ARTICLE
12 October 2020

Bank Settles FRB And OCC Charges For Risk Management Deficiencies

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The FRB Order charged the bank's holding company.
United States Finance and Banking

A national bank and its holding company settled Federal Reserve Board ("FRB") and OCC charges for failure to correct deficiencies in, among other things, risk management and internal controls, data quality management and compliance management. (See here for the FRB Cease and Desist Order, here for the OCC Cease and Desist Order and here for the Consent Order). The FRB Order charged the bank's holding company. The OCC Order charged the national bank.

To settle the FRB's charges, the bank agreed to undertake, among other things, the firm-wide correction of its risk management and internal control deficiencies. To settle the OCC's charges, the bank agreed to take comprehensive measures to correct the aforementioned deficiencies and to pay a $400 million civil money penalty.

Primary Sources

  1. Federal Reserve Order: Citigroup Inc.
  2. OCC Order: Citibank, National Association
  3. OCC Civil Money Penalty Order: Citibank, National Association

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