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# OCC Issues Comprehensive Cease and Desist Order Against USAA Federal Savings Bank
- URL: https://www.theglobalbanker.com/occ-issues-comprehensive-cease-desist-order-usaa-federal-savings-bank/
- Published: 2024-12-18T16:42:00.000Z
- Updated: 2026-10-02T13:37:00.000Z
- Description: The OCC replaced prior 2019 and 2022 enforcement orders against USAA Federal Savings Bank with a cease-and-desist covering governance, IT, consumer compliance, and SAR violations.
- Author: TGB Editorial Team
- Tags: Regulations, Americas, #archive

The Office of the Comptroller of the Currency has issued a comprehensive cease-and-desist order against USAA Federal Savings Bank, replacing enforcement actions from 2019 and 2022 that the bank had failed to fully remediate. The order, announced on 18 December 2024 in OCC News Release 2024-137, covers a broad range of deficiencies spanning management, earnings, information technology, consumer compliance, internal audit, and Suspicious Activity Report filing obligations.

The bank has been subject to OCC enforcement since 2019.

#### HEIGHTENED STANDARDS FINDING

The OCC further found that USAA Federal Savings Bank was not in compliance with the agency's Heightened Standards requirements for large banks, codified in 12 CFR Part 30, Appendix D. These standards impose enhanced expectations on institutions that meet certain size thresholds regarding the quality of their risk governance frameworks, the articulation and implementation of risk appetite, and the level of board-level engagement with risk management. 

#### GROWTH RESTRICTIONS AND REMEDIATION

The cease-and-desist order places direct operational constraints on USAA Federal Savings Bank, barring it from adding any new product or service or expanding its membership criteria without first evaluating and documenting the compliance and operational risks, with medium- or high-risk offerings requiring the prior approval of the OCC's Examiner-in-Charge. 

USAA Federal Savings Bank serves a membership base drawn from the United States military community, encompassing active-duty service members, veterans, National Guard and Reserve members, and their eligible family members. The bank will be required to develop and execute comprehensive corrective action plans across the areas identified in the order, with progress subject to ongoing OCC oversight and monitoring.