OCC Announces Enforcement Actions for February 2025

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today released enforcement actions taken against national banks and federal savings associations (banks), and individuals currently and formerly affiliated with banks the OCC supervises. The OCC also announced updates to its enforcement action search tool.

The OCC uses enforcement actions against banks to require the board of directors and management to take timely actions to correct the deficient practices or violations identified. Actions taken against banks are:

• Formal Agreement with Dearborn FSB, Dearborn, Michigan, for unsafe or unsound practices, including those related to compliance management, fair lending risk management, insider activities, and compensation practices; and violations related to recordkeeping. (Docket No. AA-CE-2025-2)
• Formal Agreement with Patriot Bank, N.A., Stamford, Connecticut, for violations and unsafe or unsound practices, including those related to strategic planning, capital planning, Bank Secrecy Act/Anti-Money Laundering risk management, payment activities oversight, credit administration, and concentration risk management. (Docket No. AA-NE-2025-05)

The OCC uses enforcement actions against an institution-affiliated party (IAP) to deter, encourage correction of, or prevent violations, unsafe or unsound practices, or breaches of fiduciary duty. Enforcement actions against IAPs reinforce the accountability of individuals for their conduct regarding the affairs of a bank. The term “institution-affiliated party,” or IAP, is defined in 12 USC 1813(u) and includes bank directors, officers, employees, and controlling shareholders. Orders of Prohibition prohibit an individual from any participation in the affairs of a bank or other institution as defined in 12 USC 1818(e)(7). Actions taken against IAPs are:

• Order of Prohibition against Max M. Bender, former Operations Processor at a Cincinnati, Ohio, location of U.S. Bank, N.A., Cincinnati, Ohio, for misappropriating funds from commercial customer deposits, resulting in a loss of at least $23,000 to the bank. (Docket No. AA-ENF-2024-99)
• Order of Prohibition against Justin Cooper, former Bank Teller at a Ramsey, New Jersey, branch of TD Bank, N.A., Wilmington, Delaware, for accessing customer records without authorization and providing customer information to a third party in exchange for money. (Docket No. AA-ENF-2024-87)
• Order of Prohibition against Larry DeWitt, former Chief Credit Officer and Lending Officer at BancCentral, N.A., Alva, Oklahoma, for, among other things, failing to secure cash collateral required for certain new market tax credit loans, which caused the bank to violate its legal lending limit, and failing to inform the bank of a customer’s impending withdrawal of millions of dollars on deposit with the bank, which he encouraged, facilitated, and understood could severely impact the bank’s liquidity. (Docket No. AA-ENF-2024-101)
• Order of Prohibition against Jackeline Graves, former Retail Banker at a Port Arthur, Texas, branch of Woodforest National Bank, The Woodlands, Texas, for gaining unauthorized access to bank customers’ personal information and forging their names onto checks to steal at least $14,000. (Docket No. AA-ENF-2025-06)
• Order of Prohibition against Derek Heaton, former Chief Lending Officer at BancCentral, N.A., Alva, Oklahoma, for failing to secure cash collateral required for certain new market tax credit loans, which caused the bank to violate its legal lending limit. (Docket No. AA-ENF-2024-102)
• Order of Prohibition and to Cease and Desist against Mark Tillman, former Loan Officer at Citizens Bank, N.A., Providence, Rhode Island, for, among other things, making false statements and statements of omission to influence the bank’s mortgage lending decisions; failing to review, identify, and escalate red flags in mortgage loan applications or supporting information; and failing to fully disclose the involvement of a mortgage broker and the broker’s fees. (Docket No. AA-ENF-2024-111)

The OCC terminates enforcement actions when a bank has demonstrated compliance with all articles of an enforcement action; or when the OCC determines that articles deemed “not in compliance” have become outdated or irrelevant to the bank’s current circumstances; or when the OCC incorporates the articles deemed “not in compliance” into a new action. Termination actions include:

• Order Terminating the Cease and Desist Order against Wells Fargo Bank, N.A., Sioux Falls, South Dakota, dated April 20, 2018 (Docket No. AA-EC-2018-15). The order addressed unsafe or unsound practices in the bank’s enterprise-wide compliance risk management program and violations of law that resulted in consumer harm. (Docket No. AA-ENF-2025-13)

The OCC also updated its enforcement actions search tool to allow users to search for enforcement actions issued since 2012 by subject matter and to easily view subject matters covered in those actions. This update provides additional transparency into and search capability for the contents of the public enforcement action database. All OCC public enforcement actions taken since August 1989 are available for download by viewing the enforcement actions database at https://apps.occ.gov/EASearch.

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Related Links

• Enforcement Action Types
• Enforcement Actions Search Tool