1-USAA hired a ton of compliance professionals from other banks after the USAA 2019 consent order.
2-USAA process owners, advisors, managers, directors, EMGs, and leadership were made aware of compliance issues from 2019 to 2024.
3-This is the culture: Decision makers did not want to hear about nor implement corrective actions to remediate the known compliance deficiencies. Now people want to point fingers, play d-mb, and lie.
4-As a result of failing to align with Federal regulatory requirements, (and given an ample amount of time to do it), the OCC closed the prior consent orders and created a new one. This new order combined the old orders from 2019, 2022, and the new issues from 2024. In other words, the new order is a continuation of known findings, which is why it is being called a Comprehensive Cease and Desist.
Footnote: Incentives should have been denied to “leadership” the first time that they failed to correct the known issues. Instead, they were continually rewarded for non-compliance so they did not feel that they had to adhere to the requirements and be held accountable. Now the regulators are going to examine everything that you do. The OCC should request resumes, reports, files, and emails because there should be a “cleaning of house” starting at the top. Layered Lies = Layered Consent Orders. Risks are here to stay and so are the Federal regulatory requirements. There is a cost for non-compliance. Are you ready to pay for it with your job?