584

October 28, 2020

The Meeting of the Advisory Committee on Community Banking

of the

Federal Deposit Insurance Corporation

Federal Deposit Insurance Corporation Building

Washington, D.C.

Open to Public Observation via Webcast

October 28, 2020 – 1:00 P.M.

The meeting of the FDIC Advisory Committee on Community 

Banking (Committee) was called to order by Jelena McWilliams, 

Chairman, Federal Deposit Insurance Corporation (FDIC) Board of 

Directors.

Committee members present at the meeting: Shaza Andersen, 

Chief Executive Officer (CEO), Trustar Bank, Great Falls, 

Virginia; Dick Beshear, Chairman, President and CEO, First 

Security Bank and Trust Company, Oklahoma City, Oklahoma; Fred 

DeBiasi, President and Chief Operating Officer (COO), Valley 

Central Bank, Liberty Township, Ohio; Keith Epstein, Executive 

Vice President and CEO, Roxboro Savings Bank, SSB, Roxboro, 

North Carolina; Sarah Getzlaff, CEO, Security First Bank of 

North Dakota, New Salem, North Dakota; Stephen Hayes, Chairman 

and President, Dakota Prairie Bank, Ft. Pierre, South Dakota; 

James J. Edwards, Jr., CEO, United Bank, Zebulon, Georgia; 

Kenneth Kelly, Chairman and CEO, First Independence Bank, 

Detroit, Michigan; Bruce Kimball, President and CEO, First 

Community Bank of the Heartland, Clinton, Kentucky; Thomas 

Leavitt, President and CEO, Northfield Savings Bank, Northfield, 

Vermont; Lori Maley, President and CEO, Bank of Bird-in-Hand, 

Bird-in-Hand, Pennsylvania; Patty Mongold, Chairperson,

President and CEO, Mt. McKinley Bank, Fairbanks, Alaska; Gilbert 

Narvaez, Jr., President and CEO, Falcon International Bank, 

Laredo, Texas; Mark Pitkin, President and CEO, Sugar River Bank, 
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October 28, 2020

Newport, New Hampshire; Alan Shettlesworth, President and COO, 

Main Bank, Albuquerque, New Mexico; and Louise Walker, President 

and CEO, First Northern Bank, Dixon, California. All Members 

attended via videoconference.

Committee members absent from the meeting: Teri 

Messerschmitt, President and CEO, South Ottumwa Savings Bank, 

Ottumwa, Iowa; and Cathy Stuchlik, Chairwoman and President, 

Clackamas County Bank, Sandy, Oregon.

Director Martin J. Gruenberg attended the meeting. 

Corporation staff in attendance: James L. Anderson, Zachary 

Anderson, Shannon M. Beattie, Mary Calkins, John Conneely, 

Kymberly K. Copa, Brian Cox, Chad R. Davis, Doreen R. Eberley, 

Diane Ellis, Pamela Farwig, Jasa J. Gitomer, Shannon Greco, 

Patricia S. Gurneau, Isaac Hernandez, Travis Hill, Angela 

Hinton, Daniel Hoople, M. Anthony Lowe, Christopher Lucas, 

Samuel Lutz, Brandon Milhorn, Jonathan Miller, Rae-Ann Miller,

Kathy Moe, Shayna Olesiuk, Mark E. Pearce, Harrel M. Pettway, 

Nicholas J. Podsiadly, Jon Pogach, John Rieger, Lisa K. Roy, 

Betty Rudolph, Mark Savi, Michael Shaheen, James P. Sheesley, 

Mona Thomas, John F. Vogel, and James Watts.

Jocelyn Sutton attended from the Consumer Financial 

Protection Bureau.

William Briggs, Dianna Seaborn, and Susan Streich attended 

from the U.S. Small Business Administration. 

Chairman Jelena McWilliams opened and presided at the 

meeting. Chad R. Davis, Deputy to the Chairman for External 

Affairs and the Committee’s Designated Federal Officer, 

moderated the proceedings.

Introductory Remarks

Chairman McWilliams welcomed members to the Committee’s 

second virtual meeting, noting that much had happened in the 

months since the Committee last met, and that the FDIC is 

working hard to ensure community banks can continue the business 
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October 28, 2020

of banking amidst dire pandemic circumstances and unprecedented 

business closures. She welcomed new Committee member Stephen 

Hayes, Chairman and President of Dakota Prairie Bank, Fort 

Pierre, South Dakota, then introduced Mr. Davis as moderator.

