Let me try ths one more time! I'm worried!

foodles · November 20, 2015, 1:53pm

Not that my opinion/action really matters, but FWIW I did follow Saul and others’ concern/recommendation to exit BOFI today even though that is something I typically do NOT do. Up to this point I’ve been a more “traditional” MF investor (buy and hold). It’s gotten me good returns so far, but nowhere near what Saul has generated.

But this position was purchased a few months ago because of this board and I know that I know less about this stock than most of those posting about it here, so I deferred to what seems to be the more prevalent current opinion, that there are too many risks or potential irregularities with this company and the way they operate. And that once the sell side folks take in all this information, that it could get ugly.

I try not to buy high and sell low, as I feel that’s not a very good investment style. But unfortunately, that’s what happened with me here, and it hurts, but I’m trying to run this “section” of my portfolio more the way this board suggests. So along those lines, I’ve redeployed some of the money into LGIH (new position for me) and will decide on another place to put the rest of it.

Good luck to those that are still long, I’ll keep reading, and if most of the risks disappear, I may be back (again, this style of investing is new to me, in the old days, I would hold basically forever).

thejusticier · November 20, 2015, 4:23pm

So, to be clear, you sold your position again? - citi

To be clear, here’s what I wrote in the description of my portfolio at the end of October :

BOFI was my third biggest last month at 15.7%, and is now gone for reasons that have been extensively discussed.

I’m not writing because I changed my mind. I’m writing because I was worried about my fellow board-mates.
-Saul

but you bought back in some after you sold, right? I think citi was asking about those.

To go back to your point: I think we should not make excuses if we know that it is not good situation.

However, what is really new lately? there is a lot of repetition of the same statements and allegations. Most folks do know that repeating the same thing over and over again do not make it true but psychologically many people can and do start to think that it may be true even if at the onset they thought it was not.

It is not about making excuses. What is new that makes keeping a position in BOFI not a good investment anymore?
I think most will not have as much as 15% of their portfolio in a small banking business.

tj

NewEchota · November 20, 2015, 6:10pm

I don’t want to go through your laundry list but here’s one item you mention:

Okay, so they are involved with this unlicensed Center Street company that specializes in fix and flip homes… But it’s not proved that Bofi is doing anything strictly illegal.

Unlicensed? Actually, Seeking Alpha says they’re Apparently Unlicensed.

Um, what is apparently unlicensed? Either they’re licensed or they’re not licensed. The author seems to really like the words “apparent” and “apparently,”: he used them 10 times in his article.

I found this response to the author within the comments section especially interesting:

You seem to know little of hard money lending. The proceeds of the loan are used to upgrade the property. Most loans are done at greater than 20% LTV. The subsequent property upgrade, which is usually done in less than 6 months, results in a 40-50% LTV. The loaned funds cannot be used for another purpose and in most cases there is fund control.

The borrower many times cannot get a bank loan as banks only lend against owner occupied property. In hard money lending, the property alone is attractive enough to cause a loan especially with 20-30% LTV and a depressed price at the onset and value added remodeling. Borrowers may have 2-3 projects going at once. While this is not a long term business as the rehab projects dry up, it is very profitable and low risk. They are not suspect loans but highly collateralized and very safe loans.

Your guilt by association assertion is just absurd. The fact that some slick lawyer alleges against Center Street as receiver in no way implicates BOFI. Lawyers assert against everybody in bankruptcy.

OneWhoWaits · November 20, 2015, 6:43pm

I try not to buy high and sell low, as I feel that’s not a very good investment style. But unfortunately, that’s what happened with me here, and it hurts…

Good luck to those that are still long, I’ll keep reading, and if most of the risks disappear, I may be back (again, this style of investing is new to me, in the old days, I would hold basically forever).

I’m with you on this one. Unfortunately, these days it is not all that uncommon to see the value of a company’s stock go all the way to ZERO. It would be one thing to just have to hold on longer to see value return and rise, but the risk of ending up with worthless stock is ever present in our times. Not so much in “the old days”.

captainccs · November 20, 2015, 7:15pm

Unlicensed? Actually, Seeking Alpha says they’re Apparently Unlicensed.

This is very typical of short hit pieces. The author is not stating a hard fact but innuendo for which he cannot be sued because he is not telling an outright lie. But he is seeding doubt and nervous nellies who have not done their homework get scared and sell, down goes the stock, mission accomplished.

This is why I said that one has to read slowly and digest each piece carefully before going on to the next one. This is the reason for making the pieces so extremely long and full of irrelevant stuff. The reader’s attention span is reached and, just to be safe, they sell and might continue reading later. But by selling, down goes the price, mission accomplished!

These short attacks can be very insidious. Carefully crafted boilerplate with links to real documents that don’t say what the author implies they say. For example, someone might be mentioned in an SEC document but that does not mean automatic guilt. One has to read the text to see what it really says. The more documents they link the longer the research gets. Let’s sell just to be safe, mission accomplished.

When people tell you to do your own due diligence, it’s just for this reason, you have to know your companies. If not, you trust to luck and if a hit piece appears, you sell just to be safe.

The author of the hit piece does not have to be right, his motivation is to get you to sell by instilling FUD – fear, uncertainty, and doubt. If you don’t know your facts or if you don’t carefully read and understand the linked documents, his mission is accomplished which is just to get you to sell.

I repeat, some shorts do get it right so you can’t dismiss the attack without investigating it. But hit pieces are very cleverly assembled to get you to sell.

After a while you get to know the characters at Seeking Alpha and you can start dismissing some of them out of hand. The Harvard Ph.D. student is one you can dismiss, he is a nasty one.

BTW, don’t reply to them, it just gives them more space to spread the venom.

Your best defense is to know your company.

Denny Schlesinger

bg333 · November 21, 2015, 10:31am

You do a disservice by spewing out this pile of insinuations; look at them closely and there is little if any substance to any of these claims which appear to be nothing more than an attempt to spread fear and doubt. You admit that you’re no banking expert … so what gives you the right to reiterate all these insinuations with no analysis? There’s nothing here that will have any material impact on a rapidly growing business that is earning solid returns for its investors … at least those investors smart enough to dismiss these insinuations.

Btscheufler · November 21, 2015, 10:57am

You admit that you’re no banking expert … so what gives you the right to reiterate all these insinuations with no analysis?

The board is called Saul’s Investing Discussions…

Arguments have been laid out on both sides, it is up to each individual investor to make a decision based on their own situation.

Brian

PeregrineTrader · November 21, 2015, 1:05pm

Unlicensed? Actually, Seeking Alpha says they’re Apparently Unlicensed.

Um, what is apparently unlicensed? Either they’re licensed or they’re not licensed. The author seems to really like the words “apparent” and “apparently,”: he used them 10 times in his article.

Apparently, (LOL!) you missed the link to the California database which Aurelius linked to, a database for the Department of Business Oversight.

http://www.dbo.ca.gov/FSD/Licensees/default.asp?flag=1&s…

Go ahead, punch in the name of Center Street Lending down below with the “Company Name Contains” clicked on and the “Both” box below it (signifying “Active” and “Inactive” licenses) clicked on too.

I can’t find any license for Center Street Lending issued in California. Can you?

So, “apparently” they ARE unlicensed in the State of California as a Financial Service or Mortgage Lending Company.

Would you not agree with that statement?

Furthermore, let’s go to Center Street Lendings website to see if they have placed their “license” no. for lending on it, as most legit mortgage businesses, contractors, Realtors, etc., do.

Well what do we find?

No Financial Service or Mortgage Lending Company license is published. But we do find these rather interesting tidbits of info:

Real Estate Broker - CA Bureau of Real Estate - License #01883377 | NMLS 905781 (bottom of this page)

http://www.centerstreetlending.com/about-us.html

So, using the State of California’s database for licenses of Financial Services or Mortgage Lending Company’s, we come up with nothing for Center Street Lending.

Yes, I would say it is “apparent” they are not licensed in the State of California as a Finacial Service Company or Mortgage Lending Company.

The questions you might want to pose next is, “Is there any advantage to operating “under the radar” without a lender’s license?” "Is Center Street Lending using the lax regulation of the “hard money business” to their advantage to continue making loans to a convicted felon (5 felonies, two-years of prison)and who now has assets “frozen” by the SEC while a receiver in court document is accusing this scam artist of not using most of his Center Street Lending loans to fix and flip as was intended, but, to line his own pockets with money to burn on other assets?

By the way, Center Street Lending is fully ware of lax regulation in the “hard money” (legalized loan sharking)business. No need to equiovocate on this by using “apparently”.

From their website according to Aurelius, and I’ve taken the liberty to highlight what Center Street Lending is brazen enough to emphasize:

“The state of California explicitly states that “any person engaging in the business of a finance lender of finance broker is required to obtain a California Finance Lenders license”. Center Street, however, considers itself a “hard money” private lender and apparently believes it is exempt from regulation. As it states on it’s website “the hard money industry has largely been unregulated by state or federal laws”. While a detailed discussion of California’s lender laws is beyond the scope of this article, BOFI’s sponsorship (as a federally chartered bank) of Center Street may eliminate any regulatory exemptions that Center Street believes it is entitled to. Further reading can be found in a recent California State Senate background paper on the topic.”

Yep, it’s there on their website. I’m reading these words now:

Legal & Regulatory Issues

From inception, the hard money industry has largely been unregulated by state or federal laws, although some restrictions on interest rates (usury laws) by state governments restrict the rates of hard money in certain situations.

http://www.centerstreetlending.com/private-lending.html

Loosely regulated, unlicensed to be a lender, and taking part in a ponzi scheme with a convicted felon whose assets are frozen and who has no way to pay Center Street Lending’s notes, what does Center Street Lending do according to a court receiver?

From the Aurelius piece:

Despite obvious red flags, the receiver alleges that Center Street (likely with BOFI provided funds) “lent money to Capital Cove on at least 86 occasions over the course of about 4 years, almost all of which were in default throughout the vast majority of the lending relationship”. The receiver makes clear that the loans had no economic basis and that Center Street:

"…could have and should have known that Capital Cove could not turn a profit on the properties that it was purchasing when considering all of the liens placed against the properties, the cost of refurbishment, the carrying costs for the properties including insurance, taxes and interest, as well as the closing costs, commissions, late fees, and taxes to be paid upon the sale of the properties.

Despite most of the earlier loans being in default (total loans valued at over $20 Million), and it being obvious that Capital Cover had no means to pay, Center Street continued to issue new “flip and fix” loans to Khalfani. The receiver alleges that Center Street continued to make new loans in an effort to help Khalfani perpetuate the scheme and attract fresh capital from unsuspecting investors so that the proceeds could be used to pay Center Street.

