[Congressional Record (Bound Edition), Volume 145 (1999), Part 20]
[House]
[Pages 29860-29863]
[From the U.S. Government Publishing Office, www.gpo.gov]




               FAILURE OF FIRST NATIONAL BANK OF KEYSTONE

  The SPEAKER pro tempore (Mr. Tancredo). Under a previous order of the 
House, the gentleman from Iowa (Mr. Leach) is recognized for 5 minutes.
  Mr. LEACH. Mr. Speaker, I rise to speak on the last day of the 
session about the introduction of a small bill related to what some 
might argue is a small event involving the loss by the Federal 
Government of an amount of money that would be considered gargantuan in 
every respect except its relative size to the United States Government 
budget.
  Given all the budget decisions involving issues like Medicare, 
defense spending, and U.N. funding, this Congress should be aware that 
three-quarters of $1 billion has just become obligated outside the 
budget process because of regulatory laxness related to the failure of 
one rural bank, the First National Bank of Keystone, West Virginia.
  The facts revealed to date suggest that this failure may cost the 
Bank Insurance Fund far more than the Federal Deposit Insurance 
Corporation estimated the fund would lose from all bank failures this 
year. Indeed, the expected loss is so high that it could make Keystone 
not only one of the 10 most expensive bank failures ever, but also one 
of the most spectacular for any institution of any size with losses 
approaching an astounding 70 percent of the bank's assets.
  The public first learned of the failure of First National Bank of 
Keystone September 1, 1999, when the Office of the Comptroller of the 
Currency (OCC) announced it was closing the bank and appointing the 
FDIC as receiver. Bank examiners had discovered that loans on the 
bank's books totaling $515 million were missing--items that represented 
roughly half the bank's $1.1 billion in total reported assets. Other 
overstated assets, questionable accounting practices, and credit 
quality problems push the total expected losses toward the 750 million 
dollar mark. The picture that is emerging is of an institution which, 
in recent years, reported high profits at the same time management 
pursued dubious investment strategies and, ultimately, mischievous 
techniques to hide massive losses from the scrutiny of examiners.
  It will take some time for criminal investigators and Federal bank 
regulators to unravel the full story of this bank failure, but it is 
not too early to ask if Federal regulators properly supervise the 
institution and prudentially stewarded the deposit insurance fund which 
back-stops risks in the banking system. For 5 or 6 years, red flag 
practices should have alerted regulators that the high-risk asset 
management strategies employed by Keystone were hardly of the kind 
expected in a rural institution situated in a West Virginia town of 627 
residents and warranted vigilant supervisory measures.
  From 1992 to 1998, Keystone increased its assets tenfold to over $1 
billion as it offered depositors up to 2 percentage points more in 
interest than competitor institutions. Rather than expanding small 
business and agricultural loans in its West Virginia market area, 
Keystone engaged in a high-risk strategy of buying, securitizing, and 
selling

[[Page 29861]]

subprime loans made to and by people the bank hardly knew. Management 
practices were reminiscent of those witnessed during the S&L crisis of 
the 1980s. Rapid asset growth, risky investment activity, and the 
practice of paying hyper-competitive interest rates were augmented by 
legal and administrative tactics designed to thwart regulatory 
oversight.
  A combination of lax management and weak supervision by the bank's 
board were conducive to the imprudent and allegedly fraudulent 
activities that have been uncovered. Over the past several years, the 
OCC made futile attempts to curb Keystone's go-go activities with 
various enforcement actions and civil money penalties; but, in 
hindsight, the measures were too weak and too late. The OCC pushed for 
management changes, but the bank's board resisted. Several experienced 
officers were hired in 1999; however, the board gave them the cold 
shoulder and they quickly resigned. In May of 1999, an external 
accountant, Grant Thornton, conducted an independent audit as required 
by the OCC, and issued an unqualified opinion of the bank's 1998 
financial statements. The firm detected no fraud. Just a few months 
later, however, federal examiners found that a half-billion dollars 
were missing from the bank's claimed assets.
  The delay in uncovering the losses apparently occurred in part 
because bank management engaged in a sustained pattern of obfuscation. 
Another tactic of Keystone management was not unlike that employed 15 
years earlier by Charles Keating. One of the hallmarks of the Keating 
tenure to the S&L called Lincoln was the hiring of many high-powered 
attorneys to represent his interests. When challenged, Keating and his 
people had a habit of threatening regulators and the United States 
Government with lawsuits.
