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Fed fines bank for flood insurance violations
On December 1, the Federal Reserve Board announced a civil money penalty against a New-York based bank. In its order, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $105,500 civil money penalty against the bank in connection with its “alleged pattern or practice of violations of Regulation H,” but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,392 per violation.
FDIC releases September enforcement actions
On October 28, the FDIC released a list of administrative enforcement actions taken against banks and individuals in September. During the month, the FDIC made public 12 orders consisting of “two consent orders, five orders of prohibition, two orders to pay a civil money penalty, two orders of termination of insurance, and one section 19 order.” The FDIC also publicly released an order to pay a civil money penalty taken against an Illinois-based bank related to alleged violations of the Flood Disaster Protection Act and the National Flood Insurance Act for failure to follow lender placement flood insurance procedures in 13 instances. The order requires the payment of an $11,625 civil money penalty.
Fed takes action against bank for flood insurance violations
On September 27, the Federal Reserve Board announced a civil money penalty against a Pennsylvania-based bank. In the order, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $41,500 penalty against the bank for an alleged pattern or practice of violations of Regulation H, but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,392 per violation.
FDIC releases July enforcement actions
On August 26, the FDIC released a list of administrative enforcement actions taken against banks and individuals in July. During the month, the FDIC issued seven orders consisting of “two orders of prohibition, two orders to pay civil money penalty, two section 19 orders, and one order terminating consent order.” Among the actions is an order to pay a civil money penalty imposed against an Iowa-based bank related to alleged violations of the Flood Disaster Protection Act (FDPA) and the National Flood Insurance Act of 1968. Among other things, the FDIC claimed that the bank: (i) “made, increased, extended, or renewed loans secured by a building or mobile home located or to be located in a special flood hazard area without requiring that the collateral be covered by flood insurance”; (ii) “made, increased, extended or renewed loans secured by a building or mobile home located or to be located in a special flood hazard area without providing timely notice to the borrower as to whether flood insurance was available for the collateral”; and (iii) “failed to comply with proper procedures for force-placing flood insurance in instances where the collateral was not covered by flood insurance at some time during the term of the loan.” The order requires the payment of a $2,500 civil money penalty. The actions also include a civil money penalty imposed against a Texas-based bank related to six alleged violations of the FDPA for “failure to obtain flood insurance or obtain an adequate amount of insurance coverage, at or before loan origination, for all structures in a flood zone, including multiple structures,” among other alleged violations. The order requires the payment of a $6,000 civil money penalty.
Fed takes action against bank for flood insurance violations
On July 7, the Federal Reserve Board announced a civil money penalty against a Massachusetts state bank. In the order, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $17,000 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,000 per violation.
Fed announces enforcement actions against Minnesota and Arkansas state banks
On June 21, the Federal Reserve Board released civil penalty orders against two state banks, both relating to alleged violations of the National Flood Insurance Act (NFIA) and its implementing regulation, Regulation H. The first civil penalty order, against a Minnesota-based bank, assessed a $4,950 penalty for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The second civil penalty order, against an Arkansas-based bank, assessed a $13,950 penalty for an alleged pattern or practice of violations of Regulation H without specifying the number or precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,000 per violation.
Fed announces enforcement action against Illinois bank
On February 10, the Federal Reserve Board announced an enforcement action against an Illinois-based bank. According to the consent order, the bank allegedly violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $253,500 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,000 per violation.
Fed announces enforcement action against Minnesota bank
On October 7, the Federal Reserve Board announced an enforcement action against a Minnesota-based bank. In the consent order, the Fed alleges that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $11,00 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,000 per violation.
Fed announces flood insurance violations
On August 12, the Federal Reserve Board announced enforcement actions against two state banks. In the first consent order issued against a Massachusetts-based bank, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $71,000 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations.
In the second consent order issued against a New York-based bank, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $11,000 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations.
Fed announces flood insurance violations
On August 3, the Federal Reserve Board announced an enforcement action against a Tennessee-based bank for alleged violations of the National Flood Insurance Act (NFIA) and Regulation H. The consent order assesses a $26,500 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,252 per violation.