Now I ask any sane person here: would you lend any money out of your pocket to Center Street Lending, who would in turn lend - 86 times, no less - a convicted felon running a Ponzi Scheme even if that money were to earn you 5%?

No?

And yet, if you are a BOFI shareholder, that is what you are doing now.

PeregrineTrader · November 21, 2015, 1:50pm

I should point out that this NMLS 905781 printed next to their California RE license is an identifier number this company (Center Street Lending) is required to use in every state it does business. It is not a California license.

http://mortgage.nationwidelicensingsystem.org/about/pages/nm…

The unique identifier granted to residential mortgage loan originators and companies through NMLS allows regulators to track mortgage providers across state lines to ensure a provider will not escape regulatory action in one state, simply by crossing into another state. The unique identifier also allows consumers and the industry to easily track specific originators’ histories and qualifications through NMLS Consumer Access.

SaulR80683 · November 21, 2015, 1:51pm

Wow! RockO, what a great post. Would you mind if I reposted it, giving you credit, on the BOFI board?
Best,
Saul

PeregrineTrader · November 21, 2015, 1:55pm

Well, go ahead. But there are a few spelling/syntax mistakes. But I think you should add the second addendum I just added about that NMLS number too as I am sure many a BOFI holder might misinterpret that as a California issued “Lender’s license” - which it is not.

SaulR80683 · November 21, 2015, 2:22pm

Thanks, I was intending to.
Saul

PeregrineTrader · November 21, 2015, 3:35pm

And let me say this: there are scads of other links which I believe too many Fools never opened and read about this “hard money lending” biz in which BOFI is holding hands with some of the most egregious abusers.

That first piece from Aurelius and this second piece have loads of documented court decisions, SEC litigation, reputable newspaper accounts, quotes from sources investigating these “hard money” firms, etc.

I’m pretty sure if any BOFI owner were to read each and every link, they’d come to a different conclusion that this is just an ill-written series of “hit pieces” by some crank on Seeking Alpha.

This guy, Aurelius, is laying out a picture painted in blacks, reds, and greys, and yet Foolish BOFI shareholders shrug their shoulders and think he’s “just a short” talking his book?

Maybe Aurelius is short BOFI. So what? He has a CFA claim in his moniker. He’s sharp, very sharp.

Sell-side analysts who haven’t downgraded this company talk their book too. They issue glowing reports about BOFI’s revenue/earnings growth without going deep into all these documents Aurelius is putting out here for all to read.

But I believe sell-side analysts will change. They always do, usually too late, after the SHHTF. (They will change their tune as more investors lose more money when the next Housing Crash strikes.)

We’ve seen sell-side analysts jump off the last Housing Bubble Train - too late - during the 2008 Credit Crisis with Countrywide, Americorp, Indymac, the TBTF banks, the rating agencies, etc. We’ve seen seen this same type of recalcitrance in analysis during the run up to the fall of Enron, Worldcom, and others.

Furthermore, independent analysis on stock boards sometimes trumps paid analysts. For instance, the best writing on Housing Bubble warnings predicting a crash was right here on Fool on the old Misheldo board (now METAR) by the founder of that board, Mike Shedlock.

Shedlock was pilloried by people long the housing, mortgage lender and banking stocks. And yet, he and a handful of other “tin foil hat wearing doomsayers” had that story right before mainstream media - and sell-side analysts - piled on with forensic reporting in the form of videos and multi-piece articles with well-documented links.

Someone in one of these threads pointed out how short-handed the SEC is today. I could not agree more.

Here’s something else to consider about the SEC: the SEC is going after “smaller fry” these days instead of the megalithic TBTJ (too big to jail) firms which were forced to pay $10 million + fines during the Crash.

As the SEC expends more manpower and energy on these smaller crimes, bigger ones are apt to get less attention, and as a recent WSJ article has pointed out, this is the case:

See graph contained in this article from the WSJ:

http://www.wsj.com/articles/sec-escalates-financial-penaltie…

My contention is there’s another crash coming. Absolutely. First-time buyers are priced out of homes today, even with ZIRP making APRs a minuscule 3%. Renting is at an all time high. Home ownership is at an all-time low.

Here in the Keys, most all the condos and apartment complexes are now owned, after many flips among them, by hedge funds and private equity firms. One apartment complex was sold five times in 7 years. The rents have gone up from $1200 a month to $2400 a month. In the other Condo buildings owned by Blackrock et al, rents have sprung up 100 to 150% in the same timeframe. Maintenance at all of these “investments” has gone out the window. Every last penny is squeezed out of these “investments” before the next crash hits and before the hedge fund or private equity fund can “flip” the property to the last bagholder standing.

That said, we are still in a ZIRP environment. What happens when rates go up? First-time homeowners will be priced further out of homeownership markets. The only way to make this up is for housing prices to come down. Supply and demand.

BOFI is lending money to many of these “hard money” lenders who in turn are lending it out to ne’er do wells who are busy buying multi-family rentals and doing fix and flip projects. Look at 2005, look at 1988, two times when “hard money lenders” were wiped out.

BOFI is extending its loan portfolio to loads of hard money lenders. And the people it lends to, many of them, cannot get loans from reputable banks. Why?

To answer that question, start reading the links Aurelius has amply provided you Sunny Day Real Estate types who think this will all blow over.

p.s. Recent article and charts (13 months old) from the Atlantic about the decline in homeownership in America among Generation Xers (people deep in their careers) vs. Millenials (just starting out) which should make any investor go Hmmmmmmm:

http://www.theatlantic.com/business/archive/2014/10/homeowne…

My question to any of you is who is buying up America’s unwanted housing stock?

Well 2 1/2 years ago, Blackstone bought 1400 “distressed” properties in the Atlanta area:

http://www.bloomberg.com/news/articles/2013-04-25/blacktone-…

Blackstone Group LP bought 1,400 properties in Atlanta, some eligible for federal low-income housing subsidies, in the biggest bulk purchase for the fledgling homes-for-lease industry.

The private-equity firm, which has spent more than $4 billion on 24,000 rental properties in the last year making it the largest buyer in the U.S., purchased the residences from Building and Land Technology, said Marcus Ridgway, chief operating officer of Invitation Homes, Blackstone’s single-family rental division.

Private-equity firms, hedge funds and individuals are racing to buy into a shrinking pool of foreclosed or distressed homes to rent. They’re seeking to profit as prices remain 29 percent below their 2006 peak and potential homebuyers can’t get mortgages with banks restricting credit. Jonathan Gray, Blackstone’s global head of real estate, said in an interview last week that it’s getting harder to acquire properties for a profit as competition intensifies.

Two years after this article ran, we see this one, concerning the same hedge fund:

http://mytradingincome.com/blackstone-is-selling-homes-expec…

The legendary CEO of The Blackstone Group (BX) has made billions of dollars investing in distressed situations and selling these investments at a profit.

One of the boldest moves that Schwarzan’s group has made in recent years was to buy more than $9 billion dollars worth of distressed homes during and after the financial crisis. When banks and mortgage companies were looking for any way to get rid of foreclosed homes on their balance sheet, Schwarzman saw an opportunity.

After swooping in and buying these homes at pennies on the dollar, Invitation Homes (the residential real estate company owned by Blackstone) held on to these properties, renovating many of them to make them suitable for renting out.

This week, Blackstone announced that Invitation homes has agreed to sell roughly 1,300 of its homes in the Atlanta market. This is the largest bulk sale of homes in the history of Invitation Homes.

p.p.s. A June, 2015 New York Times on low homeownership (with an updated chart showing some of 2015 where we are still cratering) and more Americans renting while spending more of their paycheck on high rents:

http://www.nytimes.com/2015/06/24/business/economy/more-amer…

According to the housing center’s report, the share of renters paying more than 30 percent of their income on rent — defined as “cost burdened” — has held at near-record highs. In 2013, almost half of all renters fell into that category. The share of cost-burdened renters is growing among people with moderate incomes, those who earn from $30,000 to $75,000 a year, the report said.

I will close by saying I think this board, myself included, needs to investigate Housing more closely at this point in time.

When the “smart money” (read Blackstone) is doing fix and flip and is closing out its books of distressed properties, that right there is a major red flag flapping telling me Housing is set to fall again.

p.p.p.s. Blackstone still owns a condo down here where Section 8 subsidized dwellers live. One of the inhabitants of that condo went on Facebook showing the bathrooms at the pool (which, btw, was closed down to swimmers yet again) where stall doors have lain propped against walls after having fallen off their hinges. So, maybe the hedgies don’t focus on the “fix” but just the “flip”?

PeregrineTrader · November 21, 2015, 4:22pm

I mistakenly called Blackstone a “hedge fund”. It is a private equity fund.

NewEchota · November 21, 2015, 5:07pm

Okay, so let’s discuss…

RockOYates: I can’t find any license for Center Street Lending issued in California. Can you?

So, “apparently” they ARE unlicensed in the State of California as a Financial Service or Mortgage Lending Company.

And I cannot find licenses for any of the other hard money lenders in California in a DBO search either. That’s kind of the point… Center Street Lending is a hard money lender and hard money lenders don’t have the same licensing requirements as banks or traditional mortgage lenders. The fact that they are not in the database simply means that they, as a hard money lender, do not believe they are required to be registered.

RockOYates: From their website according to Aurelius, and I’ve taken the liberty to highlight what Center Street Lending is brazen enough to emphasize:

"The state of California explicitly states that “any person engaging in the business of a finance lender of finance broker is required to obtain a California Finance Lenders license”. Center Street, however, considers itself a “hard money” private lender and apparently believes it is exempt from regulation. As it states on it’s website “the hard money industry has largely been unregulated by state or federal laws”.

Considers itself? Center Street is a private lender. And how, exactly, is that simple fact “brazen”?

You go on to quote Aurelius (my comments in brackets)…

While a detailed discussion of California’s lender laws is beyond the scope of this article [well that’s certainly convenient], BOFI’s sponsorship [in what way is a loan a sponsorship… does a bank that makes me a business loan sponsor me somehow?] (as a federally chartered bank) of Center Street may [ah, the “safe harbor” word, “may”] eliminate any regulatory exemptions [care to name them?] that Center Street believes [how does Aurelius know what Center Street believes?] it is entitled to. Further reading can be found in a recent California State Senate background paper on the topic."

Did you read this “recent” background paper (though I’m not sure how January 2012 qualifies as recent)? Funny, it has nothing to do with Center Street Lending or BofI (or even Capital Cove) but it’s a nice bit of simple guilt by association.

You also note (emphasis mine): Despite obvious red flags, the receiver alleges that Center Street (likely with BOFI provided funds) “lent money to Capital Cove on at least 86 occasions over the course of about 4 years, almost all of which were in default throughout the vast majority of the lending relationship”.

Likely?

In other words, Aurelius has no idea where the funds originated and has no way to prove his allegations but wants you to believe they originated with BofI.

