OCC Fines Bank $15 Million for Failure to Properly Supervise Third-Party Affiliate

On July 25, 2023, the OCC announced a $15 million civil money penalty against a national bank for its failure to properly supervise a third-party affiliate, and for certain violations of Customer Identification Program (CIP) regulations.

Specifically, the OCC found that, with respect to the third-party affiliate’s efforts to retain small business customers, the bank failed to properly govern and oversee the third-party affiliate, including its call monitoring and documentation process and its customer complaint process. 

In addition, the OCC found that the bank failed to collect employer identification numbers for certain customers and properly maintain records regarding compliance with CIP regulations; and failed to properly maintain records regarding its customer retention efforts and subsequently provide them in accordance with OCC requests.  

The bank neither admitted nor denied the OCC’s findings.