OCC Issues Revised Policies and Procedures for Bank Enforcement Actions

The Office of the Comptroller of the Currency ("OCC") published an updated policies and procedures manual ("PPM") for bank enforcement actions and related matters. The manual updates a previously issued document titled "Enforcement Action Policy." As stated in new Bulletin 2017-48, the OCC is rescinding OCC Bulletin 2011-37: Bank and Federal Savings Association Supervision Operation: Enforcement Action Policy.

The PPM outlines policies and procedures for OCC enforcement actions against banks that are initiated in response to violations of laws, regulations or other OCC mandates, as well as for unsafe or unsound practices. It includes guidance for selecting the most appropriate enforcement or supervisory response to undertake in order to resolve a particular deficiency. In addition, the PPM contains information on timelines, follow-up requirements, communication expectations, documentation responsibilities, and required disclosures.