US Metro Bancorp (USMT)

[LGL8054]

http://www.usmetrobank.com/
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Financial Information

2010 Annual Report
2009 Annual Report

PG.1 is Intro PDF
Luxury Expenditure Policy

Excessive and Luxury Expenditure Policy


US Metro Bank Excessive and Luxury Expenditure Policy
Page 2


I.
Statement
The board of directors and senior execu
tives of US Metro Bank are committed to
complying fully with the requ
irements of the Troubled Assets Relief Program (“TARP”)
Standards for Compensation and Corporate G
overnance as defined by the Department of
the Treasury (31 CFR Part 30) pursuant to
requirements set forth in the Emergency
Economic Stabilization Act of 2008 (“EESA”),
as amended by the American Recovery
and Reinvestment Act of 2009 (“ARRA”) during th
e period that the ba
nk participates in
the TARP Capital Purchase Program.
II.
Policy Objectives
Excessive and Luxury Expenditure Policy (“
the policy”) fulfills the requirements under
the American Recovery and Reinvestment
Act of 2009 (ARRA) enacted February 17,
2009. ARRA requires each recipi
ent of funds under the Cap
ital Purchase Program (CPP)
of the Troubled Assets Relief Program (TARP)
to have in place a company-wide policy
regarding excessive or luxur
y expenditures, as
identified by the
Secretary of the
Department of the U.S. Treasury.
III.
Responsibilities
The board of directors is required by the TARP Standards for Compensation and
Corporate Governance as defined by the Depa
rtment of Treasury (
31 CFR Part 30) to
adopt a policy of excessive and luxury ex
penditures. The board has oversight
responsibilities for th
e Bank’s compliance with the requi
rement of TARP Standards for
Compensation and Corporate Governance as de
fined by the Department of the Treasury
(31 CFR Part 30). In support
of its oversight re
sponsibilities, the
board and executive
management shall have the following roles:
1.
Approve the policy on an annual basis, or,
in the event of subsequent amendments
to the TARP Standards for Compensati
on and Corporate Governance as defined
by the Department of Treasury (31 CFR Pa
rt 30), in such time frame required by
the amendment.
2.
The board shall review any exceptions
to this policy at the next regularly
scheduled meeting subsequent
to the granting of exception.
3.
The Chief Executive Officer must provide a certification for expenditure that
could be viewed as excessi
ve and luxury expenditure.
4.
Chief Financial Officer shall monitor
expenditure addressed by the policy to
ensure compliance with the policy. Chie
f Financial Officer shall document and
justify any exceptions to the policy
and report exception
to the board.
5.
Chief Financial Officer shall promptly r
ecommend modifications of the policy to
the board to ensure it remains as define
d by the Department of Treasury (31 CFR
Part 30).
6.
Chief Financial Office shall ensure that the policy is posted on the Bank’s
website.
US Metro Bank Excessive and Luxury Expenditure Policy
Page 3


VI.
General Policy Statemen
t
US Metro Bank prohibits excessi
ve or luxury expenditures on
entertainment and events,
office or facility renovations, aviation or othe
r transportation services or other activities
or events that are not reasonable expenditu
res for conferences, staff development,
reasonable performance incentives or other
similar measure conducted in the normal
course of business operations.
All employees and directors
of the Bank are to comply
with this policy. Any employees who become
aware of any violation
of this policy must,
within a reasonable amount of time, report su
ch violation to the Audit Committee, Chief
Executive Officer or Chief Fina
ncial Officer. Violations
may result in disciplinary
action, up to and including te
rmination of employment.
Renovations:
Renovations of facilities and office spaces shoul
d be relative to the approved project and
current profit plan, and tracked within the
capital expenditure polic
y of the Company. An
exception to this can be allowe
d if management must deal w
ith an emergenc
y situation,
such as an act of nature, and the expenditure
is necessary to make the facility operational
for customer use. At no time should renovatio
ns be done that woul
d have the appearance
of being extraordinary, or excessive
from a shareholder perspective.
Entertainment:
Entertainment is defined as an activity that an
Employee or Executive would use
corporate funds for business development pur
poses relating to a current customer or
prospective customer, or to further enhance the Bank’s marketing efforts. Our
expectation is that all expenses incurred
to the Bank would be for business purposes, and
used to drive business to the bank. Occasional events such as taking customers or
prospects on trips, playing golf, eating dinn
er, or taking them to other events the
customer/prospect would find pleasurable is
a necessary part of the Bank’s marketing
efforts and is not deemed as “luxury” or a vi
olation of this Policy. These expenses should
be documented and detailed as to the bene
fit derived by the Bank through the normal
accounts payable process. Events and partie
s focused on customers for the purpose of
attracting their business woul
d not fall under this policy.
Conferences or Sponsored Events:
We encourage our staff to attend confer
ences that are appropriate educational
opportunities. These conferences should be rela
ted to the financial services industry and
have a direct correlation to their job. At
times it may be appropriate that a spouse would
travel to these conferences with Bank’s
attendees. Typically these conferences are
sponsored by vendors, banking a
ssociations, or other indust
ry related entities. The
conference or sponsored even
ts expenditures of an empl
oyee’s spouse and/or other
family members will not be funded by the Bank.
Employee Recognition/Holiday Parties:
We feel that employee recognition/holiday pa
rties are part of an
employee appreciation
process. These events should be local in ge
ographic nature, and w
ould include costs for
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