OCC Updates Effective Dates For CMP Inflation Adjustment And New Flood Insurance Penalties

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On February 8, the OCC issued Bulletin OCC 2013-7, which clarifies that the maximum amount of the OCC’s civil money penalties (CMP) as adjusted for inflation last fall apply to violations that occurred on or after December 6, 2012. The Bulletin also states that new flood insurance penalties that also were adopted last fall, apply to violations that occurred on or after July 6, 2012, and not to violations that occurred on or after December 6, 2012, as originally announced.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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