptroller General of the United States