Loading...
HomeMy WebLinkAbout14- Development Department —j6VELOPMENT DEPARTMENT OF THE CITY OF SAN BERNARDINO ECONOMIC DEVELOPMENT AGENCY REQUEST FOR COMMISSION/COUNCIL ACTION I FROM: KENNETH J.HENDERSON SUBJECT: AGENCY LOAN AND Executive Director GUARANTEE TO STEWARD AND ASSOCIATES-GAS COMPANY BUILDING DATE: August 31, 1994 ------------------------------------------------------------------------------------------------------------------------------------------- Synopsis of Previous Commission/Council/Committee Action(s): The Commission has previously approved a loan to Steward and Associates for$350,000,a loan guarantee of$1.3 million and a bridge loan of approximately$138,000. ------------------------------------------------------------------------------------------------------------------------------------------- Recommended Motion(s): (Community Development Commission) (Developer Recomendation) r MOTION: That the Community Development Commission approve the ninety day loan payoff extension submitted by Steward and Associates in connection with its$138,000 bridge loan on the old Gas Company Building located at 570 West Fourth Street. 4 Administrator HENNEkH J.HE RSON Executive Director ------------------------------------------------------------------------------------------------------------------------------------------- Contact Person(s): Kenneth J.Henderson/John Hoe eg r_ Phone: 5081 Project Area(s): All Ward(s): Seven(7) Supporting Data Attached: Staff Report: FUNDING REQUIREMENTS: Amount: N/A Source: N/A Budget Authority: N/A ------------------------------------------------------------------------------------------------------------------------------------------- Commission/Council Notes: ------------------------------------------------------------------------------------------------------------------ KJH:gas:adw COMMISSION MEETING AGENDA MEETING DATE: 09/06/1994 Agenda Item Number: DE ±, LOPMENT DEPARTME T ECONOMIC DEVELOPMENT AGENCY STAFF REPORT ------------------------------------------------------------------------------------------------------------------ Agency Loan and Guarantee to Steward and Associates- Old Gas Company Building I Previously, the Community Development Commission approved a loan to Steward and Associates in the amount of$350,000 and a loan guarantee of approximately$1.3 million to acquire and I renovate the old Gas Company Building located at 570 West Fourth Street. The agreement was subsequently amended to provide bridge financing in the approximate amount of$138,000 as a result of the Federal Deposit Insurance Corporation taking over Commerce Bank, Steward's construction lender, and stopping loan disbursements during construction. The bridge loan had an original term of ninety(90) days which was subsequently extended to August 31, 1994. The outstanding loan balance is approximately $157,000 (with accrued interest). Attached is correspondence from Alan Steward requesting an additional ninety(90) day extension and detailing the reasons for same. Also attached to Mr. Steward's letter is a memorandum from Charles R. Green, of Sabo and Green, to Timothy Steinhaus, Administrator, Economic Development Agency, concluding, ..."that prosecution of Mr. Steward's claim is highly unlikely to be successful...". With the above in mind, the developer has requested the Commission approve an additional ninety (90) day extension because, according to the developer, of the bright prospects for refinancing. A successful refinancing would enable the developer to payoff both the original $350,000 loan and the $157,000 bridge loan. Based upon the foregoing, the developer recommends the adoption of the form motion. (M r KENNETH I ANDERSON,Executive Director IDevelopment Department ------------------------------------------------------------------------------------------------------------------ KJH:gas:adw COMMISSION MEETING AGENDA MEETING DATE: 09/06/1994 Agenda Item Number: �� si-�w.c�Ro 4& A S S O C/R T E S August 31 1994 COMMERCIAL REAL ESTATE Mr. Tun Stemhaus Agency Administrator Economic Development Agency 201 N. "E" Street, 3rd Floor San Bernardino, CA 92401 RE: 570 W. Fourth Street San Bernardino, CA Dear Mr. Steinhaus: In regards to the loan due August 31, 1994, enclosed please find the letter from the FDIC to verify what I am telling you. Also enclosed is the scenario from Charles C. Green regarding our past experience with the FDIC. I am requesting a ninety day extension on the loan as I am presently pursuing a discount on the original note to American Commerce Bank, who was seized by the FDIC. The FDIC is currently doing an appraisal on the building which will take approximately sixty days. I feel there is a good possibility of having the note discounted from 1,300,000 to somewhere in the neighborhood of 1,000,000. Once the appraisal is back from the FDIC, new financing will be obtained on the building. At that time I would pay not only the interim loan but also the $350,000 that was loaned to me on the purchase, taking the City completely out of it. The City will remain a 25% partner in the building. As you know on October 1, the rent for Concordia College goes from $8,814.00 to $18,150.63. 