This page will be used to provide updates on developments in the bankruptcy case and other matters since the Trustee's last Status Report.
You may need to click here www.adobe.com to download the program to review any court documents on this page
Criminal Re-sentence Updates
Date of Re-sentence Hearing
23 years (reduced)
Alan R. Lewis
6/8/2007 at 10:30 a.m.
To be updated after hearing (30 years)
6/8/2007 at 9:30 a.m.
To be updated after hearing (20 years)
You are most welcome to attend the sentencing and you may even ask to say a few words to the Court about how this scam hurt you. The presence of many victims in the past sure made an impression, but please understand space is limited and you are not obligated to attend. We understand it would be very inconvenient and difficult for many of you attend even though we are sure you are very interested in seeing these felons receive long sentences in prison.
For Directions Please Click Here.
Louis Ratfield Update - Posted May 1, 2007
Following a five-week trial, a federal jury in West Palm Beach found defendant Louis Wayne Ratfield, a Lake Worth, Fla., tax return preparer, guilty on 50 charges against him in connection with his participation in a tax fraud scheme to hide income and assets in bogus trusts.
Ratfield marketed common law trust packages to clients throughout the United States via group seminars and individual client meetings; sold over 100 trust packages at prices ranging from $2,995 to $5,995 each; and prepared at least 252 federal tax returns in connection with the scheme. The evidence at trial established that once the IRS began auditing his clients, Ratfield took numerous unlawful steps to obstruct and impede the audits. According to the indictment, Ratfields conduct caused a tax loss to the U.S. Treasury of more than $6.4 million.
Ratfield was also the tax preparer for many of the Finfed victims and created common law trusts for them as well. This conviction and any restitition is not associated with Finfed, but I am sure many of you would like to know he was found guilty and was placed in custody immediately following the conviction. For those interested, we will post his sentencing date on this website, which will be scheduled shortly. For each of the 50 Counts of preparing false returns and corruptly impeding the tax laws carriers a penalty of up to three years. To read the full press release from the Department of Justice please click here.
Criminal Re-sentencing - Posted March 16, 2007
The Court has rescheduled the sentencing of the following defendants for Friday, May 4, 2007:
Wanda Tirado 11:00 pm
Garland Hogan 1:30 pm
Gary Pierce 2:30 pm
Zane Balsam 3:00 pm
Alan Richard Lewis 3:30 pm
If you are a victim and wish to attend, please contact Monica Bruce Ramdath at (305) 377-0661. You are most welcome to attend the sentencing and you may even ask to say a few words to the Court about how this scam hurt you. The presence of many victims in the past sure made an impression, but please understand space is limited and you are not obligated to attend. We understand it would be very inconvenient and difficult for many of you attend even though we are sure you are very interested in seeing these felons receive long sentences in prison. Please contact Monica to let her know that you are going to be attending. For address and directions, please click Courthouse.
For Directions Please Click Here.
Criminal Resentencing Update - Posted January 10, 2007
On January 5, 2007, in accordance with the U.S. Supreme Court ruling and after review of the record, the 11th District Court of Appeals entered an an order affirming the criminal convictions and remanding the case for resentencing. The 11th Circuit Court Appeals' order will now require Judge Hurley to proceed with resentencing of the criminal defendants. The criminals guilty convictions remain unchanged, and they are still incarcerated within the Federal Bureau of Prisons. As soon as Judge Hurley schedules the resentencing of the criminals, we will immediately post the information on this website.
November 4, 2005/Supreme Court Judgment - Defendants Sentencing
The individuals who were convicted for defrauding you through Financial Federated and American Benefits appealed to the Supreme Court of the United States and the highest court remanded the sentencing portion of their judgment to the Circuit Court of Appeals and now the convicted felons will need to be resentenced. This means that there will be a delay in issuing the final distribution, because all appeals must be final before I can distribute the proceeds from the remaining assets which were forfeited by the criminals. While I understand this is a disappointment to the victims who wish to put this matter behind, I have no control over the appeals and I am not involved in this process. I will update this website with information from the Courts on this matter, as soon as the information becomes available.
March 16, 2005/Zane Balsam Appeal
Zane Balsam and Juan Arroyo filed a Petition with the U.S. Supreme Court, thereby appealing the June 24, 2004, 11th Circuit Court of Appeals opinion upholding their respective sentences handed down at Finfed/ABS trial. This case is currently pending before the Supreme Court. The Government's response to the Petition is due May 23, 2005.
