Supervision & Ratings

Civil Money Penalty

Also known as CMP

A Civil Money Penalty (CMP) is a monetary fine imposed by a bank regulator for violations of law, regulation, or supervisory agreement. CMPs can range from thousands to billions of dollars depending on the violation.

See recent orders by the FDIC, OCC and Federal Reserve in the bank enforcement actions list.

How is Civil Money Penalty defined?

Maximum statutory CMP per day: Tier 1 ~$11K, Tier 2 ~$57K, Tier 3 ~$2.3M (per 12 USC §1818(i), inflation-adjusted annually).

The three statutory tiers escalate by severity. Tier 1 covers minor violations; Tier 2 covers reckless or pattern violations; Tier 3 covers knowing violations with substantial benefit or loss. Daily maximums multiplied by violation duration can produce penalties in the hundreds of millions or billions in egregious cases.

Why does Civil Money Penalty matter?

CMPs are the visible cost of enforcement. Large banks have paid some of the biggest penalties in recent years. Wells Fargo agreed in April 2018 to a $1 billion penalty to the CFPB and the OCC over auto-loan insurance and mortgage rate-lock practices. In July 2023 the CFPB and the OCC ordered Bank of America to pay about $250 million for consumer harms. JPMorgan Chase paid about $920 million in September 2020 to resolve spoofing and market-manipulation cases brought by the DOJ, CFTC and SEC. Banking-agency CMPs go to the Treasury, and CFPB penalties go to the CFPB's Civil Penalty Fund for victim relief; harmed customers may also receive restitution.

How do you interpret Civil Money Penalty?

CMP size is the regulator's signal of severity. Penalties under $1M reflect minor violations; $1M-$100M reflects significant control failures; over $100M signals systemic misconduct or material customer harm. CMPs are typically issued in conjunction with consent orders that require corrective actions.

What do Civil Money Penalty levels indicate?

Range	Label	Interpretation
< $1M	Minor	Routine violations or first-time issues.
$1M–$100M	Significant	Material control or compliance failures.
$100M–$1B	Severe	Systemic misconduct or extensive customer harm.
> $1B	Headline	Major bank-wide misconduct case.

Worked example

In September 2021 the OCC assessed a $250 million civil money penalty against Wells Fargo Bank, N.A. under 12 USC 1818(i) for deficiencies in its home lending loss-mitigation program. It was separate from Wells Fargo & Company's $3 billion settlement with the Department of Justice and the SEC in February 2020 over the fake-account scandal, which was not a banking-agency civil money penalty.

Frequently asked

Where does CMP money go?

Penalties assessed by the banking agencies go to the US Treasury. CFPB penalties go to its Civil Penalty Fund, which compensates victims. CMPs do not fund the regulators' operations. Some banks have also paid voluntary 'remediation' amounts directly to harmed customers in addition to formal CMPs.

Can multiple agencies impose CMPs for the same conduct?

Yes. A single bank misconduct can produce CMPs from multiple agencies (DOJ, OCC, FRB, FDIC, CFPB, SEC, state regulators) addressing different statutory violations. Total agency settlements in major cases often exceed $1B across all agencies.

How are individual employees affected?

CMPs against individuals (officers, directors, employees) are also authorized under §1818(i) and can include personal fines and prohibition orders. Individual prohibition orders bar named individuals from working in the banking industry.

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Sources

12 USC §1818(i): Federal banking agency CMP authority
DOJ, OCC, FRB, FDIC, CFPB enforcement action databases

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