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Financial Services Law Insights and Observations

OCC releases January enforcement actions

Bank Regulatory Federal Issues OCC Enforcement Cease and Desist

On January 17, 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. Included is a notice of charges seeking cease and desist orders against three subsidiary banks of the same bank holding company (see here, here, and here), which alleged that each bank engaged in unsafe or unsound practices relating to an investment strategy concentrated in long-term securities. The unsafe practices, the OCC explained, exposed each bank to excessive interest rate risk without adequate sources of contingency funding and contingency capital. The OCC further alleged that each bank failed to mitigate such risk in a timely manner.