OCC Policies and Procedures Manual for Bank Enforcement Actions

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Revisions Focus on Banks That Exhibit “Persistent Weaknesses” and Further Remarks Addressing the “Too Big to Manage” Problem

On May 25, the OCC issued a revised version of its policies and procedures regarding bank enforcement actions. The revisions, which are found in a new Appendix C, address the OCC’s consideration of supervisory and enforcement actions against banks that exhibit “persistent weaknesses” and appear to further remarks delivered by Acting Comptroller Hsu earlier this year regarding what he described as the “too-big-to manage (TBTM) problem.”

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