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Financial Services Law Insights and Observations

OCC releases April 2019 enforcement actions

Federal Issues OCC Enforcement Flood Insurance Flood Disaster Protection Act Civil Money Penalties

Federal Issues

On May 16, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. The new enforcement actions include personal cease-and-desist orders, removal and prohibition orders, notice of charges against an individual, and terminations of existing enforcement actions against individuals and banks. The release also includes two civil money penalty orders discussed below.

On April 9, the OCC assessed $35,000 in civil money penalties against an Oklahoma-based bank for an alleged pattern or practice of violations of the Flood Disaster Protection Act and its implementing regulations. Additionally, on April 24, the OCC assessed $136,000 in civil money penalties against a Texas-based bank for an alleged pattern or practice of failing to ensure timely notification and force-placement of flood insurance on property in special flood hazard areas, in violation of the National Flood Insurance Act.

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