A brief list of January enforcement actions released Thursday by the Comptroller of the Currency includes no civil money penalty assessments, cease-and-desist orders, or removal/prohibition orders against institution-affiliated persons.
The list of four actions taken last month by the Office of the Comptroller of the Currency (OCC) includes three terminations of previous enforcements and a new formal agreement for one supervised banking institution.
The formal agreement cites findings of “unsafe or unsound” practices at Commonwealth National Bank, Mobile, Ala., described as being in “troubled” condition. The “unsafe or unsound” practices, the agreement states, include some related to strategic planning, loan portfolio management, and internal audit.
The agreement describes requirements for the bank to establish a compliance committee to follow and report on corrective actions; create a strategic plan addressing, among other things, the bank’s overall risk profile, earnings performance, growth, balance sheet mix, off-balance sheet activities, liability structure, capital and liquidity adequacy; adopt an acceptable written loan portfolio management program; and adopt a comprehensive, written internal audit program.
If the strategic plan includes a proposed sale or merger of the bank under 12 U.S.C. § 215a-3 [addressing a merger with a nonbank subsidiary or affiliate], the agreement states, that plan “shall, at a minimum, address the steps that shall be taken and the associated timeline to effect the implementation of that alternative.”