You note that Aurelius writes that …Center Street continued to issue new “flip and fix” loans to Khalfani.

What is a “flip and fix” loan, anyway? It sounds worse than a “fix and flip” loan (which I assume he means to write) but who knows?

Bottom line time: So the allegation is that BofI lent money to Center Street which lent money to Capital Cove which pocketed the funds and defrauded investors? And that BofI is somehow liable for those Capital Cove misdeeds or, if not liable, is at the very least guilty of making an unethical loan because BofI should have know what Center Street intended to do with their pool of funds?

BTW, please explain to me how, as Aurelius suggests, that “BOFI is funding Center Street via another undisclosed, off-balance sheet special purpose entity…”?

NewEchota · November 23, 2015, 3:01pm

Since this laundry list of “red flags” was published and highlighted as “Post of the Day” all weekend, I wanted to review what was written, analyzing which of these line items is true, false, misleading, or perhaps irrelevant. I’ll try to review them one by one when I have the time. If you’re uninterested in BofI or tired of these posts, please click Ignore Thread or skip this post.

The first red flag concerns insider loans.

SaulR80683 writes: 1. Okay, so they are giving insiders huge loans at preferential rates…

Quoting from FDIC PART 215—LOANS TO EXECUTIVE OFFICERS, DIRECTORS, AND PRINCIPAL SHAREHOLDERS OF MEMBER BANKS (REGULATION O); § 215.5 Additional restrictions on loans to executive officers of member banks [all added emphasis, mine].

(c) A member bank is authorized to extend credit to any executive officer of the bank:
(1) In any amount to finance the education of the executive officer’s children;
(2) In any amount to finance or refinance the purchase, construction, maintenance, or improvement of a residence of the executive officer, provided:
(i) The extension of credit is secured by a first lien on the residence and the residence is owned (or expected to be owned after the extension of credit) by the executive officer; and
(ii) In the case of a refinancing, that only the amount thereof used to repay the original extension of credit, together with the closing costs of the refinancing, and any additional amount thereof used for any of the purposes enumerated in this paragraph (c)(2), are included within this category of credit;

To repeat… any executive officer in any amount.

Now, as far as the allegation that the executives are getting “preferential rates” is concerned:

FDIC PART 215—LOANS TO EXECUTIVE OFFICERS, DIRECTORS, AND PRINCIPAL SHAREHOLDERS OF MEMBER BANKS (REGULATION O); § 215.4 General prohibitions.
(a) Terms and creditworthiness.–(1) In general. No member bank may extend credit to any insider of the bank or insider of its affiliates unless the extension of credit:
(i) Is made on substantially the same terms (including interest rates and collateral) as, and following credit underwriting procedures that are not less stringent than, those prevailing at the time for comparable transactions by the bank with other persons that are not covered by this part and who are not employed by the bank;

Now you may argue that the rates to employees are more than “substantially” below prevailing rates. Fair enough; but every loan that Aurelius at Seeking Alpha highlights is a balloon loan (with a couple of commercial loans mixed in) and balloon loans have a lower upfront interest rate.

More importantly, Aurelius at Seeking Alpha writes that:

Unfortunately, the public loan documents I reviewed do not have individual borrower rates attached, so my analysis relies on the interest rate disclosed across the entire program (the 1% I calculated above). In other words, I cannot make any claims around the rates on individual loans.

To repeat: Aurelius at Seeking Alpha cannot make any claims around the rates on individual loans.

In short, he making a wild guess and suggesting his guess is a fact!

He goes on to the tax consequences of these loans, insisting taxes are not being paid because he cannot not figure out how they were accounted for on the BOFI balance sheet.

Well, here’s one easy explanation (quoting the US Department of the Treasury on Employer-Assisted Mortgage Programs for banks): “In addition, if the employer provides its employees with interest free or reduced interest loans in excess of $10,000, the IRS will impute interest income to the employees based on the applicable federal rate.”

In short, tax consequences often are passed on to the employee who declares them on a federal income tax return.

Bottom line time: the loans are completely legal and many banks offer them to their employees. Aurelius at Seeking Alpha admits that he cannot make any claims around the rates on individual loans. And his allegations concerning the tax consequences lack full knowledge of how the loans were structured and are little more than wild, unsubstantiated guesses.

NewEchota · November 24, 2015, 10:39am

This is a continuation of the review of the laundry list of “red flags” published and highlighted as “Post of the Day” this past weekend in order to review what was written, analyzing which of line items are true, false, misleading, half-truths or perhaps irrelevant. Again, if you’re uninterested in BofI or tired of these posts, please click Ignore Thread or skip this post.

Another red flag that was raised concerns BofI executives who previously worked at failed banks (and the implication that these executives are corrupt or incompetent).

SaulR80683 writes:
Okay, so BOFI insiders were connected to two banks involved in the biggest scandals and bankruptcies in California… But that could just be coincidence. It doesn’t prove anything.

Going back to the Seeking Alpha article written by Aurelius, he states that BofI is led “by a senior management team that has collectively been involved in two of California’s largest bank failures,” the implication being that the entire team is tainted. Two executives at BofI, Durrans and Swanson, were with IndyMac. However, Durrans left IndyBank in 2005, three years before the IndyMac failure.

Garrabrants was with Imperial Capital Bank, another bank that failed; please note though that Imperial failed in 2009, a full two years after Garrabrants left to join BofI, being appointed President and CEO of BofI Federal Bank in 2007.

Bottom line: let’s call these half-truths and innuendos. Durrans and Garrabrants did work for banks that failed but left them long before their failures; only Swanson was employed at a failing bank during the time of its bankruptcy.

Oh, and if you’re thinking bank scandals and failures have been few and far between… think again. There were 140 bank failures in 2009, including 22 in California (all listed below). Scroll down (warning, very scrolly) and you’ll also see a list of the 157 bank failures in 2010.

I’ll wager that most of the executives who worked for these failed banks (and actually were working at them when they failed) are still working in the banking industry today (but that’s a different argument).

2009
December


First Federal Bank of California, F.S.B., Santa Monica, CA with 
approximately $6.1 billion in assets and approximately $4.5 billion in 
deposits was closed. OneWest Bank, Pasadena, CA has agreed to assume all 
deposits. (PR-239-2009)

Imperial Capital Bank, La Jolla, CA with approximately $4.0 billion in 
assets and approximately $2.8 billion in deposits was closed. City 
National Bank, Los Angeles, CA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-238-2009)

Independent Bankers' Bank, Springfield, IL, with approximately $585.5 
million in assets and $511.5 million in deposits was closed. The FDIC 
created a bridge bank, Independent Bankers' Bank Bridge Bank (IBB Bridge 
Bank, N.A.), to take over operations. (PR-237-2009)

New South Federal Savings Bank, Irondale, AL with approximately $1.5 
billion in assets and approximately $1.2 billion in deposits was closed. 
Beal Bank, Plano, TX has agreed to assume all deposits. (PR-236-2009)

Citizens State Bank, New Baltimore, MI, with approximately $168.6 
million in assets and $157.1 million in deposits was closed. Deposit 
Insurance National Bank of New Baltimore, New Baltimore, MI has agreed 
to assume insured deposits. (PR-235-2009)

Peoples First Community Bank, Panama City, FL with approximately $1.8 
billion in assets and approximately $1.7 billion in deposits was closed. 
Hancock Bank, Gulfport, MS has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-234-2009)

RockBridge Commercial Bank, Atlanta, GA, with approximately $294.0 
million in assets and approximately $291.7 million in deposits was 
approved for payout by the FDIC Board of Directors. (PR-233-2009)

SolutionsBank, Overland Park, KS with approximately $511.1 million in 
assets and approximately $421.3 million in deposits was closed. Arvest 
Bank, Fayetteville, AR has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-227-2009)

Valley Capital Bank, National Association, Mesa, AZ with approximately 
$40.3 million in assets and approximately $41.3 million in deposits was 
closed. Enterprise Bank & Trust, Clayton, MO has agreed to assume all 
deposits. (PR-226-2009)

Republic Federal Bank, National Association, Miami, FL with 
approximately $433.0 million in assets and approximately $352.7 million 
in deposits was closed. 1st United Bank, Boca Raton, FL has agreed to 
assume all deposits, excluding certain brokered deposits. (PR-225-2009)

Greater Atlantic Bank, Reston, VA with approximately $203.0 million in 
assets and approximately $179.0 million in deposits was closed. 
Sonabank, McLean, VA has agreed to assume all deposits. (PR-224-2009)

Benchmark Bank, Aurora, IL with approximately $170.0 million in assets 
and approximately $181.0 million in deposits was closed. MB Financial 
Bank, N.A., Chicago, IL has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-223-2009)

AmTrust Bank, Cleveland, OH with approximately $12.0 billion in assets 
and approximately $8.0 billion in deposits was closed. New York 
Community Bank, Westbury, NY has agreed to assume all deposits. (PR-222-
2009)

The Tattnall Bank, Reidsville, GA with approximately $49.6 million in 
assets and approximately $47.3 million in deposits was closed. 
HeritageBank of the South, Albany, GA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-221-2009)

First Security National Bank, Norcross, GA with approximately $128.0 
million in assets and approximately $123.0 million in deposits was 
closed. State Bank and Trust Company, Macon, GA has agreed to assume all 
deposits, excluding certain brokered deposits. (PR-220-2009)

The Buckhead Community Bank, Atlanta, GA with approximately $874.0 
million in assets and approximately $838.0 million in deposits was 
closed. State Bank and Trust Company, Macon, GA has agreed to assume all 
deposits, excluding certain brokered deposits. (PR-219-2009)

November

Commerce Bank of Southwest Florida, Fort Myers, FL with approximately 
$79.7 million in assets and approximately $76.7 million in deposits was 
closed. Central Bank, Stillwater, MN has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-211-2009)

Pacific Coast National Bank, San Clemente, CA with approximately $134.4 
million in assets and approximately $130.9 million in deposits was 
closed. Sunwest Bank, Tustin, CA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-207-2009)

Orion Bank, Naples, FL with approximately $2.7 billion in assets and 
approximately $2.1 billion in deposits was closed. IBERIABANK, 
Lafayette, LA has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-206-2009)

Century Bank, a Federal Savings Bank, Sarasota, FL with approximately 
$728 million in assets and approximately $631 million in deposits was 
closed. IBERIABANK, Lafayette, LA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-205-2009)

United Commercial Bank, San Francisco, CA with approximately $11.2 
billion in assets and approximately $7.5 billion in deposits was closed. 
East West Bank, Pasadena, CA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-201-2009)

Gateway Bank of St. Louis, St. Louis, MO with approximately $27.7 
million in assets and approximately $27.9 million in deposits was 
closed. Central Bank of Kansas City, Kansas City, MO has agreed to 
assume all deposits. (PR-200-2009)

