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  • Fed announces enforcement actions against Montana and Iowa state banks

    Federal Issues

    On April 22, the Federal Reserve Board announced enforcement actions against two state banks.  In a consent order with a Montana-based bank, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $9,500 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.

    Separately, an Iowa-based bank entered a written agreement with the Fed and the Iowa Superintendent of Banking “to strengthen board oversight of the management and operations of the Bank, by improving the Bank’s condition and maintaining control of the Bank’s main operations and activities, including the Bank’s credit risk management, asset quality, capital, and earnings.” According to the agreement, the bank must provide an acceptable written plan designed to reinforce credit risk management practices to the Fed and the Superintendent within 60 days. In addition, the plan must include: “(i) a comprehensive budget for 2021, including income statement and balance sheet projections; and (ii) a description of the operating assumptions that form the basis for, and adequately support, major projected income, expense, and balance sheet components.”

    Federal Issues Federal Reserve Enforcement Regulation H Flood Insurance National Flood Insurance Act Bank Regulatory

  • Fed targets flood insurance violations

    Federal Issues

    On March 18, the Federal Reserve Board announced an enforcement action against a Pennsylvania-based bank for alleged violations of the National Flood Insurance Act (NFIA) and its implementing Regulation H. The consent order assesses a $105,000 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.

    Federal Issues Federal Reserve Enforcement Flood Insurance National Flood Insurance Act Regulation H Bank Regulatory

  • Fed targets flood insurance violations

    Federal Issues

    On November 10, the Federal Reserve Board (Fed) announced an enforcement action against an Arkansas-based bank for alleged violations of the National Flood Insurance Act (NFIA) and Regulation H, which implements the NFIA. The consent order assesses a $12,000 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.

    Federal Issues Federal Reserve Flood Insurance Enforcement National Flood Insurance Act Regulation H

  • Fed targets flood insurance violations

    Federal Issues

    On October 15, the Federal Reserve Board announced an enforcement action against a New York-based bank for alleged violation of the National Flood Insurance Act (NFIA) and Regulation H, which implements the NFIA. The consent order assessed a $546,000 penalty against the bank for an alleged pattern or practice of violations of Regulation H, but did 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.

    Federal Issues Enforcement Flood Insurance National Flood Insurance Act Regulation H

  • Fed enforcement action targets flood insurance

    Federal Issues

    On July 2, the Federal Reserve Board announced an enforcement action against a West Virginia-based bank for alleged violations of the National Flood Insurance Act (NFIA) and Regulation H, which implements the NFIA. The consent order assesses a $24,500 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.

    Federal Issues Federal Reserve Enforcement Flood Insurance National Flood Insurance Act Regulation H

  • Federal Reserve hits bank for flood insurance violations

    Federal Issues

    On January 30, the Federal Reserve Board (Fed) announced an enforcement action against a New York-based bank for allegedly violating the National Flood Insurance Act (NFIA) and Regulation H, which implements the NFIA. The consent order assesses a $36,500 civil money 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 for each violation. The consent order was signed by both the bank and the Fed on January 24.

     

    Federal Issues Federal Reserve Enforcement National Flood Insurance Act Regulation H Flood Insurance Consent Order

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