Supervision & Ratings
Enforcement Actions
Also known as Enforcement
Enforcement actions are formal and informal measures bank regulators take against an institution or its officers: consent orders, cease-and-desist orders, civil money penalties, and written agreements. They are the public footprint of supervisory problems.
See recent orders by the FDIC, OCC and Federal Reserve in the bank enforcement actions list.
How is Enforcement Actions defined?
Issued by the OCC, FDIC, Federal Reserve, NCUA, or CFPB. Formal actions are public and legally enforceable; informal actions (memoranda of understanding) are often non-public. The type and severity signal how serious supervisors consider the underlying problem.
Why does Enforcement Actions matter?
An enforcement action is a regulator putting supervisory concern on the record. A consent order over capital, asset quality, or BSA/compliance failures often constrains the bank's activities and is a strong signal of elevated risk, and frequently precedes failure in severe cases.
How do you interpret Enforcement Actions?
Read the type, subject, and recency. A formal capital- or safety-and-soundness order is far more serious than a routine compliance MOU, and a cluster of actions or a still-open order points to unresolved problems. Terminated actions indicate the issue was addressed.
What do Enforcement Actions levels indicate?
| Range | Label | Interpretation |
|---|---|---|
| None | Clean | No public enforcement actions on record. |
| Informal / resolved | Low | Minor or terminated actions; issues addressed. |
| Formal order open | Watch | Active consent or C&D order constraining the bank. |
| Severe / multiple | Concern | Serious safety-and-soundness or repeat actions; elevated failure risk. |
Worked example
Frequently asked
What is the difference between a formal and informal enforcement action?
Formal actions (consent orders, cease-and-desist orders, civil money penalties) are public and legally enforceable. Informal actions, such as memoranda of understanding, are typically non-public and used for less severe concerns.
Who issues bank enforcement actions?
A bank's primary federal regulator: the OCC for national banks, the FDIC and state regulators for state nonmember banks, the Federal Reserve for state member banks and holding companies, and the NCUA for credit unions, plus the CFPB for consumer matters.
Sources
- OCC, FDIC, Federal Reserve, and NCUA enforcement action databases
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