1887 Business Center Drive, Suite 3 San Bernardino, California 92408 Tel. (909)381-9922 FAX(909)381-2481 j, This building has been a struggle because the FDIC seized the building and we had to make rent concessions of 50% rent for the first year in order to keep our tenants. We also have invested in excess of$125,000 of our own funds to complete the tenant improvements and maintain the building. We have succeeded in making it through our first year and the future for the building is very bright. Thanking�iou in advance, I remain, Allan B. Steward President, CEO ABS/ks encls cc:Ken Henderson I lLI FDIC ' `. ; Federal Deposit Insurance Corporation e.'�,a' :.'�f P.O. sox 7549 Newpon Beach, CA 92658-7549 1714) 263-7100 ♦ FAX 1714) 263-7242 August 4, 1994 Mr. Allan Steward Allan Steward, Inc. c/o Steward and Associates 1887 Business Center Drive San Bernardino, CA 92408 SUBJECT: AMERICAN COMMERCE NATIONAL BANK, 4576 Anaheim, CA - In Receivership LAMIS No. 501121231 ALLAN STEWARD, INC. Dear Mr. Steward: k As discussed today, the terms of the above-referenced note called for an interest rate of 4% for the first year and an interest rate of Bank Prime plus l% for the remainder of the note term, with interest payable monthly. Additionally, monthly principal payments of $10,250 were to commence on April 2, 1994. The FDIC agreed to allow you to cure the interest arrearage by paying $10,000 cash in December 1993 plus $2,000 over and above your regularly scheduled monthly payment until the arrearage was brought current. It is unfortunate that there was a misunderstanding over those terms and that the loan is still in arrears. The FDIC will consider a discounted payoff or loan workout/restructure offer to resolve _ t1- above-referenced asset. The basic criteria for a discounted payoff or workout is - tncial distress, i.e. an inability on the part of the debtor or guarantor to honor the t-.me of the obligation. The following information must be submitted to support any offer other than full payoff: 1. Current personal financial statement for Allan and Kathleen Steward (FDIC form enclosed) - notarized signatures 2. Current financial statement for Allan Steward, Inc. 3. Current financial statement for the guarantor, Redevelopment Agency of the City of San Bernardino 4. Copies of federal tax returns for the debtor and guarantors ` for 1992 and 1993 5. Income and expense information for the collateral property The information and offer must be received in this office no later than 5 p.m. on September 15, 1994. In the event your offer requires takeout refinancing, a commitment letter from the financial institution must be included in the information. If the obligation is still delinquent as of that date and an offer supported by the required information is not being considered by the FDIC, then collection action will recommence. The FDIC will arrange for an appraisal on the collateral property and will provide Spencer Browns name as the contact person. As discussed today, the appraisal information will be confidential to the FDIC. The data will be used in our financial analysis of your offer. The City of San Bernardino Redevelopment Agency will be sent a copy of this letter. Your financial situation, the value of the collateral property and the financial ability of the ILI SABO & GREEN A PEKJNW3Fd OVAL CO2POKATION Al-MENZY8 AT LAW F1T=H 400 6850 CAM)PGA AYTL-. tJm WOODLAND kuL.L.S,CALIFORNIA 91397 18181 70"IL95 TELECOPI$R(918)""720 XzKomm TO: Timothy C. Steinhaus FROM: Charles R. Green DATE: February 24, 1994 RE: FDIC Claim Relating to Al Steward owner Participation Agreement; our File SBE00001-58 As requested, I have undertaken to review the factual background and legal status of the claim which Al Steward asserts should be made against the Federal Deposit insurance Corporation ("FDIC") in connection with his acquisition of that real property located at 570 West 4th Street (the "Property") . As you know, the Agency entered into an Owner Participation Agreement (00FA") with Allan Steward, Inc. , whereby the Agency agreed to guarantee a loan made by American Commerce National Bank (the "Bank") to mr. Steward in the principal sum of $1,300,000, the proceeds of which were to be used to purchase the Property from the Bank. In addition, the Agency agreed to extend a loan of $350,000 to Mr. Steward to assist in the renovation of the structures located on the Property. Pursuant to the foregoing, Mr. Steward acquired the Property and began renovation. It appears from the documents which I have in my possession that the Bank agreed to complete certain tenant improvements on space leased to Concord Career Colleges and Inland Counties Legal Services, as well as to credit Mr. steward