XVI. GROUNDS FOR ASSESSMENT OF CIVIL MONEY PENALTIES

 	351. As set forth in paragraphs 114 through 117, Respondents MAXXAM, 
Federated, Hurwitz, and Gross violated or participated in violations of 
12 U.S.C. 1730a (1988) and 12 C.F.R. ¤ 584.1(a), (b) (1985-88).
 	352. Respondents MAXXAM, Federated, Hurwitz, and Gross violated or 
participated in violations of 12 U.S.C. 1730a (1988) and 12 C.F.R. ¤ 
584.1(a), (b) continuously from December 24, 1985 through at least 
December 30, 1988.
 	353. As set forth in paragraphs 330 and 331, Respondents Berner and 
Munitz violated laws and regulations, breached their fiduciary duty, and 
recklessly engaged in unsafe and unsound practices by receiving severance 
payments from UFG, and thereby dissipated assets that should have been 
used to infuse capital into USAT in compliance with the UFG Net Worth 
Maintenance Obligation.
 	354. Respondents Berner and Munitz' violations, practices, and breaches 
caused more than a minimal loss to USAT or resulted in pecuniary gain or 
other benefit to them.