On February 10, 2022, in a most unusual case, the Office of the Comptroller of the Currency (OCC) issued a Consent Order for the payment of a $3,000 civil money penalty to Craig Meader, the president and a board member of First National Bank of Kansas, Burlington, Kansas.

The OCC found, and Meader neither admits nor denies, that, during the period from August to September 2020, Meader directed employees to implement extended holds on ACH deposits in violation of the Expedited Funds Availability Act and 12 C.F.R. § 229.10(b)(1). Meader was aware that the extended holds would violate the EFAA and 12 C.F.R. § 229.10(b)(1). Respondent’s actions resulted in nine instances of violations of 12 C.F.R. § 229.10(b)(1).

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Lessons Learned – Recent Deposit Compliance Enforcement Actions; and

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