On November 24, the Board of Governors of the Federal Reserve System announced the execution of two settlement agreements in enforcement actions against two regional banks concerning alleged violations of the National Flood Insurance Act (“NFIA”), 42 U.S.C. § 4012a(f)(4). The Board of Governors asserted that where a pattern or practice of violations of the NFIA is found, civil money penalties can be imposed up to $2,000 per violation. To resolve the enforcement actions, the banks consented to civil money penalties of $5,000 and $28,640 respectively. The banks did not admit wrongdoing and the agreements were entered without any “finding on any issue of fact or law.”
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