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“The Western Pennsylvania Senior Living Limited Partnership (‘Western PA’) loan was a $4.5-million participation loan. AMB was to be the lead lender of the Western PA loan in the amount of $3 million, and the remaining $1.5 million was to be participated to another bank. The purpose of the loan was to allow borrowers to purchase three mortgages at a 22 percent discount on the face amount, secured by two assisted-living facilities and raw land in New Stanton, Pennsylvania. Despite the deficiencies discussed below, Townsend ‘crammed down’ this loan and personally wired the funds on or about December 28, 2006, without obtaining loan committee approval.”
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