Mr. Davis invited opening comment from Director Gruenberg, 

who thanked members for their participation, and said he looked 

forward to hearing their current experiences and their outlook 

on the upcoming months. 

Community Banking Conditions

Mr. Davis then introduced a roundtable discussion of 

community banking conditions. The Committee members discussed a 

range of trends and issues related to local banking environments 

and conditions, including the following: 

COVID-19 Pandemic. The pandemic and its economic and 

banking consequences permeated the members’ discussion. Those 

from areas with significant COVID-19 case numbers early in the 

pandemic generally reported improvement in conditions over the 

summer, while some members from rural areas less affected by the 

late winter and spring outbreaks described increasing spikes. 

All members indicated concern about the prospects of rising 

cases with winter’s arrival, and with it the potential for 

economically consequential responses. Within that uniformity, 

members described a variety of local conditions and operational 

responses. 

Although all members indicated that some modifications to 

operations were in place to protect their employees and the 

public, the actual practices ranged from continuing branch or 

lobby closures to business-as-usual (with masks) in the front 

office and expanded telework behind the scenes. Many stated 

their institutions increasingly relied on “non-contact channels” 

such as online and telephone banking. Those members reporting 

COVID-19 infections among staff expressed a belief that their 

operational response had precluded spread within their offices, 

with several stressing the importance of protecting customer and 

staff alike. Two members recounted positive experience with 

remote examinations necessitated by the pandemic: Member DeBiasi 

stated his hopes that this experience leads to a “paradigm 
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October 28, 2020

shift” in the manner of conducting examinations of smaller 

institutions, while Member Maley noted the continuing importance 

of face-to-face contact during this process.

Committee members also noted that the pandemic highlighted 

the importance of community banking. Member Shettlesworth 

echoed Chairman McWilliams’s prior public statement that 

community banks hit “above their weight” in delivering stimulus 

to their communities during the crisis, noting that the 

institution in his state with the most deposits did not make a 

single Paycheck Protection Program (PPP) loan in-state. Member 

Epstein expressed a belief that the community bankers’ customer 

knowledge enabled prudent exercise of flexibility in managing 

the credit needs of borrowers impacted by the crisis. Member 

Maley noted a sense that, unlike prior financial crises, “banks 

were friends, not foes” providing aid to communities through 

extensions of PPP loans and Coronavirus Aid, Relief, and 

Economic Security (CARES) Act funds, as well as by sharing rate 

reductions with customers. 

Most members who reported involvement in PPP described 

their experience with the forgiveness program, noting some 

difficulties and surprise at the requirement to deduct Economic 

Injury Disaster Loan (EIDL) advances from the forgiveness amount 

– resulting in an unexpected need to carry a balance on the loan 

after forgiveness. Member Mongold commented favorably on the 

recent Interim Final Rule providing temporary relief from Part 

363 Audit and Reporting requirements for banks that have 

experienced temporary growth due to participation in the PPP and 

other stimulus programs.

Member Leavitt and Member Kelly said that their 

institutions had resumed action on long-term strategic 

initiatives paused earlier in the pandemic. Still, no member 

indicated that the end of the pandemic is in sight. Subsequent 

sections of these minutes address the variety of continuing 

effects of and responses to the pandemic, which the members 

expect to continue until an effective vaccine or therapeutic 

treatment is widely available.

 

Economic Conditions. Members reported significant economic 

improvement since the July 2020 meeting. Most said that the 
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October 28, 2020

robust employment recovery continued in their communities, 

though Member Leavitt noted that many job seekers had “opted 

out” of the labor market, and Member Epstein expressed concern 

that anticipated pandemic closings would lead to increases in 

unemployment. Nearly all members described robust single-family 

housing market conditions, with high demand for construction, 

expansion, purchase, and refinance loans. This demand, members 

said, was attributed to low rates and strong price appreciation 

due to limited inventory – itself a result of increased purchase 

interest and high construction labor and materials costs. 

