OCC Cracks Down on Banks & Employees in February 2025 Enforcement Actions

Key Takeaways:

• Dearborn FSB and Patriot Bank: Both banks have received formal agreements from the OCC to correct unsafe practices, including issues with compliance management, fair lending, and oversight of capital and credit risks.
• Prohibited Employees: Several former bank employees, including individuals from U.S. Bank, TD Bank, and BancCentral, have been banned from future participation in the banking industry for misconduct.
• Wells Fargo Gets a Clean Bill of Health: After making significant strides in compliance, Wells Fargo’s enforcement action from 2018 has been officially terminated.
• New Transparency Tool: A revamped OCC enforcement search tool now offers easier access to enforcement records since 2012, further opening up the agency’s enforcement activities to public scrutiny.

Deep Dive

The Office of the Comptroller of the Currency (OCC) is keeping a close watch on both banks and their employees with its February enforcement actions. The agency has taken action against several banks and individuals for serious compliance failures and misconduct. It’s not just about issuing penalties, it’s about ensuring lasting change and reinforcing accountability across the banking industry.

First, Dearborn FSB and Patriot Bank are now under formal agreements with the OCC for failing to uphold key banking practices. Dearborn FSB in Michigan was called out for its poor compliance management and flawed fair lending practices, while Patriot Bank in Connecticut is under fire for everything from ineffective capital plans to weak anti-money laundering controls. These are the types of institutional failings that can hurt customers and create real systemic risks.

For these banks, the OCC is demanding action—compelling them to overhaul their compliance programs, strengthen their risk management efforts, and make sure these mistakes don’t happen again. This is the kind of oversight that keeps the financial system functioning smoothly and securely.

Personal Accountability in Action

‍But the OCC’s enforcement actions aren’t just about institutions. The agency is also focusing on the individuals who’ve made choices that negatively impacted their banks and customers. Several former employees are now permanently banned from working in the banking industry for serious misconduct.

Take Max M. Bender, for example. The former operations processor at U.S. Bank in Cincinnati misappropriated more than $23,000 from commercial customer deposits. His actions illustrate just how damaging a single employee’s lack of integrity can be—not just for the bank, but for the trust that customers place in their financial institutions.

Then there’s Justin Cooper, a former teller at TD Bank in New Jersey. He accessed customer records without permission and sold that sensitive data for personal gain. This is a breach of confidentiality that goes beyond ethical failure—it’s a betrayal of the public trust.

The OCC is committed to ensuring that individual bad actors don’t escape the consequences of their actions. Misuse of power will be met with severe consequences.

Wells Fargo’s Redemption Story

Not all the news is grim. Wells Fargo has officially had its 2018 cease-and-desist order lifted. After years of intense regulatory scrutiny, the bank has made significant strides in fixing its compliance and risk management practices. This is a moment of redemption for Wells Fargo, which has worked hard to improve its operations. While they still have work to do, this is a sign that major institutions can turn things around with a commitment to change. (Docket No. AA-ENF-2025-13)

It’s a hopeful reminder that accountability, while tough, can lead to real progress. And for Wells Fargo, this milestone signals a new phase where the bank is on track to meet the standards expected of it.

OCC Introduces New Transparency Tool

‍In addition to these enforcement actions, the OCC is rolling out a new search tool that will make it easier for the public to track enforcement activities. The updated tool now allows users to search actions by subject matter, providing more transparency and better access to the information behind the OCC’s decisions. Whether you’re a regulatory professional or simply interested in how the OCC is holding banks accountable, this new tool will make it easier than ever to follow what’s going on.

This latest round of enforcement actions from the OCC isn’t just about penalties and compliance fixes—it’s a reflection of a broader push toward accountability at every level of the banking system. For Dearborn FSB and Patriot Bank, the road ahead will require serious work to rebuild trust and make real changes to their risk management and compliance practices. For the individuals banned from the industry, it’s a stark reminder that no role is exempt from scrutiny, and that integrity matters more than ever.

And for Wells Fargo, this marks a turning point—a reminder that recovery is possible, but only through consistent, meaningful change. The fact that the OCC is willing to acknowledge progress where it’s due sends a strong message: it’s not just about past mistakes, but about what institutions are willing to do moving forward.

With the launch of the updated search tool, the OCC is opening the door for greater transparency, allowing the public to get a clearer view of how enforcement decisions are shaping the industry. The banking sector is under a microscope, and the consequences of failing to comply with standards are more visible than ever.

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