With the OCC's publication of a $452K flood CMP against Citi today (the order was from Oct 10) this year's total is at $2.7 million in CMPs and the FDIC hasn't added this months contributions yet.
This is 61% more than in 2007 and is the highest since I've been tracking it in the last 12 years. Certainly the increase in the CMP fine itself is a major factor, but at the end of the day, lenders are still having problems.
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AndyZ CRCM
My opinions are not necessarily my employers.
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