Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total AUM
Total Accounts
10Y AUM Change
Private Funds
Private funds reported by U.S. Bancorp Asset Management, Inc..
Loading private fund disclosures…
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total Employees
Clients per Employee
10Y Employee Change
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Each range applies to a separate reported relationship and should not be added together.
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
0%25%50%75%100%
U.S. BANK NATIONAL ASSOCIATIONDirect owner · Schedule AInterest in U.S. BANCORP ASSET MANAGEMENT, INC.
75%+
U.S. BANCORPIndirect owner · Schedule BInterest in U.S. BANK NATIONAL ASSOCIATION
75%+
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to U.S. Bancorp Asset Management, Inc...
Reported ownership and control details
Form ADV · Filing date 2026-08-28 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | U.S. BANK NATIONAL ASSOCIATIONSHAREHOLDERDomestic entity | U.S. BANCORP ASSET MANAGEMENT, INC. | 75% or moreCode E | Yes | SHAREHOLDER03/2001 | Schedule APDF page 41 |
| 2 | RICHARD JUDE ERTELDIRECTOR, CHIEF COUNSEL AND SECRETARYIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | DIRECTOR, CHIEF COUNSEL AND SECRETARY01/2011 | Schedule APDF page 41 |
| 3 | ERIC JAMES THOLEDIRECTOR, CHIEF EXECUTIVE OFFICER & PRESIDENTIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | DIRECTOR, CHIEF EXECUTIVE OFFICER & PRESIDENT06/2014 | Schedule APDF page 41 |
| 4 | JAMES DAVID PALMERDIRECTOR, CHIEF INVESTMENT OFFICERIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | DIRECTOR, CHIEF INVESTMENT OFFICER06/2014 | Schedule APDF page 41 |
| 5 | JILL MICHELE STEVENSONHEAD OF OPERATIONSIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | HEAD OF OPERATIONS09/2014 | Schedule APDF page 41 |
| 6 | LISA ANN ISAACSONCHIEF ADMINISTRATIVE OFFICERIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | CHIEF ADMINISTRATIVE OFFICER10/2024 | Schedule APDF page 41 |
| 7 | GREG RICHARD KIRCHHOFFINTERIM CHIEF COMPLIANCE OFFICERIndividual | U.S. BANCORP ASSET MANAGEMENT, INC. | Less than 5%Code NA | Yes | INTERIM CHIEF COMPLIANCE OFFICER08/2026 | Schedule APDF page 41 |
| 8 | U.S. BANCORPSHAREHOLDERDomestic entity | U.S. BANK NATIONAL ASSOCIATION | 75% or moreCode E | Yes | SHAREHOLDER07/1958 | Schedule BPDF page 42 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 8/28/2026 12:22:55 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies1 Yes1 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?Yes
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions3 Yes2 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings1 Yes3 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?Yes
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 16 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
criminal · block 1PDF pages 42–44
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANCORP
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship.
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number).
UNITED STATES DISTRICT COURT - SOUTHERN DISTRICT OF NEW YORK - 1:18-CR-00150-LAK-1
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related).
A CRIMINAL INFORMATION WAS FILED ON FEBRUARY 15, 2018, IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW
YORK CHARGING U.S. BANCORP ("USB") WITH (1) ONE COUNT OF WILLFULLY FAILING TO MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING
PROGRAM, IN VIOLATION OF 31 U.S.C. §§ 5318(H) AND 5322(A), AND (2) ONE COUNT OF WILLFULLY FAILING TO FILE A SUSPICIOUS ACTIVITY
REPORT, IN VIOLATION OF 31 U.S.C. §§ 5318(G) AND 5322(A) AND 31 C.F.R. § 1020.320(A) (THE "INFORMATION"). USB WAIVED INDICTMENT,
AGREED TO THE FILING OF THE INFORMATION, AND ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR THE ACTS OF ITS OFFICERS AND
EMPLOYEES AS SET FORTH IN THE ACCOMPANYING STATEMENT OF FACTS. A PLEA WAS NOT ENTERED IN RESPECT OF ANY OF THE CHARGES.
C.
Did any of the Charge(s) within the Event involve a felony?
Yes
No
D.
Current status of the Event?