with the deposit of $18,724 from Concord career Colleges. The only document which has been provided to me which reflects the Bank's obligation to provide such tenant improvements is a letter dated February 17, 1 LL L7 J, Y..r'Y-i •• • •v Timothy C. Steinhaus February 24, 1994 Page 2 1993, from Robert G. Young, Senior vice-President. A copy of that letter is attached hereto as Attachment I. I requested copies of the purchase documents between tor. Steward and the Bank relating to the acquisition of the Property, and both Mr. steward and Spencer L. Brawn of Tri city Services, the individual acting as the agent for Mr. Steward, have advised me that there are no additional documents. Mr. steward indicates that there was no escrow, and therefore no escrow instructions, nor was there any formal purchase agreement. Mr. Brown, acting on behalf of Mr. Steward, filed a claim with the FDIC for reimbursement of $15o,000 of tenant improvements which Mr. Steward alleges were expended for tenant improvements that were the obligation of the Bank. on January 4, 1994, the FDIC rejected that claim. A copy of the letter rejecting the claim is attached hereto as Attachment 2. You will note that any legal action seeking to overcome this disallowance must be filed within sixty (60) days) from the date of the letter, or by March 4, 1994. THA zs$II� The issue presented is whether Mr. Steward has a claim under Federal law for enforcement of the agreement of the Bank as set forth in the letter of February 17, 1993. Following from that issue, of course, is the subsequent issue of whether the Agency would or should undertake to fund or otherwise participate in any litigation to enforce such a right. As will be seen in this Memorandum, I do not reach the policy issue of whether the Agency should participate inasmuch as I conclude that the claim is not valid in the first instance. The United States Congress has provided a comprehensive scheme for the operation of the FDIC, which is found at 12 U.S.C.A. The provisions which deal with the expenditure of FDIC funds are found at 12 U.S.C.A. Section 1823. More specifically, at Section 1823 (a) # Congress has outlined the legal requirements which pertain to any agreement which is asserted to diminish or defeat the interest of the FDIC in any asset acquired by it. The full text of 12 U.S.C.A. 1823 (e) is set forth as Attachment 3 hereto. As you can see, in order to assert any agreement against the interests of the FDIC, that agreement must meet four requirements, which are as follows: Timothy C. steinhaus February 24, 1994 Page 3 1. The agreement must be in writing; 2. The agreement must have been executed by the depository institution (i.e. , the Bank) , any pergqn clairnina an adverse interest thpreunst (i.e. , Mr. Steward) , including the obligor, and the execution of the agreement must have been contemporaneous with the acquisition of the asset by the depository institution; 3. The agreement must have been approved by the Board of Directors of the Bank or its loan committee, which approval must be reflected in the minutes of the Board or the Committee, and 4. The agreement must have been continuously, from the time of its execution, an official record of the Bank. The letter of February 17, 1993, upon which Mr. steward's claim is founded, does not meet the prima facie requirements) of Section 1823 (e) in the following respects. 1. Firstly, the letter cannot clearly be characterized as an "agreement." While it is a written document, it appears to memorialize an oral agreement rather than be an agreement in and of itself. 2. Even if this letter can be characterized as an agreement, it has not been executed by the person claiming an adverse interest thereunder (i.e. , Mr. steward) . 3. The requirement is that this letter have been written contemporaneously with the acquisition of the asset by the Bank. In this scenario, since the Bank was selling the Property to Mrr. Steward, the asset acquired by the Bank would appear to be the promissory note and deed of trust made by the Bank as a purchase money loan in favor of Mr. Steward, and which the Agency guaranteed. The records provided to me do not include copies of the purchase documents between Nr. Steward and thia Bank, and I am therefore unable to determine whether the letter of February 17 was executed contemporaneously with those purchase documents and the note and deed of trust. If the letter from the Bank followed the date of execution of the purchase documents, or even preceded the execution of those documents, by any significant degree, then this element of the requirement of Section 1823(e) has likewise not been met. 4. The last two requirement®, which are that the agreement have been approved by the Hoard of Directors or the loan / -r Timothy C. steinhaus February 24, 1994 Page 4 committee and have been continuously an official record of the Bank, are outside the scope of our knowledge at this time. The only way