Prosperan Bank, Oakdale, MN with approximately $199.5 million in assets 
and approximately $175.6 million in deposits was closed. Alerus 
Financial, National Association, Grand Forks, ND has agreed to assume 
all deposits, excluding certain brokered deposits. (PR-199-2009)

Home Federal Savings Bank, Detroit, MI,  with approximately $14.9 
million in assets and approximately $12.8 million in deposits was 
closed. Liberty Bank and Trust Company, New Orleans, LA has agreed to 
assume all deposits. (PR-198-2009)

United Security Bank, Sparta, GA with approximately $157 million in 
assets and approximately $150 million in deposits was closed. Ameris 
Bank, Moultrie, GA has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-197-2009)

October

North Houston Bank, Houston, TX,  with approximately $326.2 million in 
assets and approximately $308.0 million in deposits was closed. U.S. 
Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

Madisonville State Bank, Madisonville, TX,  with approximately $256.7 
million in assets and approximately $225.2 million in deposits was 
closed. U.S. Bank National Association, Minneapolis, MN has agreed to 
assume all deposits. (PR-195-2009)

Citizens National Bank, Teague, TX,  with approximately $118.2 million 
in assets and approximately $97.7 million in deposits was closed. U.S. 
Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

Park National Bank, Chicago, IL,  with approximately $4.7 billion in 
assets and approximately $3.7 billion in deposits was closed. U.S. Bank 
National Association, Minneapolis, MN has agreed to assume all deposits. 
(PR-195-2009)

Pacific National Bank, San Francisco, CA,  with approximately $2.3 
billion in assets and approximately $1.8 billion in deposits was closed. 
U.S. Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

California National Bank, Los Angeles, CA,  with approximately $7.8 
billion in assets and approximately $6.2 billion in deposits was closed. 
U.S. Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

San Diego National Bank, San Diego, CA,  with approximately $3.6 billion 
in assets and approximately $2.9 billion in deposits was closed. U.S. 
Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

Community Bank of Lemont, Lemont, IL,  with approximately $81.8 million 
in assets and approximately $81.2 million in deposits was closed. U.S. 
Bank National Association, Minneapolis, MN has agreed to assume all 
deposits. (PR-195-2009)

Bank USA, National Association, Phoenix, AZ,  with approximately $212.8 
million in assets and approximately $117.1 million in deposits was 
closed. U.S. Bank National Association, Minneapolis, MN has agreed to 
assume all deposits. (PR-195-2009)

First DuPage Bank, Westmont, IL with approximately $279 million in 
assets and approximately $254 million in deposits was closed. First 
Midwest Bank, Itasca, IL has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-192-2009)

Riverview Community Bank, Otsego, MN,  with approximately $108 million 
in assets and approximately $80 million in deposits was closed. Central 
Bank, Stillwater, MN has agreed to assume all deposits. (PR-191-2009)

Bank of Elmwood, Racine, WI with approximately $327.4 million in assets 
and approximately $273.2 million in deposits was closed. Tri City 
National Bank, Oak Creek, WI has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-190-2009)

Flagship National Bank, Bradenton, FL with approximately $190 million in 
assets and approximately $175 million in deposits was closed. First 
Federal Bank of Florida, Lake City, FL has agreed to assume all 
deposits. (PR-189-2009)

Hillcrest Bank Florida, Naples, FL with approximately $83 million in 
assets and approximately $84 million in deposits was closed. Stonegate 
Bank, Fort Lauderdale, FL has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-188-2009)

American United Bank, Lawrenceville, GA with approximately $111 million 
in assets and approximately $101 million in deposits was closed. Ameris 
Bank, Moultrie, GA has agreed to assume all deposits. (PR-187-2009)

Partners Bank, Naples, FL with approximately $65.5 million in assets and 
approximately $64.9 million in deposits was closed. Stonegate Bank, Fort 
Lauderdale, FL has agreed to assume all deposits. (PR-186-2009)

San Joaquin Bank, Bakersfield, CA with approximately $775 million in 
assets and approximately $631 million in deposits was closed. Citizens 
Business Bank, Ontario, CA has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-185-2009)

Southern Colorado National Bank, Pueblo, CO with approximately $39.5 
million in assets and approximately $31.9 million in deposits was 
closed. Legacy Bank, Wiley, CO has agreed to assume all deposits. (PR-
181-2009)

Jennings State Bank, Spring Grove, MN with approximately $56.3 million 
in assets and approximately $52.4 million in deposits was closed. 
Central Bank, Stillwater, MN has agreed to assume all deposits. (PR-180-
2009)

Warren Bank, Warren, MI with approximately $538 million in assets and 
approximately $501 million in deposits was closed. The Huntington 
National Bank, Columbus, OH has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-179-2009)

September

Georgian Bank, Atlanta, GA with approximately $2 billion in assets and 
approximately $2 billion in deposits was closed. First Citizens Bank and 
Trust Company, Inc., Columbia, SC has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-177-2009)

Irwin Union Bank, F.S.B., Louisville, KY with approximately $493 million 
in assets and approximately $441 million in deposits was closed. First 
Financial Bank, N.A., Hamilton, OH has agreed to assume all deposits. 
(PR-174-2009)

Irwin Union Bank and Trust Company, Columbus, IN with approximately $2.7 
billion in assets and approximately $2.1 billion in deposits was closed. 
First Financial Bank, N.A., Hamilton, OH has agreed to assume all 
deposits. (PR-174-2009)

Venture Bank, Lacey, WA with approximately $970 million in assets and 
approximately $903 million in deposits was closed. First-Citizens Bank & 
Trust Company, Raleigh, NC has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-170-2009)

Brickwell Community Bank, Woodbury, MN with approximately $72 million in 
assets and approximately $63 million in deposits was closed. CorTrust 
Bank N.A. Mitchell, SD has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-169-2009)

Corus Bank, N.A., Chicago, IL with approximately $7 billion in assets 
and approximately $7 billion in deposits was closed. MB Financial Bank, 
N.A., Chicago, IL has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-168-2009)

First State Bank, Flagstaff, AZ with approximately $105 million in 
assets and approximately $95 million in deposits was closed. Sunwest 
Bank, Tustin, CA has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-165-2009)

Platinum Community Bank, Rolling Meadows, IL, with approximately $345.6 
million in assets and approximately $305.0 million in deposits was 
approved for payout by the FDIC Board of Directors. (PR-164-2009)

Vantus Bank, Sioux City, IA with approximately $458 million in assets 
and approximately $368 million in deposits was closed. Great Southern 
Bank, Springfield, MO has agreed to assume all deposits. (PR-163-2009)

InBank, Oak Forest, IL with approximately $212 million in assets and 
approximately $199 million in deposits was closed. MB Financial Bank, 
National Association, Chicago, IL has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-162-2009)

First Bank of Kansas City, Kansas City, MO with approximately $16 
million in assets and approximately $15 million in deposits was closed. 
Great American Bank, De Soto, KS has agreed to assume all deposits. (PR-
161-2009) 

August

Affinity Bank, Ventura, CA with approximately $1 billion in assets and 
approximately $922 million in deposits was closed. Pacific Western Bank, 
San Diego, CA has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-157-2009)

Mainstreet Bank, Forest Lake, MN with approximately $459 million in 
assets and approximately $434 million in deposits was closed. Central 
Bank, Stillwater, MN has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-156-2009)

Bradford Bank, Baltimore, MD with approximately $452 million in assets 
and approximately $383 million in deposits was closed. Manufacturers and 
Traders Trust Company, Buffalo, NY has agreed to assume all deposits. 
(PR-155-2009)

Guaranty Bank, Austin, TX with approximately $13 billion in assets and 
approximately $12 billion in deposits was closed. BBVA Compass, 
Birmingham, AL has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-150-2009)

CapitalSouth Bank, Birmingham, AL with approximately $617 million in 
assets and approximately $546 million in deposits was closed. 
IBERIABANK, Lafayette, LA has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-149-2009)

First Coweta Bank, Newnan, GA, with approximately $167 million in assets 
and approximately $155 million in deposits was closed. United Bank, 
Zebulon, GA, has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-148-2009)

ebank, Atlanta, Georgia, with approximately $143 million in assets and 
approximately $130 million in deposits was closed. Stearns Bank, 
National Association, St. Cloud, MN, has agreed to assume all deposits. 
(PR-147-2009)

Community Bank of Nevada, Las Vegas, Nevada, with approximately $1.52 
billion in assets and approximately $1.38 billion in deposits was 
closed. The FDIC has created the Deposit Insurance National Bank of Las 
Vegas, NV ("DINB of Las Vegas") to facilitate the resolution of 
Community Bank of Nevada, Las Vegas, NV. (PR-146-2009)

Community Bank of Arizona, Phoenix, Arizona, with approximately $158.5 
million in total assets, was closed. MidFirst Bank, Oklahoma City, OK, 
has agreed to assume all deposits, excluding certain brokered deposits 
(approximately $143.8 million).	(PR-145-2009)

Union Bank, N.A., Gilbert, Arizona, with approximately $124 million in 
assets and approximately $112 in deposits was closed. MidFirst Bank, 
Oklahoma City, OK, has agreed to assume all non-brokered deposits. (PR-
144-2009)

Colonial Bank, Montgomery, Alabama, with approximately $25 billion in 
assets, was closed. Branch Banking and Trust Company (BB&T),	Winston-
Salem, NC, has agreed to assume all deposits (approximately $20 
billion). (PR-143-2009)

Dwelling House Savings and Loan Association, Pittsburgh, Pennsylvania, 
with approximately $13.4 million in assets, was closed. PNC Bank,	
Pittsburgh, PA, has agreed to assume all deposits (approximately $13.8 
million). (PR-142-2009)

Community First Bank, Prineville, Oregon, with approximately $209 
million in total assets, was closed. Home Federal Bank, Nampa, ID, has 
agreed to assume all deposits, excluding certain brokered deposits 
(approximately $182 million).	(PR-141-2009)

Community National Bank of Sarasota County, Venice, Florida, with 
approximately $97 million in assets, was closed. Stearns Bank,	
N.A.,St. Cloud, MN, has agreed to assume all deposits (approximately $93 
million). (PR-140-2009)

First State Bank, Sarasota, Florida, with approximately $463 million in 
assets, was closed. Stearns Bank, N.A., St. Cloud, MN, has agreed to 
assume all deposits, excluding certain brokered deposits (approximately 
$387 million). (PR-139-2009)

July

Mutual Bank, Harvey, Illinois, with approximately $1.6 billion in 
assets, was closed. United Central Bank, Garland, Texas, has agreed to 
assume all deposits (approximately $1.6 billion). (PR-137-2009)

