Notification of Inflation Adjustments for Civil Money Penalties
Published Date: 1/10/2025
Rule
Summary
Starting January 10, 2025, the Office of the Comptroller of the Currency is raising the maximum fines it can charge for certain violations to keep up with inflation. This means anyone facing civil money penalties from the OCC for actions after November 2, 2015, might see higher fines. These updates help keep penalties fair and effective as prices change over time.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 5 costs, 1 mixed.
OCC raises civil money penalty caps
The Office of the Comptroller of the Currency raised its maximum civil money penalties effective January 10, 2025 for conduct on or after November 2, 2015. The OCC applied the OMB inflation multiplier of 1.02598 to the 2024 maximums to calculate the 2025 amounts.
Common Tiered penalties increased to three levels
For many OCC-administered violations, the 2025 maximum per-day penalty amounts are now Tier 1 = $12,567, Tier 2 = $62,829, and Tier 3 = $2,513,215. These tiered amounts apply to multiple statutes listed in the notice starting January 10, 2025 for conduct on or after November 2, 2015.
Post-employment restriction penalty set at $413,388
The maximum penalty for violating post-employment restrictions (12 U.S.C. 1820(k)(6)(A)(ii)) is $413,388 per violation beginning January 10, 2025 for conduct on or after November 2, 2015. This amount is the 2025 inflation-adjusted cap.
Securities-related CMPs vary by person type
For violations under 15 U.S.C. 78u-2(b), the 2025 maximums differ for natural persons and other persons: Tier 1 natural person = $11,823, Tier 1 other person = $118,225; Tier 2 natural = $118,225, Tier 2 other = $591,127; Tier 3 natural = $236,451, Tier 3 other = $1,182,251. These apply to penalties assessed on or after January 10, 2025 for conduct on or after November 2, 2015.
Other specific adjusted penalty amounts (appraisal, flood)
The notice lists other 2025 caps such as Appraisal Independence: first violation $14,435 and subsequent violations $28,866; Flood Insurance violation $2,730. These amounts apply to penalties assessed on or after January 10, 2025 for conduct on or after November 2, 2015.
Pre-2015 conduct subject to older CMP caps
Penalties assessed for violations that occurred before November 2, 2015 remain subject to the OCC's pre-2015 regulatory maximum amounts rather than these 2025 adjusted caps. The 2025 adjustments apply only to conduct on or after November 2, 2015.
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