OCC Revises Civil Money Penalty Policies and Procedures Manual

The OCC revised its Policies and Procedures Manual ("PPM 5000-7") on assessing civil money penalties ("CMPs") in response to misconduct. The revised manual, which supersedes the 2018 guidance (see related coverage), will become effective on January 1, 2023.

The revisions expand the list of mitigating factors that the OCC would consider in an enforcement decision, specifically, factors relating to self-identification, remediation of misconduct and restitution. The revisions also update the matrix that the OCC uses to guide its established enforcement penalties to further differentiate misconduct by degree and institution size.