Pending
On Appeal
Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY):
Exact
Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
ON FEBRUARY 15, 2018, USB ENTERED INTO A DEFERRED PROSECUTION AGREEMENT ("DPA") WITH THE OFFICE OF THE UNITED STATES ATTORNEY FOR
THE SOUTHERN DISTRICT OF NEW YORK ("DOJ"). PROSECUTION WAS DEFERRED FOR TWO YEARS FROM THE DATE OF THE DPA. AS PART OF THE DPA,
USB SETTLED ANY AND ALL CRIMINAL CLAIMS FOR THE SUM OF $528,000,000, LESS THE AMOUNT OF ANY CIVIL MONEY PENALTY PAID BY USB TO THE
OFFICE OF THE COMPTROLLER OF THE CURRENCY IN CONNECTION WITH ITS CONCURRENT SETTLEMENT, PAID TO THE DOJ ON FEBRUARY 15, 2018.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
AS DESCRIBED IN THE DPA, FROM 2009 TO 2014, USB WILLFULLY FAILED TO ESTABLISH, IMPLEMENT, AND MAINTAIN AN ADEQUATE ANTI-MONEY
LAUNDERING PROGRAM AND INTENTIONALLY IMPLEMENTED AND MAINTAINED BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") SYSTEMS
AND POLICIES THAT RESULTED IN USB FAILING TO IDENTIFY SUSPICIOUS ACTIVITY FLOWING THROUGH USB DUE TO A FAILURE TO PROVIDE
ADEQUATE BSA/AML STAFFING AND RESOURCES. FROM OCTOBER 2011 TO NOVEMBER 2013, USB, ACCORDING TO THE DPA, ALSO WILLFULLY FAILED
TO TIMELY REPORT SUSPICIOUS TRANSACTIONS OF A PARTICULAR CLIENT INVOLVING PROCEEDS FROM AN ILLEGAL PAYDAY LENDING SCHEME.
PURSUANT TO THE DPA, USB AGREED TO PAY A CRIMINAL FINE, CONTINUE ITS ONGOING EFFORT TO IMPLEMENT AND MAINTAIN AN ADEQUATE BSA/AML
PROGRAM, PROVIDE SEMI-ANNUAL REPORTS TO THE DOJ OF REMEDIAL CHANGES TO USB'S BSA/AML COMPLIANCE PROGRAM, AND CONTINUE
COOPERATING WITH GOVERNMENT AGENCIES REGARDING RELATED MATTERS FOR TWO YEARS (UNLESS THE DPA IS OTHERWISE EXTENDED).regulatory · block 1U.S. BANK NATIONAL ASSOCIATIONPDF pages 44–46
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC)
- Monetary/Fine Amount — filed text
- $ 10,000,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
ON APRIL 13, 2011, THE OCC ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JUNE 16, 2015, U.S. BANK AGREED TO AMEND THE CONSENT ORDER. THE AMENDMENT REQUIRED U.S. BANK TO COMPLETE AN ACTION PLAN TO RESOLVE OUTSTANDING ISSUES UNDER THE CONSENT ORDER AND OBTAIN APPROVAL FROM THE OCC BEFORE TAKING CERTAIN ACTIONS RELATED TO RESIDENTIAL MORTGAGE SERVICING. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION.
Other filed details
Description of allegations — filed text
THE OCC IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS.