  In Keating-esque fashion, Keystone went so far as to hire a former 
Comptroller of the Currency to contest the OCC's supervisory 
activities. In an escalated twist, examiners on bank premises were so 
harassed and felt so threatened that the OCC had to request United 
States marshals to protect them when they were going over bank records.
  In addition to similarities with respect to the 1980's go-go 
activities of S&Ls that cost American taxpayers approximately $140 
billion, the Keystone case adds new elements. The profile of 
questionable bank leadership is no longer simply the smooth-talking 
male huckster, but it would now appear that Keystone's cops, Federal 
banking authorities, were taken in by a scam perpetrated by an 
institution headed by a grandmother.
  With the threats to examiners and recent discovery that three 
truckloads of bank documents were buried on the property of a senior 
bank official, indictments have been issued for obstruction of a 
Federal examination, an unusual legal precept which some may find 
humorous; others, chilling.
  Keystone's failure has not only revealed costly inadequacies at the 
field supervisory level, but also flaws in interagency cooperation in 
Washington.
  For this reason, I have today introduced H.R. 3324, a bill designed 
to bolster the independence of the Federal Deposit Insurance 
Corporation.
  By background, state chartered banks are regulated primarily by state 
banking agencies with the Federal Reserve serving as the primary 
federal regulator for state members. National banks are regulated by 
the OCC, and holding companies of all banks are regulated by the 
Federal Reserve. Analogously, state agencies regulate state chartered 
savings and loans, and the Office of Thrift Supervision (OTS) serves as 
the federal thrift regulator. The FDIC is a back-up regulator for all 
federally-insured institutions (banks and S&Ls) because it is 
responsible for stewardship of the deposit insurance system. It is also 
the primary federal regulator for state chartered banks which are not 
members of the Federal Reserve system. In order to avoid, to the 
maximum extent possible, duplicative regulation, the regulators are 
expected to cooperate and coordinate their examination activities. On 
the whole, this cooperation works, well, in part because America's 
banking system is so strong. But just as there is private sector 
competition for profits, there can at times be public sector 
competition for power, in this case, regulatory jurisdiction.
  From a Congressional perspective, the Keystone failure is worrisome 
because it appears that the FDIC was stymied at key points in its 
desire to conduct reviews of the bank's activities. The regulators--the 
OCC and the FDIC--failed to cooperate closely. Although satisfactory 
communication among the FDIC, the OCC, and other federal regulators in 
routine cases appears to be the norm, the Keystone case reveals some 
potentially serious flaws in the federal oversight system.
  The tension between the OCC and the FDIC over Keystone was 
particularly evident in the period leading up to the 1998 examination 
of the bank. Instead of welcoming FDIC expertise and assistance in 
analyzing the increasingly complex operations of the bank, the OCC 
initially denied the FDIC's request to participate in a bank 
examination. The OCC says its decision was based in part largely on 
concerns that the inclusion of additional FDIC examiners might 
exacerbate the increasingly difficult environment for the examiners at 
the bank and heighten management's resistance to examiners' requests 
for information.
  Retired examiners, like old soldiers and athletes, sometimes have a 
tendency to exaggerate reminiscences. In a discussion about Keystone, 
one opined to me the other day that the old rule was if a bank ever 
displayed reluctance in cooperating with examiners, a swat team of 
accountants should immediately be brought in, and if intransigence 
continued, the bank should immediately be closed. This perspective may 
be callously insensitive to law and to a system where agencies because 
of their extraordinary authority have an obligation to act with great 
caution. But one truth is self-evident: bank intransigence is a reason 
for more, not fewer, examiners.
  In this regard, it is noteworthy that the OCC itself has acknowledged 
that by September of 1997 it considered Keystone's extensive problems 
required a ``significant amount of examiner expertise.'' For it then to 
suggest that its objection to having FDIC professionals join the OCC in 
examinations of Keystone related less to turf concerns, than to 
apprehension that feathers would be ruffled at the bank, is profoundly 
indefensible.
