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Ryan Steger, fmr. Pres., CEO, Director, Commonwealth Bank, FSB, Mount Sterling, KY

Mount Sterling, KY
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OCC EA #2015-095

The Comptroller finds, and Respondent neither admits nor denies, the following:
(1) The Comptroller and the Bank entered into a formal agreement on January 8, 2013 (“Formal Agreement”);
(2) Respondent was President, CEO, and Director of the Bank from prior to January 8, 2013 through May 31, 2015.
(3) Article IV of the Formal Agreement required the Board to “develop, implement and thereafter ensure Bank adherence to a written program to establish internal controls to safeguard and manage Bank assets and ensure Bank resources are only used for legitimate business purposes.” Accordingly, the Board of Directors adopted the “Internal Controls Guidance Procedures for Business Expenses for Travel, Entertainment & Reimbursements for Directors, Officers, Employees or Affiliates,” effective February 15, 2013 (“Internal Controls Policy”), requiring Bank employees, directors, and officers to keep records substantiating the business purpose for each charge to the Bank’s credit card.
(4) Between July 2014 and February 2015, Respondent used the Bank’s credit card for personal fuel expenses approximately 32 times, totaling approximately $2,200, causing the Bank to pay for Respondent’s personal expenses in violation of the Formal Agreement and in contravention of the Internal Controls Policy. On or about April 6, 2015, Respondent reimbursed the Bank for payments the Bank made on his behalf for personal fuel expenses.
(5) By reason of the foregoing conduct, Respondent caused, brought about, participated in, counseled, or aided or abetted the Bank’s violation of the Formal Agreement, recklessly engaged in an unsafe or unsound practice, and breached his fiduciary duty to the Bank. Respondent’s actions resulted in pecuniary gain to him.

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