In a landmark enforcement action related to a bank data breach, the Office of the Comptroller of the Currency (“OCC”) assessed an $80 million civil monetary penalty and entered into a cease and desist order with the bank subsidiaries of Capital One on August 6, 2020.  The actions follow a 2019 cyber-attack against Capital One.  The Federal Reserve Board also entered into a cease and desist order with the banks’ parent holding company.  The […]

Since April 2020, more than 5,400 lenders across the United States have faced common challenges arising from the Paycheck Protection Program (“PPP”). Participating lenders have been charged with interpreting a slew of evolving regulatory guidance while vetting millions of borrower applications. Participating lenders have also been tasked with responding to information requests from Congress, federal regulators and law enforcement authorities investigating potential fraud and abuse in the emergency loan program. Yet another challenge looms […]