  Concerned that Keystone posed a serious risk to the insurance fund, 
FDIC staff decided to elevate their request to take part in the 1998 
examination to the full FDIC board, of which the Comptroller is one of 
five statutory members. In the end, they chose not to present the case 
to the board because, after a lengthy delay, the OCC eventually 
acquiesced to limited FDIC participation. But what has become apparent 
in extensive discussions with FDIC and OCC staff is clear resistance on 
the OCC's part to FDIC review of banks in certain difficult situations 
and of some timidity of FDIC staff to challenge Treasury Department 
hegemony.
  Although the OCC reversed its original position just one week before 
the June 30, 1998, FDIC board meeting at which this issue was to be 
discussed, it would appear that the OCC's reluctance to involve the 
FDIC in the examination and other important meetings may have 
contributed to a lesser FDIC involvement than was warranted. For 
example, in February of 1998, the FDIC asked for three examiner slots 
for the upcoming 1998 examination, but the OCC agreed, in the week 
before the June Board meeting, to allow only one. Although the OCC 
later agreed to permit two FDIC examiners, its basis for wanting to 
limit FDIC involvement is not clear. Less than a year later, after 
Keystone's condition had further deteriorated, the OCC agreed to allow 
seven FDIC examiners to participate in the 1999 examination. It was 
during that examination that the stunning losses were uncovered.
  The turf battle over the number of examiners reflected the 
substantive disagreements the two agencies had over the bank's 
operations. The FDIC in 1998 questioned the valuation of the residual 
assets on Keystone's books and the potential loss exposure of the 
bank's subprime lending activities. In particular, the FDIC believed 
that Keystone's valuation of its residual assets, which comprised over 
200 percent of keystone's capital, was not supported. After the OCC 
agreed to limited FDIC participation in the 1998 examination, the FDIC 
contends that its examiners were to remain on site until all questions 
about the bank's accounting and recordkeeping were answered. The OCC, 
however, completed the on-site portion of the examination in 15 
workdays without obtaining sufficient support for the residual 
valuation and without completing the reconcilement of balance sheet 
accounts, leaving FDIC examiners with no resolution to this critical 
concern. When the bank's accountant finally provided the missing 
information to the OCC at a meeting in January 1999, the FDIC reports 
that it was neither invited nor even informed of the meeting--this 
despite the fact that the FDIC had specifically asked to be kept fully 
informed as insurer and backup supervisor on issues relating to 
Keystone. Similarly, the OCC did not invite the FDIC to an

[[Page 29862]]

April 1999 meeting with the developers of the bank's residual valuation 
model, which was a primary FDIC concern because it was central to 
determining the risk to the Bank Insurance Fund.
  The bureaucratic turf battle over Keystone disturbingly reveals flaws 
in the current system. While the FDIC, to the maximum extent possible, 
should coordinate examinations with other regulators, it has long been 
the assumption of legislators that the FDIC could, at its discretion, 
fully participate in examinations with other regulators or conduct 
special examinations of any federally-insured institution without delay 
or interference whenever it identified a risk of loss to the insurance 
fund. The Keystone incident shows the FDIC to be coerced, not by the 
regulated, but by its fellow regulators, who have a shared 
accountability with the FDIC to the American taxpayer.
  The FDIC has a unique role in our financial system and it must be 
insulated from regulatory turf battles and political considerations. It 
is instrumental in maintaining the safety and soundness of the banking 
industry, and is responsible for safeguarding the deposits of customers 
of all insured financial institutions. Implicitly, the FDIC also has a 
role in assuring competitive equity. By safeguarding the insurance 
funds it keeps insurance premiums as low as possible and protects well-
run institutions from assuming liabilities associated with high flyers.
  It would appear that the FDIC, in its role as guardian of the 
insurance funds, should have taken a more aggressive stance in 
insisting on its authority to examine Keystone. In response to a letter 
of mine on the subject, the FDIC made a strong case that it should have 
been given a more active role in Keystone examinations. Yet the agency 
did not rigorously pursue its rights and obligations in the matter. For 
example, the FDIC initially agreed to the OCC's terms of allowing only 
one FDIC examiner in the 1998 examination of Keystone despite its 
judgment four months earlier that it needed three. If the FDIC had 
serious concerns about Keystone's threat to the fund, it had a 
fiduciary obligation to press its case to the Board that three 
examiners were needed and should be approved.
