Enforcement actions in the banking industry
Trends and lessons learned
Regulators issue hundreds of enforcement actions to banks each year. Recent research sheds light on current trends in the number, type, and severity of these actions, with implications for ways that banks may be able to better anticipate and respond to them.
The new realities
Tough, clear, and direct—such was Comptroller Curry’s tone on the day he announced the issuance of enforcement actions (EAs) levying nearly a billion dollars in fines against banks for manipulating the foreign exchange market between 2008 and 2013.
While this particular case is far from the typical EA in terms of the severity of the fines involved, it is, nevertheless, indicative of the heightened regulatory scrutiny banks have had to contend with in recent years. For instance, in 2014 alone, federal banking regulators—that is, the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration (NCUA)—issued 583 EAs of various types, with the majority of them coming from the FDIC. This number, however, is significantly lower than the peak in 2010, when banking regulators issued a total 1,795 EAs.
While it is not possible to determine what the next wave of EAs will be, our goal in this report is to help banks learn from the past and better anticipate future trends.