March 15, 2005 and April 27, 2005/Ray and Ronalee Levy Sentencing US Capital Case.
Ray Levy was sentenced a term of imprisonment of approximately nineteen and half years (19.5) and supervised release of three (3) years for his role in the U.S. Capital Funding scam. On April 27, 2005, Ray Levy's daughter, Ronalee Orlick Levy, was sentenced to 5 years in prison for her role in the U.S. Capital Funding scam. It was alleged that Defendant Ray Levy recruited hundreds of insurance agents throughout the country to solicit approximately $48 million be sent to U.S. Capital Funding from approximately 400 investors residing in Florida, New York, Indiana, Virginia, Maine, New Hampshire, and Washington. According to statements made in court, of the $48 million, approximately $33 million was forwarded to First Capital Services by U.S. Capital Funding. The entire $33 million was lost. It was alleged that Orlick caused interest and principal payments to be made to pre-existing investors with funds received not from earnings on their investments, but rather simply from new investor funds. .
March 1, 2005/Levy Appeal
Raphael Levy filed a Petition with the U.S. Supreme Court, thereby appealing the June 23, 2004, 11th Circuit Court of Appeals opinion upholding his sentence of 14 years handed down at Finfed/ABS trial. This case is currently pending before the Supreme Court. The Government's response to the Petition was due May 4, 2005.
September 29, 2004-- 1st Distict Court of appeals in Tallahassee
The 1st District Court of Appeal in Tallahassee, Per Quriam, the lower court's Final Judgment of Dismissal of the class action lawsuit filed against the Department of Insurance. This simply means that the court agreed with the lower court's decision to dismiss the class action lawsuit. As you may recall, the suit was predicated on allegations that it breached its duty owed to the victims of Finfed/ABS. The case was dismissed by the lower court, in part, on the doctrine of sovereign immunity which the court held resulted in an absolute shield protecting the Department of Insurance.
August 15, 2004-- Notice to Victims
As you may recall, we previously advised the state class action suit against the Department of Insurance, filed by Benjamin Schwartzman, on behalf of the victims in the FinFed fraud, was dismissed last year. However, the Court's Order of dismissal was appealed to Florida's First District Court of Appeals, in Tallahassee. The court has scheduled Oral Argument of the appeal for Friday, September 24, 2004 at 9:00 a.m. If you live near Tallahassee and wish to attend the Oral Argument, click here for driving and parking instructions http://www.1dca.org/courthouseinfo.html#Parking Remember, Identification is required to gain access to the building, and no cell phones are permitted.
We will, of course, keep you posted as new developments arise. Be sure to periodically check our website for updates. We have updated our "recent developments" link at www.finfedinfo.com
August 3,2004-- Criminal Appeals News Update
The 11th Circuit Court of Appeal denied Ray Levy’s Petition for Rehearing.
June 23,2004-- Criminal Appeals News Update
The 11th Circuit Court of Appeals affirmed the U.S. District Court’s sentence of 14 years. Ray Levy argued that the Government breached the plea agreement and the district court deprived him of due process. In part, Levy argued against a vulnerable victim and role enhancements, and by allowing testimony of nine victims. The 11th Circuit Court Appeals concluded that the lower court did not deprive Levy of due process by considering John W. Kozyak’s and the victims’ statements in determining whether to apply the vulnerable victim enhancement [which ultimately lead to four additional years.
April 14 ,2004-- Criminal Appeals News Update:
New Addition to the site: Jewelry Sales for upcoming action. The date has yet to be announced.
December 12, 2002-- TAX ADVICE:
I have repeatedly told you I could not provide you with tax advice. I just learned that the J.K. Harris Company has sent many of you letters offering tax help if you act quickly. I have absolutely no connection or familiarity with this company and have no opinion regarding the services it is trying to sell you.
Please do not call or write Monica Bruce or me about tax advice, the J.K. Harris Company or others may have gotten your name and address from the court file.
July 23, 2002 - BRANDAU’S APPEAL:
We are pleased to inform you that on July 23, 2002, the United States Court of Appeals for the Eleventh Circuit affirmed the conviction of Frederick C. Brandau. In a 23 page opinion the court found that the evidence was sufficient to uphold the findings of guilt on 43 counts, including mail fraud and money laundering. In addition, the court affirmed the 55 year sentence imposed by the district court.