  Concern also exists about the length of time that elapsed between the 
FDIC's February 1998 request to participate in the Keystone examination 
and its planned presentation of the case to the Board in June. While 
this delay allowed the agencies time to negotiate before the start of 
the examination, the FDIC should have acted on a more forceful and 
timely basis to resolve the disagreement. While coordination among the 
agencies is important, cooperation should not overshadow the FDIC's 
primary responsibility to protect the safety and soundness of the 
insurance funds.
  In attempting to understand the interagency conflict that existed in 
the supervision of Keystone, it is instructive to review the 
legislative history of the FDIC's authority to examine national banks 
and other insured institutions. Prior to 1950, the FDIC could utilize 
its special examination authority to examine a national bank only with 
the written consent of the OCC. This veto power over the FDIC proved 
untenable and the House passed legislation that year, which permitted 
the FDIC to examine national banks as back-up supervisor without the 
OCC's written consent. In conference with the Senate, however, the bill 
was modified to require the full FDIC board--of which the OCC is a 
member--to authorize any special examination requests. This provision 
has survived to this day as Section 10(b)(3) of the Federal Deposit 
Insurance Act. While more restrictive of FDIC independence than the 
original House language, the 1950 change in law ended the ability of 
other agencies to veto FDIC participation in examinations as back-up 
supervisor, as was possible from 1935 until 1950.
  In 1950, the FDIC board consisted of three members. Only the 
Comptroller was from the Treasury Department; the other two directors 
were affiliated only with the FDIC. In 1989, the board was changed to 
the current five-member format. There are now three independent 
members, plus the heads of the OCC and the OTS, who represent the 
Treasury Department. This arrangement does not give Treasury agencies 
majority control under normal circumstances. When, however, there is a 
vacancy in one of the three FDIC positions, half of the four remaining 
board members represent agencies of the Treasury Department. If two of 
the independent seats were to be vacant, the Treasury Department would 
effectively control the FDIC board. This is not an insignificant 
matter, considering that the current statutory language regarding FDIC 
back-up examination authority was written at a time when the majority 
of the FDIC's original three-member Board reflected control by an 
independent agency, rather than a Cabinet department.
  However, when there is a vacancy on the FDIC board, the Treasury 
Department assumes a larger role than Congress intended, and the FDIC's 
back-up authority can be subject to challenge. From 1983 until 1993, 
for example, the OCC and the FDIC operated under an agreement whereby 
the OCC would invite FDIC participation in examinations of banks with 
composite `4' and `5' ratings indicating a troubled bank; additionally, 
the OCC would allow FDIC participation in examination of higher rated 
banks, with an emphasis on `3'-rated banks.
  In September 1993, this collegial arrangement changed. Two of the 
independent seats were vacant, and the FDIC's board, then dominated by 
the two Treasury representatives voted to end this long-standing 
agreement. The new policy reserve to the FDIC Board all decisions 
regarding concurrent or special examinations, regardless of the rating 
of the institution. This change in policy was entered into despite an 
explicit written communication to the FDIC by then-House Banking 
Committee Chairman Henry B. Gonzalez and me, the then-Ranking Member, 
that Congress had serious reservations that the proposal under 
consideration would have the effect of the FDIC improperly derogating 
its authority.
  While the OCC board member seemed sympathetic at the time to the need 
for FDIC special examinations for `4'- and `5'-rated institutions, he 
clearly had concerns about FDIC involvement in higher-rated 
institutions. Yet, the FDIC Acting Chairman and FDIC staff who attended 
the meeting insisted that under certain circumstances it may be more 
important to involve the FDIC as back-up supervisor in examinations of 
deteriorating `3'-rated banks than in the examinations of `4'- and `5'-
rated institutions with already identified and addressed problems. 
Keystone is a case in point.
  Two years later, in 1995, the FDIC board delegated authority to its 
Division of Supervision to authorize participation in certain back-up 
examination activities of institutions when the FDIC is invited by the 
primary regulator, or when the FDIC asks and the primary regulator does 
not object. In cases such as Keystone, however, when the primary 
regulator objects, FDIC policy dictates that the case must be brought 
to the full FDIC Board regardless of the rating or conditions of the 
bank.