to determine whether these requirements have baen met would be the discovery process undertaken in a litigation matter. i The FDIC has indicated that there is no such record. In reviewing the Case law applicable to this situation, I found further evidence of the lack of viability of Mr. steward's claim. First of all, state law is preempted by federal statutes in this area, and we can therefore look only to federal law and the cases interpreting it. The United States Supreme court has created a doctrine, referred to as the "D'Oench Duhme Doctrine," which is a common law theory applied by the courts to any agreement which tends to diminish or defeat an interest of the FDIC in any asset acquired by it. Section 1823 merely codifies that doctrine. The courts have even gone beyond the bounds of Section 1823 (e) and applied this broader common law theory to protect the FDIC against such agreements. The D'oench Duhme Doctrine provides that the FDIC may not be held liable for a claim that is inconsistent with written documents of a failed banking institution or is based on unrecorded oral or written side agreements, and operates to bar both defenses and affirmative claims for relief that would either diminish the value of an insolvent institution or increase its liabilities. Torke v. FDIC, D. Colo. 1991, 761 F. Supp. 754. The federal policy of protecting the FDIC from such agreements is to assist the FDIC in preserving the integrity of the banking system in the United States. The primary purpose of the Doctrine is to allow federal and state bank examiners to rely on the Bank'a regular and official records in evaluating the worth of the Bank's assets. we West Federal SAM,, a d Lo n Assn. , 1992, 12 Cal. Rptr. 2d 468. The FDIC's actual knowledge or lack of knowledge of the agreement is irrelevant. If the agreement meets the requirements of the statute governing the use of side agreements, then it is valid even if the FDIC did not know of the agreement. However, any agreement that does not meet the statutory requirements fails even if the FDIC knew of it. FDIC v, ar wer, S.D. Doss. , 1993, 823 F. Supp. 1341. My analysis with regard to the nature of the "asset" acquired by the Sank as being Mr. Steward's obligation on the purchase money note is confirmed in the case of FDIC Y, 14Rnmttr E.D. Ark. 19881 688 F. Supp. 1327, which found that a maker's indebtedness on a note is an asset within the provisions of Section 1823(c) . Iq Timothy C. Stsinhaus February 24, 1994 Page 5 Mr. steward's reliance on a letter as a form of "agreement" is negated in the case of Fra 1jn A alch Ltd, partnership _Ys M s D.D.C. 1992, 794 F. Supp. 402, wherein the Court found that an agreement to increase a loan amount was not "executed" in the absence of formalities with respect to the making and signing of contracts, including the signatures of all parties. This is especially true in view of the fact that the criteria of the D10ench Duhme Doctrine, as codified in section 1823 (e) , are stringent and a failure to show satisfaction of each and every requirement is fatal to every claim or defense. TaIno Y. 901C, S.D. Fla. 1991, 782 F. Supp. 1538. Even "substantial compli.anca" is not sufficient. ' , Ill. App. 1 Dist. 1993, 618 N.E. 2d 818. The District court is specifically prohibited from attempting to balance the equitieg between the parties and is required to apply the strict letter of the statute. FDrC vv._ TWT ENploration Co. . Inc. , W.D. okl. 1985, 626 F. Supp. 149. In one cage dealing with escrow instructions where an individual purchased real property from a failed institution, the court found that escrow instructions requiring the completion Of a clubhouse on the real property were not binding on the government because, among other reasons, the escrow instructions were not contemporaneously executed with the loan documents, and were not mentioned in the nestings of the savings and loan association's board of directors or recorded in the association's records. It should be noted that, while the Doctrine clearly applies to breach of contract claims, it also applies to other forms of claims. For example, a debtor attempting to assert defenses of failure of consideration, estoppel and duress was not permitted to use an alleged agreement with the lender because the debtor could not show the basis for such defenses in writing from the minutes of the board of directors or loan committee meetings. There are a number of cases which find that fraud in the inducement in connection with any loan or contract cannot be asserted under the D'oench Duhme Doctrine, based upon the theory that bank examiners would not be able to ob6erve such defenses in the review of bank records. See, for example, In re 604 CoInatMA Ave, Rea v , C.A. i (Mass.) 19920 968 F. 2d 1332. Timothy C. Steinhaus February 24, 1994 Page 6 Based upon the material which is presently available and upon my understanding of the transaction as determined from those documents and discussions with Agency staff, Mr- Mr. and Mr. Brown, it is my conclusion that this claim cannot be successfully maintained in court. The sole basis presented to the FDIC by Mr. Brown in support of Mr. steward's claim was the letter of February 17, 1993. That letter clearly does not comply I prima facie requirements of 12 U.S.C.A. Section 1823(e) , nor am able to find any case law which would provide an exception to that statute and the facts presented. I therefore must conclude that prosecution of Steward's highly annotrocommand hat the Agency eith rYparticipatecinsor fund any Such litigation. 