OCC Announces Enforcement Actions for February 2025: A Detailed Overview
The Office of the Comptroller of the Currency (OCC) has unveiled a series of enforcement actions against national banks, federal savings associations, and individuals affiliated with these institutions. These measures, announced in February 2025, aim to address unsafe or unsound banking practices, violations of law, and breaches of fiduciary duty. The OCC also introduced updates to its enforcement action search tool, enhancing transparency and accessibility for the public. Below is a structured breakdown of the key actions, individuals involved, and their implications.
Enforcement Actions Against Banks
The OCC’s actions against banks are designed to compel boards of directors and management to rectify identified deficiencies promptly. Two notable cases include:
- Dearborn FSB, Dearborn, Michigan: The OCC entered into a Formal Agreement with Dearborn FSB for unsafe or unsound practices, including failures in compliance management, fair lending risk management, insider activities, and compensation practices. The bank was also cited for recordkeeping violations. This action underscores the OCC’s focus on ensuring robust internal controls and adherence to regulatory standards. (Docket No. AA-CE-2025-2)
- Patriot Bank, N.A., Stamford, Connecticut: Patriot Bank faced a Formal Agreement for violations and unsafe practices related to strategic planning, capital planning, Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk management, payment activities oversight, credit administration, and concentration risk management. These issues highlight systemic weaknesses in the bank’s operational and risk management frameworks. (Docket No. AA-NE-2025-05)
Enforcement Actions Against Individuals
The OCC also targeted institution-affiliated parties (IAPs), including former bank employees and officers, to hold them accountable for misconduct. Key actions include:
- Max M. Bender: A former Operations Processor at U.S. Bank, N.A., in Cincinnati, Ohio, Bender was issued an Order of Prohibition for misappropriating funds from commercial customer deposits, resulting in a $23,000 loss to the bank. (Docket No. AA-ENF-2024-99)
- Justin Cooper: A former Bank Teller at TD Bank, N.A., in Ramsey, New Jersey, Cooper was prohibited from banking activities for unauthorized access to customer records and selling customer information to a third party for personal gain. (Docket No. AA-ENF-2024-87)
- Larry DeWitt: Former Chief Credit Officer at BancCentral, N.A., in Alva, Oklahoma, DeWitt was penalized for failing to secure cash collateral for new market tax credit loans, leading to violations of the bank’s legal lending limit. He also failed to inform the bank of a customer’s impending withdrawal of millions, jeopardizing the bank’s liquidity. (Docket No. AA-ENF-2024-101)
- Jackeline Graves: A former Retail Banker at Woodforest National Bank in Port Arthur, Texas, Graves was prohibited for stealing $14,000 by forging customer names on checks and accessing personal information without authorization. (Docket No. AA-ENF-2025-06)
- Derek Heaton: Former Chief Lending Officer at BancCentral, N.A., Heaton faced an Order of Prohibition for similar failures as DeWitt, including inadequate collateral management for tax credit loans. (Docket No. AA-ENF-2024-102)
- Mark Tillman: A former Loan Officer at Citizens Bank, N.A., in Providence, Rhode Island, Tillman was issued an Order of Prohibition and to Cease and Desist for making false statements to influence mortgage lending decisions, failing to identify red flags in loan applications, and not disclosing a mortgage broker’s involvement and fees. (Docket No. AA-ENF-2024-111)
These actions reflect the OCC’s commitment to deterring misconduct and reinforcing individual accountability within the banking sector.
Termination of Enforcement Actions
The OCC terminates enforcement actions when banks demonstrate compliance or when specific provisions become outdated. A notable termination in February 2025 involved:
- Wells Fargo Bank, N.A., Sioux Falls, South Dakota: The OCC terminated a Cease and Desist Order issued in April 2018, which addressed unsafe practices in the bank’s compliance risk management program and violations causing consumer harm. The termination signifies the bank’s progress in rectifying past deficiencies. (Docket No. AA-ENF-2025-13)
Enhanced Enforcement Action Search Tool
To improve public access to enforcement actions, the OCC updated its search tool to allow users to filter actions issued since 2012 by subject matter. This update enhances transparency and enables stakeholders to better understand the scope and nature of regulatory violations.
Key Takeaways
- The OCC’s February 2025 enforcement actions targeted both banks and individuals, addressing a wide range of violations, from compliance failures to outright fraud. These measures underscore the agency’s role in maintaining the integrity of the U.S. banking system.
- The termination of the Wells Fargo enforcement action highlights the OCC’s willingness to acknowledge corrective efforts, while the updated search tool reflects its commitment to transparency and public accountability.
By holding institutions and individuals accountable, the OCC continues to play a critical role in safeguarding the financial system and protecting consumers. These actions serve as a reminder of the importance of robust governance, compliance, and ethical conduct in the banking industry.
