For those of you counting, there were 9 flood CMPs on the FDIC list this month. http://www.bankersonline.com/compliance/floodcmps.html

Total flood CMPs YTD = $1,141,995 which exceeds all of 2008, $947,835.
There have been 86 penalties YTD, 89 total in 2008.
The AVG CMP in 2009 is $13,279 compared to $10,650 last year.

Taking the total dollars of CMPs and dividing it by calendar days in the year that have already come, the daily average CMP in 2008 was $2,590, while 2009 is $4,277.
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AndyZ CRCM
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