Members Edwards and Walker spoke of home buying in exurban and 

rural areas being driven by workers exploring telework as a 

result of the pandemic, while Member Kimbell posited that the 

draw of “country living” explained increased demand in his 

region. Member Andersen said that her institution purchased a 

mortgage company to expand its reach in this market, while 

Member Epstein said his bank invested in an improved online 

platform to compete with nonbank mortgage lenders. According to 

the members, agriculture is also performing above expectations 

in 2020, thanks to direct support programs and improved growing 

conditions over 2019. Member Kimbell said that farming “is on 

top of its game” and that this buoys all sectors in some rural 

areas. Member Walker noted the strength of the education and 

healthcare sectors.

Members identified difficulties in other sectors, notably 

hospitality and commercial real estate. Most members reported 

that the hospitality industry in their markets continued to 

suffer from pandemic-driven reductions in demand. Some members

observed that summertime recovery was now at risk due to the 

return of indoor weather and the threat of shutdowns aimed at 

controlling COVID-19 infections. Member Narvaez said that 

border crossing restrictions in his location had heavily 

affected hospitality businesses. The transition to telework 

raises long-term questions about demand for office space, 

according to Members Getzlaff and Andersen. Other impacted 

industries include the nonprofit sector, with Member Pitkin 

noting that the survival of many nonprofits may hinge on 

additional stimulus.

Many members attributed the overall positive economic 

conditions to federal and state stimulus programs. Members 
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October 28, 2020

indicated that doubts as to further stimulus programs, just like 

doubts about the course of the pandemic itself, give rise to 

overall uncertainty about 2021, a year that Member DeBiasi 

described as a “wildcard.” 

Banking Conditions. Across the board, members reported 

strong banking conditions prevailing in their institutions and 

local markets. Member Shettlesworth expressed a shared 

sentiment of surprise, noting that his bank will end the year 

with record earnings and loan and customer growth, which 

“doesn’t make sense” given the challenges posed by the pandemic 

and recession. 

Nearly all members reported strong asset quality, with few 

borrowers continuing to use the deferrals, extensions, and other 

forbearance extended earlier in the year. Member Edwards said 

that past-due loans were at “unbelievably” low levels even 

without considering the pandemic. Members Leavitt and Epstein 

praised the conscientiousness and fortitude of borrowers in 

keeping loans current despite 2020’s challenges. Members also 

reported asset growth, with a fraction attributed to stimulus 

programs but with organic growth noted as well. Member Kelly 

observed that asset quality is strong, but qualified this as a 

“short run” observation, and that his institution was increasing 

its allowances for loan losses – something reported by roughly 

half of the members.

Members continued to report significant deposit growth, 

attributing much of it to the stimulus programs as well as to 

traditional asset-growth strategies, such as branch openings. 

Members told of a variety of strategies to address the capital 

implications of asset and deposit growth. Member Maley described 

a successful capital raise, and Member Shettlesworth said his 

institution was considering one. 

Several members noted record years for earnings, with some 

pointing to mortgage origination and sales as a “bright spot”

for community banks. Members identified net interest margin 

compression, reduced interchange fees due to recession-related 

decreases in spending, and the earnings effects of increasing 

reserves as challenges to earnings. Some members expressed 

caution about earnings prospects for 2021.
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October 28, 2020

Diversity and Inclusion. Several members complimented the 

FDIC’s efforts, and Chairman McWilliams’s leadership, on 

diversity and inclusion in 2020. Member Kelly noted that in “a 

capitalist society, economics are the measuring stick” and that 

2020 provides an opportunity to be equitable. To this end, he 

called attention to the National Bankers Association’s 

priorities of equity investments, revenue-generating business 

opportunities, and deposits. Member Leavitt mentioned the 

FDIC’s recent publication, “Investing in the Future of Mission 

Driven Banks” and his institution’s support for a Vermont 

community development financial institution, as well as its own 

“Equity Framework.” 

Other Topics. Members mentioned competition with nonbank 

lenders, with Member Hayes noting that recent revisions to 

agricultural appraisal requirements helped level the playing 

field with nonbank agricultural lenders. Member Maley urged a 

reconsideration of FDIC treatment of “Amish Aid” flood 

insurance, saying that discrepancies in regulatory approach 

advantage national banks over FDIC-supervised institutions. 

Member Epstein recounted recent experience with cyber-attacks in 

his area, noting the success of his institution’s response plans 

and his initiation of further training and testing to prevent 

social engineering attacks. Member Pitkin discussed the 

importance of vigilance against fraud, especially in the area of 

unemployment insurance claims. Member Hayes told of a 

successful emerging leaders program at his institution, designed 

to train newer workers and involve them in succession planning. 

