I understand what you are saying, but bank failures are rarely "unforseen". Anybody who read the newspaper in those days when there were bank failures daily (and our bank's problems were on the front page of the local paper) could see that the chances were better than even that a failure was in our future.

The restructuring of accounts is something banks in that climate do routinely in response to nervousness from their customers. There is nothing fraudulent about it. The FDIC spends a good deal of their time and energy informing the public and banking sectors about the proper way to structure accounts for maximum coverage. If banks weren't able to do this, they would be much more likely to become the victim of a run triggered by the withdrawal of large accounts.

I should clarify that what we did was in response to individual customer concern, not a wholesale pre-emptive move on our part.