Federal Banking Enforcement Up Sharply in 2010

Last week, the Bureau of National Affairs printed a must read review of the 2010 enforcement actions by federal banking agencies. The article, entitled "2010 Bank Enforcement Actions: A Hardened Government Attitude" contains a sobering account of the federal government's 2010 enforcement activity, penalties assessed, consent orders executed and, perhaps most importantly, enforcement trends as compiled by the authors.

That the article was not published until mid-April 2011 is likely not so much a comment on its importance (it is important) as a comment on the amount of time required to obtain the enormous amounts of information and data that were crunched into nine single spaced pages. Bottom line: If you work in the world where finance and law intersect, represent players in the financial industry, are interested in understanding why "recrimination" is in the title of this blog, or would like a view into what we can expect from the Consumer Financial Protection Bureau and/or the states' Attorneys General in the coming months and years, this is required reading. Thanks to my partner and leading banking law expert, Don Lampe for turning us on to this excellent piece of journalism.

If the current trends continue, it appears that our major banks have no more chance to avoid recrimination and enforcement than the Pink Floyd's plaintiff children have to avoid "education" and "thought control" in "The Wall Part 2." And, at the risk of stretching the metaphor, the "teacher" will not "leave those kids alone."