  Unfortunately, the FDIC Board has not had its full complement of five 
directors since an independent director resigned over a year ago, which 
results in Treasury having influence disproportionate to Congressional 
intent. During this period of time, the Administration has failed to 
submit a nominee for this current vacancy on the FDIC board. The result 
is that proposed actions or policies supported by the two independent 
FDIC directors can be blocked by the two directors who are affiliated 
with the Treasury agencies, the OCC and the OTS. This is not good 
governance. By failing to nominate a person for the unfilled board 
position, the Administration has forced the FDIC to operate without 
clear independence from the power considerations of the OCC and OTS. 
Such a situation could have been a factor in the FDIC's decision not to 
vigorously pursue in the Spring of 1998 its original request in the 
Keystone case. The bottom line is that all regulators share a common 
responsibility to protect the safety and soundness of the U.S. 
financial system--a responsibility that should not be affected by turf 
concerns.
  The OCC's principal response to date in the aftermath of the Keystone 
failure has been to declare that all FDIC requests to participate in an 
OCC examination or conduct a special examination of a national bank 
will now be considered directly by the Comptroller himself. While this 
procedure is certainly better than having OCC staff deny a request and 
forcing the FDIC to ask the board for approval, the response is still 
inadequate because it would do nothing to address the potential for 
undue Treasury agency influence on the FDIC Board. When a vacancy 
exists, the Treasury is, in effect, in control; it has veto power over 
FDIC participation. This is clearly contrary to Congressional intent 
that the FDIC operate as an independent agency and that it alone be 
able to determine whether an examination is necessary for insurance 
purposes, without undue influence by another federal regulator.
  From a broader perspective, I might add that since looking into the 
details of the Keystone case, I have learned that a lack of cooperation 
is rare, but not isolated. Despite the generally constructive working 
relationship among federal bank regulators in some 90 instances of 
back-up examinations over the past four years, there have been, in 
addition to Keystone, four other cases in which the primary regulatory 
agency initially rejected the FDIC's request to participate in an 
examination. Three of these cased involved the OCC and the other the 
OTS. In all four instances,

[[Page 29863]]

as with Keystone, the primary agency ultimately agreed to some form of 
FDIC participation without formal board action.
  The record of these five cases confirms that disagreements among 
agencies are the exception, rather than the norm There are also no 
indications that the FDIC is capriciously using its back-up authority. 
Nevertheless, the Keystone failure makes a graphic case that the 
current process needs improving.
  Accordingly, to reinforce FDIC independence on matters affecting the 
insurance fund, I have introduced today legislation (H.R. 3374) to give 
the FDIC Chairman authority in special circumstances to direct FDIC 
examiners to examine any insured institution, instead of the current 
provision vesting such authority with the FDIC Board of Directors. This 
authority will continue to be used only when, in the words of Section 
10(b)(3) of the Federal Deposit Insurance Act, an examination is 
``necessary to determine the condition of such depository institution 
for insurance purposes.'' The legislation would require that in 
exercising this authority all reasonable efforts be made to coordinate 
with any other appropriate regulator and to minimize any disruptive 
effect of a special examination on the operation of the depository 
institution. The intent is not to press new FDIC regulation on the 
banking system, but simply to stress that in unusual, special 
circumstances the FDIC must be able to act as an independent, rather 
than subordinate, agency of government.
  I believe this legislation will help assure the safety and soundness 
of the American financial system and protect the insurance funds by 
underscoring statutorily the long-term intent of Congress that FDIC 
back-up authority must be of an independent nature. The Chairman would 
be required to notify other FDIC board members (and the Federal Reserve 
and State banking authority as applicable) whenever he or she makes 
such a decision. As the custodian of the insurance funds, the FDIC must 
be allowed to perform its role as a backup regulator on a timely basis 
whenever circumstances warrant.
  It is worth noting that the Inspector General (IG) of the FDIC has 
come to similar conclusions. In an October 19, 1999, memorandum to the 
FDIC Chairman, the IG recommended that the FDIC board delegate its 
special examination authority to the FDIC Chairman or that the law be 
amended to vest that authority in the Chairman. The legislation I am 
introducing today would address the IG's concerns, as well as my own.
  The IG argued that the agency's backup examination authority was 
particularly critical in this era of increasing bank consolidation. 
While the ``megabanks'' created by recent mergers pose the greatest 
risks to the insurance funds, the FDIC is the primary regulator for 
only two of the nation's 39 largest institutions. Obstacles to future 
FDIC access to relevant information about megabank operations in its 
role as back-up supervisor could have consequences far greater than the 
Keystone case.
