OVERVIEW

Sullivan & Cromwell’s Banking Enforcement Actions Tracker—or BEAT—is a web-based tool that aggregates and displays data pertaining to significant enforcement actions from January 1, 2008 to the present against banking organizations by the federal banking agencies and select other federal and state agencies. The BEAT permits users to directly search and sort the actions based on key factors of interest and using search terms, and provides important summary information about each action, thus making unnecessary the labor-intensive manual searches and reviews that, until now, have been required to compile meaningful information about enforcement actions.

There are two versions of the BEAT: a limited version, which is publicly available, and a full version, which is available to clients of Sullivan & Cromwell and offers additional features as outlined below:



The BEAT’s development and broad availability demonstrate Sullivan & Cromwell’s ongoing commitment to adding value for our clients with banking regulatory needs.
 
Sullivan & Cromwell intends to regularly update the BEAT and welcomes feedback on the tool. Clients interested in access to the full version are encouraged to contact any Sullivan & Cromwell partner you work with.  

Last Updated: June 19, 2017

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634
EverBank Financial Corp.
June 8, 2017
FRB
Consent Order (CMP)
$1,800,000
Mortgages
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unspecified
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633
Fay Servicing, LLC
June 7, 2017
CFPB
Consent Order (C&D)
Mortgages
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 C.F.R. § 1024.38 (General Servicing Policies, Procedures, and Requirements)
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
Real Estate Settlement Procedures Act, 12 U.S.C. §§ 2601 et seq.
Regulation X, 12 C.F.R. § 1024.41 (Loss Mitigation Procedures)
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632
Deutsche Bank AG; Deutsche Bank AG (New York Branch); DB USA Corporation; Deutsche Bank Trust Company Americas
May 26, 2017
FRB
Consent Order (CMP & C&D)
$41,000,000
BSA/AML
Yes No Yes
LOOKBACK: Yes
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 211.24(f) (BSA Program)
12 C.F.R. § 211.24(j) (BSA Program)
12 C.F.R. § 225.4(f) (SARS)
31 C.F.R. Chapter X (FinCEN Regulations)
Bank Secrecy Act, 31 U.S.C. §§ 5311 et seq.
Regulation H, 12 C.F.R. § 208.62 et seq. (SARS)
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631
SunTrust Bank
May 24, 2017
FRB
Consent Order (CMP)
$1,501,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973, 42 U.S.C. §§ 4001, et seq.
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630
Banamex USA
May 18, 2017
DOJ (Crim)
Non Prosecution Agreement
$97,440,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Bank Secrecy Act, 31 U.S.C. §§ 5311 et seq.
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624
U.S. Bank, N.A.
April 25, 2017
OCC
Consent Order (CMP)
$15,000,000
Other
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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621
Deutsche Bank AG; DB USA Corp.; Deutsche Bank AG (New York Branch)
April 20, 2017
FRB
Consent Order (CMP & C&D)
$136,950,000
Anti-Trust/Market Related
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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622
Deutsche Bank AG
April 20, 2017
FRB
Consent Order (CMP & C&D)
$19,710,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Section 619, Dodd-Frank Wall Street Reform and Consumer Protection Act (Volcker Rule)
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623
UBS AG
March 22, 2017
OCC
Written Agreement
BSA/AML
Yes No No
LOOKBACK: Yes
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 21.21 (BSA Program)
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482
Santander Holdings USA, Inc; Santander Consumer USA Inc.
March 21, 2017
FRB
Written Agreement
Consumer Compliance
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Unspecified
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629
Nationstar Mortgage LLC
March 15, 2017
CFPB
Consent Order (CMP & C&D)
$1,750,000
Consumer Compliance
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. part 1003 (Regulation C of the Home Mortgage Disclosure Act)
Home Mortgage Disclosure Act, 12 U.S.C. § 2801 et seq.
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448
Merchants Bank of California, N.A.
February 16, 2017
FinCEN
Consent Order (CMP)
$7,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 21.21 (BSA Program)
31 C.F.R. § 1010.610 (Due Diligence for Foreign Correspondent Accounts)
31 C.F.R. § 1020.210 (BSA Program)
31 C.F.R. § 1020.320 (SARs)
31 U.S.C. § 5318(g) (SARs)
31 U.S.C. § 5318(h) (BSA Program)
31 U.S.C. § 5318(i) (Due Diligence for Foreign Correspondent Accounts)
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447
Merchants Bank of California, N.A.
February 14, 2017
OCC
Consent Order (CMP)
$1,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 21.21 (BSA Program)
Violation of Prior Order
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628
UniRush LLC
February 1, 2017
CFPB
Consent Order (CMP & C&D)
$3,000,000
Consumer Compliance
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
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451
Deutsche Bank AG; Deutsche Bank AG (New York Branch)
January 30, 2017
NYDFS
Consent Order (CMP & C&D)
$425,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
3 NYCRR § 116.2 (AML Program)
New York State Banking Law § 200-c (Maintenance of Books, Accounts and Records)
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For this purpose, "significant" is defined as (1) an action against a Global Systemically Important Bank or (2) that involves at least one of the following: (a) penalties of $1 million or more; (b) substantial consumer relief requirements; or (c) coordinated or parallel actions by a federal banking agency and at least one other agency.

Disclaimer Notice: Banking Enforcement Actions Tracker is an informational product provided by Sullivan & Cromwell LLP and should not be regarded as a substitute for legal advice.