53BO=I\VI uoa z,24,94 zoo Iw I American Commerce NA-noNAL BANK 3t1n0 East La Palma,ltentle•AndblKiM.Caliicxn,a 92807 Telephone: 1:714'610-4.500•Teleivc 1::1.1 630.1493 February 17, 1943 Arlan Steward, Inc. 268 W. Hospitality Lane Suite 201 San Bernardino , Ca. 92408 Dear Kr . Steward: This is to advise you that American Commerce National Bank has agreed to the following e in connection with your purchase of 570 West Fourth Street, 1 . Tenant improvements on space leased to Concord Career Colleges and inland Countie' s legal Services will be completed by the kbank with a Certificate of •occupancy obtained by the bank. ` 2. The deposit check of $18,720 .00 from Concord Career Colleges f will be transferred to you within 72 bouts of closing the transaction. 3. property taxes will be paid by the bank up to 2/19/93 . If you have any questions please feel free to call. Sincerely, t Robert G. Young Senior vice r sides RGY7s1 t cc! Gerald Garner ATTACMMNT NO. 1 sa FDIC Federal Deposit Insurance Corporation Cl21=JS&Wernents1CW$1r%98 C8panment 17141 Z6s-7100 FAX 17741 2p-7667 p.0.Bat 7649 Newport 8"ch,CA 92668-7549 January 4, 1944 LO Spencer L. Brawn dba TRi CITY SERVICES 104 East State St. Redlands, CA 92373 Subject: 4576 American Commerce Bank N.A. Anaheim, CA - In Receivership Notl of 1J' al w rice f tai Dear Mr, Brown: On April 30, 1493, the American Commerce Bank N. A. located in Ana helm, CA was closed by Comptroller of the Currency, and the Federal Deposit insurance Corporation ("FDIC') was appointed as Receiver. Your claim on behalf of ALLAN STEWARD for $150,000.00 plus disallow your c elated the has been reviewed by the Receiver. The Receiver has determined following reason: The letter agreement on which the claim he b� does�°smut R���rfQrm of the law.writing 12 USC Section 1823 (e) requires that � by eitlser executed by the person cla'uning an interest thereunder; and have been approved the book's board of directors or its loan �t=��� t''.e��C a�reemen PProv� Ye he I Alean Stewat}d did not execute t1tC agreement. loan committee or the Board of Directors, and was not reflected on its minutes of meetings. �•E}t dicSat �tprmination You have the right to seek judicial determination a nor�rd rig disallowance o you clai claim obtain such review', you must file a lawsuit (or co p � the district or territorial court or the United states for located district widlig which United Status Distri Court for�the Bank N.A.'s prutcipal place of bilsines ' District of Columbia, within SIXTY (60) days of the date of this letter. ATTACHMFM N0. 2 . 4576 American Commerce tional Bank ' Spencer Brown/Allan Steward page two of two January 4, 1994 YOUR gAjLtMF,TO FILE SUIT (or mare the court to continue a prior pending action) ON OR BEFORE MTX DAYS FROM THE DATE OF THIS DETER, WILL RESULT YOU WILL HAVE I+iO FURTf[ER EtiT YOUR CLAIM BEING FOREVER pA�, ,� YOUR CLAIM.RIGHTS OR 1 Your only means of review of the disallowance of your claim is to file a lawsuit as set forth above. The statutory provisions governing this claims process t� to obtain advice rrom(dan ttorney of Title 12 of the United States Code. You may concerning the claims process; the FDIC cannot provide you with legal advice. If u have any questions, please contact Marietta D. Bertumen at (714) 263-7662 or at the Y'a above address. Sincerely. Roberta Valdez Department Head operations C 14 PAGE 9 12 USCG s 1823 offerors; (iv) prohibits discrimination o the basis of race, sex, or ethnic groups rs in the solicitation and consideration of offers; and (v) maximizes the preservation of the availability and affordability of residential real property for low- and moderate-income individuals. (4) Loans The Corporation, in its discretion, may make loans on the security of or may purchase and liquidate or sell any part of the assets of an insured depository institution which is now or may hereafter be in default. (e) Agreements against interests of Corporation No agreement which tends to diminish or defeat the interest of the corporatior in any asset acquired by it under this section or section 1821 of this title, depository t ginstitution,ashall be validragainstrthe Corporation unless such insured agreement-- (1) is in writing, (2) was executed by the depository institution and any person claiming an adverse interest thereunder, including the obligor, contemporaneously with the acquisition of the asset by the depository institution, (3) was approved by the board of directors of the depository institution or its loan committee, which approval shall be reflected in the minutes of said board or committee, and ab , s time of its execution, an official record of the depository institution. 