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OCC BULLETIN 2011-37
To: Chief Executive Officers of All National Banks, Federal Branches and Agencies, Federal Savings Associations, Department and Division Heads, and All Examining Personnel

Description: Enforcement Action Policy

Pursuant to section 316 of Dodd–Frank Wall Street Reform and Consumer Protection Act, the Office of the Comptroller of the Currency (OCC) has revised the scope of its Policies & Procedures Manual (PPM) policy for taking appropriate enforcement action in response to violations of law, rules, regulations, final agency orders and unsafe and unsound practices or conditions (Enforcement Action Policy) to include federal savings associations. The revised PPM (attached) will provide for consistent and equitable enforcement standards for national banks and federal savings associations. This PPM supersedes PPM 5310-3, Enforcement Action Policy, dated July 30, 2001, and Supplement 1 to PPM 5310-3(REV), dated November 10, 2004. It also supersedes Office of Thrift Supervision (OTS) Examination Handbook Section 080, Enforcement Actions, dated July 18, 2008, and any OTS policies and guidance that relate to issues addressed by OTS Examination Handbook Section 080 that are addressed in this PPM.

This bulletin makes public PPM 5310-3 (REV), dated September 9, 2011, which describes the OCC’s Enforcement Action Policy, as revised to include federal savings associations. This PPM is applicable to all types of national banks, federal branches and agencies of foreign banks, and federal savings associations. It is also applicable to enforcement actions that the OCC may take against bank service companies under 12 USC 1861.

Various links to the revised policy are:

For further information, contact Special Supervision at (202) 649-6550.


Michael L. Brosnan
Senior Deputy Comptroller for
Large Bank Supervision

Jennifer C. Kelly
Senior Deputy Comptroller for
Midsize and Community Bank Supervision