Fed announces two enforcement actions against banks

Orrick, Herrington & Sutcliffe LLP
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On March 20, the Fed announced two enforcement actions against banks last month. On February 24, the Fed issued a civil money penalty order against a state member bank in Hawaii. That bank agreed to pay a $15,500 penalty for violations of Regulation H, which implements the National Flood Insurance Act. The funds will be sent to the National Flood Insurance Program.

On February 20, the Fed issued a cease and desist order against a registered bank holding company in Tennessee, after identifying deficiencies with respect to the bank holding company’s ability to serve as a source of strength to the state nonmember bank that it owns. The order required the company utilize its resources to serve as a source of strength to the bank, and to obtain prior written approval from the Fed before, among other things, declaring or paying dividends, incurring additional debt, engaging in share repurchases, or making any capital distribution. Additionally, the company must submit a statement of its planned sources and uses of cash for debt service, operating expenses, and other purposes for 2025 to the Federal Reserve Bank of Atlanta.

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