On April 22, the Federal Reserve Board announced enforcement actions against two state banks.  In a consent order with a Montana-based bank, the Fed alleged that the bank violated the National Flood Insurance Act (NFIA) and Regulation H. The order assesses a $9,500 penalty against the bank for an alleged pattern or practice of violations of Regulation H but does not specify the number or the precise nature of the alleged violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,252 per violation.

Separately, an Iowa-based bank entered a written agreement with the Fed and the Iowa Superintendent of Banking “to strengthen board oversight of the management and operations of the Bank, by improving the Bank’s condition and maintaining control of the Bank’s main operations and activities, including the Bank’s credit risk management, asset quality, capital, and earnings.” According to the agreement, the bank must provide an acceptable written plan designed to reinforce credit risk management practices to the Fed and the Superintendent within 60 days. In addition, the plan must include: “(i) a comprehensive budget for 2021, including income statement and balance sheet projections; and (ii) a description of the operating assumptions that form the basis for, and adequately support, major projected income, expense, and balance sheet components.”