Finally, Member Getzlaff recounted her involvement in a recent 

small business panel convened by the Consumer Protection 

Financial Bureau as part of its rulemaking to implement Section 

1071 of the Dodd-Frank Act. Member Getzlaff explained some of 

the issues explored by the panel relating to data collections 

regarding applications for credit by women-owned and minorityowned businesses. She advocated for a $10 billion institution 

size threshold for loan-level data collection requirements to 

avoid unintended impacts on borrowers and undue burdens on 

smaller institutions. 

After the committee member roundtable, Mr. Davis introduced 

FDIC staff members to discuss their national and regional 
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observations. Shayna Olesiuk, Associate Director, National and 

Regional Risk Analysis, Division of Insurance and Research

(DIR), presented on the national economy and banking trends. 

John Conneely, Regional Director, Chicago region, and Kathy Moe, 

Regional Director, San Francisco region, presented observations 

from local FDIC staff. 

Following this discussion, Mr. Davis announced the meeting 

would briefly recess. Accordingly, the meeting stood in recess 

at 3:13 p.m.

Update from the Minority Depository Institutions Subcommittee

The Committee reconvened at 3:22 pm. Mr. Davis introduced 

Member Narvaez and Ms. Rudolph, National Director, Minority and 

Community Development Banking, RMS, to present an update on the 

Minority Depository Institutions (MDI) Subcommittee, which had 

met the day before. 

Following the presentation, Member Kelly provided feedback 

about the request for proposal (RFP) for financial advisors to 

support the new Mission Driven Bank Fund. He expressed concern 

about the RFP creating exclusion based on experience. By way of 

example, he said that if an RFP has a magnitude of $2 billion, 

but no minority firm reaches that threshold, the RFP should 

include some provision for inclusion. In addition, he suggested 

that minority organizations have a representative in the process

of standing up the fund. He expressed his willingness to work 

with the MDI Subcommittee to ensure the process is inclusive. 

Ms. Rudolph thanked him for those suggestions, and she 

shared that the MDI Subcommittee had discussed the importance of 

ensuring the fund investment committee understands the MDI and 

CDFI bank sector, which is different from mainstream banking. 

She added that the FDIC solicited minority and women-owned law 

firms to assist in drafting fund documents and helping with the 

RFP. She noted that the FDIC is focused on ensuring diversity 

of participation.
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Proposed Changes to the Supervisory Appeals Process

Mr. Davis next introduced Samuel Lutz and James Watts, both 

Counsel in the Legal Division’s Assessment Unit, who presented

on proposed changes to the supervisory appeals process. 

Following their presentations, Members Hayes and Edwards 

asked whether the FDIC had considered adding a banker to the 

proposed Office of Supervisory Appeals to enhance its 

independence. Mr. Watts responded that the FDIC had received 

similar comments in writing as well as in listening sessions and 

webinars and will consider these comments as the proposal is 

finalized. Member Edwards added that new office should be 

diverse and include others besides bankers. 

Supervision Update

Mr. Davis then introduced a panel of RMS representatives to 

provide updates on supervisory matters. Doreen Eberley, 

Director, RMS, outlined the topics to be discussed. 

Next, John Rieger, Chief Accountant, RMS, discussed

Financial Institution Letter (FIL) 74-2020 issued on August 3, 

2020, which provides direction on prudent risk management and 

consumer protection principles for financial institutions to 

work with borrowers as loans near the end of their initial 

accommodation period.

Then Shannon Beattie, Deputy Chief Accountant, highlighted

differences between Section 4013 of the CARES Act and 

discussions in the Interagency Statements of April 7 and August 

3, 2020 regarding loan modifications related to COVID-19.

Mr. Rieger then discussed an interim final rule the Board 

approved on October 20 that provides certain relief under Part 

363 regarding audits, financial reporting, internal controls,

and the makeup of Boards.

Ms. Beattie then concluded the panel’s presentation by 

discussing the Call Reports for March 31, 2020 and June 30, 

2020. She noted that those Call Reports contained revisions 

associated with several capital-related and other interim final 
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rules and a final rule issued in response to COVID-19’s impact 

on financial markets and strain on the U.S. economy. Ms. 

