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For immediate release

March 7. 1997

The Federal Reserve Board today announced the execution
of a Written Agreement by and among Luis A. Ortega, an officer
and director of Interbank Holding Company, Miami, Florida, a bank
holding company, the former Chairman of the board of directors
and a current director of the Pan American Bank,

Miami,

Florida;

Interbank Holding Company: the Federal Reserve Bank of Atlanta;
and the Department of Banking and Finance, Division of Banking,
State of Florida.
The Federal Reserve Board also announced the execution
of a Written Agreement by and among Glenn M. Goldhagen, a former
officer of Interbank Holding Company, and the former Chief
Executive Officer and a former director of the Pan American Bank:
the Federal Reserve Bank of Atlanta; and the Department of
Banking and Finance, Division of Banking, State of Florida.
Copies of the Written Agreements are attached.

Attachments

UNITED STATES OF AMERICA
OF

BEFORE THE BOARD

GOVERNORS

OF

THE FEDERAL RESERVE SYSTEM

WASHINGTON, D.C.
STATE OF FLORIDA
DEPARTMENT OF BANKING AND FINANCE
DIVISION

OF

BANKING

'.

TALLAHASSEE, FLORIDA

Written Agreement by and among

i

LUIS A. ORTEGA

1

an institution-affiliated
party of Interbank Holding Company
and the Pan American Bank,
both of Miami, Florida

1
)

INTERBANK
HOLDING COMPANY
Miami, Florida

FEDERAL RESERVE BANK
Atlanta, Georgia

OF

DocketNo. 96-OlS-WA/RB-11
96-OlS-WA/HC
Admin. Procedure No.
3517-B-5/96

1
1
i

ATLANTA

,'
;

and
DEPARTMENT OF BANKING AND FINANCE,
DIVISION OF BANKING

STATE OF FLORIDA
Tallahassee, Florida

j
)
;
I

WHEREAS, in recognition of their common goal to
maintain the financial eoundneee of the Pan American Bank, Miami,
Florida (the "Bank"), a state member bank, the Federal Reserve
Sank of

Atlanta (the *Reserve Bank"), the Department'of Banking

and Finance, Divieion of Bankin$of
'Department"), Luie

A.

Ortega

the State of

Florida (the

("Dr. Ortega"), an officer of

2
Interbank Holding Company, Miami, Florida ("Interbank"),

a

registered bank holding company. the former Chairman of the board
of directors of :he Bank, and a current director of the Bank, and
Interbank, have mutually agreed to enter into this Agreement; and

WHEREAS, this Agreement is being executed in accordance
with the Rules Regarding Delegation of Authority of the Board of

Governors of the Federal Reserve System (the "Board of
Governors"), specifically 12 C.F.R. 265.11(a)(15), and the
Reserve Bank has received the prior approval of the Director of
the Division of Banking Supervision and Regulation and the
General Counsel of the Board of Governors to enter into this
Agreement with Dr. Ortega and Interbank.

NOW, THEREFORE, before the taking of any testimony or
adjudication of or finding on any issue of fact or law herein,
and without this Agreement constituting an admission of any
allegation made or implied by the Board of Governore or the
Department, the Reserve Bank, the Department, Dr. Ortega and
Interbank agree as follows:

1.

(a)

Dr. Ortega and Interbank shall comply fully

with the conditions imposed in writing by the Board of Governors
by letter dated December 24, 1991, in connection with Interbank's
acquisition of the Bank.

3
bj

Dr. Ortega and Interbank shall comply fully

with :he provislcns of the Bank Holding Company Act of.1956, as
amended, and zhe regulations issued by the Board of Governors
thereunder ( and shall comply fully with any applicable provisions
of Florida law contained in Chapter 655, Florida Statutes, or the
..
%
regulations thereunder.

Restrictions on Transactiona
2.

(a)

Without the prior review of the Reserve Bank

and the Department, the Affected Parties shall not, directly or
indirectly, engage, undertake or in any manner participate in any
financial transaction with the Bank.

