arkmundi said:

Unfortunately, the FDIC has had to step in a lot recently.  Please periodically visit http://www.fdic.gov/bank/histo…..index.html and be reminded that banks are failing a lot right now.  … There are lots of relevant questions to ask here, including the question of whether the credit markets are in the process of shutting down more, or are easing.  I believe it to be the former, and will likely persist for some time to come.  If so, what's the implication of this for CGB?

Here's another great link – the Problem Bank List at http://calculatedriskimages.bl…..gspot.com/.  Which can be sorted by state, to find all the banks in MA (there now six, up from two when I posted two months ago):

Athol-Clinton Co-operative Bank, Athol
First Trade Union Bank, Boston    
OneUnited Bank,    Boston
Stoneham Savings Bank, Stoneham
The Community Bank – A Massachusetts Cooperative Bank, Brockton
The First National Bank of Ipswich

Taking this a bit further, open any one of the "Enforcement Action Type" documents; for instance the Cease & Desist Order for the The Community Bank, and find (The red highlight added by me just to emphasize of few points about management practices and policies, adequate capital, and supervision.

FEDERAL DEPOSIT INSURANCE CORPORATION
             WASHINGTON, D.C.
                         and
COMMONWEALTH OF MASSACHUSETTS
             DIVISION OF BANKS
_______________________________
         THE COMMUNITY BANK
     BROCKTON, MASSACHUSETTS
(INSURED STATE NONMEMBER BANK)

In the Matter of:  ORDER TO CEASE AND DESIST; FDIC-09-212b

The Community Bank, Brockton, Massachusetts (Bank), having been advised of its right to a Notice of Charges and of Hearing under section 8(b) of the Federal Deposit Insurance Act (Act), 12 U.S.C. § 1818(b), detailing the unsafe or unsound banking practices and violations of law and regulations alleged to have been committed by the Bank, and of its right to a hearing on such alleged charges, and having waived those rights, and having waived any rights that the Bank has or may have under the Massachusetts General Laws, entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST (CONSENT AGREEMENT) with a representative of the Legal Division of the Federal Deposit Insurance Corporation (FDIC), and with the Commissioner of Banks of the Commonwealth of Massachusetts (Commissioner), dated June 25, 2009, whereby solely for the purpose of this proceeding and without admitting or denying any unsafe or unsound banking practices or violations of law or regulations, the Bank consented to the issuance of an ORDER TO CEASE AND DESIST (ORDER) by the FDIC and the Commonwealth of Massachusetts Division of Banks (Division).

The FDIC and the Division considered the matter and determined that they had reason to believe that the Bank engaged in unsafe or unsound banking practices and violations of law and regulations.
The FDIC and the Division, therefore, accepted the CONSENT AGREEMENT and issued the following: ORDER TO CEASE AND DESIST

IT IS HEREBY ORDERED that the Bank, its institution- affiliated parties, as that term is defined in section 3(u) of the Act, 12 U.S.C. § 1813(u), and its successors and assigns, cease and desist from the following unsafe or unsound banking practices and violations of law and regulations:

a. Operating with deficient supervision by the Board of Directors (“Board”);

b. Operating with deficient management, policies, and practices;

c. Engaging in hazardous lending practices, including, but not limited to, poor credit administration practices and ineffective underwriting standards and practices.

d. Engaging in practices that produce an excessive volume of criticized assets;

e. Engaging in practices that produce an excessive volume of concentrations of credit;

f. Failing to provide for an effective system to identify problem assets and prevent deterioration;

g. Operating with a deficient allowance for loan and lease losses for the volume, type, and quantity of loans and leases held;

h. Operating with a deficient level of capital for the Bank’s risk profile;

i. Operating with deficient earnings;

j. Operating with a deficient level of liquidity and deficient funds and liquidity management practices;

k. Engaging in violations of applicable laws and regulations;

l. Engaging in contraventions of Interagency guidelines and statements of policy;

m. Operating without proper internal routine and controls; and

n. Operating with weaknesses in the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance program.

___________

Unfortunately, the FDIC has had to step in a lot recently.  Please periodically visit http://www.fdic.gov/bank/histo…..index.html and be reminded that banks are failing a lot right now.  The credit markets open and the credit markets close, and the FDIC is one of the gate keepers.  I believe this is highly relevant, for all kinds of reasons in consideration of CGB design, timing, etc.  Let's please not blame the FDIC for doing its job.  It did not cause this financial crisis, but is doing a rather remarkable job of cleaning up after the fact.  There are lots of relevant questions to ask here, including the question of whether the credit markets are in the process of shutting down more, or are easing.  I believe it to be the former, and will likely persist for some time to come.  If so, what's the implication of this for CGB?