In their latest semi-annual article analyzing federal bank enforcement actions, Tom Vartanian and Larry Nesbitt describe how the recent financial turmoil has resulted in an unprecedented surge in the number of enforcement actions taken in 2009. See Vartanian and Nesbitt, Enforcement Actions Against Banks Exceeded 1000 for First Time in 2009, 94 Banking Rep. (BNA) 444 (Mar. 2, 2010).
Fried Frank monitors all enforcement actions brought by the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Office of Thrift Supervision, whether the Firm is representing parties in the actions or not, in order to identify agency enforcement trends, new provisions in agency enforcement actions, the order of magnitude of civil money penalties and developing defenses. If you have any questions about enforcement policies or actions, please do not hesitate to call us.
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