July 9, 2002 SEC vs. BRANDAU, LEVY AND PAINE
On May 9, 2000, the SEC filed an administrative complaint against Frederick Brandau, Ray Levy and Jeffrey Paine in the Federal District Court, Southern Division of Florida, for violations stemming their participation in the FinFed fraud, which involved the unregistered distribution of investment contracts, for engaging in an unregistered distribution of securities and being unregistered brokers/agents.
According to the SEC's litigation press release, on July 8, 2002 and July 9, 2002 the Court entered Final Judgments of Permanent Injunction against Ray Levy and Jeffrey Paine. The Judgments bar them from being associated with any registered broker-dealer and ordered civil penalties.
June 25, 2002 - Brandau Appeal
On June 25, 2002, the United States Court of Appeals for the Eleventh Circuit, heard argument on the appeal of the conviction and sentence of Frederick C. Brandau. Brandau argued the following issues: whether there was sufficient evidence to sustain the conviction; whether the length of sentence was cruel and unusual; and whether the victims were vulnerable as defined by the law. An Opinion is not expected for quite some time, which could possibly take up to a year or more before one is rendered.
APRIL 4, 2002: COURT RULINGS
GARY PIERCE, 51, of Studio City, California, was sentenced in connection with his conviction on multiple counts of mail fraud and money laundering. He was previously convicted of conspiracy to commit mail fraud, conspiracy to commit money laundering, and two counts of money laundering relating to his role in taking over Financial Federated Title & Trust. During a three-month trial last year in West Palm Beach, federal prosecutors demonstrated that Financial Federated was a massive Ponzi scheme in which old investors were paid with new investors' monies.
PIERCE was sentenced to a term of 240 months' (20 years) incarceration, $31,093,005.35 in restitution, 3 years' supervised release and a special assessment of $400.
Attorney GARLAND HOGAN, 46, of Ft. Lauderdale, Florida, was sentenced in connection with his conviction on multiple counts of mail fraud and money laundering. In July, 2001, Hogan had been convicted of ten counts of mail fraud, and three counts of money laundering relating to his role as in house attorney for Financial Federated Title & Trust. Acting as the attorney for Financial Federated GARLAND HOGAN personally signed hundreds of fraudulent insurance assignments falsely attesting to the existence of real viaticated insurance benefits.
HOGAN was sentenced to a term of 324 months (27 years) incarceration, $108,947,157.73 restitution, 3 years supervised release and a special assessment of $1,200.
We will continue to bring you updates on the remaining defendants' sentences, which are continuing this week.
JANUARY 24, 2002: NOTICE OF SALE OF PROPERTY
You can read this document Here.
NOVEMBER 30, 2001 UPDATE: RAY LEVY SENTENCED:
Ray Levy successfully postponed his sentencing hearing from June 29th until November 30th. Many of you expressed disappointment that he had been permitted to plea bargain by admitting two counts of conspiring to commit mail fraud and conspiring to commit money laundering, which carried a maximum 10 year sentence.
The courtroom was packed on November 30th with more than eighty victims. The probation officer had submitted a presentence investigative report, which recommended more than a ten year sentence, because the probation officer had determined Mr. levy was one of the principals in the fraud and had preyed upon elderly people. Mr. Levy's lawyer objected to those conclusions and the prosecutors reluctantly advised Judge Hurley that the terms of the plea agreement precluded the government from introducing evidence on those points. Fortunately, about eight or nine victims volunteered to testify and they told Judge Hurley how they had been swindled. Several of them had direct communications with Mr. Levy. Approximately 40 investors had also submitted notarized victim statements, which I tried to introduce into evidence.
U.S. District Court Judge Daniel T.K. Hurley sentenced Ray Levy to 14 years, after determining he was a principal in the fraud scheme and had targeted elderly investors. Mr. Levy will also forfeit his interest in vehicles, which had been seized, and he was ordered to pay $117 million in restitution. Following the sentencing Mr. Levy was taken into custody and started serving his sentence. I sincerely appreciate the victims who helped us add more years onto his sentence.
