betcha you thought I forgot
ICYMI
8/6 @CapitalOne

“..OCC found the noted deficiencies to constitute unsafe or unsound practices and resulted in noncompliance with 12 CFR Part 30; Appendix B, "Interagency Guidelines Establishing Information Security Standards."
...there’s more https://twitter.com/File411/status/1155988791108128770
“...bank's failure to establish effective risk assessment processes prior to migrating significant information technology operations to the public cloud environment and the bank's failure to correct the deficiencies in a timely manner...”
Cloud environment
Board of Directors...
You can’t have a “so stipulated” sans Order or Consent Decree
“By Aug 31, 2020, the Board shall appoint a Compliance Committee of at least -3 members of which a majority shall be directors who are NOT employees or officers of the Bank or any of its subsidiaries or affiliates...”
Article V paragraphs 1-6 BRUTAL

“..requires changes to the Action Plan, the Bank shall incorporate the required changes into the Action Plan and submit the revised Action Plan... for review and prior written determination of no supervisory objection by the Deputy Comptroller”
Unlike some I genuinely believe my followers SHOULD have access to Original Sourced Documents and I’m a fan of sharing is caring
I don’t do disinformation or misinformation
OCC Assesses $80 Million Civil Money Penalty Against Capital One | OCC
https://www.occ.treas.gov/news-issuances/news-releases/2020/nr-occ-2020-101.html#.XzQLyt52o5c.twitter via @usocc
Links to the OCC & CapitalOne enforcement actions below

Consent Order for the Assessment of a Civil Money Penalty👇🏻

https://www.occ.gov/static/enforcement-actions/ea2020-036.pdf

Cease and Desist Order 👇🏻
https://www.occ.gov/static/enforcement-actions/ea2020-037.pdf
I spent a decent amount of time reading the OCC enforcement page. Nothing in the public record suggest Trump pressured Mnuchin
I’m NOT saying it’s not a possibility (it might be), as of right now there’s zero data in the public domain do not support that assertion /files complete
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