The balance, $2,887,500, is to be remitted to the U. S. Treasury as a penalty payment for the Board's finding that the bank, over a period of more than one year, as a result of changes in loan servicing platforms and third-party service providers, Regions did not effectively monitor a significant number of home equity loans and home equity lines of credit subject to the Flood Act for compliance with Regulation H. The bank discovered that certain home equity loans and home equity lines of credit were not being properly monitored for compliance with Regulation H, Regions addressed the monitoring failure and enhanced its flood compliance program by 2017.

Is 2017 a misprint?

The above cite came from

https://www.bankersonline.com/penalty/174224

I saw that too - but the wheels sometimes turn slowly when you are talking this large of a fine.

I just looked at the actual order and 2017 is the date in the order.

Note that this was a consent order (in general, all CMP orders for flood insurance violations are by consent, since banks generally don't want the hassle and expense of hearings, etc., that could lead up to a flood penalty anyhow).

This is the first order I have seen that includes not only the statutory flood violation penalty of $2,000 per incident (modified for inflation each year), but also a safety and soundness penalty for the described failure of flood insurance monitoring for over a year ($2,887,500). I'm guessing it took some time for Regions and the Fed to negotiate the size of that penalty.

I just found it strange the order is coming down 6 years after they changed their procedures. I guess for that size penalty there was a lot of back and forth before an agreement was reached.

Crazy

There was also likely a delay in detection by the bank examiners. Exams are always backwards looking and based on a sample of loans. There may have been flood samples that excluded all affected loans, especially since recent FRB flood exams have focused on commercial loans (at least in my experience).