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WNITED
BEFORE

THE

BOARD

STATES

GOVERNORS

OF

OF

WASHINGTON,

In the Matter
JEROME

of

WHEREAS,

(12 U.S.C.
Federal
Order

director,

and

sections

3(u)

Federal

to sections
Act,

(the "Board

president,

98-009-E-11

former

System,

("Bancorp") , formerly
Bechstein's

alleged

or unsound

practices

Pursuant to
Insurance

(the

bank

and Towne

a registered

participation
regarding

(i) (3) of the

"FDI Act")

of Governors

of the

issues

against

C. Bechstein

chief

Towne

and

of Governors")
Jerome

executive

party,

8(b) (3) of the FDI Act

a state-chartered

Reserve

8(e)

as amended

(the "Order")

1818(b) (3)), of the
("Towne"),

No.

1

institution-affiliated
and

SYSTEM

D. C .

(i) (3)), the Board

System

, former

and

;

Insurance

of Prohibition

("Bechstein")

RESERVE

Order of Prohibition
Issued Upon Consent
the Federal Deposit
Act, as Amended

1

pursuant

1818(e)

Reserve

FEDERAL

;

An Institution-Affiliated
Party of the former
Towne Bank
Perrysburg,
Ohio
and
Towne Bancorp,
Inc.
Perrysburg,
Ohio

Deposit

THE

Docket

C. BECHSTEIN

Federal

AMERICA

OF

Bank,

officer,

as defined

(12 U.S.C.

Perrysburg,
a member

Bancorp,

Inc.,

holding

in violations

the lending

in

1813(u)

and

Ohio

that was

bank

this

of the

Perrysburg,
company,

due

Ohio
to

of law and unsafe

function

at Towne;

and

2
WHEREAS,
has

consented

Governors
have

and has waived

otherwise

(a) to the

in this

the basis,

enforceability
any and all
against

of this

claims

Towne,

("Exchange"),
common

issuance,

for fees

or Bancorp

law or under

limited

to, Ohio

NOW,
adjudication
forth

state

prior

of or finding

in any

or contest

hereof;

(e) to

Order

Luckey,

whether

or

and

to this

Bank,

or

of this

effectiveness

statute,

Governors

in connection

Ohio

arising

including,

made

without

taking

issue

this

herewith,

of this matter

to the

on any

and without

of any allegation

proceedings:

implied

review

related

the Exchange

for the

in

but

not

law.

admission

settlement

terms,

or its successors,

THEREFORE,

herein,

judicial

(d) to challenge

of any

or

to prohibit

to any matter

or expenses

the terms

263,

of intent

or any provision

its successor,

Part

of

otherwise

(b) to a hearing

respect

validity,

Order

he might

12 C.F.R.

Order;

Bechstein

by the Board

rights

(c) to obtain

hereof;

hereunder,

Order

of a notice

with

Order;

all
and

in this

evidence

or any provision

manner

set

forth

of taking

forth

Order

set

1818

issuance

signature

of this

any and

to 12 U.S.C.

on any matter

set

his

to the issuance

pursuant

purpose

by affixing

Order

of fact

solely

protracted

testimony

or law

constituting

or implied
and

of any

or

implied
an

by the Board

of

for the purpose
or extended

of

or

3
IT IS HEREBY
(i) (31, and

ORDERED,

(j) of the FDI Act

pursuant

to sections

8(e),

(12 U.S.C.

1818(e),

(i)(3),

and

written

approval

of

(j)), that:

1.

the Board

Bechstein,

of Governors

without
and,

the prior

where

section

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

another

federal

hereby

financial

and henceforth

(a)

From

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

institution,

attempting
consent,
any

from

(d)

institution

to, any

voting
with

or agency

(12 U.S.C.
insured

soliciting,

described

approved

agency,

in any manner

institution

or authorization

(cl

acting

limited

to transfer,

institution

previously

of any

or depository

(b)

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

regulatory

participating

section

not

to

is

prohibited:

of the affairs

but

pursuant

(12 U.S.C.

institution

conduct

including,

necessary

or attempting

8(e)(7)(A)

by any

banking

party,

any proxy,
rights

of the FDI

in
Act;

agreement

agency;

for a director,

as an institution-affiliated

transferring,

to any voting

any voting

from voting

company;

to vote

from violating
federal

in

depository

procuring,

in section

specified

1818(e)(7)(A)),

holding

respect

in the

or

or serving

as defined

in

or

4
section

3(u)

employee,

of the FDI Act,

in any

such

institution

as an officer,

described

director

in section

or

8(e)(7)(A)

of

the FDI Act.

2.
subject
both

under

shall

stayed,

violation

Bechstein

Order

criminal

8 of the FDI Act

This

remain

of this

to appropriate

section

3.
and

Any

Order,

fully

modified,

and

each

effective

terminated

shall

or civil

(12 U.S.C.

and

and

separately

every

or

1818).

provision

enforceable

or suspended

penalties

hereof,

until

in writing

is

expressly

by the Board

of Governors.

4.
addressed

All

communications

regarding

this

Order

shall

be

to:

5.

(a)

Mr. R. Chris Moore
Senior Vice President
Federal Reserve Bank of Cleveland
1455 East Sixth Street
44101
Cleveland,
Ohio

(b)

Mr. Jerome C. Bechstein
16967 Bowling Green Road West
43402
Bowling Green, Ohio

The provisions

or otherwise

prevent

state

or department

agency

of this

the Board
from

Order

of Governors
taking

any

shall

not bar,

or any
other

federal

action

estop,
or

affecting

5

Bechstein,

Towne,

Exchange,

institution-affiliated

By order

parties

of the Board

13%

Bancorp

or any

former

or current

thereof.

of Governors
_

effective

this

, 1998.

BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM

/
&zLc

By:

Bechstein

Secretary

of the Board