Number of regulatory enforcement actions increased in Q3 2017 from Q2 2017
HIGHLIGHTS FROM Q3 2017:
Q3 2017 SUMMARY
The number of regulatory enforcement actions increased 13 percent in Q3 2017 from Q2 2017, as seen in Figure 1, to a level comparable to the frequency observed in Q3 2016. 78 percent of enforcement actions were issued by the five major federal agencies, with 11 from the CFPB; eight each from the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Bank (FRB), and Department of Justice (DOJ); and five from the Office of the Comptroller of Currency (OCC) (see Figure 2). Compared to Q2 2017, the CFPB, OCC, FRB, and DOJ all experienced a measurable uptick in actions. Yet despite this increased activity, state or local regulators were involved in a total of 12 actions, surpassing the CFPB (with 11 items) as the most frequent actor in the period.
The CFPB’s actions centered around unfair, deceptive, or otherwise improper mortgage practices or other consumer lending practices in violation of the Real Estate Settlement Procedures Act (RESPA), Fair Credit Reporting Act (FCRA), and Equal Credit Opportunity Act (ECOA), while the FDIC, OCC, and FRB issued actions for violations of rules and regulations including the Bank Secrecy Act (BSA) and anti-money laundering (AML) programs, capital adequacy requirements, the National Flood Insurance Program, and general governance deficiencies. The DOJ focus was centered on violations of the SCRA and False Claims Act.
Special thanks to contributors Caitlin Cremin and Siwen Tang.
“The number of regulatory enforcement actions increased 13 percent in Q3 2017 from Q2 2017 to a level comparable to the frequency observed in Q3 2016.
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