InfoBytes Blog
Fed releases enforcement action against Wyoming-based bank holding company
On April 4, the Federal Reserve released an enforcement action against a Wyoming-based bank holding company as part of a September 2023 inspection that found alleged deficiencies related to the “fintech business strategy, board oversight, capital, earnings, liquidity, risk management, and compliance.” The consent order with the bank holding company requires the holding company to: (i) serve as a source of strength to its bank subsidiary; (ii) submit a written plan to strengthen board oversight, including a staffing assessment and succession plan; (iii) submit a written plan to strengthen its risk management program, including adopting written policies and procedures to manage compliance and fraud risks; (iv) submit an enhanced liquidity risk management program, a capital plan, and a written business plan to improve earnings; and (v) ensure compliance with regulations governing affiliate transactions. The consent order additionally placed limits on the holding company’s fintech activities and required the holding company to submit a wind-down plan for fintech-related business. According to the consent order, following the September 2023 inspection, the holding company had voluntarily stopped pursuing its fintech business strategy and had been winding down all related activities.