Beattie added that institutions should refer to the separate 

stand-alone September 2020 COVID-19 Related Supplemental 

Instructions, which address these revisions.

Following these presentations, Member Walker asked whether 

the FDIC had considered adjusting the CRA thresholds due to the 

unusual growth in assets. Ms. Eberley responded that the FDIC 

is looking at other thresholds and factors that might have been 

affected, as noted in the background section of the Federal 

Register notice relating to the recent Part 363 interim final 

rule (as announced in FIL-99-2020).

Member Hayes then requested clarification on the evaluation 

process regarding Threshold Adjustments Due to Unusual Asset 

Growth mentioned in the presentation. Ms. Eberley responded 

that it related to the foregoing discussion of how the FDIC is 

evaluating regulatory thresholds in light of balance sheet 

increases, and made one adjustment while continuing to review 

others. 

Next, Member Epstein suggested, as a topic for future 

consideration, the challenges banks will encounter in evaluating 

extensions of commercial credit as a result of the pandemic 

impact on cash flow or debt service coverage for 2020. He 

suggested considering these measures over a multi-year period, 

or substituting a pro forma statement for 2020 figures. Ms. 

Eberley responded by referencing the examiner guidance and

instructions issued in June, which advises examiners to be 

cognizant of difficulties with financial statements and the 

potential use of pro forma financial statements due to 

continuing uncertainty or disruption. Ms. Miller added that 

examiners are instructed to look at the risk assessment process, 

and she expressed a willingness to discuss the topic at the next 

meeting.
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Rapid Prototyping Competition and Request for Information on 

Proposed Voluntary Certification Program to Promote New 

Technologies

Mr. Davis then introduced Brandon Milhorn, Deputy to the 

Chairman and Chief of Staff, who presented an update from 

FDiTech on the Rapid Prototyping Competition and Request for 

Information on Proposed Voluntary Certification Program to 

Promote New Technologies. Member Epstein expressed support for 

the initiative. 

Update from the U.S. Small Business Administration

Mr. Davis then introduced staff from the U.S. Office of 

Small Business Administration (SBA) – William Briggs, Deputy 

Associate Administrator, Office of Capital Access; Dianna 

Seaborn, Director, Office of Financial Assistance; and Susan 

Streich, Director, Office of Credit Risk Management – to discuss 

issues relating to forgiveness of PPP loans. 

Ms. Seaborn noted the National Association of Government 

Guaranteed Lenders national conference was occurring that week, 

and the SBA had been hearing more about issues regarding PPP 

loan forgiveness. She added that the SBA recently issued

information on change of ownership rules for business owners who 

received PPP funds. 

Mr. Briggs reported that the SBA released its FY-20 data

that day. Combining PPP, EIDL, and the SBA’s regular loan 

program, the SBA had issued nearly nine million loans and over 

$750 billion worth of financial assistance for small businesses 

this year – a record in the agency’s history.

Member Shettlesworth asked about the SBA’s timeline for 

responding to forgiveness applications, and whether the SBA can 

send forgiveness notices to lenders who communicate directly 

with the borrowers. 

Mr. Briggs began by reminding the Committee that the 

borrowers apply to the lenders for forgiveness, and the lenders 

then send the forgiveness decisions to the SBA. He noted that 

the SBA has not yet received the vast majority of forgiveness 
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decisions from lenders. Mr. Briggs added that the SBA has begun 

remitting payments to lenders who submitted forgiveness 

applications, and he expects that pace to pick up. He stated 

that since the remittance payment is the point at which taxpayer 

funds are exposed, the SBA has been working with its Inspector 

General as well as the U.S. Government Accountability Office 

(GAO) and congressional committees on implementation of the PPP. 

He expressed willingness to look into how forgiveness notices 

are distributed. Ms. Seaborn noted that they will evaluate 

whether they can provide access to the portal to more staff 

members at each lender. She added that direct receipt of 

forgiveness notices is facilitated by lenders’ signing up in the 

portal, and ensuring they enter correct ACH information. 

Member Shettlesworth next asked about potential tax 

consequences of PPP loan forgiveness. Mr. Briggs and Ms. 

Seaborn provided general responses regarding federal and state 

tax consequences, with Ms. Seaborn advising that the SBA is in 

discussion with the IRS about CARES Act tax exemptions. 

