The Office of the Comptroller of the Currency (OCC) on 21 August 2025 published a formal agreement with First National Bank & Trust Company of Clinton, Illinois, citing unsafe or unsound practices, including those related to capital, strategic planning, liquidity and contingency funding planning. The agreement, docket number AA-CE-2025-30, was released as part of the OCC's enforcement actions for August 2025. It was signed by the bank's board on 9 July and by the OCC on 16 July 2025.
HIGHER CAPITAL MINIMUMS
Under the agreement, the bank must achieve by 30 September 2025, and maintain thereafter, a leverage ratio of at least 9% and a total capital ratio of at least 12%. It must submit a capital plan within 90 days and review its capital planning process, and it may pay dividends only with prior OCC approval. The board is required to review the bank's performance against the capital plan each quarter.
The bank must also submit, within 90 days, a strategic plan covering at least three years, addressing matters including its mission, risk assessment, staffing, budget, financial forecasts and performance measures. It may not deviate significantly from the plan without the OCC's prior written approval.
LIQUIDITY AND CONTINGENCY FUNDING
Within 90 days the bank must adopt a liquidity risk management programme that includes cash flow projections, diversified funding sources and stress testing, and must produce monthly liquidity reports. It must also revise its contingency funding plan within the same period to address liquidity stress events and early-warning indicators.
The board must set up compliance reporting, with an initial report due within 120 days and quarterly reports thereafter describing the corrective actions taken and their results. The agreement also provides that the bank is in troubled condition, which makes it ineligible for certain regulatory exemptions.
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