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UNITED

BOARD

OF GOVERNORS

STATES

OF AMERICA

BEFORE

THE

OF THE FEDERAL
WASHINGTON.

JOHN

Docket

97-002-E-I
97-002-CMP-I

Combined Order of
Prohibition
and
Assessment
of a Civil Money
Penalty,
Issued Pursuant
to the Federal Deposit
Insurance Act, as Amended

A Former Employee and
Institution-Affiliated
Party of

A Former

Nos.

of

E. COLLEY

TRUSTCO BANK
Schenectady,

SYSTEM

DC

---X

In the Matter

RESERVE

NEW
New

State

YORK
York

Member

Bank
---f,

WHEREAS,

pursuant

of the Federal

Deposit

55 1818(e)

1818(i))

and

of the Federal
this

combined

Money

Penalty

in Section

of Trustco

Bank

fiduciary
the

sale

customers,
belonging

System

3(u)

New York,

duty

relating

of numismatic
and

Schenectady,

and

coins

the custodial

to a Trustco

trust

of Governors

of John

E. Colley

(12 U.S.C.

New

York

and a member
alleged

its customers
to certain

customer;

and

party,
§ 1813(u))

("Trustco"),

of the

Federal

breaches

of his

in connection

of Trustco's

arrangements

issues

of a Civil

institution-affiliated

to Colley's

to Trustco

(12 U.S.C.

of Governors")

and Assessment

of the FDI Act

bank

8(i)

the Board

the consent

and

and

as amended

(the "Board

upon

employee

a State-chartered
System,

8(e)

(the "FDI Act"),

(the "Order")

as defined

Reserve

Act,

of Prohibition

("Colley") , a former

formerly

Insurance

Reserve
Order

to Sections

for a coin

with

trust
collection

WHEREAS,
has

consented

Governors
of this

and

consented

a notice

of assessment

the purpose

implied

or set

of this

Order

contest

in any

of a civil

of taking
forth

collectibility

provision

hereof;
NOW,

or adjudication
herein,
any

allegation

connection

hearings

this

made

with

of settlement

or

this

to any

matter

judicial

review

of this

Order

or any

of any testimony

of fact

or law
of

by the Board

of Governors

in

proceeding

solely

without

or

effec-

an admission

and

for the purpose

protracted

or extended

or testimony:

to Section

8(e)

Colley,

of Governors

ORDERED,

where

prior

written

necessary

Section

8(e) (7) (B) of the FDI Act

another

Federal

financial

hereby

agrees

that,

of the FDI Act:

without

and,

and Colley

(12 U.S.C.

institution

not:

2

approval

pursuant

of the

to

5 1818(e) (7) (B)),

regulatory

of

(b) to a hearing

validity,

issue

and

constituting

proceeding,

of this

1.
Board

Order

or otherwise

(d) to challenge

to the taking

on any

implied

IT IS HEREBY
pursuant

prior

of or finding

and without

and

issuance,

have

and of hearing

respect

or enforceability

THEREFORE,

263,

(c) to obtain

hereof;

the basis,

tiveness,

Part

of

provision

he might

penalty;

with

Order;

or any provision
matter

money

evidence

in this

and every

all rights

of charges

colley

by the Board

each

or 12 C.F.R.

of a notice

hereunder,

Order

with

any and

§ 1818

signature

of this

to comply

and waived

issuance

his

issuance

to 12 U.S.C.

(a) to the

for

to the

Order,

pursuant

by affixing

agency,

shall

(a)
of the

affairs

Section

Participate

of any

in any manner

institution

or agency

8ie) 17) (Ai of the FDI Act

including,

but

not

assigns,

or any

company

thereof;

limited

other

transfer,

vote

authorization
institution

or attempt
with

to vote

respect

described

procure,

§ 1818(e) (7) (A)),

institution

transfer,

any proxy,

to any voting

in Section

in

its successors

depositary

solicit,

(b)

conduct

specified

(12 U.S.C.

to, Trustco,

insured

in the

or
or holding

attempt

consent,

rights

to
or

in any

8(e) (7) (A) of the FDI

Act;
violate

(c)

approved

by any Federal

banking

vote

(d)

institution

such

2.
Section
pay

8(i)

that

System"

payable
and

to William
of the

the

time

"Board

forwarded

Federal

in Section
or employee

ORDERED,

Colley

pursuant

is assessed

sum of $40,000

assessed

at the

to the

W. Wiles,

or acting
3(u)

as

of

in any

to
and

shall

for alleged

duty.

The penalty
in full,

or serving

8(e) (7) (A) of the FDI Act.

of the FDI Act,

3.

Order,

director

FURTHER

of Governors

previously

or

as defined

in Section

of fiduciary

be remitted

party,

IT IS HEREBY

to the Board

breaches

agency;

as an officer,

described

agreement

for a director,

an institution-affiliated
the FDI Act,

any voting

with

Colley's

System,

to this

of Colley's

of Governors

Secretary

Reserve

pursuant

execution

copy

of the Board,

3

DC

Board

shall

of this

of the Federal

executed

Washington,

Order

Reserve

of this

Order,

of Governors

20551.

The

Board

of Governors
United

shall

States

the payment

as required

4.
sent

remit

All

to the Treasury

of the

by statute.

communications

regarding

this

Order

shall

be

to:
Robert A. O'Sullivan
Senior Vice President
Federal Reserve Bank
of New York
33 Liberty Street
New York, NY
10045

(a)

and

a copy

to:

James J. Hilton, Esq
Legal Department
Federal Reserve Bank
of New York
33 Liberty Street
New York, NY
10045
John E. Colley
c/o William Dreyer, Esq.
Dreyer Boyajian,
LLP
75 Columbia Street
Albany, NY
12210

(b)

Any

5.
subject
under

Colley
Section

violations

to appropriate
8(i)

6.

and

The provisions
prevent

state

or department

Colley,
take

any

provided,

action

presently

known

addressed

by this

shall

or criminal

of this

the Board

however,

further

7.

civil

order

separately

penalties

or both

Cj) of the FDI Act

or otherwise
agency

of this

Order

of Governors,

from

taking

that

the Board

against

by the Board

shall

or any

any other

Colley

upon

relating

estop,

federal

action

of Governors

based

of Governors

not bar,

or

affecting
shall

not

information
to the matters

Order

Each

provision

effective

and enforceable

suspended

in writing

of this

until

Order

stayed,

by the Board

4

shall

modified,

of Governors.

remain
terminated

OL

By order
Reserve

System,

of the Board

effective

of Governors

this 3 d

day

of

of the Federal
/-%--JJYI,

/

, 1998.

BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM

By:

Jofy
v

E. Colley
CI

I

)!,A

William W. Wiles
Secretary
of the

Board