Is There a New Three Strikes Rule for Some California Banks?

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Community bankers did not design or market subprime mortgages nor did they devise or promote credit default swaps. Community bankers did make many loans to longtime customers whose businesses, employees and communities have been hurt by a historic economic downturn that few foresaw, resulting, in many cases, in dramatic losses in loan portfolio values. The ensuing examination and enforcement spiral seems to leave many community banks with few growth options and all too often a demoralizing message from their regulators: Raise capital or face failure.

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