(b)

The term "financial transaction" shall be

defined as:

(i) The exteneion of credit (or the renewal
or modification of any extension of credit), as defined in
section 215.3 of Regulation 0 of the Board of Governors
(12 C.F.R. 215.31, including any overdrafts on either a daylight
or overnight basis;

(ii)

the

maintenance

of

any deposit account;

(iii) the di:ect or indirect payment,
..'
guarantee or confirmation of anf'obligation;
c

4
iiv)

the payment of any service or management

tv)

the transfer, contribution, purchase or

fee;

sale of any asset; and
1:
ivi) the transfer of cash or cash-like
instruments.

(cl

(i) Dr. Ortega,

The term "Affected Parties" means

(ii) any family member,

(iii) any related

interest of Dr. Ortega or of any family member, (iv) Interbank,

(v) any person that currently is, or was since December 24, 1991,
an affiliate of the Bank or Interbank, (vi) any person that
currently is, or was since December 24, 1991, a related party of
the Bank or Interbank.

(d) The term "family member" mean8
Dr. Ortega' s spouse, parents, siblings, children, and nieces and

nephews, and the spouses thereof.

(e) The term 'related interests" shall be defined
as set forth in section 215.2(n) of Regulation 0 of the Board of
Governors (12 C.F.R. 215.2(n)) and section 658.48(4), Florida
,: Statutes.

5
if)

The term "related party" shall be defined as

(i) any person holding an ownership interest in excess of
25 percent of Interbank or the Bank, or any of Interbank's or the
Bank's subsidiaries,

(ii) any person, or group of persons acting

in concert, that controls, is controlled by, or is under common
control with Interbank or the Bank, (iii) any family member of
any person or group of persons holding an ownership interest in
excess of 25 percent in Interbank or the Bank, or in any of
Interbank's or the Bank's subsidiaries, and (iv) any company,
partnership, trust or other entity controlled by any person
described in this paragraph; provided, however, that "related
party" shall not include any person who would be included by
virtue solely of being an investor in any related interest of
Dr. Ortega or of any family member of Dr. Ortega.

(9)

The term waffiliateN shall be defined as set

forth in 12 U.S.C. 371c(b) (1).

(h)

The term "control n shall be defined as set

forth in 12 U.S.C. 1841(a) (2).

(i)

The term npersonn shall mean a corporation,

unincorporated association, partnership, trust or any other
entity or individual.
.)

,,
0,

X

Y

6
3.

The prohibitions of paragraph 2(a) hereof shall

not :ii prevent any Affected Party from repaying any indebtedness
or other obiigation owed to the Bank, nor require the prepayment
by any Affected Party of amounts due under any such indebtedness
or obligation existing on the date hereof, or (ii) prevent the
Bank from complying with any indemnity obligation that the Bank Y

may have by virtue of Florida law.

Performance of Duties as Director
4.

The provisions of paragraph 2(a) hereof shall not

prevent Dr. Ortega, as a duly elected director of the Bank, from
exercising any of the rights, or performing any duty or function
or exercising any power or authority which customarily attaches
to such position; provided, however, that Dr. Ortega shall not,
in addition to the restrictions set forth in paragraph 2(a)
hereof, participate, directly or indirectly, in any lending or
funds transfer activities of the Bank.

.

.

MiscelLgneous Provrslons
5.

All communications regarding this Agreement shall

be sent to:
(a) Mr. Marion P. Rivers, III
Assistant Vice President
Federal Reserve Bank of Atlanta
104 Marietta Street, N.W.
Atlanta, Georgia 30303-2713

7

ibj

Ms. Li.nda R. Townsend
Chief, Bureau of Financial Institutions,
District II, Division of Banking ~
State of Florida
Office of the Comptroller
101 East Gaines Street, Suite 636
Tallahassee, Florida 32399-0350

Cc)

Dr. Luis A. Ortega
c/o Carlos E. Loumiet, Esq.
Greenberg Traurig
1221 Brickell Avenue
Miami, Florida 33131

Cd)

Interbank Holding Company
c/o Carlos E. Loumiet, Esq.

Greenberg Traurig
1221 Brickell Avenue
Miami, Florida 33131
6.

The provisions of this Agreement shall be binding

upon Dr. Ortega and Interbank and shall remain effective and
enforceable until stayed, modified, terminated or suspended by
the Reserve Bank and the Department.

1.

