Oh, yes indeed that letter. Not only the double talk about the 144's and increasing the number of shares but this little bit of deceptive representation:
Having a thrift on the team provides PanAmerican BanCorp with liquidity and added stability.
Too bad that the only liquidity that the thrift can provide is profits if they happen to ever make any. They are prohibited from making loans or pledging assets to other aspects of the PABN/PRWT empire. And of course they have to actually file if they ever want to start one. Hahahahahaha.
Congress also recognized, however, the difference between, on the one hand, the traditional thrift focus on home mortgage lending and ancillary consumer services and, on the other hand, the commercial lending and more wide-ranging business-oriented services provided by banks. In recent years, the major thrust of legislation has been aimed not at curbing the unrelated business activities of thrift holding companies, but rather at reinforcing the residential and consumer lending mission of their subsidiary associations. Congress first imposed a "qualified thrift lender test" ("QTL test") of "thriftness" on savings associations in 1987. Failure of a savings association to meet the QTL test can lead to substantial operational sanctions for a subsidiary thrift, and, more significantly, to required divestiture of non-banking business activities for the parent unitary holding company.2 Two years later, Congress barred thrifts from making loans or extension of credit to affiliates engaged in non-banking activities.
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