Office of Comptroller Updates Enforcement Action Policy for Federal Savings Associations


On September 9, the Office of the Comptroller of the Currency (OCC), pursuant to section 316 of the Dodd–Frank Wall Street Reform and Consumer Protection Act, revised the scope of its Policies & Procedures Manual (PPM) policy for taking appropriate enforcement action in response to violations of law, rules, regulations, final agency orders and unsafe and unsound practices or conditions (Enforcement Action Policy) to include federal savings associations. The revised PPM (linked below) will provide for consistent and equitable enforcement standards for national banks and federal savings associations. This PPM supersedes PPM 5310-3, Enforcement Action Policy, dated July 30, 2001, and Supplement 1 to PPM 5310-3(REV), dated November 10, 2004. It also supersedes Office of Thrift Supervision (OTS) Examination Handbook Section 080, Enforcement Actions, dated July 18, 2008, and any OTS policies and guidance that relate to issues addressed by OTS Examination Handbook Section 080 that are addressed in this PPM.

This bulletin makes public PPM 5310-3 (REV), which describes the OCC’s Enforcement Action Policy, as revised to include federal savings associations. This PPM is applicable to all types of national banks, federal branches and agencies of foreign banks, and federal savings associations. It is also applicable to enforcement actions that the OCC may take against bank service companies under 12 USC 1861 and service providers under 12 USC 1464(d)(7)(D).

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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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