I just don't see the examiners keeping the penalties low. These CMPs go to FEMA, not Treasury (and maybe that is part of the answer) but FEMA is worse than broke. Charging penalties for violations makes more "cents" than all the fees they are assessing or requiring banks to reduce. You can only take so much from each bank, why not hit the violators harder. Anyway, each agency has published the new rates and that may have been the hurdle they were waiting for.
This last month, Nov for October, there was a very small number of flood and HMDA penalties. I was surprised.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell