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Financial Services Law Insights and Observations

OCC fines bank $250 million for inadequate fiduciary controls

Federal Issues OCC Enforcement

Federal Issues

On November 24, the OCC assessed a $250 million civil money penalty against a national bank for allegedly failing to maintain adequate internal controls for its fiduciary activities. According to the consent order, the bank—which neither admits nor denies the agency’s findings—allegedly had deficient risk-management practices and lacked appropriate checks for avoiding conflicts of interest. The OCC states that the bank has since remediated the alleged deficiencies leading to this action.