The provisions of this Agreement shall not bar,

estop or otherwise prevent the Board of Governors, the
Department, or any federal, state or local agency or department
from taking any action affecting Dr. Ortega or Inter-bank;
provided, however, that this Agreement forever settles and bars
any future action by the Board of Governors and the Department
relating to those matters which are the subject of administrative
action commenced by the Board of Governors and the Department
against Interbank, the Bank, Dr. Ortega and~Qlcnn M.'Ooldhaqen.
.:

.
.

L

a
a.

This Agreement is a '*written agreement" for the

purposes of section B of the FDI Act (12 U.S.C. 1818):

9.

Dr. Ortega agrees to the entry of a Final Order

issued by the Department incorporating this Written Agreement.
.'
The Final Order shall constitute final agency action by the
Department,

for which the Department may seek enforcement

pursuant to Chapters 655, 658 and 120, Florida Statutes, and
Dr. Ortega further voluntarily and knowingly waives:

(a)

Any right to receipt of a Notice of Rights

pursuant to Chapters 120, 655 and 658, Florida Statutes;

(b) any right to an administrative hearing or
issuance of a recommended order provided by Chapter 120, Florida
Statutes (1996 Supp.) or Chapters 3-7, 26 or 60, Florida
Administrative Code;

(c) any right to contest the validity of any
term, condition, obligation or duty created hereby in any
judicial or administrative forum; and

(d) any and all objections to or challenges in
any judicial proceeding, including but not limited to, appeal
,:

pursuant to Section 120.68, Florida Statutes (1996 Supp.), any
.'
i'
8

'?'

9

lspocc ,

provioion or requirementconcerningthe content,

lseu~~ce,procedure or tlrnelincsr
of the

10.

The

partimm agree that esch party horein lhell

solely r*opanslblmfor

the

saporate

incurred uy to the execution of
entry of the Final Order
Intarbarm

Daprrtmemt
and

hereby

W8lVe,

in

thie

releum

cortn

the

and

Written

mattar.

urd

Dr.

forwer

wkvr

by Dr. Ortaga

without

tbm

uxi m~rgloyeea
from any

arising Out
Ywpta

of this

thi8

releaer

lckaovledging.vhilo lxpremely

denying, that any csusoe 09 setion etiat.

S-r

the

and

dimeharge

and it= agonto, rrprameatrtivor

all causes of action la law or Wty

and

Ortega

be

foe*

PttOIIIoy’m

Agrownt

administrativeproceeding. The oepurment
lnd

odor.

Dapmtmontro

the~rtieebavec.susmdtNe

ted a0 of the (ntf\day of mwch, 1997.

~sDQuI,ltEsERvxwoPATLAwrA

-4

UNITED STATES OF
BEFORE THE BOARD

OF

AMERICA

GOVERNORS OF 'THEFEDED&
WASHINGTON.

RESERVE

SYSTW

D.C.

STATE OF FLORIDA
DEPARTNBNT

OF

BANRINQ AND FINANCE

DIVISION

OF

BANRINQ

TALLANASSER, FLORIDA

Written Agreement by and among
GLENN M. GOLDHAGEN

I

DocketNo. 96-OlB-WA/RB-12
a former institution-affiliated
;
party of Interbank Holding Company )
and the Pan American Bank,
both of Miami, Florida
;
FEDERAL RESERVE BANK OF ATLANTA
Atlanta, Georgia

Admin. Procedure No.
3517-b-5/96

;
1

and
;
DEPARTMENT OF BANKING AND FINANCE,
DIVISION OF BANKING
STATE OF FLORIDA
Tallahassee, Florida

)
1

WHEREAS, in recognition of their common goal to
maintain the financial soundness of Interbank Holding Company,
Miami, Florida ("Interbank"), a registered bank holding company,
and the Pan American Bank, Miami, Florida (the "Bank"), a state
member bank, the Federal Reserve Bank of Atlanta (the "Reserve
Bank"), the Department of Banking and Finance, Division

of

2
Banking of the State of Florida

(the 'tDepartment"), and Glenn M.

Goldinagen ("Mr. Goldhagen"), a former officer of Inter-bank and
the former Chief Executive Officer and a former director of the
Bank, have mutually agreed to enter into this Agreement;

and

WHEREAS, this Agreement is being executed in accordance
with the Rules Regarding Delegation of Authority of the Board of
Governors of the Federal Reserve System
Governors"),

(the "Board of

specifically 12 C.F.R. 265.11(a) (15), and the

Reserve Bank has received the prior approval of the Director of
the Division of Banking Supervision and Regulation and the
General Counsel of the Board of Governors to enter into this
Agreement with Mr. Goldhagen.

