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Financial Services Law Insights and Observations

Federal Reserve enters into written compliance agreement with Oklahoma state bank

Federal Issues Enforcement Compliance Supervision Federal Reserve

Federal Issues

On October 22, the Federal Reserve Board (Board) entered into a written agreement with an Oklahoma state chartered bank, which outlines a compliance proposal to “maintain the financial soundness” of the bank. The agreement requires the bank to submit, within 60 days, written plans to improve various aspects of the bank’s functions including, but not limited to, (i) internal controls; (ii) credit risk management; (iii) liquidity and funds management; (iv) interest rate risk management; (v) information technology/cybersecurity; and (vi) BSA/AML compliance. The agreement also prevents the bank from extending, renewing, or restructuring any credit for any borrower whose loans or other extensions of credit were part of the Board’s examination critiques, without prior approval from the board of directors, who are required to document the reasons for the credit extension and certify its compliance with the terms of the agreement.