Comptroller updates bank enforcement action policies, procedures

New bank enforcement action policies and procedures will be effective Dec. 1 from the Office of the Comptroller of the Currency (OCC), with an objective of “enhancing standard processes for initiating, tracking, and resolving enforcement actions,” the agency announced in a bulletin Tuesday.

Under the updates made in the agency’s Comptroller’s Handbook, the OCC said it is applying goals and practices related to:

  • Ensuring agency-wide consistency of the enforcement action process.
  • Reinforcing the importance of timely and thorough follow-up and tracking of bank management’s corrective actions and milestones to those actions.
  • Communicating a bank’s compliance or noncompliance with an enforcement action in a consistent format using consistent terminology.
  • Conveying the relationship between violations, concerns documented in matters requiring attention, and enforcement actions.
  • Emphasizing the need for examiners to communicate effectively and in a timely manner with the bank’s board of directors, the bank’s management team, and OCC supervisors.

The OCC said its updated policies and procedures do not address civil money penalty actions or enforcement actions against individuals. Also excluded are operating agreements and conditions imposed in the context of a bank’s licensing filing.

This agency added that the bulletin rescinds OCC Bulletin 2011-37, “Bank and Federal Savings Association Supervision Operation: Enforcement Action Policy,” issued Sept. 9, 2011.

OCC Bulletin 2017-48: Updated Guidance