More (Though Not New) Thoughts on Bank Civil Money Penalties Insurance

A client asked about my knowledge of the history of civil money penalties against bank board members. The question was prompted by a note I sent about AmTrust's CMP insurance policy. My Reply: CMP against banks seems to be mostly for issues of lack of flood insurance on loan collateral that is in flood areas. CMP against directors is exceedingly … [Read more...]

Summary of Bank Civil Money Penalty Issue As Of Now

I just sent the following to a bank client. We had completed a coverage review and thought that the issue of Civil Money Penalties should be in a separate email - making it easier to forward on to his board. John Smith, In our conversation yesterday I recommended that the bank consider removing civil money penalties insurance from the directors' … [Read more...]

Bank Civil Money Penalties Insurance & The FDIC

Bankers got a note a month ago from the FDIC telling them that civil money penalties insurance on a bank directors' and officers' insurance policy was a no-no. CMP is a topic I have written about a fair amount. Today I had a conversation with several bankers and an association executive on the issue. I thought a video might be … [Read more...]

FDIC Stomps On Civil Money Penalties Insurance

This note was just sent to my email list of bankers... I have been expecting action by the FDIC on the issue of Civil Money Penalties (CMP) for some time now. This one is not subtle. Actually, I expected the FDIC to start hitting banks buying CMP with civil money penalties. (Wink) For about a year now I have been urging my clients not buy … [Read more...]

Civil Money Penalties Update

I've had several (OK, many, many) conversations over the past few weeks on the issue of bank directors and officers insurance civil money penalties coverage.  (See my other posts on this blog on this topic.) I have worked on dozens of D&O renewals in the past few months.  Not once has the insurer or agent brought the subject of CMP up - … [Read more...]

Bank Civil Money Penalties Insurance Update

A note from a client today - to his agent, cc to me:~~~~~Bob (not the agent's real name), With the many new laws, regulations and agencies to enforce them, we are concerned about the possibility of errors in the mortgage lending area and possible fines related thereto.  It is our understanding that it is possible for the institution, and the loan … [Read more...]

Civil Money Penalties Insurance & Banks

Lots of heat (and little light) lately in the discussion of civil money penalties insurance within bank directors' and officers' insurance.     I talked with a client today on the issue and promised a letter he could send to his attorney.  (Names changed...)   ~~~~~~~~~~~ Bill and Steve,   We discussed the issue of civil money penalties … [Read more...]