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    Edelman, Combs, Latturner, & Goodwin, LLC

    20 South Clark Street
    Suite 1500
    Chicago, IL 60603
    Phone: 312-739-4200
    Fax: 312-419-0379

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    OCC Fines JPMorgan Chase $30 Million for Deficiencies in Debt Collection Practices and Servicemembers Civil Relief Act Compliance

    OCC Fines JPMorgan Chase $30 Million for Deficiencies in Debt Collection Practices and Servicemembers Civil Relief Act Compliance

    WASHINGTON — The Office of the Comptroller of the Currency (OCC) today assessed a $30 million civil money penalty against JPMorgan Chase Bank, N.A.; JPMorgan Bank and Trust Company, N.A.; and Chase Bank USA, N.A. for unsafe or unsound practices related to the non-home loan debt collection litigation practices and to the Servicemembers Civil Relief Act (SCRA) compliance practices.

    The unsafe or unsound practices involved deficiencies in the bank’s practices and procedures related to the preparation and notarization of affidavits and other sworn documents used in the bank’s debt collection litigation and deficiencies in its SCRA compliance program.

    The penalty, paid to the U.S. Treasury, follows the enforcement action issued by the OCC on September 18, 2013. That order required the bank to provide remediation to affected consumers and to correct deficiencies in the bank’s practices and procedures.

    As of June 2015, consumers have received more than $50 million as a result of the OCC’s 2013 orders. Bank management continues to identify impacted consumers and servicemembers as required under the OCC Consent Order, and will pay additional restitution to affected consumers as necessary.

    OCC national bank examiners continue to monitor the bank’s compliance with the order.

    The Consumer Financial Protection Bureau (CFPB) along with 47 states and the District of Columbia, are taking separate actions, which were also announced today.

    Statement of Thomas J. Curry Comptroller of the Currency On Civil Money Penalties Assessed Against JPMorgan Chase Bank July 8, 2015 The civil money penalty we are assessing today follows an enforcement action that we took against JPMorgan Chase Bank N.A. and two of its affiliates in 2013. That action focused on non-mortgage debt collection practices and Servicemember Civil Relief Act compliance. At that time, we required corrective action to address the deficiencies plus restitution for customers harmed by improper practices. To date, more than $50 million in restitution has been paid by the bank to affected customers. Compliance with the Servicemembers Civil Relief Act, or SCRA, is a matter of great concern to me and to the OCC. The men and women who serve in the uniformed military not only put themselves at risk, but they give up the comforts of home and family, and they sacrifice financially. Congress took note of their financial sacrifice in passing the SCRA, and we recognized it in changes we made to our examination procedures in 2013. At that time, we mandated that SCRA compliance be evaluated as part of every exam at every institution we supervise. Each of those examinations must include a review of the process the bank uses to comply with rate reduction requests from individuals who go on active duty, as well as an evaluation of the bank’s foreclosure practices with respect to servicemembers. Although these steps are not required by law, we felt they were necessary to ensure that the men and women who serve our country receive the legal protections they are entitled to. With respect to debt collection, it was dismaying to find that documents being used in litigation were being rushed through in a process that has come to be known as “robosigning.” Our action in 2013 was aimed at ensuring that affidavits and other sworn documents are accurate, based on the knowledge of the person signing the document, and properly notarized. Today, after having taken time to assess the full extent of the deficiencies, we are joining with the CFPB and the states in assessing monetary penalties. These come on top of the restitution required by our previous order, and they will help ensure that banks treat all customers, including member of the armed services, fairly