On February 22, the FDIC announced a list of administrative enforcement actions taken against banks and individuals in January 2019. The 25 orders include “10 Section 19 orders; two civil money penalty; six prohibition orders; three consent orders; one prompt corrective order; three terminations of consent orders; and one notice.” The FDIC assessed a civil money penalty against a Texas-based bank for alleged violations of the Flood Disaster Protection Act including failing to either (i) obtain flood insurance coverage on loans at or before origination; or (ii) increase, renew, or extend flood insurance coverage on several loans secured by collateral located or to be located in special flood hazard areas.

The FDIC assessed a second civil money penalty against an Oklahoma-based bank related to alleged weaknesses in its programs concerning Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance, information technology (IT), and internal audits. Among other things, the bank was ordered to (i) grant the board full responsibility for the approval of bank policies and objectives related to the identified programs, as well as supervision of bank management; (ii) retain qualified personnel responsible for managing the BSA/AML and IT programs; (iii) revise its internal control programs to correct the identified deficiencies; (iv) obtain an independent public accounting firm to conduct an external financial statements audit and internal controls review; and (v) implement comprehensive written BSA/AML compliance programs.