Civil Money Penalty Maximums Going Up

By Mary Crotty, Freelance Writer for Banks and Third-Party Service Providers

If your bank or credit union is cited for a compliance violation this year, expect to pay more. Within the last week, each of the primary financial regulatory agencies announced increases to their maximum civil money penalties (CMPs). These increases adjust for inflation as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

Financial Regulatory Agencies Announce CMP Maximum Increases

On January 10, the Board of Governors of the Federal Reserve System (Fed) published a final rule adjusting its CMPs for inflation, which was effective that same day.

The Federal Deposit Insurance Corporation (FDIC) and the Consumer Financial Protection Bureau (CFPB) each published a final rule for adjusting maximum CMPs on January 12 with an effective date of January 15, 2018.

For its part, the Office of the Comptroller of the Currency  (OCC) issued A Notice of Monetary Penalties 2018 that is “applicable to penalties assessed on or after January 12, 2018, for conduct occurring on or after November 2, 2015.”

Finally, the National Credit Union Administration (NCUA) issued its final rule in the Federal Register on January 16 with an effective date of January 15, 2018.

Communication Is Key to Avoiding CMPs

Well written documentation and routine communication with employees about your organization’s compliance requirements is a vital part of a sound and robust compliance program. If you need help creating compliance documentation or communicating policy updates or requirement changes, contact bank risk and compliance writer Mary Crotty at






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