November 29, 2001
The second distribution of payments under the Bankruptcy Plan and the Criminal Restitution order should be made within two weeks. The Trustee fully recognizes he advised victims in July that he expected to make the next distribution before Thanksgiving. We are approximately two weeks behind
that schedule and will explain the delays in the status letter accompanying the checks. We know you are anxious and are doing everything possible to get the next checks out to you.
Ray Levy's sentencing hearing is still scheduled to take place on Friday, November 30th at the Federal Building, 701 Clematis Street, W. Palm Beach, Florida at 9:30 A.M. Please check with the U.S. Marshal as you enter the building to confirm the courtroom this will be held in, if you are planning to attend. We have asked for the largest room, because we expect and want a very large crowd. If you decide to attend BRING A PHOTO ID in order to enter the courtroom.
November 28, 2001:
The US Attorneys' Office filed a pleading this morning stating its position regarding Mr. Ray Levy's sentencing. Pursuant to the government's plea agreement with Mr. Levy, it is contractually obligated not to recommend more than a 10 year sentence, even though the Probation Office, acting as an arm of the Court prepared a pre-sentencing report and recommended an offense level which would subject Mr. Levy to a 14 to 17.5 year sentence under the sentencing guidelines.
The US Attorneys' Office had been provided with a notebook prepared by Mr. Kozyak's paralegal, including approximately 40 notarized statements from victims. The US Attorneys Office has stated that it is not in a position to introduce evidence which might result in a sentence higher than 10 years, according to the pleading filed today.
Mr. Kozyak is expecting a large turnout of victims for the sentencing hearing on Friday . He has been advised a number of victims are driving long distance to confront Mr. Levy before he is sentenced.
November 9, 2001 Update
The Trustee has filed a motion to approve the sale of two large insurance policies on the same person. The combined face amount of the two policies is $2.5 million and the Trustee will receive $806,000 or approximately 32%. The estate will also be spared $76,000 in premiums annually for these two policies.
The sale of these two policies is subject to better or higher offers. If you are aware of anyone who might be interested in purchasing these or any of the policies, more information can be obtained from Scott Page, Wm. Scott Page & Associates, 2110 East Oakland Blvd., Suite 300, Fort Lauderdale, Florida 33308, Phone (954) 568-3658.
Despite what was promised and "sold" to the victims of this Ponzi scheme, relatively few of the viators died within the projected periods and few policies have matured to date. It is now costing tens of thousands of dollars annually to maintain these policies. The Trustee is investigating ways to sell some of them in an effort to raise money for distribution to the victims and to reduce expenses. The Trustee has refused to "dump" the policies and will hold onto them, like he did with the seized real estate, until he can obtain fair offers.
October 8, 2001:
News Release from Department of Justice:
Guy A. Lewis, United States Attorney for the Southern District of Florida, Hector M. Pesquera, Special Agent in Charge, Federal Bureau of Investigation, Miami Field Division, and Jose Marrero, Special Agent in Charge, Criminal Investigation Division, Internal Revenue Service, Southeast Region, Plantation announced today that IVAN BURGOS, of Weston, Florida, was sentenced in connection with his guilty plea to conspiracy to engage in money laundering in connection with FINANCIAL FEDERATED TITLE & TRUST. BURGOS acknowledged engaging in money laundering in the amount of $1,757,835.31, which represents automobiles and real estate bought with victim money. BURGOS, was sentenced to a term of 37 months incarceration, $1,757,835.31 restitution, $10,000.00 fine, 3 years supervised release and a special assessment of $100.00.
Mr. Lewis commended the efforts of Federal Bureau of Investigation Special Agents Gary Van Eerde, Anthony L. Yanketis, Gary Hellmer, and Stephen Lucchesi; and Internal Revenue Service Special Agents Klaus Hurme and Suzanne Kalwara for their detailed efforts in uncovering the massive scheme that led to the indictment. Mr. Lewis also recognized the contributions of the State of Florida, Department of Banking & Finance, to the prosecution effort. Mr. Lewis commended the efforts of Korinne Harper, financial analyst with the Department of Banking & Finance, for her analytical work in tracing funds related to the underlying fraud. The case is being prosecuted by Assistant United States Attorneys Ellen Cohen and Steve Carlton in West Palm Beach, Florida.
