The Office of the Comptroller of the Currency announced a Formal Agreement with First Federal Savings and Loan Association of Lorain, based in Lorain, Ohio, on 18 April 2024, citing unsafe or unsound practices relating to strategic planning, liquidity and interest rate risk management and its Bank Secrecy Act and anti-money laundering compliance programme. The action was published in OCC News Release 2024-41, dated 18 April 2024, and identifies five distinct areas of deficiency that the regulator has directed the institution to address under the terms of the agreement.
FIVE AREAS OF COMPLIANCE DEFICIENCY IDENTIFIED
The OCC's action cited five distinct compliance failings at the institution. These included the failure to develop and implement a strategic plan, failure to manage liquidity and interest rate risks adequately, inadequate BSA/AML internal controls, failure to appoint a BSA Officer possessing the requisite skills and experience for the role, and violations of the ongoing customer due diligence requirements that federal regulation imposes on all bank and thrift entities.