OCC bulletin details recent 2.5% civil money penalty inflation adjustment

A 2.5% civil money penalty (CMP) inflation adjustment that took effect Jan. 1 is detailed in a bulletin issued Friday by the Office of the Comptroller of the Currency (OCC).

Under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, federal agencies with CMP authority must annually adjust each CMP authorized by law that they have jurisdiction to administer, in accordance with guidance published by the Office of Management and Budget (OMB). Agencies must adjust their CMPs no later than Jan. 15 of each year and publish those adjustments in the Federal Register.

The OCC published its notice of adjustment in the Dec. 27 Federal Register, with maximum penalties under the adjustment made effective for violations occurring on or after Nov. 2, 2015.

The adjustment is based on guidance provided in OMB Memorandum M-19-04 issued Dec. 14, 2018, the agency said in the bulletin. It noted that this change “does not affect the OCC’s discretion to assess a CMP in an amount lower than the maximum allowed.”

OCC Bulletin 2019-2

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