The OCC said in the order that it intervened after it found “unsafe or unsound” practices tied to strategic and capital planning, credit risk management, the loan-loss allowance methodology, corporate governance and internal controls.
The $247 million-asset bank is required to form a compliance committee and provide regular written progress reports to the OCC. It must also ensure that effective and qualified management is in place.
Unity, the only black-owned bank in Texas, must prepare a series of reports, including a three-year strategic plan, a credit risk management program and a concentration risk management program. It must also establish an internal capital planning process, among other things.
The bank must have “a sufficient process” in place to make sure that management appropriately responds to any audit, compliance and regulatory criticisms.
Unity was also prohibited from entering into any new business transaction with bank affiliates until its board has established a written program that provides for effective policies and control systems over those relationships.
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