Giant jack-o-lanterns, witches, and ghouls are starting to decorate our neighborhoods, and spooky stories are being told around the campfires.
Don’t you love this time of year?
Remember, frightening compliance stories can continue year-round.
The number and size of fines financial institutions can be assessed for violating Regulations can be quite steep. Institutions of every size, not just the big ones, are getting hit.
It’s why compliance departments and all employees—especially an institution’s Board of Directors—are accountable and must know what goes on in their institutions by asking:
- How do we keep an eye on our compliance function?
- What do our internal monitoring reports and external audits tell us?
- How do we track and monitor corrective action to ensure things are correct going forward?
Keep in mind that Civil Money Penalties (CMP) are adjusted for Inflation – see Federal Register: Notice of Inflation Adjustments for Civil Money Penalties.
Institutions can be fined for each violation. That means, for instance, that a CMP for Flood at $2,661 (adjusted amount for 2024) may be assessed per violation: If you have a flood file with five different rule violations, you can get fined for each one.
That’s over a cool $13,000 on just one file.
Just consider some recent fines that have been levied.
- Federal Reserve – First Interstate Bank/Billings, MT – $70,000 Flood Insurance Penalty
- CFPB – Fay Servicing – $2M for Mortgage servicing violations related to its foreclosure practices.
- FDIC – Personal CMP Justin Holt former SVP/Loan Officer, Bank of Tyler – Disbursing construction loan funds without proper documentation and failure to follow their own policy regarding the same.
- Federal Reserve – Silvergate Capital Corporation and Silvergate Bank – $43M for AML deficiencies.
- FDIC – Bank of England/England, AR – $1.5M for Section 5 of the FTCA, RESPA, FCRA and HMDA violations.
Additionally, nine former employees were assessed personal Civil Money Penalties.
Egad! That is scary!
Sidestep Chilling Penalties
It’s a team effort to ensure your institution doesn’t end up with this regulatory scare.
TCA can see you through the alarming compliance pitfalls with our four-step process. It involves:
- Discussing results of your last Regulatory Exam, the issues that emerged, and the corrective action and monitoring you’ve put in place.
- Looking at the risks that can cause the most damage to the Institution and ensuring those items are addressed.
- Reviewing your policies, procedures, and checklists to ensure they make for a solid CMS.
- Developing a long-term plan to be sure you’re not living in fear of fines and penalties.
Share your compliance demons, and TCA will show you A Better Way to cast them out for good. Contact us at [email protected] or at (800) 934-7347.
TCA – A Better Way!