First BankAmericano, Elizabeth, New Jersey, with approximately $166 
million in assets, was closed. Crown Bank, Brick, New Jersey, has agreed 
to assume all deposits (approximately $157 million). (PR-136-2009)

Peoples Community Bank, West Chester, Ohio, with approximately $705.8 
million in assets, was closed. First Financial Bank, N.A., Hamilton, 
Ohio, has agreed to assume all deposits, excluding certain brokered 
deposits (approximately $598.2 million). (PR-135-2009)

Integrity Bank, Jupiter, Florida, with approximately $119 million in 
assets, was closed. Stonegate Bank, Fort Lauderdale, Florida, has agreed 
to assume all deposits, excluding certain brokered deposits 
(approximately $102 million). (PR-134-2009)

First State Bank of Altus, Altus, Oklahoma, with approximately $103.4 
million in assets, was closed. Herring Bank, Amarillo, Texas, has agreed 
to assume all deposits (approximately $98.2 million). (PR-133-2009)

Security Bank of Gwinnett County, Suwanee, GA; Security Bank of North 
Fulton, Alpharetta, GA; Security Bank of North Metro, Woodstock, GA; 
Security Bank of Bibb County, Macon, GA; Security Bank of Houston 
County, Perry, GA; and Security Bank of Jones County, Gray, GA, with 
approximately $2.8 billion in combined assets, were closed. State Bank 
and Trust Company, Pinehurst, Georgia, has agreed to assume all deposits 
(approximately $2.4 billion). (PR-130-2009)

Waterford Village Bank, Williamsville, New York, with approximately 
$61.4 million in assets, was closed. Evans Bank, National Association, 
Angola, New York, has agreed to assume all deposits (approximately $58 
million). (PR-129-2009)

Temecula Valley Bank, Temecula, California, with approximately $1.5 
billion in assets, was closed. First-Citizens Bank & Trust Company, 
Raleigh, North Carolina, has agreed to assume all deposits, excluding 
certain brokered deposits (approximately $1.3 billion). (PR-126-2009)

Vineyard Bank, N.A., Rancho Cucamonga, California, with approximately 
$1.9 billion in assets, was closed. California Bank & Trust, San Diego, 
California, has agreed to assume all deposits, excluding certain 
brokered deposits (approximately $1.6 billion). (PR-125-2009)

BankFirst, Sioux Falls, South Dakota, with approximately $275 million in 
assets, was closed. Alerus Financial, National Association, Grand Forks, 
North Dakota, has agreed to assume all deposits (approximately $254 
million). (PR-124-2009)

First Piedmont Bank, Winder, Georgia, with approximately $115 million in 
assets, was closed. First American Bank and Trust Company, Athens, 
Georgia, has agreed to assume all deposits (approximately $109 million). 
(PR-123-2009)

Bank of Wyoming, Thermopolis, Wyoming, with approximately $70 million in 
assets, was closed. Central Bank & Trust, Lander, Wyoming, has agreed to 
assume all deposits, excluding certain brokered deposits (approximately 
$67 million). (PR-122-2009)

Founders Bank, Worth, Illinois, with approximately $962.5 million in 
assets, was closed. The PrivateBank and Trust Company, Chicago, 
Illinois, has agreed to assume all deposits (approximately $848.9 
million). (PR-119-2009)

Millennium State Bank of Texas, Dallas, Texas, with approximately $118 
million in assets, was closed. State Bank of Texas, Irving, Texas, has 
agreed to assume all deposits (approximately $115 million). (PR-118-
2009)

The First National Bank of Danville, Danville, Illinois, with 
approximately $166 million in assets, was closed. First Financial Bank, 
N.A., Terre Haute, Indiana, has agreed to assume all deposits 
(approximately $147 million). (PR-117-2009)

The Elizabeth State Bank, Elizabeth, Illinois, with approximately $55.5 
million in assets, was closed. Galena State Bank and Trust Company, 
Galena, Illinois, has agreed to assume all deposits (approximately $50.4 
million). (PR-116-2009)

Rock River Bank, Oregon, Illinois, with approximately $77 million in 
assets, was closed. The Harvard State Bank, Harvard, Illinois, has 
agreed to assume all deposits (approximately $75.8 million). (PR-115-
2009)

The First State Bank of Winchester, Winchester, Illinois, with 
approximately $36 million in assets, was closed. The First National Bank 
of Beardstown, Beardstown, Illinois, has agreed to assume all deposits 
(approximately $34 million). (PR-114-2009)

The John Warner Bank, Clinton, Illinois, with approximately $70 million 
in assets, was closed. State Bank of Lincoln, Lincoln, Illinois, has 
agreed to assume all deposits (approximately $64 million). (PR-113-2009)

June

Mirae Bank, Los Angeles, California, with approximately $456 million in 
assets, was closed. Wilshire State Bank, Los Angeles, California, has 
agreed to assume all deposits (approximately $362 million). (PR-105-
2009)

MetroPacific Bank, Irvine, California, with approximately $80 million in 
assets, was closed. Sunwest Bank, Tustin, California, has agreed to 
assume all non-brokered deposits (approximately $73 million). (PR-104-
2009)

Horizon Bank, Pine City, Minnesota, with approximately $87.6 million in 
assets, was closed. Stearns Bank N.A., St. Cloud, Minnesota, has agreed 
to assume all deposits, excluding certain brokered deposits 
(approximately $69.4 million). (PR-103-2009)

Neighbor Community Bank, Newnan, Georgia, with approximately $221.6 
million in assets, was closed. CharterBank, West Point, Georgia, has 
agreed to assume all deposits (approximately $191.3 million). (PR-102-
2009)

Community Bank of West Georgia, Villa Rica, Georgia, with approximately 
$199.4 million in assets and approximately $182.5 million in deposits 
was approved for payout by the FDIC Board of Directors. (PR-101-2009)

First National Bank of Anthony, Anthony, Kansas, with approximately 
$156.9 million in assets, was closed. Bank of Kansas, South Hutchinson, 
Kansas, has agreed to assume all deposits (approximately $142.5 
million). (PR-96-2009)

Cooperative Bank, Wilmington, North Carolina, with approximately $970 
million in assets, was closed. First Bank, Troy, North Carolina, has 
agreed to assume all deposits, excluding certain brokered deposits 
(approximately $774 million). (PR-95-2009)

Southern Community Bank, Fayetteville, Georgia, with approximately $377 
million in assets, was closed. United Community Bank, Blairsville, 
Georgia, has agreed to assume all deposits (approximately $307 million). 
(PR-94-2009)

Bank of Lincolnwood, Lincolnwood, Illinois, with approximately $214 
million in assets, was closed. Republic Bank of Chicago, Oak Brook, 
Illinois, has agreed to assume all deposits (approximately $202 
million).
(PR-86-2009)

May

Citizens National Bank, Macomb, Illinois, with approximately $437 
million in assets, was closed. Morton Community Bank, Morton, Illinois, 
has agreed to assume all non-brokered deposits (approximately $400 
million). (PR-76-2009)

Strategic Capital Bank, Champaign, Illinois, with approximately $537 
million in assets, was closed. Midland States Bank, Effingham, Illinois, 
has agreed to assume all deposits (approximately $471 million).
(PR-75-2009)

BankUnited, FSB, Coral Gables, Florida, with approximately $12.8 billion 
in assets, was closed. BankUnited, Coral Gables, Florida, has agreed to 
assume all deposits (approximately $8.6 billion).
(PR-72-2009)

Westsound Bank, Bremerton, Washington, with approximately $334.6 million 
in assets and $304.5 million in deposits, was closed. Kitsap Bank, Port 
Orchard, Washington, has agreed to assume all non-brokered deposits. 
(PR-69-2009)

America West Bank, Layton, Utah, with approximately $299.4 million in 
assets, was closed. Cache Valley Bank, Logan, Utah, has agreed to assume 
all deposits (approximately $284.1 million).
(PR-63-2009)

Citizens Community Bank, Ridgewood, New Jersey, with approximately $45.1 
million in assets, was closed. North Jersey Community Bank, Englewood 
Cliffs, New Jersey, has agreed to assume all deposits (approximately 
$43.7 million). (PR-62-2009)

Silverton Bank, N.A., Atlanta, Georgia, with approximately $4.1 billion 
in assets and $3.3 billion in deposits was closed. The FDIC created a 
bridge bank, Silverton Bridge Bank, N.A., to take over operations. (PR-
61-2009)

April

First Bank of Idaho, Ketchum, Idaho, with approximately $488.9 million 
in assets, was closed. U.S. Bank, National Association, Minneapolis, MN, 
has agreed to assume all non-brokered deposits (approximately $374 
million). (PR-60-2009)

First Bank of Beverly Hills, Calabasas, California, with approximately 
$1.5 billion in assets and approximately $1 billion in deposits was 
approved for payout by the FDIC Board of Directors. (PR-59-2009)

Michigan Heritage Bank, Farmington Hills, Michigan, with approximately 
$184.6 million in assets, was closed. Level One Bank, Farmington Hills, 
Michigan, has agreed to assume all deposits (approximately $151.7 
million). (PR-58-2009)

American Southern Bank, Kennesaw, Georgia, with approximately $112.3 
million in assets and approximately $104.3 in deposits was closed. Bank 
of North Georgia, Alpharetta, Georgia, has agreed to assume all non-
brokered deposits. (PR-57-2009)

Great Basin Bank of Nevada, Elko, Nevada, with approximately $270.9 
million in assets, was closed. Nevada State Bank, Las Vegas, Nevada, has 
agreed to assume all deposits (approximately $241.4 million). (PR-55-
2009)

American Sterling Bank, Sugar Creek, Missouri, with approximately $181 
million in assets was closed. Metcalf Bank, Lee's Summit, Missouri, has 
agreed to assume all deposits (approximately $171.9 million).  (PR-54-
2009)

New Frontier Bank, Greeley, Colorado, with approximately $2.0 billion in 
assets and approximately $1.5 billion in deposits was closed. Deposit 
Insurance National Bank of Greeley, Greeley, Colorado has agreed to 
assume the non-brokered insured deposits. (PR-53-2009)

Cape Fear Bank, Wilmington, North Carolina, with approximately $492 
million in assets, was closed. First Federal Savings and Loan 
Association, Charleston, South Carolina, has agreed to assume all 
deposits, excluding certain brokered deposits (approximately $403 
million). (PR-52-2009)

March

Omni National Bank, Atlanta, Georgia, with approximately $956.0 million 
in assets and approximately $796.8 million in deposits was closed. 
SunTrust Bank, Atlanta, Georgia has agreed to assume the non-brokered 
insured deposits. (PR-50-2009)

TeamBank, National Association, Paola, Kansas, with approximately $669.8 
million in assets, was closed. Great Southern Bank, Springfield, 
Missouri, has agreed to assume all deposits (approximately $492.8 
million). (PR-46-2009)