  To assess risk in large institutions where it does not have an 
ongoing presence, the FDIC requires timely information and records on 
important aspects of operations. Therefore, the bill I am introducing 
also includes language emphasizing the right of the FDIC to prompt 
access to information from other regulators and requiring the federal 
banking agencies to establish procedures for sharing other information, 
in addition to examination reports, whenever such information is 
relevant to the FDIC's responsibility to protect the insurance funds. 
This provision of the bill underscores the importance of interagency 
coordination and information sharing to ensure that the FDIC has the 
necessary data to assess risk to the insurance funds. It is intended to 
have the practical benefit of potentially minimizing the number of 
occasions in which the FDIC must exercise its special examination 
authority.
  The vast majority of institutions will not be affected in any way by 
this legislation. For most institutions, the FDIC does not need any 
special information other than that already available to it, nor does 
it need to perform any form of back-up examination. But, clearly, in 
cases where the potential risk to the fund is great--banks with 
significant weaknesses, especially if they are megabanks with 
exceedingly complex activities--the FDIC should be able to function as 
Congress expects it to function and receive from the primary regulator 
the information it needs to assess relevant risk.
  I might add before closing that my concerns in the Keystone case 
extend beyond the issues of regulatory cooperation and FDIC special 
examination authority. There are also troubling questions here about 
the regulators' ability to identify and stem high risk bank activities 
in a timely fashion. There was another bank failure involving extremely 
high losses relative to assets just over a year ago. On July 23, 1998, 
Colorado State Banking authorities closed BestBank--an FDIC-supervised 
state bank located in Boulder--after state and FDIC examiners found 
$134 million in losses in high-risk, unsecured subprime credit card 
accounts. Although the FDIC initially estimated the cost of that 
failure to the insurance fund at about $28 million, by year's end the 
estimate had risen 6-fold to $171.6 million. I mention the BestBank 
case because of its striking similarities to the Keystone case. Like 
the junk-bond investments of S&Ls in the 1980s, both BestBank and 
Keystone were disproportionately involved in high-risk activities, 
namely subprime loans. Both banks relied heavily on outside, third 
party servicers. Both banks had experienced extraordinarily high asset 
growth. Both banks had high public profiles: In the mid-1990's, 
BestBank was labeled in one banking publication as the ``best performer 
among U.S. banks,'' and Keystone captured the title of the nation's 
most profitable community bank for three straight years. Keystone and 
BestBank also engaged in similar tactics to frustrate federal 
examiners, and fraud is alleged to have played a part in the failure of 
both. Unfortunately, I suspect we may also find some parallels in how 
federal regulators handled the two cases. The FDIC IG, in conducting 
the material loss review in the BestBank case, concluded that the FDIC 
could have been more effective in controlling the bank's rapid asset 
growth and thus curbing losses to the insurance fund.
  While we do not yet know the final outcome of the investigations into 
either of these recent bank failures, it is clear that the banking 
agencies need to continue to review their supervisory strategies for 
banks engaging in inherently risky activities, such as subprime 
lending. Accordingly, I am asking each of the federal banking 
regulators to keep the Committee informed of any new policies and 
procedures for identifying institutions with profiles similar to those 
of Keystone and BestBank, and any changes in their supervisory 
practices with respect to such institutions. Also I am interested in 
any initiatives that would assist examiners in the detection of fraud, 
which is becoming a factor in an increasing percentage of failures. In 
this regard, I am pleased to note that FDIC Chairman Donna Tanoue 
recently announced that the FDIC is developing guidelines to require 
additional capital for subprime portfolios and reviewing potential 
increases in insurance premiums for banks that continue to engage in 
high risk activities of this nature without appropriate safeguards.
  In closing, the insurance fund should not have to suffer an excessive 
loss during this era of generally favorable economic conditions. 
Expensive failures impose unfair costs in the form of higher insurance 
premiums on honest, law abiding community banks around the country. 
Failures also impose costs on depositors whose accounts exceed 
insurance limits. And, as illustrated by the Keystone case, failure can 
take a heavy toll on the local community and those whose jobs depend on 
the survival of the bank.
  Clearly, it is critical that federal regulators cooperate with each 
other and pay particular attention to unusually rapid asset growth and 
potentially risky banking practices if future Keystones and BestBanks 
are to be averted.

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