Q3 2018 SUMMARY

A total of 36 actions were levied in Q3 2018. The number of regulatory enforcement actions decreased 8% from Q2 2018 and was driven primarily by a decrease in activity from the Office of the Comptroller of the Currency (OCC), The five major federal regulators issued 56% of total enforcement actions this quarter, with six from the Department of Justice (DOJ), four from the Consumer Financial Protection Bureau (CFPB), four from the Federal Deposit Insurance Corporation (FDIC), four from the Federal Reserve Bank (Fed), and two from the OCC. The number of OCC actions dropped in Q3 2018 to two, which is the fewest actions from the regulator in a single period observed over the past five quarters.

HIGHLIGHTS FROM Q3 2018:

Actions by Regulators

• A total of 36 actions were observed this period. This is only the second quarter since Guidehouse began publishing the tracker where the number of actions fell below 40. The current quarter is a 33% decrease from Q3 2017, and an 8% decrease since last quarter.
• In Q3 2018, there were 20 actions levied by the five main federal regulators, including CFPB, OCC, FDIC, Fed, and the DOJ. The number is a 51% decrease from Q3 2017, and a 9% decrease since last quarter.
• The decrease in number of total actions in Q3 2018 levied by federal regulators was primarily caused by a lower number of OCC actions. In Q3 2018, there were only two actions levied by the OCC, which is a 60% decrease compared to Q3 2017 and a 67% decrease since last quarter. This is also the fewest actions from the OCC in a single period observed over the past five quarters.
• The DOJ had six actions in the quarter, with a total of nearly $7 billion civil money penalties and fines enforced. Two of these actions were related to securitized mortgage products in violation of Regulation AB: Asset-backed Securities and RMBS, and resulted in $4.9 billion and $2 billion monetary penalties, respectively.
• Actions by state and local regulators continue to increase, with 14 actions observed in Q3 2018, representing 39% of total Q3 actions. The number of state actions increased 17% compared to that in Q3 2017 and increased 27% since last quarter.