Responding to Capital Directives and Related Enforcement Actions

Pillsbury Winthrop Shaw Pittman LLP
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This discussion is being provided to our clients and friends to analyze the challenges presented in this difficult economic environment when an FDIC insured institution experiences a capital difficulty and is directed by the Banking Regulators to restore the institution's capital adequacy. In the past four years, the FDIC has closed approximately 400 insured institutions—as of January 1, 2012, the FDIC has indicated that there were over 800 banks on its "problem bank list." The difficulties experienced by many of these institutions are summarized in this analysis— and may provide useful guidance when attempting to resolve capital issues in the next few years.

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