September 13, 2001: CSI Ag Ltd., a Bahamian corporation, was sentenced to 5 years probation and the forfeiture of numerous houses, three motor vehicles, and three bank accounts located in the Bahamas after being found guilty of conspiracy to commit mail and wire fraud and conspiracy to engage in money laundering in connection with Financial Federated Title & Trust. Like all the other convicted defendants, CSI was ordered to pay restitution in the amount of $122,527,160, and a special assessment in the amount of $800, but this company is not the multi-million dollar international business operation Gary Pierce touted it as when he was attempting to lull investors and throw the government off FinFed’s trail. After the forfeited property is sold, it will be distributed to the victims of this massive fraud, but there will still be very major losses. The recent set of convictions has not yet resulted in the discovery of substantial, new assets. This sentencing is important because it will make it possible to make another restitution distribution to investors this calendar year. The amounts and date have not been determined.
September 12, 2001: The State Securities Board conducted a joint investigation of American Benefits Services and Financial Federated Title & Trust with the Florida Comptroller Department of Banking & Finance, the Florida Department of Insurance, and the Tennessee Attorney General's Office. The Tarrant County Grand Jury in the state of Texas returned 15 indictments against 5 individuals for violations of the Texas Securities Act in connection with the sales of certificates of viaticated insurance benefits issued by Fiunancial Federated Title & Trust, Inc., and American Benefits Services, Inc. Indicted for sales of unregistered securities and selling securities without being registered as a securities dealer or sales agent were Ronalee Levy Orlick, the Vice-President of American Benefits Services, Inc., of Wellington, Florida, Ihor A. "Gary" Humesky, the President of U.S. Investors Group, Inc., of Clearwater, Florida, Montgomery Lee Merrell, Owner of CMI financial of Fort Worth, Sharon Jane Hutchinson of Fort Worth, and Kenneth Dale Ledford, doing business as Cornerstone Financial, of Arlington, Texas. Ronalee Orlick also was indicted for engaging in fraud in connection with the sales of certificates of viaticated benefits issued by American Benefits Services in June of 1999, after the Texas Securities Commissioner had issued a Cease and Desist Order against American Benefits Services, Inc. The sales of the certificates of viaticated benefits to the Tarrant County investors took place from September of 1998 through June of 1999.
August 28, 2001: Guy A. Lewis, United States Attorney for the Southern District of Florida, Hector M. Pesquera, Special Agent in Charge, Federal Bureau of Investigation, Miami Field Division, and Jose Marrero, Special Agent in Charge, Criminal Investigation Division, Internal Revenue Service, Southeast Region, Plantation announced today that HARVEY BRANDAU, 64, of Wellington, Florida, was sentenced in connection with his guilty plea to conspiracy to engage in money laundering in connection with FINANCIAL FEDERATED TITLE & TRUST. BRANDAU earlier acknowledged engaging in money laundering in the amount of $167,250.00, which represents an Aston Martin automobile bought with victim money for Harvey Brandau. Brandau is the brother of Frederick C. Brandau, the leader of the Financial Federated scheme. Brandau, was sentenced to a term of 15 months incarceration, $858,455.71 restitution, $5,000.00 fine, 3 years supervised release and a special assessment of $100.00. Brandau was remanded to the custody of the United States Marshal at the conclusion of the hearing.
August 15, 2001: Please note that the sentencing of Ray Levy and Ivan Burgos have been POSTPONED. The sentencing hearing WILL NOT occur on August 24. Ray Levy's sentencing has been rescheduled to November 30, 2001 at 9:30 a.m. Ivan Burgos' sentencing has not yet been rescheduled. Harvey Brandau's sentencing remains on schedule for August 24, 2001 at 2:00 p.m. The U.S. District Court's website has Driving Instructions.
August 6, 2001: On August 3, 2001 Jeffrey Paine was sentenced to five years in prison plus restitution after he plead guilty to conspiracy to engage in wire fraud and mail fraud. Here is a link to the U.S. Attorney's Press Release.
July 16, 2001: On July 9, 2001 Bankruptcy Judge Ray entered an Order in the Trustee's action against ABS Trust determining that the ABS Policies, with a face value of approximately $18 million, are property of the bankruptcy estate and not the separate property of the ABS Trust investors. A copy of the Order Granting Trustee's Motion for Summary Judgment Against ABS Trust is reproduced here.