Sanction detail — filed text
U.S. BANK WAS REQUIRED TO (1) IMPLEMENT A COMPLIANCE PROGRAM DESIGNED TO ENSURE THAT U.S. BANK'S MORTGAGE SERVICING AND FORECLOSURE OPERATIONS COMPLY WITH ALL APPLICABLE LEGAL REQUIREMENTS, OCC SUPERVISORY GUIDANCE, AND THE REQUIREMENTS OF THE ORDER AND ARE CONDUCTED IN A SAFE AND SOUND MANNER; (2) RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A FORECLOSURE REVIEW FOR LOANS SERVICED BY U.S. BANK PENDING AT ANY TIME FROM JANUARY 1, 2009 TO DECEMBER 31, 2010, AS WELL AS RESIDENTIAL FORECLOSURE SALES THAT OCCURRED DURING THIS TIME PERIOD (THE "FORECLOSURE REPORT"); AND (3) REMEDIATE ANY FINANCIAL INJURY TO BORROWERS CAUSED BY ANY ERRORS, MISREPRESENTATIONS, OR OTHER DEFICIENCIES IDENTIFIED IN THE FORECLOSURE REPORT. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) 2. Principal Sanction: Undertaking Other Sanctions: CIVIL MONEY PENALTY 3. Date Initiated (MM/DD/YYYY): 04/13/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AA-EC-11-18 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: RESIDENTIAL MORTGAGES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE OCC IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 02/08/2016 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: THE OCC'S CONSENT ORDER REQUIRED U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITITATION AND HANDLING OF FORECLOSURE PROCEEDINGS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: U.S. BANK WAS REQUIRED TO (1) IMPLEMENT A COMPLIANCE PROGRAM DESIGNED TO ENSURE THAT U.S. BANK'S MORTGAGE SERVICING AND FORECLOSURE OPERATIONS COMPLY WITH ALL APPLICABLE LEGAL REQUIREMENTS, OCC SUPERVISORY GUIDANCE, AND THE REQUIREMENTS OF THE ORDER AND ARE CONDUCTED IN A SAFE AND SOUND MANNER; (2) RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A FORECLOSURE REVIEW FOR LOANS SERVICED BY U.S. BANK PENDING AT ANY TIME FROM JANUARY 1, 2009 TO DECEMBER 31, 2010, AS WELL AS RESIDENTIAL FORECLOSURE SALES THAT OCCURRED DURING THIS TIME PERIOD (THE "FORECLOSURE REPORT"); AND (3) REMEDIATE ANY FINANCIAL INJURY TO BORROWERS CAUSED BY ANY ERRORS, MISREPRESENTATIONS, OR OTHER DEFICIENCIES IDENTIFIED IN THE FORECLOSURE REPORT. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON APRIL 13, 2011, THE OCC ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JUNE 16, 2015, U.S. BANK AGREED TO AMEND THE CONSENT ORDER. THE AMENDMENT REQUIRED U.S. BANK TO COMPLETE AN ACTION PLAN TO RESOLVE OUTSTANDING ISSUES UNDER THE CONSENT ORDER AND OBTAIN APPROVAL FROM THE OCC BEFORE TAKING CERTAIN ACTIONS RELATED TO RESIDENTIAL MORTGAGE SERVICING. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION.
regulatory · block 2U.S. BANK NATIONAL ASSOCIATIONPDF pages 46–48
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC)
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
ON APRIL 25, 2017, THE OCC ISSUED A CONSENT ORDER WHICH ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK. U.S. BANK CONSENTED TO ENTRY OF THE ORDER AND PAID THE CIVIL MONEY PENALTY TO THE U.S. TREASURY.
Other filed details
Description of allegations — filed text
THE OCC IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO BANKRUPTCY COURT FILINGS COMPLETED BETWEEN 2009 AND 2014 THAT DID NOT COMPLY WITH BANKRUPTCY LAWS.
Sanction detail — filed text
ON APRIL 24, 2017, U.S. BANK PAID A $15 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY AS REQUIRED UNDER THE CONSENT ORDER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/25/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AA-EC-2017-12 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Banking Products (Other than CD(s)) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE OCC IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO BANKRUPTCY COURT FILINGS COMPLETED BETWEEN 2009 AND 2014 THAT DID NOT COMPLY WITH BANKRUPTCY LAWS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 04/25/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 15,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON APRIL 24, 2017, U.S. BANK PAID A $15 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY AS REQUIRED UNDER THE CONSENT ORDER. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON APRIL 25, 2017, THE OCC ISSUED A CONSENT ORDER WHICH ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK. U.S. BANK CONSENTED TO ENTRY OF THE ORDER AND PAID THE CIVIL MONEY PENALTY TO THE U.S. TREASURY.
regulatory · block 3U.S. BANK NATIONAL ASSOCIATIONPDF pages 48–50
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE BOARD")
- Monetary/Fine Amount — filed text
- $ 4,400,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
ON APRIL 13, 2011, THE FEDERAL RESERVE BOARD ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. ON FEBRUARY 28, 2013, THE CONSENT ORDER WAS AMENDED TO MEMORIALIZE U.S. BANK'S AGREEMENT TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION.
Other filed details
Description of allegations — filed text
THE FEDERAL RESERVE BOARD IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS.
