Alliance Partners Llc

Allegations: THE FDIC AND OFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN (I) UNSAFE AND UNSOUND BANKING PRACTICES RELATING TO, AMONG OTHER THINGS, DEFICIENCIES AND WEAKNESSES IN THE SUPERVISION AND DIRECTION OF MANAGEMENT BY THE BANK'S BOARD OF DIRECTORS; MANAGEMENT PERFORMANCE; RISK MANAGEMENT; CAPITAL PLANNING; LIQUIDITY AND FUNDS MANAGEMENT; AND INTEREST RATE RISK; (II) VIOLATIONS OF LAW OR REGULATIONS, INCLUDING SECTION 22(H) OF THE FEDERAL RESERVE ACT AS IMPLEMENTED BY 12 C.F.R. § 215, AND MARYLAND ANNOTATED CODE, FINANCIAL INSTITUTIONS ARTICLE 2 § 3-403(B); AND (III) NONCONFORMANCE WITH THE INTERAGENCY GUIDELINES ESTABLISHING STANDARDS FOR SAFETY AND SOUNDNESS, APPENDIX A TO 12 C.F.R. PART 364 WITH RESPECT TO THE BANK'S INTERNAL CONTROLS AND INFORMATION SYSTEMS, AND INTEREST RATE EXPOSURE. Status: Final Sanction Detail: FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMMEDIATELY INCREASE, COMMENSURATED WITH THE SIZE OF THE BANK AND THE NATURE, SCOPE, COMPLEXITY, AND RISK OF BANK ACTIVITIES, ITS SUPERVISION AND DIRECTION OF BANK MANAGEMENT, AND ITS OVERSIGHT AND MONITORING OF THE BANK'S FINANCIAL CONDITION, RISK PROFILE, OPERATIONS; (B) ENSURE THAT THE BANK'S FUNDS MANAGEMENT PROGRAM, RELATED POLICIES & PROCEDURES, AND THE LIQUIDITY ANALYSIS IS REVISED TO ADEQUATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (C) REVISE ITS CAPITAL PLANNING AND MONITORING FRAMEWORK AND SUBMIT IT TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (D) ENSURE IT ADDRESSES THE DEFICIENCIES AND WEAKNESSES RELATED TO INTEREST RATE RISK MANAGEMENT; (E) ENSURE THAT THE BANK DOES NOT DECLARE OR PAY ANY CASH DIVIDENDS OR OTHER CAPITAL DISTRIBUTIONS WITHOUT THE PRIOR NON-OBJECTION OF THE DRD AND THE COMMISSIONER; (F) ENSURE THAT THE BANK'S TOTAL ASSETS, DO NOT INCREASE BY MORE THAN 5% DURING ANY CALENDAR QUARTER AND DO NOT INCREASE BY MORE THAN 10% ANNUALLY; (G) SUBMIT A WRITTEN PLAN DETAILING HOW THE BOARD WILL ENSURE THE REQUIREMENTS OF THIS ORDER ARE MET IN A TIMELY MANNER TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (H) TO FURNISH WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER TO THE DRD AND THE COMMISSIONER; (I) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY. Summary: ON MAY 3, 2024 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.

Allegations: THE FDIC AND OCFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES OR VIOLATIONS OF LAW OR REGULATION RELATING TO, AMONG OTHER THINGS, TO DEFICIENCIES AND WEAKNESSES IN THE BANK'S ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM PROGRAMS. Status: Final Sanction Detail: FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMPROVE, CONSISTENT WITH THE ROLE AND EXPERTISE EXPECTED FOR DIRECTORS OF BANKS OF COMPARABLE SIZE AND RISK, ITS SUPERVISION AND DIRECTION OF THE AML/CFT PROGRAM; (B) ENSURE THAT THE AML/CFT PROGRAM IS REASONABLY DESIGNED TO ASSURE AND MONITOR THE BANK'S COMPLIANCE WITH THE BSA AND PROVIDE CLEAR AND UP-TO-DATE GUIDANCE TO BANK STAFF; (C) SUBMIT A PROPOSED ENGAGEMENT LETTER OR CONTRACT FOR REVIEW AND NON-OBJECTION TO RETAIN A QUALIFIED FIRM ACCEPTABLE TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER TO CONDUCT A REVIEW OF ALL ACCOUNTS AND TRANSACTION ACTIVITY FOR THE SPECIFIED TIME PERIOD; (D) ENSURE THAT THE BANK COMPLIES WITH THE REQUIREMENTS OF THE LAWS AND REGULATIONS ADMINISTERED BY THE OFFICE OF FOREIGN ASSETS CONTROL AND THAT THE PROGRAM ESTABLISHED BY THE BANK ENABLES THE BANK TO COMPLY WITH THE OFAC REQUIREMENTS; (E) ESTABLISH A BOARD AML/CFT COMPLIANCE COMMITTEE WITH THE RESPONSIBILITY OF OVERSEEING THE BANK'S COMPLIANCE WITH THIS ORDER, THE BSA, AND THE AML/CFT PROGRAM; (F) ENSURE THAT ALL STEPS NECESSARY, CONSISTENT WITH OTHER PROVISIONS OF THIS ORDER AND SOUND BANKING PRACTICES, ARE TAKEN TO ELIMINATE AND CORRECT ANY VIOLATIONS OF LAW OR REGULATION CITED AND APPROPRIATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (G) FURNISH TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER; (H) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY. Summary: ON DECEMBER 14, 2022 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.