Welcome to the latest Enforcement Actions Roundup. August was a quiet month on the enforcement front, with just one action to report: a Written Agreement from the Federal Reserve Board placing new source-of-strength and capital-conservation obligations directly on a bank holding company after deficiencies surfaced at its subsidiary bank.
Each month, we break down what went wrong, why it matters, and what your financial institution (FI) can do to stay ahead — giving you two resources: the Enforcement Actions Tracker, a running tally of actions by agency, category, and topic, and the Enforcement Deep Dive below, a closer look at each action's details, takeaways, and controls to revisit.
Related: Bookmark the Ncontracts Enforcement Action Tracker to search the latest enforcement actions by date, category, and regulator.
| Year | Fair Lending | Advertising | AML/CFT | Underwriting | UDAAP | Electronic Funds Transfers | Insider Activities | Flood Insurance | Financial Risk | Concentration | Military Lending | Government Loan Programs | |
| CFPB | 2025 | 1 | 2 | 4 | 1 | 1 | |||||||
| 2026 YTD | 1 | ||||||||||||
| DOJ | 2025 | ||||||||||||
| 2026 YTD | 2 | 2 | 1 | ||||||||||
| OCC | 2025 | 3 | 1 | 8 | 3 | ||||||||
| 2026 YTD | 1 | 1 | |||||||||||
| FRB | 2025 | 1 | 3 | 1 | |||||||||
| 2026 YTD | 1 | 2 | 2 | ||||||||||
| FDIC | 2025 | 5 | 3 | 1 | 1 | 1 | 10 | 6 | |||||
| 2026 YTD | 1 | 1 | 2 | 2 | 6 | 3 | |||||||
| NCUA | 2025 | ||||||||||||
| 2026 YTD |
The CFPB issued no institutional enforcement actions in August 2026.
The OCC issued no institutional enforcement actions in August 2026.
The FRB and a state banking department entered into a Written Agreement with the holding company of the bank after an offsite review identified deficiencies at the organization. The agreement follows an earlier consent order already in place at the bank and extends source-of-strength obligations to the holding company on a consolidated basis. The board of directors must affirmatively demonstrate the holding company’s ability to serve as a source of financial and managerial strength to the bank, including a willingness to raise capital or contribute assets in the event of its financial distress.
Within 60 days, the holding company must submit an acceptable capital plan addressing current and projected capital sources and uses, an analysis of asset quality and earnings capacity, a capital-raising action plan, and an enhanced capital contingency plan, together with a parent-only cash flow projection for 2026 and each subsequent calendar year. Effective immediately, the holding company may not declare or pay dividends, repurchase shares, make other capital distributions, or incur, increase, prepay, or guarantee debt without the prior written approval of its supervisors.
The agreement also imposes notice requirements for new directors and senior executive officers, restricts indemnification and severance payments, and requires quarterly progress reports, including parent-company-only financial statements.
This action illustrates that supervisory findings at a subsidiary bank do not stay contained at the bank level; a separate holding-company agreement layers explicit source-of-strength, capital-planning, and capital/debt-conservation obligations directly onto the parent. Institutions with a holding company structure should not assume that remediating conditions at the bank satisfies supervisory expectations at the consolidated organization; the holding company board should independently assess and document its capacity to serve as a source of financial and managerial strength.
The agreement also confirms that capital conservation restrictions on dividends, repurchases, and debt attach immediately upon execution rather than on a future compliance date, so banks entering similar agreements should have dividend and debt approval workflows and board reporting processes ready in advance.
Finally, the prior-notice requirement for new directors and senior executive officer appointments reinforces that governance changes during a formal enforcement period draw heightened regulatory scrutiny and should be tracked against a defined internal approval timeline.
Related: Board Members: Keep an Eye on Internal Controls
Ncomply Sample Policies
Nrisk Risk Assessments
The FDIC issued no institutional enforcement actions in August 2026.
The NCUA issued no institutional enforcement actions in August 2026.
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