On September 25, 2014, the OCC announced a $4 million civil monetary penalty  against US Bank National Association in Cincinnati, Ohio and ordered restitution  of $47.9 million to more than 420,000 consumer accounts. The OCC enforcement  action, made in coordination with the Consumer Financial Protection Bureau  (“CFPB”), found that the bank’s practices violated the Federal Trade Commission  Act, prohibiting unfair acts or practices.  Among those consumers eligible for  restitution are those who were unfairly billed for identity theft protection products  marketed by the bank and sold by its vendor. The restitution will include the full  amount paid for these products, plus any associated over-limit fees and finance  charges. In addition, the OCC order requires the bank to improve its governance  of third-party vendors associated with “add-on” consumer products and to submit  to the OCC a third-party management program plan for add-on consumer products  marketed or sold by the bank or its vendors. In the coordinating action, the CFPB issued a separate order against the bank  based on unfair billing for identity theft protection products. The CFPB order  required the bank to pay a $5 million civil money penalty and ordered restitution  to harmed consumers. 

The full text of the OCC enforcement order is available at: 

http://occ.gov/static/enforcement-actions/ea2014-115.pdf. 

The full text of the CFPB consent order is available at: 

http://files.consumerfinance.gov/f/201409_cfpb_consent-order_us-bank.pdf.