Colorado National Bank, Colorado Springs, Colorado, with approximately 
$123.5 million in assets, was closed. Herring Bank, Amarillo, Texas has 
agreed to assume all deposits (approximately $82.7 million). (PR-45-
2009)

FirstCity Bank, Stockbridge, Georgia, with approximately $297.0 million 
in assets and approximately $278.0 million in deposits was approved for 
payout by the FDIC Board of Directors. (PR-44-2009)

Freedom Bank of Georgia, Commerce, Georgia, with approximately $173.0 
million in assets and approximately $161.0 million in deposits, was 
closed. Northeast Georgia Bank, Lavonia, Georgia has agreed to assume 
all deposits. (PR-37-2009)

February

Security Savings Bank, Henderson, Nevada, with approximately $238.3 
million in assets, was closed. Bank of Nevada, Las Vegas, NV has agreed 
to assume all non-brokered deposits (approximately $175.2 million). (PR-
32-2009)

Heritage Community Bank, Glenwood, Illinois, with approximately $232.9 
million in assets, was closed. The MB Financial Bank, National 
Association, Chicago, Illinois has agreed to assume all deposits 
(approximately $218.6 million). (PR-31-2009)

Silver Falls Bank, Silverton, Oregon, with approximately $131.4 million 
in assets was closed. Citizens Bank, Corvallis, Oregon has agreed to 
assume all deposits (approximately $116.3 million). (PR-24-2009)

Pinnacle Bank of Oregon, Beaverton, Oregon, with approximately $73.0 
million in assets was closed. Washington Trust Bank, Spokane, Washington 
has agreed to assume all deposits (approximately $64.0 million). (PR-23-
2009)

Corn Belt Bank and Trust Company, Pittsfield, Illinois, with 
approximately $271.8 million in assets and approximately $234.4 million 
in deposits, was closed. The Carlinville National Bank, Carlinville, 
Illinois has agreed to assume all non-brokered deposits. (PR-22-2009)

Riverside Bank of the Gulf Coast, Cape Coral, Florida, with 
approximately $539.0 million in assets and approximately $424.0 million 
in deposits, was closed. TIB Bank, Naples, Florida has agreed to assume 
all non-brokered deposits. (PR-21-2009)

Sherman County Bank, Loup City, Nebraska, with approximately $129.8 
million in assets was closed. Heritage Bank, Wood River, Nebraska has 
agreed to assume all deposits (approximately $85.1 million). (PR-20-
2009) 

County Bank, Merced, California, with approximately $1.7 billion in 
assets was closed. Westamerica Bank, San Rafael, California has agreed 
to assume all deposits (approximately $1.3 billion). (PR-19-2009)

Alliance Bank, Culver City, California, with approximately $1.14 billion 
in assets and approximately $951.0 million in deposits was closed. 
California Bank & Trust, San Diego, California has agreed to assume all 
deposits. (PR-18-2009)

FirstBank Financial Services, McDonough, Georgia, with approximately 
$337.0 million in assets was closed. Regions Bank, Birmingham, Alabama 
has agreed to assume all deposits (approximately $279.0 million). (PR-
17-2009)

January

Ocala National Bank, Ocala, Florida, with approximately $223.5 million 
in assets and approximately $205.2 million in deposits, was closed. 
CenterState Bank of Florida, Winter Haven, Florida has agreed to assume 
all non-brokered deposits. (PR-14-2009)

Suburban Federal Savings Bank, Crofton, Maryland, with approximately 
$360.0 million in assets was closed. Bank of Essex, Tappahannock, 
Virginia has agreed to assume all deposits (approximately $302.0 
million). (PR-13-2009)

MagnetBank, Salt Lake City, Utah, with approximately $292.2 million in 
assets and approximately $282.8 million in deposits was approved for 
payout by the FDIC Board of Directors. (PR-12-2009)

1st Centennial Bank, Redlands, California, with approximately $803.3 
million in assets and approximately $676.9 million in deposits was 
closed. First California Bank, Westlake Village, California has agreed 
to assume the non-brokered insured deposits. (PR-7-2009)

Bank of Clark County, Vancouver, Washington, with approximately $446.5 
million in assets and approximately $366.5 million in deposits was 
closed. Umpqua Bank, Roseburg, Oregon has agreed to assume the non-
brokered insured deposits. (PR-6-2009)

National Bank of Commerce, Berkeley, Illinois, with approximately $430.9 
million in total assets and $402.1 million in total deposits, was 
closed. In addition to assuming all of the failed bank's deposits, 
Republic Bank of Chicago, Oak Brook, Illinois agreed to pay a discount 
of $44.9 million, and will purchase approximately $366.6 million of 
assets. The FDIC will retain the remaining assets for later disposition. 
(PR-5-2009)

2010
December

Community National Bank, Lino Lakes, MN with approximately $31.6 million 
in total assets and $28.8 million in total deposits was closed. Farmers 
& Merchants Savings Bank, Manchester, IA, has agreed to assume all 
deposits. 
(PR-276-2010).

First Southern Bank, Batesville, AR with approximately $191.8 million in 
total assets and $155.8 million in total deposits was closed. Southern 
Bank, Poplar Bluff, MO has agreed to assume all deposits excluding 
certain brokered deposits. 
(PR-275-2010).

United Americas Bank, N.A., Atlanta, GA with approximately $242.3 
million in total assets and $193.8 million in total deposits was closed. 
State Bank and Trust Company, Macon, GA has agreed to assume all 
deposits excluding certain brokered deposits. 
(PR-274-2010).

Appalachian Community Bank, FSB, McCaysville, GA with approximately 
$68.2 million in total assets and $76.4 million in total deposits was 
closed. Peoples Bank of East Tennessee, Madisonville, TN has agreed to 
assume all deposits excluding certain brokered deposits. 
(PR-273-2010).

Chestatee State Bank, Dawsonville, GA with approximately $244.4 million 
in total assets and $240.5 million in total deposits was closed. Bank of 
the Ozarks, Little Rock, AR has agreed to assume all deposits. 
(PR-272-2010).

The Bank of Miami, National Association (N.A.), Coral Gables, FL with 
approximately $448.2 million in total assets and $374.2 million in total 
deposits was closed. 1st United Bank, Boca Raton, FL has agreed to 
assume all deposits excluding certain brokered deposits. 
(PR-271-2010).

Earthstar Bank, Southampton, PA with approximately $112.6 million in 
total assets and $104.5 million in total deposits was closed. Polonia 
Bank, Huntingdon Valley, PA has agreed to assume all deposits. 
(PR-264-2010).

Paramount Bank, Farmington Hills, MI with approximately $252.7 million 
in total assets and $213.6 million in total deposits was closed. Level 
One Bank, Farmington Hills, MI has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-263-2010).

November

First Banking Center, Burlington, WI with approximately $750.7 million 
in total assets and $664.8 million in total deposits was closed. First 
Michigan Bank, Troy, MI has agreed to assume all deposits excluding 
certain brokered deposits. 
(PR-255-2010).

Allegiance Bank of North America, Bala Cynwyd, PA with approximately 
$106.6 million in total assets and $92.0 million in total deposits was 
closed. VIST Bank, Wyomissing, PA has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-254-2010).

Gulf State Community Bank, Carrabelle, FL with approximately $112.1 
million in total assets and $112.2 million in total deposits was closed. 
Centennial Bank, Conway, AR has agreed to assume all deposits excluding 
certain brokered deposits. 
(PR-253-2010).

Copper Star Bank, Scottsdale, AZ with approximately $204.0 million in 
total assets and $190.2 million in total deposits was closed. Stearns 
Bank, N.A., Saint Cloud, MN has agreed to assume all deposits excluding 
certain brokered deposits. 
(PR-250-2010).

Darby Bank & Trust Co., Vidalia, GA with approximately $654.7 million in 
total assets and $587.6 million in total deposits was closed. Ameris 
Bank, Moultrie, GA has agreed to assume all deposits excluding excluding 
certain brokered deposits. 
(PR-249-2010).

Tifton Banking Company, Tifton, GA with approximately $143.7 million in 
total assets and $141.6 million in total deposits was closed. Ameris 
Bank, Moultrie, GA has agreed to assume all deposits including certain 
brokered deposits. 
(PR-249-2010).

First Vietnamese American Bank, Westminster, CA with approximately $48.0 
million in total assets and $47.0 million in total deposits was closed. 
Grandpoint Bank, Los Angeles, CA has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-245-2010).

Pierce Commercial Bank, Tacoma, WA with approximately $221.1 million in 
total assets and $193.5 million in total deposits was closed. Heritage 
Bank, Olympia, WA has agreed to assume all deposits. 
(PR-244-2010).

Western Commercial Bank, Woodland Hills, CA with approximately $98.6 
million in total assets and $101.1 million in total deposits was closed. 
First California Bank, Westlake Village, CA has agreed to assume all 
deposits. 
(PR-243-2010).

K Bank, Randallstown, MD with approximately $538.3 million in total 
assets and $500.1 million in total deposits was closed. Manufacturers 
and Traders Trust Company, Buffalo, NY has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-242-2010).

October

First Arizona Savings, A FSB, Scottsdale, AZ with approximately $272.2 
million in total assets and $198.8 million in total deposits was closed. 
The FDIC has approved the payout of the insured deposits of First 
Arizona Savings, A FSB. 
(PR-237-2010).

Hillcrest Bank, Overland Park, KS with approximately $1.65 billion in 
total assets and $1.54 billion in total deposits was closed. Hillcrest 
Bank, N.A., Overland Park, KS has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-236-2010).

First Suburban National Bank, Maywood, IL with approximately $148.7 
million in total assets and $140.0 million in total deposits was closed. 
Seaway Bank and Trust Company, Chicago, IL has agreed to assume all 
deposits excluding certain brokered deposits. 
(PR-235-2010).

The First National Bank of Barnesville, Barnesville, GA with 
approximately $131.4 million in total assets and $127.1 million in total 
deposits was closed. United Bank, Zebulon, GA has agreed to assume all 
deposits excluding certain brokered deposits. 
(PR-234-2010).

The Gordon Bank, Gordon, GA with approximately $29.4 million in total 
assets and $26.7 million in total deposits was closed. Morris Bank, 
Dublin, GA has agreed to assume all deposits. 
(PR-233-2010).

Progress Bank of Florida, Tampa, FL with approximately $110.7 million in 
total assets and $101.3 million in total deposits was closed. Bay Cities 
Bank, Tampa, FL has agreed to assume all deposits excluding certain 
brokered deposits. 
(PR-232-2010).

First Bank of Jacksonville, Jacksonville, FL with approximately $81.0 
million in total assets and $77.3 million in total deposits was closed. 
Ameris Bank, Moultrie, GA has agreed to assume all deposits. 
(PR-231-2010).

