Archive

HMDA Enforcement Actions in 2023… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome requirements. These changes continue to prove to be cumbersome and taxing. Program failures continue to plague financial institutions and in 2023, there were three very large enforcement actions for failing to file accurate data. Additionally, due to a lawsuit the CFPB had to rescind the 100 loan […]

Today, the Office of the Comptroller of the Currency (OCC) announced a $15 million civil money penalty against American Express National Bank (American Express). The penalty is a result of American Express failing to govern and oversee a third-party affiliate and for violations of regulations relating to certain efforts to retain small business customers. This is the first CMP issued since the agencies released their interagency guidance on June, 9th. The OCC found that American […]

The FDIC, FRB, NCUA, CFPB and FinCEN have each announced adjustments to the maximum amount of civil money penalties (CMP), for which they have assessment authority, to account for inflation. The adjustments serve to maintain the deterrent effect of civil penalties and to promote compliance with the law. Compliance Resource previously reported of the OCC’s final rule announcing changes to the maximum amount of each civil money penalty for national banks and Federal savings associations […]