Coincidence or SOP by FNB?

Two excerpts from two documents.....

#1

 Examiners determined that the bank had masked its OREO problems by financing OREO sales on liberal terms, capitalizing property taxes, and advancing funds on borrowers’ other loans to cause the borrowers to remain current on OREO loans. The 2011 MRA expressed concerns over First National’s aggressive strategy to sell OREO without implementing proper accounting policies and practices, and directed the board to make accounting adjustments and file amended call reports.

#2

27.   Grantor represents that this deed of trust and the Note are given for the following purposes:

A portion (approximately $100,000.00) of the debt evidenced by the Note is being or has been advanced by the Beneficiary to or on behalf of Grantor in part payment of the purchase price of the Property and/or for ad valorem taxes paid as part of the acquisition of the Property from prior owner(s);  the debt is secured both by this deed of trust and by a vendor's lien on the Property, which is expressly retained in a deed to Grantor of even date.  This deed of trust does not waive the vendor's lien, and the two liens and the rights created by this instrument shall be cumulative.  Beneficiary may elect to foreclose under either of the liens without waiving the other or may foreclose under both.  The deed is incorporated into this deed of trust.

Who is going to be accountable????

Surely the FBI has already taken note of this!!