OCC Fines Bank $15 Million over Deceptive Account Disclosures

The OCC recently announced a consent order with a national banking association (the Bank), imposing a $15 million civil money penalty for deceptive practices concerning the Bank’s account disclosures that the OCC found were in violation of Section 5 of the FTC Act.

The OCC found (and the Bank neither admits nor denies) that the Bank failed to apply certain fee waivers and discounts described in its account disclosures.  The OCC determined that the Bank’s practices, which resulted in pecuniary gain to the Bank, are attributable to at least one weakness in the design or execution of procedures and internal controls.

According to the consent order, the Bank self-identified these violations of law and is taking appropriate remedial actions, including reimbursing the affected customers.