Old Glory Bank

Elmore City, OK 2022--2024 Community Banks / Credit Unions
FDIC Oklahoma State Banking Department Capital Adequacy Unsafe Unsound Practices Strategic Planning Interest Rate Risk
Penalty
$0

Outcome

Old Glory Bank of Elmore City, Oklahoma — a self-described "anti-woke" patriotism-themed community bank — entered an FDIC consent order on May 1, 2024 for unsafe and unsound banking practices after posting losses in its first year of operation, requiring the bank to maintain a 14% Tier 1 leverage ratio, update its three-year business plan, restrict dividend and bonus payments, and obtain prior regulatory approval for 10%+ balance sheet deviations.

Details

Old Glory Bank — FDIC Consent Order: Capital and Safety and Soundness (2024)

Outcome: Old Glory Bank of Elmore City, Oklahoma, a de novo community bank that marketed itself using patriotism and "anti-woke" themes, entered an FDIC consent order effective May 1, 2024 (Docket FDIC-24-0016b) for unsafe and unsound banking practices after sustaining losses during its first year of operation, with the bank required to maintain a 14% Tier 1 leverage ratio, restrict executive compensation and dividends, update its business plan through 2026, and obtain prior regulatory approval before any significant balance sheet deviation.

Old Glory Bank was chartered as a de novo community bank in Elmore City, Oklahoma, positioning itself in the "patriotism" banking niche — advertising itself as an "anti-woke" banking alternative and focusing its brand on American values themes. The bank launched in 2022 and posted operating losses during its first year, creating capital adequacy concerns that triggered the FDIC and Oklahoma State Banking Department's enforcement response.

The consent order's capital requirements were significantly more stringent than standard well-capitalized minimums: Old Glory Bank was required to maintain its Tier 1 leverage capital ratio at 14% of average total assets — compared to the standard 5% well-capitalized threshold — to provide a substantial capital cushion while the bank addressed its operational losses and business model challenges. As of March 31 before the order, the bank had a CET1 ratio of approximately 9.2%, well below the 14% consent order requirement.

Additional requirements included: updating the 2022 original business plan with specific projections for 2024–2026 covering earnings, budget, growth, balance sheet mix, liability structure, and capital; obtaining prior regulatory approval before any balance sheet account deviation of 10% or more; quarterly board review and documentation of interest rate risk management model results; no dividend or bonus payments without prior written FDIC and state approval; and mandatory notification and state approval before adding any director or hiring any executive officer.

Primary Source: FDIC Consent Order FDIC-24-0016b — Old Glory Bank (May 1, 2024)

How Crucible Prevents This

Crucible's quality-gate hook would flag business plans where projected revenue and capital retention were inconsistent with actual first-year performance data. The instinct-observer would detect the pattern of first-year losses combined with a capital ratio below the required consent order threshold. The pre-tool-check hook would require board-approved capital projections and stress test results before approving any significant balance sheet change.

Source: FDIC Consent Order FDIC-24-0016b — Old Glory Bank (May 1, 2024)

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