Premier Bank, Jefferson City, MO with approximately $1.18 billion in 
total assets and $1.03 billion in total deposits was closed. Providence 
Bank, Columbia, MO has agreed to assume all deposits excluding certain 
brokered deposits. 
(PR-228-2010).

WestBridge Bank and Trust Company, Chesterfield, MO with approximately 
$91.5 million in total assets and $72.5 in total deposits was closed. 
Midland States Bank, Effingham, IL has agreed to assume all deposits 
excluding certain brokered deposits. 
(PR-227-2010).

Security Savings Bank, F.S.B, Olathe, KS with approximately $508.4 
million in total assets and $397.0 million in total deposits was closed. 
Simmons First National Bank, Pine Bluff, AR has agreed to assume all 
deposits. 
(PR-226-2010).

Shoreline Bank, Shoreline, WA with approximately $104.2 million in total 
assets and $100.2 million in total deposits was closed. GBC 
International Bank, Los Angeles, CA has agreed to assume all deposits 
excluding certain brokered deposits.
(PR-221-2010).

Wakulla Bank, Crawfordville, FL with approximately $424.1 million in 
total assets and $386.3 million in total deposits was closed. Centennial 
Bank, Conway, AR has agreed to assume all deposits excluding certain 
brokered deposits.
(PR-220-2010).

September

North County Bank, Arlington, WA with approximately $288.8 million total 
assets and $276.1 million in total deposits was closed. Whidbey Island 
Bank, Cupeville, WA has agreed to assume all deposits excluding certain 
brokered deposits.
(PR-215-2010).

Haven Trust Bank Florida, Ponte Vedra Beach, FL with approximately 
$148.6 million total assets and $133.6 million in total deposits was 
closed. First Southern Bank, Boca Raton, FL has agreed to assume all 
deposits excluding certain brokered deposits.
(PR-214-2010).

Maritime Savings Bank, West Allis, WI with approximately $350.5 million 
total assets and $248.1 million in total deposits was closed. North 
Shore Bank, FSB, Brookfield, WI has agreed to assume all deposits 
excluding certain brokered deposits.
(PR-210-2010).

Bramble Savings Bank, Milford, OH with approximately $47.5 million total 
assets and $41.6 million in total deposits was closed. Foundation Bank, 
Cincinnati, OH has agreed to assume all deposits excluding certain 
brokered deposits.
(PR-209-2010).

The Peoples Bank, Winder, GA with approximately $447.2 million total 
assets and $398.2 million in total deposits was closed. Community & 
Southern Bank, Carrollton, GA has agreed to assume all deposits 
excluding certain brokered deposits.
(PR-208-2010).

First Commerce Community Bank, Douglasville, GA with approximately 
$248.2 million total assets and $242.8 million in total deposits was 
closed. Community & Southern Bank, Carrollton, GA has agreed to assume 
all deposits excluding certain brokered deposits.
(PR-208-2010).

Bank of Ellijay, Ellijay, GA with approximately $168.8 million total 
assets and $160.7 million in total deposits was closed. Community & 
Southern Bank, Carrollton, GA has agreed to assume all deposits. 
(PR-208-2010).

ISN Bank, Cherry Hill, NJ with approximately $81.6 million total assets 
and $79.7 million in total deposits was closed. New Century Bank, 
Phoenixville, PA has agreed to assume all deposits excluding certain 
brokered deposits.
(PR-207-2010).

Horizon Bank, Bradenton, FL with approximately $187.8 million total 
assets and $164.6 million in total deposits was closed. Bank of the 
Ozarks, Little Rock, AR has agreed to assume all deposits excluding 
certain brokered deposits.
(PR-205-2010).

August

Sonoma Valley Bank, Sonoma, CA with approximately $337.1 million in 
total assets and $255.5 million in total deposits was closed. 
Westamerica Bank, San Rafael, CA has agreed to assume all deposits.
(PR-196-2010).

Los Padres Bank, Solvang, CA with approximately $870.4 million in total 
assets and $770.7 million in total deposits was closed. Pacific Western 
Bank, San Diego, CA has agreed to assume all deposits.
(PR-195-2010).

Butte Community Bank, Chico, CA with approximately $498.8 million in 
total assets and $471.3 million in total deposits was closed. Rabobank, 
National Association (N.A.), El Centro, CA has agreed to assume all 
deposits.
(PR-194-2010).

Pacific State Bank, Stockton, CA with approximately $312.1 million in 
total assets and $278.8 million in total deposits was closed. Rabobank, 
National Association (N.A.), El Centro, CA has agreed to assume all 
deposits, excluding certain brokered deposits.
(PR-194-2010).

ShoreBank, Chicago, IL with approximately $2.16 billion in total assets 
and $1.54 billion in total deposits was closed. Urban Partnership Bank, 
Chicago, IL has agreed to assume all deposits, excluding certain 
brokered deposits.
(PR-193-2010).

Imperial Savings and Loan Association, Martinsville, VA with 
approximately $9.4 million in total assets and $10.1 million in total 
deposits was closed. River Community Bank, National Association (N.A), 
Martinsville, VA has agreed to assume all deposits.
(PR-192-2010).

Independent National Bank, Ocala, FL with approximately $156.2 million 
in total assets and $141.9 million in total deposits was closed. 
CenterState Bank of Florida, National Association (N.A.), Winter Haven, 
FL has agreed to assume all deposits.
(PR-191-2010).

Community National Bank at Bartow, Bartow, FL with approximately $67.9 
million in total assets and $63.7 million in total deposits was closed. 
CenterState Bank of Florida, National Association (N.A.), Winter Haven, 
FL has agreed to assume all deposits, excluding certain brokered 
deposits.
(PR-191-2010).

Palos Bank and Trust Company, Palos Heights, IL with approximately 
$493.4 million in total assets and $467.8 million in total deposits was 
closed. First Midwest Bank, Itasca, IL has agreed to assume all 
deposits.
(PR-189-2010).

Ravenswood Bank, Chicago, IL, with approximately $264.6 million in total 
assets and $269.5 million in total deposits was closed. Northbrook Bank 
and Trust Company, Northbrook, IL has agreed to assume all deposits, 
excluding certain brokered deposits.
(PR-181-2010).

July

LibertyBank, Eugene, OR with approximately $768.2 million in total 
assets and $718.5 million in total deposits was closed. Home Federal 
Bank, Nampa, ID has agreed to assume all deposits.
(PR-176-2010).

The Cowlitz Bank, Longview, WA, with approximately $529.3 million in 
total assets and $513.9 million in total deposits was closed. Heritage 
Bank, Olympia, WA has agreed to assume all deposits, excluding certain 
brokered deposits.
(PR-175-2010).

Coastal Community Bank, Panama City Beach, FL with approximately $372.9 
million in total assets and $363.2 million in total deposits was closed. 
Centennial Bank, Conway, AR has agreed to assume all deposits
(PR-174-2010).

Bayside Savings Bank, Port Saint Joe, FL with approximately $66.1 
million in total assets and $52.4 million in total deposits was closed. 
Centennial Bank, Conway, AR has agreed to assume all deposits
(PR-174-2010).

Northwest Bank & Trust, Acworth, GA, with approximately $167.7 million 
in total assets and $159.4 million in total deposits was closed. State 
Bank and Trust Company, Macon Georgia, has agreed to assume all 
deposits, excluding certain brokered deposits.
(PR-172-2010).

Home Valley Bank, Cave Junction, OR with approximately $251.80 million 
in total assets and $229.6 million in total deposits was closed. South 
Valley Bank & Trust, Klamath Falls, OR has agreed to assume all deposits
(PR-169-2010).

SouthwestUSA Bank, Las Vegas, NV with approximately $214.0 million in 
total assets and $186.7 million in total deposits was closed. Plaza 
Bank, Irvine, CA has agreed to assume all deposits, excluding certain 
brokered deposits
(PR-168-2010).

Community Security Bank, New Prague, MN with approximately $108.0 
million in total assets and $99.7 million in total deposits was closed. 
Roundbank, Waseca, MN has agreed to assume all deposits
(PR-167-2010).

Thunder Bank, Sylvan Grove, KS with approximately $32.6 million in total 
assets and $28.5 million in total deposits was closed. The Bennington 
State Bank, Salina, KS has agreed to assume all deposits, excluding 
certain brokered deposits
(PR-166-2010).

Williamsburg First National Bank, Kingstree, SC with approximately 
$139.3 million in total assets and $134.3 million in total deposits was 
closed. First Citizens Bank and Trust Company, Inc., Columbia, SC has 
agreed to assume all deposits, excluding certain brokered deposits
(PR-165-2010).

Crescent Bank and Trust Company, Jasper, GA with approximately $1.01 
billion in total assets and $965.7 million in total deposits was closed. 
The Renasant Bank, Tupelo, MS has agreed to assume all deposits, 
excluding certain brokered deposits
(PR-164-2010).

Sterling Bank, Lantana, FL with approximately $407.9 million in total 
assets and $372.4 million in total deposits was closed. IBERIABANK, 
Lafayette, LA has agreed to assume all deposits, excluding certain 
brokered deposits
(PR-163-2010).

Mainstreet Savings Bank, FSB, Hastings, MI with approximately $97.4 
million in total assets and $63.7 million in total deposits was closed. 
Commercial Bank, Alma, MI has agreed to assume all deposits
(PR-159-2010).

Olde Cypress Community Bank, Clewiston, FL with approximately $168.7 
million in total assets and $162.4 million in total deposits was closed. 
CenterState Bank of Florida, National Association, Winter Haven, FL has 
agreed to assume all deposits, excluding certain brokered deposits.
(PR-158-2010).

Turnberry Bank, Aventura, FL with approximately $263.9 million in total 
assets and $196.9 million in total deposits was closed. NAFH National 
Bank, Miami, FL has agreed to assume all deposits
(PR-157-2010).

Metro Bank of Dade County, Miami, FL with approximately $442.3 million 
in total assets and $391.3 million in total deposits was closed. NAFH 
National Bank, Miami, FL has agreed to assume all deposits, excluding 
certain brokered deposits.
(PR-157-2010).

First National Bank of the South, Spartanburg, SC with approximately 
$682.0 million in total assets and $610.1 million in total deposits was 
closed. NAFH National Bank, Miami, FL has agreed to assume all deposits, 
excluding certain brokered deposits.
(PR-157-2010).

Woodlands Bank, Bluffton, SC with approximately $376.2 million in total 
assets and $355.3 million in total deposits was closed. Bank of the 
Ozarks, Little Rock, AR has agreed to assume all deposits, excluding 
certain brokered deposits.
(PR-156-2010).

