Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player
From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued 701 formal enforcement actions, representing more than a fifty percent reduction in enforcement actions since the high water mark in 2010. Nevertheless, relative to more normal periods, such as 2004 to 2008, this still suggests a bumper crop of enforcement actions. While the relative decrease in recent enforcement activity reflects the banking industry’s recovery from the financial crisis, regulators imposed record financial penalties in 2013. This is an ominous trend for financial institutions.
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