On September 18, the OCC announced its monthly enforcement actions for September, which included the termination of a 2023 consent order against a national bank and the termination of a 2020 consent order against a federal savings association. Both terminations followed earlier OCC findings of unsafe or unsound practices and alleged violations of federal banking and consumer protection laws.
The 2023 consent order, issued in October 2023, required the institution to meet higher capital minimums, implement revised capital and strategic planning processes, and maintain detailed project management standards. It also mandated improvements to liquidity and interest rate risk management, adoption of stronger IT controls, and the establishment of formal risk governance for new products and custody account operations. In its September 2025 termination order, the OCC stated that the safety and soundness of the institution and its compliance with laws and regulations did not require the continued existence of the 2023 order.
The 2020 consent order, which replaced an earlier 2011 action, directed a federal savings association to strengthen board and management supervision, establish a comprehensive internal audit program, and implement an enhanced consumer compliance management system. It also required revisions to credit risk administration, appointment and resourcing of a qualified BSA Officer, improvements to BSA/AML internal controls and customer due diligence procedures, and adherence to accurate books and records requirements. The OCC stated that continued maintenance of the order was no longer necessary for the institution’s safety and soundness or legal compliance.
Putting It Into Practice: The OCC continues to drop consent orders once it determines that ongoing enforcement is no longer required for an institution’s safety and soundness or compliance with laws and regulations (previously discussed here). Institutions subject to consent orders should anticipate that the OCC will continue to require extensive corrective measures before termination.