disclosures that might go back to the childhood of the applicants, their place
of origin, their education, their financial details, their criminal records, and
their business history, in detail. The application also called for a complete
description of the reasons why the new control persons wanted to take con-
trol of the bank, how they would operate the bank, what their business
plans were for the bank, and how they would serve and improve the bank’s
service to the community. The regulators also required that the new control
group prepare a complete business plan for the bank’s future budget and
financial projections.
In an effort to reduce legal expenses and the pre-acquisition cost, our
team first took the applications from Mr. Findley’s office and then would
spend very long nights completing them and preparing the plans and reports
the application requested. In many cases, some of us were traveling out of
the country and would operate via telephone and fax, because the Internet
was not popular yet. We would send the completed forms and reports to
Mr. Findley, who would edit them and pass them on to the regulators. The
regulators would respond with more questions and inquiries for Mr. Find-
ley, who would pass them on to us. We would again prepare the detailed
answers to these questions. The word ‘‘detailed’’ here sometimes worked to
our detriment because, as we learned from Mr. Findley’s office, when we
got a question from a government agency, that question had to be answered
in a specific fashion, in full and clear details, and in a direct way, without
opening new topics or subjects. Not abiding by these rules and course of
action triggered more questions. The process took approximately one year
of back-and-forth communications that culminated in a telephone meeting
in January 1998 (duringRamadan) that was attended by:
&The OCC in California and in Washington, D.C.
&The Federal Reserve Bank in Washington, D.C. and the Federal
Reserve Bank of San Francisco
&The FDIC in Washington, D.C.
&Mr. Gary Findley and his associate
&Our teamThegovernmentagentsthankedus—theapplicants—for‘‘...your
patience, perseverance, detailed answers, and your posture as humble pro-
fessionals... .’’ We, in return, thanked them for their wonderful and
refreshing due diligence. I wanted to lighten the atmosphere, so I told them
that they now knew more about us than our parents and family ever had.
This experience is shared here in great detail to reassure the reader of the
quality of the U.S. banking system and the meticulous detail the system
goes through to make sure that the regulations of the system are put in
292 THE ART OF ISLAMIC BANKING AND FINANCE