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Financial Services Law Insights and Observations

OCC policy and procedure update addresses institution-affiliated party enforcement actions

Agency Rule-Making & Guidance OCC Enforcement Institution-Affiliated Party

Agency Rule-Making & Guidance

On November 13, the OCC issued OCC Bulletin 2018-41, announcing the release of Policies and Procedures Manual 5310-13 (PPM 5310-13), which outlines the OCC’s policy and framework for taking enforcement actions against institution-affiliated parties (IAP) of national banks, federal savings associations, and foreign banks’ federal branches and agencies. Among other things, PPM 5310-13 explains the definition of an individual who qualifies as an IAP and describes common enforcement actions taken against current or former IAPs, which include “violations of law, regulation, final agency orders, conditions imposed in writing, or written agreements; unsafe or unsound practices; or breaches of fiduciary duty.” PPM 5310-13 also outlines procedures and processes related to most informal and formal IAP enforcement actions.

Additionally, the OCC issued updated policies and procedures (see PPMs 5310-3 and 5000-7) concerning bank enforcement actions and related matters, as well as civil money penalties, to ensure consistency with PPM 5310-13. All three PPMs are effective immediately.

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