NOW, THEREFORE, before the taking of any testimony or
adjudication of or finding on any issue of fact or law herein,
and without this Agreement constituting an admission of any
allegation made or implied by the Board of Governors or the
Department, the Reserve Bank, the Department and Mr. Goldhagen
agree as follows:

3
Particination in the Conduct of the Affairs of Interbank or the

Mr. Goldhagen shall not:

1.

(a)

Participate in any manner in the conduct of

the affairs of Interbank or the Bank;

(b)

solicit, procure, transfer, attempt to

transfer, vote or attempt to vote any proxy, consent, or
authorization with respect to voting rights in Interbank or the
Bank;

(c)

violate any voting agreement previously

approved by any federal banking agency with respect to Interbank
or the Bank; or

(d)

vote for a director or serve or act as an

institution-affiliated

party, as defined in

sections 3(u) and 8(b) (3) and (4) of the Federal Deposit
Insurance Act

(the "FDI Act") (12 U.S.C. 1813(u) and 1818(b) (3)

and (b) (4)), such as an officer, director or employee, of
Interbank or the Bank.

4
Restrictions on Transactions
2.

(a)

Mr. Goldhagen and his related interests shall

not, directly or indirectly, engage, undertake or in any manner
participate in any transaction with Interbank or the Bank.

(b)

The term "transactionfi shall include, without

limitation:

(i)

The extension of credit (as defined in

section 215.3 of Regulation 0 of the Board of Governors
(12 C.F.R. 215.3). including any overdrafts on either a daylight
or overnight basis;

(ii) the direct or indirect payment,
guarantee or confirmation of any obligation;

(iii) the payment of any service or
management fee, salary or bonus, or the payment or reimbursement
of any expense incurred by Mr. Goldhagen or his related
interests; and

(iv) the transfer, contribution, purchase or
sale of any asset.

(cl

The term "related interests" shall

as set forth in section 215.2(n) of Regulation 0 of

be defined

the Board of

5
Governors (12 C.F.R. 215.2(n)) and section 658.46(4), Florida
Statutes.

Miscellaneous Provisions
3.

All communications regarding this Agreement shall

be sent to:

4.

(a)

Mr. Marion P. Rivers, III
Assistant Vice President
Federal Reserve Bank of Atlanta
104 Marietta Street, N.W.
Atlanta, Georgia 30303-2713

(b)

Ms. Linda R. Townsend
Chief, Bureau of Financial Institutions,
District II, Division of Banking
State of Florida
Office of the Comptroller
101 East Gaines Street, Suite 636
Tallahassee, Florida 32399-0350

Cc)

Mr. Glenn M. Goldhagen
c/o Carlo6 E. Loumiet, Esq.
Greenberg Traurig
1221 Brickell Avenue
Miami,
Florida 33131

The provisions of this Agreement shall be binding

upon Mr. Goldhagen and shall remain effective and enforceable
until stayed, modified, terminated or suspended by the Reserve
Bank and the Department.

5.

No provieion of this Agreement is intended to

affect any indemnity obligation the Bank or Interbank may have to
Mr. Goldhagen arising by operation of Florida law or by virtue of
the Bank's or Interbank's Articles of Incorporation or Bylaws.

6

The provfeione of =his Agreement shall

6.

emtop or oeherwioe

prevent

Department,

or

other

from

any

caking

respect

any

bar,

the Board of Governors or cha
federal

or state

affecting

acEiOn

other

not

Mr.

agency or department
GddbfBgOn,

exempt

fn the Board of Qtmenerm’s
..
the Department's procetiingm against Mr. Goldhagen.

to the mattrra

fii8

7.

purpomm

of

1~

lsctioa

lyrawmt
a of

WImBss

Agreement to be

rddrematd

emouted

ir a Hwritten agrementm

tha FD;TAct

tha

UJiERBo?,

u

of

m

FBIERAL

and

for the

(12 O.S.C. 1818).

parties

tbe

with

day

have

of

caused

thl#

&arch

, 1937.

BESXRVB BanK OF ArLAwrA

By:

&&rt

I.

U

.

,