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OCC, Report of the Ombudsman (2005-2006)

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OCC, Report of the Ombudsman (2005-2006) Appendix A OCC Formal Enforcement Actions in the Consumer Protection Area 2009: • Florida Capital Bank, N.A., Jacksonville, Florida (formal agreement – March 26, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. • National Bank of Arkansas, North Little Rock, Arkansas (formal agreement – March 30, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. • Merchants Bank of California N.A., Carson, California (formal agreement – March 31, 2009). We required the bank to strengthen internal controls to improve its information security program and to improve compliance with applicable consumer laws and regulations. • Ozark Heritage Bank, N.A., Mountain View, Arkansas (operating agreement – Apr. 10, 2009). We required the bank to adopt and ensure adherence to a written consumer compliance program. • Farmers and Merchants National Bank of Hatton, Hatton, North Dakota (formal agreement – May 11, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. • Stone County National Bank, Crane, Missouri (formal agreement – June 25, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations and to strengthen internal controls to improve its information security program. • Union National Community Bank, Lancaster, Pennsylvania (formal agreement – Aug. 27, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. 2008: • Crown Bank N.A., Ocean City, New Jersey (consent order – Feb. 19, 2008). We required the bank to pay a civil money penalty of $7,500 for violations of HMDA and its implementing regulation. • Wachovia Bank, N.A., Charlotte, North Carolina (consent order and formal agreement – Apr. 24, 2008). In this FTC Act action, we required the bank to set aside $125 million for restitution to affected consumers and to develop policies 1 and procedures governing its banking relationships with customers who regularly deposit remotely created checks. We also imposed a civil money penalty of $10 million and required the bank to $8.9 million to fund consumer education programs directed at the elderly. • First National Bank USA, Boutte, Louisiana (formal agreement – May 21, 2008). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. • Home National Bank, Blackwell, Oklahoma (formal agreement – June 18, 2008). We required the bank to strengthen internal controls to improve compliance with applicable laws and regulations. • Granite Community Bank, N.A., Granite Bay, California (formal agreement – July 21, 2008). We required the bank to strengthen internal controls to improve its information security program. • Vineyard Bank, N.A., Corona, California (consent order – July 22, 2008). We required the bank to strengthen internal controls to improve its information security program. • Texas Republic Bank, N.A., Frisco, Texas (formal agreement – Aug. 14, 2008). We required the bank to strengthen internal controls to improve its information security program and to improve compliance with applicable consumer laws and regulations. • Beach First National Bank, Myrtle Beach, South Carolina (formal agreement – Sept. 30, 2008). We required the bank to strengthen internal controls to improve its information security program. • TomatoBank, N.A., Diamond Bar, California (consent order – Nov. 19, 2008). We required the bank to strengthen internal controls to improve its information security program. 2007: • Commerce Bank/Harrisburg N.A., Harrisburg, Pennsylvania (formal agreement – Jan. 29, 2007). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • The Farmers National Bank of Osborne, Osborne, Kansas (formal agreement – March 28, 2007). We required the bank to strengthen its internal controls to improve its information security program and compliance with all applicable consumer laws and regulations. 2 • The First National Bank of Monahans, Monahans, Texas (formal agreement – Aug. 22, 2007). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations. • First National Bank of Lewellen, Lewellen, Nebraska (formal agreement – Oct. 27, 2007). We required the bank to strengthen internal controls to improve its information security program. • First National Bank, Goodland, Kansas, Agreement (formal agreement – Dec. 13, 2007). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. 2006: • Alaska First Bank & Trust, N.A., Anchorage, Alaska (formal agreement – Feb. 2, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • City First Bank of DC, N.A., Washington, DC (formal agreement – Feb. 6, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • Maryland Bank and Trust Company, N.A., Lexington Park, Maryland (formal agreement – Feb. 10, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • First National Bank, Fort Collins, Colorado (formal agreement – July 20, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • The First National Bank of Lindsay, Lindsay, Oklahoma (formal agreement – July 25, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations • AB&T National Bank, Dotham, Alabama (formal agreement – July 27, 2006). We required the bank to strengthen its internal controls to improve its information security program. • Albany Bank and Trust, N.A., Albany, Georgia (formal agreement – July 27, 2006). We required the bank to strengthen its internal controls to improve its information security program • Cornerstone Mortgage Co., Houston, Texas, an operating subsidiary of First National Bank of Omaha, Omaha, Nebraska (consent order – Aug. 7, 2006). We required the company to pay a civil money penalty of $25,000 for violations of HMDA and its implementing regulation. 3 • First National Bank of New Holland, New Holland, Ohio (consent order – Sept. 26, 2006). We required the bank to remedy violations of Regulation C, Home Mortgage Disclosure. • First United Bank, N.A., Englewood, Colorado (consent order – Oct. 5, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • First National Bank, Julesburg, Colorado (formal agreement – Oct. 24, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. 2005: • Peoples National Bank of Colorado, Colorado Springs, Colorado (formal agreement – Feb. 22, 2005). We required the bank to provide training for its employees on the Truth in Lending Act and the Real Estate Settlement Procedures Act and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • Chicago Title Insurance Company, acting as agent for Frost National Bank, San Antonio, Texas; Southwest Bank of Texas, N.A., Houston, Texas; and Whitney National Bank, New Orleans, Louisiana (consent order – Feb. 24, 2005). We required the company to pay a civil money penalty of $5 million and to ensure the accuracy of real estate settlement documents provided to federally insured depository institution lenders and borrowers. • The Fulton County National Bank and Trust Co., McConnellsburg, Pennsylvania (consent order – March 23, 2005). We required the bank to employ a consultant to assess compliance with the Truth in Lending Act and the Real Estate Settlement Procedures Act and to provide information to the Assistant Deputy Comptroller regarding any violations requiring reimbursement. • The First National Bank of Cainesville, Cainsville, Missouri (formal agreement – May 23, 2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations and to improve its information security program. • Amcore Bank, N.A., Rockford, Illinois (formal agreement – May 31, 2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations. • First Citizens Bank, N.A., Columbia Falls, Montana (formal agreement – June 9, 2005). We required the bank to strengthen its internal controls to improve 4 compliance with applicable consumer laws and regulations and to improve its information security program. • The Exchange National Bank of Cottonwood Falls, Cottonwood Falls, Kansas (formal agreement – June 17, 2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations and to improve its information security program. • First National Bank of Catlin, Catlin, Illinois (formal agreement –June 27, 2005). We required the bank to strengthen its internal controls to improve its information security program and compliance with applicable consumer laws and regulations. • First Horizon Home Loan Corporation,
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