Enforcement Actions Roundup: March 2026

Welcome to the latest Enforcement Actions Roundup, covering March’s enforcement actions. Each month, we break down what went wrong, why it matters, and what your financial institution (FI) can do to stay ahead.

A note on this month's roundup: We're expanding coverage to include Department of Justice enforcement actions and settlements moving forward. There are no DoJ actions in this month’s edition, but keep an eye out for them in future posts.

This roundup features two key resources:  

• Enforcement Actions Tracker: A running tally of actions by agency, category, and topic — making it easy to spot enforcement trends and emerging hot spots.  
• Enforcement Deep Dive: A closer look at each action, including what happened, key takeaways, and the controls your FI should revisit to avoid similar missteps.

Let's explore this month’s enforcement actions.

Related: Bookmark the Ncontracts Enforcement Action Tracker to search the latest enforcement actions by date, category, and regulator.    

2025/2026 Enforcement Action Tracker

Enforcement Actions Deep Dive: March 2026

CFPB Enforcement Actions

The CFPB issued no institutional enforcement actions in March 2026.

DOJ Enforcement Actions

The DOJ issued no institutional enforcement actions in March 2026.

OCC Enforcement Actions

The OCC issued no institutional enforcement actions in March 2026. 

FRB Enforcement Actions

The FRB issued no institutional enforcement actions in March 2026.  

FDIC Enforcement Actions

FDIC Issues Amended and Restated Consent Order for Liquidity and Capital Deficiencies 

• Category: Governance, Risk, Compliance 
• Topic: Financial Risk
• Date: Issued February 19, 2026; Announced March 27, 2026
• Regulation: 12 CFR 324; 12 CFR 329
• Enforcement Action
• Related Guidance: Updated Guidance: Interagency Policy Statement on Funding and Liquidity Risk Management on the Importance of Contingency Funding Plans (FIL-39-2023); Risk Management Manual of Examination Policies

The FDIC issued an amended and restated consent order for a bank, consolidating three prior orders from 2022 and 2024. Those orders called out material weaknesses in the bank's liquidity and contingency funding framework, as well as inadequate capital monitoring triggers and early warning indicators. The recurrence of these findings across multiple exam cycles suggests deeper governance failures, including insufficient board oversight and an inability to fully implement and sustain corrective actions. 

Takeaways

Regulators expect programs to be dynamic. Plans must be stress-tested regularly and updated to reflect the institution's current risk profile. Capital monitoring programs should include clearly defined early warning indicators and escalation triggers with documented remediation timelines, ensuring that emerging issues are captured before attracting regulatory attention.  

The repeated nature of the violations underscores the importance of substantive and ongoing board oversight. Liquidity and capital reporting at board meetings — documented in meeting minutes — is key to ensuring that deficiencies don’t persist.  

Controls to Evaluate

1. ALCO Board Reporting: Asset Liability Committee (ALCO) reports regularly to the Board regarding the institution's liquidity risk profile, interest rate risk profile, and credit risk profile, as well as risk measurement and reporting systems and contingency funding plans. 
2. Liquidity and Fundings Management Policy: Liquidity and funds management policy is comprehensive and reviewed periodically. The policy may include: 
   1. Structure and responsibilities of the Asset Liability Committee (ALCO) 
   2. Requirement of periodic review of the FI's deposit structure/composition 
   3. Permissible funding sources and concentration limits 
   4. Calculation for cost of funds 
   5. Procedures for measuring and monitoring liquidity, including static measurements and cash flow projections using base case and stress scenarios 
   6. Type and mix of permitted investments 
   7. System of internal controls, including independent reviews of liquidity management practices, compliance with internal policies, procedures, and risk limits 
   8. Contingency funding plan 
   9. Periodic testing requirement of liquidity lines 
   10. Procedures for reviewing and documenting assumptions used in liquidity projections 
       
   11. Procedures for approving exceptions to policies, limits, and authorizations 
   12. Permissible wholesale funding sources and authority levels for accessing them 
   13. Process for measuring and monitoring unused borrowing capacity 
   14. Established target liquidity ratios and parameters 
3. Contingency Funding Plan: Contingency funding plan is established and outlines procedures for accessing additional liquidity during stressed market conditions or unexpected funding needs. Plans include identification of available funding sources, activation procedures, decision-making authorities, and communication protocols.  
   

Related Ncontracts Content in Your Platform

Ncomply Sample Policies

• Liquidity Risk Management Policy
• Asset Liability Management (ALM) Policy

Nrisk Risk Assessments

• Asset Liability Management (ALM) 

NCUA Enforcement Actions

The NCUA issued no institutional enforcement actions in March 2026.  

Your compliance program doesn’t have to live in spreadsheets and email threads. Ncomply centralizes your tasks, oversight, and regulatory tracking so nothing falls through the cracks.