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REGULATORY MATTERS AND SETTLEMENT OF OTS ENFORCEMENT ACTIONS | 3 Months Ended
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Dec. 31, 2014
REGULATORY MATTERS AND SETTLEMENT OF OTS ENFORCEMENT ACTIONS [Abstract] |
REGULATORY MATTERS AND SETTLEMENT OF OTS ENFORCEMENT ACTIONS |
NOTE 13. | REGULATORY MATTERS AND SETTLEMENT OF OTS ENFORCEMENT ACTIONS
As previously disclosed in our Annual Report on Form 10-K, on July 21, 2011, pursuant to the Dodd Frank Act, the OTS was integrated into the OCC and the functions of the OTS related to thrift holding companies were transferred to the Federal Reserve. The OCC is responsible for the ongoing examination, supervision and regulation of the Bank. The Dodd Frank Act maintains the existence of the federal savings association charter and the HOLA, the primary statute governing federal savings banks. The Federal Reserve is now responsible for the ongoing examination, supervision and regulation of the Company, including matters with respect to the Consent Order against the Company. Prior to passage of the Dodd-Frank Act, the OTS had issued supervisory directives to the Bank, consent orders to the Bank and the Company, and had taken other regulatory action to require the Bank to reimburse certain consumers in connection with a credit program that was discontinued. All supervisory directives have been terminated, and on August 7, 2014 the OCC terminated the Bank’s Consent Order. The Consent Order against the Company is still in effect, although management believes its effect on the Company’s financial condition and results of operations has been and will continue to be immaterial. The Company anticipates (but cannot guarantee) that the order will be terminated in the second calendar quarter of 2015. On January 5, 2015, the Federal Deposit Insurance Corporation (“FDIC”) published industry guidance (the “Guidance”) in the form of Frequently Asked Questions with respect to the categorization of deposit liabilities as "brokered" deposits. Following the Company's review of the Guidance, it has determined, effective for the quarter ended December 31, 2014, to treat $1.3 billion, or 72% of its deposit liabilities, as brokered deposits. Due to the Bank’s status as a "well-capitalized" institution under the FDIC's prompt corrective action regulations, and further with respect to the Bank’s financial condition in general, the Company does not at this time anticipate that the Guidance will have an adverse impact on the Company’s liquidity, statements of financial condition, or results of operations going forward. However, should the Bank ever fail to be well-capitalized in the future, as a result of failing to meet the well-capitalized requirements, or the imposition of an individual minimum capital requirement or similar formal requirements, then, notwithstanding that the Bank has capital in excess of the well-capitalized minimum requirements, the Bank would be prohibited, absent waiver from the FDIC, from utilizing brokered deposits (i.e., may not accept, renew or rollover brokered deposits) which could produce serious adverse effects on the Company’s liquidity, and financial condition and results of operations.

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