The OCC recently issued new civil money penalty guidance and Bank Secrecy Act/Anti-Money Laundering supervision procedures. The NCUA said although it will address CMPs during the board's June meeting, it does not currently plan to make changes to its BSA/AML regulatory regirm.

On Feb. 26, the OCC revised its Policies and Procedures Manual policy for assessing civil money penalties. The bulletin, which is guidance and not a formal rule, detailed a new CMP matrix for institutions. 

The matrix included 11 factors to consider when rating the severity of the regulatory violation: Intent; continuation after notification; concealment; financial gain or other benefit as a result of violation; loss or risk of loss to the bank; impact or harm other than financial loss to the bank; loss or harm to consumers or the public (consumer law or Bank Secrecy Act violations), previous concern or administrative action for similar violation; history of violations and tendency to engage in violations; duration and frequency of violations before notification; and, effectiveness of internal controls and compliance program.