July 12, 2001: On July 11, 2001 the jury convicted all of the remaining defendants in the Criminal Case, finding them guilty of all charges. The remaining defendants were Gary Pierce, Gar Hogan, Zane Balsam, Al Lewis, Wanda Tirado, Juan Arroyo, and CSI Ag., Ltd. All of the defendants have been taken into the custody of the U.S. Marshal.
June 21, 2001: On June 20, Bankruptcy Judge Raymond B. Ray entered an order confirming the Trustee's Chapter 11 Plan. All creditors will be receiving a copy of the Order, as required by the Court. The Order also has been reproduced on this website: FinFed Confirmation Order. The confirmation of the Plan enables the Trustee to start preparing to make an initial distribution to creditors, which should occur in the next 30 days.
June 18, 2001: On June 15,2001 U.S. District Court Judge Hurley sentenced Ms. Cheryl Poindexter to one year and one day in prison. According to the plea agreement she had reached with the U.S. Attorneys' Office her sentence under the applicable guidelines was 12-18 months and the government recommended the lower range. She was also ordered to pay $759,000, but there is little expectation she will actually pay anything. All restitution payments will be distributed to FinFed victims.
Ms. Poindexter is a 53 year old business woman who had a relationship with Gary Pierce for approximately eight years before he was arrested in connection with his role in the FinFed fraud. Investors may recall receiving letters in the summer of 1999 promising that Gary Pierce controlled a company, CSI Ag.Ltd., which had the resources to pay all of the FinFed investors. In reality, Ms. Poindexter had supported Mr. Pierce, a convicted armored car robber, for most of their relationship until Fred Brandau showed up and started giving Ms. Poindexter and Mr. Pierce money and valuables, including a new Corvette.
Ellen Cohen, the lead prosecutor, had warned Ms. Poindexter to stay away from Gary Pierce when Poindexter testified before the Grand Jury. Instead, she helped funnel money from the Bahamas through a neighbor to Mr. Pierce's former criminal lawyer.
Ms. Poindexter's lawyer made an articulate argument to Judge Hurley and pointed out that his client had no previous criminal experiences and that she had a history of abuse, including physical and mental abuse imposed by Mr. Pierce. The lawyer argued that her business and ability to care for her father would be destroyed if she was incarcerated. He asked for probation or house arrest. At a minimum he wanted Ms. Poindexter to be able to voluntarily surrender to her prison. I was again impressed by Judge Hurley's grasp of the facts underlying the FinFed fraud. He ruled that Ms. Poindexter was "in the criminal activity with both feet" and that she had not met her burden to show that her actions were coerced. Ms. Poindexter was immediately taken into custody and was quite emotional.
Judge Hurley also sentenced American Benefits Services ("ABS") on Friday, June 15th. Trustee Kozyak appeared for ABS and had agreed to plead guilty to 5 years of probation, to not engage in the sale of viaticals, and most importantly, to turn over all available funds for restitution. Mr. Kozyak advised Judge Hurley that his bankruptcy plan was set for confirmation on Wednesday, June 20, and that he expected to make a bankruptcy distribution within a few weeks thereafter. He also mentioned that he would distribute the proceeds from the assets the government had seized as soon as the criminal forfeiture process would permit him to do so. Ms. Cohen advised the Court that $1.4 million would be available for distribution with bankruptcy court checks in July and that several million dollars were in the pipeline and would be made available to Mr. Kozyak in his capacity as Restitution Receiver as soon as possible. There should be a minimum of $8 million available from the houses and helicopters and watercraft which Mr. Kozyak and the government have already sold, if the criminal forfeiture process is successful. Hopefully, this process will not only be successful but also completed by the Fall, so that an additional restitution check can be distributed to victims (Note: trade creditors and assignees of claims must read the Plan and prior communications which detail why they are not entitled to a criminal restitution distribution).
June 15, 2001: The Florida Office of the Comptroller, Department of Banking and Finance, has changed position and has now agreed that it will seek restitution payments from the more than 100 brokers against whom it filed administrative complaints. We are extremely grateful that the Comptroller's Office has listened to the requests of the Trustee and the hundreds of investors who wrote to Comptroller Robert Milligan, Governor Jeb Bush, their State Representatives, and others, asking that the Department seek restitution for victims rather than fines which would go to the State. A copy of the letter being sent to investors by Gilford G. Robinson, Regional Director of the Department of Banking and Finance, is reproduced here: Comptroller's Letter.