Home National Bank, Blackwell, OK with approximately $644.5 million in 
total assets and $560.7 million in total deposits was closed. RCB Bank, 
Claremore, OK has agreed to assume all deposits ( PR-152-2010).

USA Bank, Port Chester, NY with approximately $193.3 million in total 
assets and $189.9 million in total deposits. The FDIC entered into a 
purchase and assumption agreement with New Century Bank (doing business 
as Customer’s 1st Bank), Phoenixville, PA, to assume all of the deposits 
of USA Bank. (PR-151-2010).

Ideal Federal Savings Bank, Baltimore, MD with approximately $6.3 
million in total assets and $5.8 million in total deposits was closed. 
The FDIC has approved the payout of the insured deposits of Ideal 
Federal Savings Bank. (PR-150-2010).

Bay National Bank, Baltimore, MD with approximately $282.2 million in 
total assets and $276.1 million in total deposits was closed. To protect 
the depositors, the FDIC entered into a purchase and assumption 
agreement with Bay Bank, FSB, Lutherville, MD, to assume all of the 
deposits of Bay National Bank. ( PR-149-2010).

June

High Desert State Bank, Albuquerque, NM with approximately $80.3 million 
in assets and approximately $81.0 million in deposits was closed. First 
American Bank, Artesia, NM, GA has agreed to assume all deposits (PR-
145-2010).

First National Bank, Savannah, GA with approximately $252.5 million in 
assets and approximately $231.9 million in deposits was closed. The 
Savannah Bank, National Association, Savannah, GA has agreed to assume 
all deposits, excluding certain brokered deposits (PR-144-2010)

Peninsula Bank, Englewood, FL with approximately $644.3 million in 
assets and approximately $580.1 million in deposits was closed. Premier 
American Bank, Miami, FL has agreed to assume all deposits excluding 
certain brokered deposits. ( PR-143-2010)

Nevada Security Bank, Reno, Nevada (also known as Silverado Bank, 
Roseville, CA), with approximately $480.3 million in assets and 
approximately $479.8 million in deposits was closed. Umpqua Bank, 
Roseburg, OR has agreed to assume all deposits, excluding certain 
brokered deposits. ( PR-137-2010)

Washington First International Bank, Seattle, WA with approximately 
$520.9 million in assets and approximately $441.4 million in deposits 
was closed. East West Bank, Pasadena, CA has agreed to assume all 
deposits. (PR-133-2010)

TierOne Bank, Lincoln, NE with approximately $2.8 billion in assets and 
approximately $2.1 billion in deposits was closed. Great Western Bank, 
Sioux Falls, SD has agreed to assume all deposits. ( PR-132-2010)

Arcola Homestead Savings Bank, Arcola, IL with approximately $17.0 
million in assets and approximately $18.1 million in deposits was 
approved for payout by the FDIC Board of Directors. (PR-131-2010)

First National Bank, Rosedale, MS with approximately $60.4 million in 
assets and approximately $63.5 million in deposits was closed. Jefferson 
Bank, Fayette, MS has agreed to assume all deposits. (PR-130-2010)

May

Sun West Bank, Las Vegas, NV with approximately $360.7 million in assets 
and approximately $353.9 million in deposits was closed. City National 
Bank, Los Angeles, CA has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-127-2010)

Granite Community Bank, NA, Granite Bay, CA with approximately $102.9 
million in assets and approximately $94.2 million in deposits was 
closed. Tri Counties Bank, Chico, CA has agreed to assume all deposits. 
(PR-126-2010)

Bank of Florida - Tampa Bay, Tampa, FL with approximately $245.2 million 
in assets and approximately $224.0 million in deposits was closed. 
EverBank, Jacksonville, FL has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-125-2010)

Bank of Florida - Southwest, Naples, FL with approximately $640.9 
million in assets and approximately $559.9 million in deposits was 
closed. EverBank, Jacksonville, FL has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-125-2010)

Bank of Florida - Southeast, Fort Lauderdale, FL with approximately 
$595.3 million in assets and approximately $531.7 million in deposits 
was closed. EverBank, Jacksonville, FL has agreed to assume all 
deposits, excluding certain brokered deposits. (PR-125-2010)

Pinehurst Bank, St. Paul, MN with approximately $61.2 million in assets 
and approximately $58.3 million in deposits was closed. Coulee Bank, La 
Crosse, WI has agreed to assume all deposits. (PR-118-2010)

Midwest Bank and Trust Company, Elmwood Park, IL with approximately 
$3.17 billion in assets and approximately $2.42 billion in deposits was 
closed. FirstMerit Bank, National Association, Akron, OH has agreed to 
assume all deposits. (PR-116-2010)

Southwest Community Bank, Springfield, MO with approximately $96.6 
million in assets and approximately $102.5 million in deposits was 
closed. Simmons First National Bank, Pine Bluff, AR has agreed to assume 
all deposits. (PR-115-2010)

New Liberty Bank, Plymouth, MI with approximately $109.1 million in 
assets and approximately $101.8 million in deposits was closed. Bank of 
Ann Arbor, Ann Arbor, MI has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-114-2010)
Satilla Community Bank, Saint Marys, GA with approximately $135.7 
million in assets and approximately $134.0 million in deposits was 
closed. Ameris Bank, Moulteri, GA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-113-2010)

1st Pacific Bank of California, San Diego, CA with approximately $335.8 
million in assets and approximately $291.2 in deposits was closed. City 
National Bank, Los Angeles, CA has agreed to assume all deposits, 
excluding certain brokered deposits. (PR-109-2010)

Towne Bank of Arizona, Mesa, AZ with approximately $120.2 million in 
assets and approximately $113.2 million in deposits was closed. Commerce 
Bank of Arizona, Mesa, AZ has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-108-2010)

Access Bank, Champlin, MN with approximately $32.0 million in assets and 
approximately $32.0 million in deposits was closed. PrinsBank, 
Prinsburg, MN has agreed to assume all deposits. (PR-107-2010)

The Bank of Bonifay, Bonifay, FL with approximately $242.9 million in 
assets and approximately $230.2 million in deposits was closed. First 
Federal Bank of Florida, Lake City, FL has agreed to assume all 
deposits. (PR-106-2010)

April

Frontier Bank, Everett, WA with approximately $3.50 billion in assets 
and approximately $3.13 billion in deposits was closed. Union Bank, 
National Association, San Francisco, CA has agreed to assume all 
deposits, excluding certain brokered deposits. (PR-101-2010)

BC National Banks, Butler, MO with approximately $67.2 million in assets 
and approximately $54.9 million in deposits was closed. Community First 
Bank, Butler, MO has agreed to assume all deposits. (PR-100-2010)

Champion Bank, Creve Coeur, MO with approximately $187.3 million in 
assets and approximately $153.8 million in deposits was closed. 
BankLiberty, Liberty, PR has agreed to assume all deposits, excluding 
certain brokered deposits. (PR-099-2010)

CF Bancorp, Port Huron, MI with approximately $1.65 billion in assets 
and approximately $1.43 billion in deposits was closed. First Michigan 
Bank, Troy, MI has agreed to assume all deposits, excluding certain 
brokered deposits. (PR-098-2010)

W

NewEchota · November 24, 2015, 6:10pm

To bring you up to date, this is a continuation of the review of the laundry list of “red flags” waived about investing in Bank of the Internet (BofI) that was posted and highlighted as “Post of the Day” this past weekend. My aim is to review what was written, analyze each bullet point to determine which ones are true, false, misleading, or perhaps irrelevant. Again, if you’re uninterested in BofI or tired of these posts, please click Ignore Thread or skip this post. And I promise not to bore you with anymore until after the holiday.

Next up, is BofI skirting regulations and acting illegally?

SaulR80683 writes:
Okay, so they are helping this shady company evade banking laws by opening loans for them and selling them the loan after 24 hours…

I believe Saul is conflating an accusation (BofI is helping an unlicensed lender evade regulations by acting as a front for their loan activities) and a common marketing pitch of “hard money” lenders (24-hour turnaround on loans).

Let’s turn to the Seeking Alpha article by Aurelius to see: he claims that one of BofI’s customers, the “apparently unlicensed Center Street” Lending, “specializes in highly suspect, single family ‘fix and flip’ loans requiring ‘no doc’, ‘no FICO’, and ‘no income verification’.

False and false.

First, remember that Center Street Lending is a customer of BofI and Aurelius is trying to make you believe that anything bad he has to say about Center Street Lending applies to BofI as well. Innuendo.

And Aurelius is wrong: Center Street Lending is licensed in California.

Here’s its Mortgage Loan Origination license: http://www2.dre.ca.gov/PublicASP/pplinfo.asp?License_id=0188…

If you’ll scroll to the bottom and look to the left of the linked document, you’ll read in the comments section the words NO DISCIPLINARY ACTION.

And while you’re at it, click on the link to the right of MLO License Endorsement: 905781 (Click here to check the status of the MLO License Endorsement.) and you’ll go to the NMLS Consumer Access database where you can examine additional details about Center Street Lending, including, at the bottom of the page, any Regulatory Actions taken against Center Street Lending. What you’ll see is this: No regulatory actions have been posted in NMLS.

Now, let’s explore its risky,”highly suspect, single family ‘fix and flip’ loans.”

Here are the Underwriting Guidelines from the Center Street Lending web site:

Loan to Value (“LTV”):
The maximum loan to value is 65% of the as repaired value of the property.

Minimum Down Payment:
Borrowers are required to contribute a minimum of 20% - 30% equity for each loan. This must be in the form of cash consideration, not “created” equity.

Personal Guarantee:
Personal guaranties are required for all loans for the entire loan amount. If a borrower is an entity then a personal guarantee is required by the entity owner(s). If the borrower is an individual, then the guarantor cannot be a spouse.

Interest Impound:
Borrowers are required to deposit up to two months of interest payments at loan closing that are held in case of a loan default to be applied to the borrower’s account at Center Street Lending’s discretion. In the event that the borrower complies with all of the terms and conditions of the loan, the interest impound is credited to the borrower at full loan payoff.

While we’re at it, let’s address Aurelius’ allegation that Center Street Lending “provides credit lines as well as construction loans for ‘investors who plan to build homes on vacant land’" (implying the vacant land or commercial loans are collateral). Well, wrong again.


Prohibited Collateral:
     **Vacant land**
     Multi-family rental properties over 4 units
     Mobile homes
     **Commercial properties**
     Construction loans
     Partially constructed properties with significant unfinished work

Bottom line time: Center Street Lending is licensed, has no enforcement actions lodged in the California Enforcement Actions and Orders database (see here: http://www.dbo.ca.gov/ENF/Default.asp), limits LTV to 65%, requires a minimum of 20% - 30% equity for each loan in cash, personal guaranties are required for all loans for the entire loan amount, and borrowers are required to deposit up to two months of interest payments at loan closing that are held in case of a loan default.