A total of 54 actions were levied in Q4 2018. The number of regulatory enforcement actions increased 50% from Q3 2018 and was driven primarily by an increase in activities from the Office of the Comptroller of Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) (see Figure 1).
The five major federal regulators issued 61% of total enforcement actions this quarter, with 13 from the FDIC, eight from the OCC, five from the Consumer Financial Protection Bureau (CFPB), four from the Federal Reserve Bank (FED), and three from the Department of Justice (DOJ). The number of FDIC actions increased to 13 and the number of OCC actions increased to eight in Q4 2018, which are the most actions from these two regulators in a single period observed over the last five quarters.
Highlights from Q4 2018:
- A total of 54 actions were observed this period. After two consecutive quarters where the number of actions fell below 40, regulators are active again. The current quarter is a 20% increase from Q4 2017, and a 50% increase since last quarter.
- In Q4 2018, there were 33 actions levied by the five main federal regulators, including CFPB, OCC, FDIC, FED, and DOJ. The number is a 6% increase compared to Q4 2017, and a 65% increase since last quarter.
- The Q4 2018 increase was primarily driven by higher activity from the OCC and the FDIC. In Q4 2018, there were eight actions levied by the OCC, which is a 60% increase compared to Q4 2017, and a 300% increase since last quarter. This is the most actions from the OCC in a single period observed over the last five quarters.
- In Q4 2018, there were 13 actions levied by the FDIC, which is a 63% increase compared to Q4 2017, and a 225% increase since last quarter. This is also the most actions from the FDIC in a single period observed over the last five quarters.
- Compared to other federal regulators who had increased number of total actions, the DOJ only undertook three actions in the past quarter, which was a 50% decrease compared to both Q4 2017 and the previous quarter. Although the number of actions decreased, DOJ collaborated with District Attorney of New York to levee $880 million in civil money penalties on an action related to violations of regulations promulgated by the Office of Foreign Assets Control (OFAC), which was the largest amount observed in Q4 2018.
- State and local regulators continue to be active in the past quarter, with 14 actions observed in Q4 2018, representing 26% of total Q4 actions. The number of state actions was the same as last quarter and increased 27% compared to that in Q4 2017.
Special thanks to contributors Caitlin Cremin and Siwen Tang.