'f) Assisted emergency interstate acquisitions (1) This subsection shall apply only to an acquisition of an insured bank or holding company by an out-of-State bank [FN3MV] savings association or out-of- State holding company for which the corporation provides assistance under subsection (e) of this section. (2) (A) Whenever an insured bank with total assets of $500,000,000 or more (as determined from its most recent report of condition) is in default, the Corporation, as receiver, may, in its discretion and upon such terms and conditions as the Corporation may determine, arrange the sale of assets of the bank in default and the assumption of the liabilities of the bank in default, including the sale of such assets to and the assumption of such liabilities by an insured depository institution located in the State where the bank in default was chartered but established by an out-of-State bank or holding company. Where otherwise lawfully required, a transaction under this subsection must be approved by the primary Federal or State supervisor of all parties thereto. (B) (i) Before making a determination to take any action under subparagraph (A) , the Corporation shall consult the state bank supervisor of the State in which the in default insured bank [F'N4MV) was chartered. (ii) The State bank supervisor shall be given a reasonable opportunity, and 0 ATTACIiM NT NO. 3 II FDIC Federal Deposit Insurance Corporation P.O. Box 7549 Newport Beach, CA 92658-7549 lk (714) 263-7100 ♦ FAX(714)263.7242 ~�F CG �� August 4, 1994 Mr. Allan Steward Alitn Steward, Inc. c/o St&:yard and Associates 1887 Business Center Drive San Bernardino, CA 92408 SUBJECT: AMERICAN COMMERCE NATIONAL BANK, 4576 Anaheim, CA - In Receivership LAMIS No. 501121231 ALLAN STEWARD, INC. Dear Mr. Steward: As discussed today, the terms of the above-referenced note called for an interest rate of 4% for the first year and an interest rate of Bank Prime plus 1• for the remainder of the note term, with interest payable monthly. Additionally, monthly principal payments of $10,250 were to commence on April 2, 1994. The FDIC agreed to allow you to cure the interest arrearage by paying $10,000 cash in December 1993 plus $2,000 over and above your regularly scheduled monthly payment until the arrearage was brought current. It is unfortunate that there was a misunderstanding over those terms and that the loan is still in arrears. FDIC will consider a discounted payoff or loan workout/restructure offer to resolve ,_j above-referenced asset. The basic criteria for a discounted payoff or workout is financial distress, i.e. an inability on the part of the debtor or guarantor to honor the .terms of the obligation. The following information must be submitted to support any offer other than full payoff: 1. Current personal financial statement for Allan and Kathleen Steward (FDIC form enclosed) - notarized signatures 2. Current financial statement for Allan Steward, Inc. . 3. Current financial statement for the guarantor, Redevelopment Agency of the City of San Bernardino 4. Copies of federal tax returns for the debtor and guarantors for 1992 and 1993 S. Income and expense information for the collateral property The information and offer must be received in this office no later than 5 p.m. on September 15, 1994. In the event your offer requires takeout refinancing, a commitment letter from the financial institution must be included in the information. If the obligation is still delinquent as of that date and an offer supported by the required information is not being considered by the FDIC, then collection action will recommence. The FDIC will arrange for an appraisal on the collateral property and will provide Spencer Brown's name as the contact person. As discussed today, the appraisal information will be confidential to the FDIC. The data will be used in our financial analysis of your offer. T' City of San Bernardino Redevelopment Agency will be sent a copy of this letter. Your i icial situation, the value of the collateral property and the financial ability of the s----- �--- ---•�� .�• -v. Page Two August 4, 1994 :antors will all be considered in analyzing the feasibility of your offer. it is assumed that the Redevelopment Agency of the City of San Bernardino executed the guaranty in good faith and is prepared to honor its obligation if necessary. Please contact the undersigned at (714) 263-7192 to discuss this matter further if you have any questions or comments. Very truly yours, 412d� Patricia Bolster Credit Specialist Ic Guarantors: Allan and Kathleen Steward Redevelopment Agency of the City of San Bernardino