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Financial Services Law Insights and Observations

OCC releases September and October enforcement actions

Federal Issues OCC Enforcement Flood Disaster Protection Act OREO

Federal Issues

On October 18, 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 civil money penalty orders, prompt corrective action directives, removal and prohibition orders, and terminations of existing enforcement actions against individuals and banks. Included among the actions is a $100,000 civil money penalty issued against a Louisiana-based bank for an alleged pattern or practice of violations of the Flood Disaster Protection Act and its implementing regulations. The list also includes a $30 million consent order issued against a national bank for allegedly violating the statutory holding period for other real estate owned (previously covered by InfoBytes here).

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