Next, Member Walker asked the SBA’s timeline for responding 

to borrowers after banks submit requested items for forgiveness 

applications. Mr. Briggs responded that the SBA does not have a 

specific timeframe, but tries to handle applications 

expeditiously. 

Member Mongold then asked about unexpected reductions of 

forgiveness by EIDL advances. Mr. Briggs emphasized that 

Section 1110 of the CARES Act requires EIDL advance deduction 

from the forgiveness amount. He said the SBA is aware of this 

issue, but it would require a statutory remedy. He noted that 

EIDL advances are shown in the portal. 

Next, Member Leavitt asked how to ensure the SBA does not 

subtract the EIDL advance amount again during the forgiveness 

process, in the event a borrower already subtracted it. Mr. 

Briggs responded that the SBA is looking into that with the 

Department of Treasury. He advised that, since the SBA will 

deduct the EIDL amount, if a borrower already deducted the EIDL 

advance amount, the lender should wait to apply for the

forgiveness decision as the SBA and Treasury work to resolve the 

problem. 
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Member Shettlesworth then asked what documentation the SBA 

wants lenders to send with forgiveness applications under Form 

3508S for smaller loans. Mr. Briggs said that supporting 

documentation is required regardless which form is used. Ms. 

Seaborn added that the SBA does not expect a level of 

confirmation involving external review, but does expect that a 

lender would not move a forgiveness application forward if they 

believe, in good conscience, that there is an issue.

Division of Insurance and Research Update

Mr. Davis then introduced a panel from DIR: Angela Hinton, 

Senior Financial Analyst; Daniel Hoople, Financial Economist; 

and Jonathan Pogach, Chief, Financial Modeling & Research 

Section. They discussed deposit trends, the Deposit Insurance 

Fund, and the FDIC's Academic Challenge.

Ms. Hinton highlighted the unprecedented deposit growth 

reported in the first half of 2020. She presented statistics 

for the industry as a whole, and for all FDIC-insured 

institutions, and detailed the impact of that deposit growth on 

the FDIC's reserve ratio.

Next, Mr. Hoople discussed the restoration plan adopted by 

the FDIC Board in September, including the necessity for the 

plan, its components, and underlying analysis.

Following the presentations, Member Shettlesworth asked 

about the possibility of the FDIC increasing deposit insurance 

assessments to raise the DIF ratio. He questioned whether, in 

those circumstances, the increased assessments would apply 

across the industry, or focus on larger institutions. Mr. 

Hoople responded by noting that the FDIC’s desire to avoid 

overburdening the banking system at this time is evidenced by 

its recent decision to maintain assessment rates, but described 

scenarios in which increased assessments could become necessary 

and related considerations.

Finally, Mr. Pogach presented on the 2020-2021 Academic 

Challenge, a nationwide undergraduate competition. 
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October 28, 2020

Closing Remarks

Mr. Davis invited closing comments from Director Gruenberg, 

who thanked the Committee Members for their participation in the 

lengthy virtual meeting and useful discussion. He reiterated 

that the Committee has been a valuable asset to the FDIC over 

the years, providing a line of sight into what community banks 

experience at the local level, and that their presentations 

reflect the value and commitment community banks offer to their 

communities. 

Chairman McWilliams closed the meeting by thanking the 

Committee members and presenters for the feedback and 

interesting data points to consider on regulatory and 

supervisory fronts. She expressed her gratitude for the members 

whose Committee terms end this year: Members DeBiasi, Edwards,

Epstein, Kimbell, Leavitt, Maley, Shettlesworth, and Walker. 

Having no further business to discuss, the meeting 

adjourned at 5:38 p.m.

_____________________________

Debra A. Decker

Federal Deposit Insurance Corporation

Deputy Executive Secretary

and Committee Management Officer

FDIC Advisory Committee on Community Banking
Minutes

of the

Meeting of the FDIC Advisory Committee on Community Banking

of the

Federal Deposit Insurance Corporation

Held in the Board Room

Federal Deposit Insurance Corporation Building

Washington, D.C.

Open to Public Observation Via Webcast

October 28, 2020 – 1:00 P.M.

I hereby certify that, to the best of my knowledge, the attached minutes are accurate and 

complete.

________________________________

Jelena McWilliams

Chairman

Board of Directors

Federal Deposit Insurance Corporation