Sanction detail — filed text
ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE BOARD") 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST 3. Date Initiated (MM/DD/YYYY): 04/13/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 11-027-B-HC 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: RESIDENTIAL MORTGAGES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FEDERAL RESERVE BOARD IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 01/12/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 4,400,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: U.S. BANK WAS REQUIRED TO SUBMIT PLANS ACCEPTABLE TO THE FEDERAL RESERVE BOARD THAT WOULD, AMONG OTHER THINGS, STRENGTHEN COORDINATION OF COMMUNICATIONS WITH BORROWERS, ESTABLISH ROBUST CONTROLS AND OVERSIGHT OVER ACTIVITIES OF THIRD-PARTY VENDORS THAT PROVIDE RELATED MORTGAGE AND FORECLOSURE SERVICES, PROVIDE REMEDIATION TO BORROWERS WHO SUFFERED FINANCIAL INJURY AS A RESULT OF PAST PRACTICES, AND STRENGTHEN PROGRAMS TO ENSURE COMPLIANCE WITH STATE AND FEDERAL LAWS REGARDING MORTGAGE SERVICING AND FORECLOSURES. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON APRIL 13, 2011, THE FEDERAL RESERVE BOARD ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. ON FEBRUARY 28, 2013, THE CONSENT ORDER WAS AMENDED TO MEMORIALIZE U.S. BANK'S AGREEMENT TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION.
regulatory · block 4U.S. BANCORP; USB AMERICAS HOLDINGS COMPANYPDF pages 50–52
- Advisory affiliate name — filed text
- U.S. BANCORP; USB AMERICAS HOLDINGS COMPANY
- Regulator name — filed text
- BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE BOARD ORDER REQUIRES THAT USB AND/OR THE AGREEMENT CORPORATION SUBMIT TO THE RESERVE BANK WRITTEN PLANS REGARDING ITS BSA/AML AND OFAC COMPLIANCE AND BOARD OVERSIGHT THEREOF. THE BOARD ORDER ALSO REQUIRES THAT USB ACT AS A SOURCE OF STRENGTH TO U.S. BANK, INCLUDING TAKING STEPS TO ENSURE U.S. BANK COMPLIES WITH ANY SUPERVISORY ACTION TAKEN AGAINST U.S. BANK BY ITS REGULATORS.
Other filed details
Description of allegations — filed text
U.S. BANCORP ("USB") LACKED ADEQUATE RISK MANAGEMENT AND COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") AND USB AMERICAS HOLDINGS COMPANY (THE "AGREEMENT CORPORATION") COMPLIED WITH APPLICABLE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") AND OFAC RULES AND REGULATIONS AND WERE TIMELY REPORTED IN RESPONSE TO INQUIRIES BY THE FEDERAL RESERVE BANK OF MINNEAPOLIS ("RESERVE BANK").
Sanction detail — filed text
PURSUANT TO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "BOARD ORDER"), THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ORDERED USB TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANCORP; USB AMERICAS
HOLDINGS COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S)
3.
Date Initiated (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
18-005-B-HC; 18-005-B-AC; 18-005-CMP-B-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
U.S. BANCORP ("USB") LACKED ADEQUATE RISK MANAGEMENT AND COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES
CONDUCTED AT U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") AND USB AMERICAS HOLDINGS COMPANY (THE "AGREEMENT CORPORATION")
COMPLIED WITH APPLICABLE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") AND OFAC RULES AND REGULATIONS AND WERE TIMELY
REPORTED IN RESPONSE TO INQUIRIES BY THE FEDERAL RESERVE BANK OF MINNEAPOLIS ("RESERVE BANK").
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 15,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
PURSUANT TO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "BOARD ORDER"), THE BOARD OF
GOVERNORS OF THE FEDERAL RESERVE SYSTEM ORDERED USB TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE BOARD ORDER REQUIRES THAT USB AND/OR THE AGREEMENT CORPORATION SUBMIT TO
THE RESERVE BANK WRITTEN PLANS REGARDING ITS BSA/AML AND OFAC COMPLIANCE AND BOARD OVERSIGHT THEREOF. THE BOARD ORDER ALSO
REQUIRES THAT USB ACT AS A SOURCE OF STRENGTH TO U.S. BANK, INCLUDING TAKING STEPS TO ENSURE U.S. BANK COMPLIES WITH ANY
SUPERVISORY ACTION TAKEN AGAINST U.S. BANK BY ITS REGULATORS.regulatory · block 5U.S. BANK NATIONAL ASSOCIATIONPDF pages 52–53
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- FINANCIAL CRIMES ENFORCEMENT NETWORK
- Monetary/Fine Amount — filed text
- $ 70,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
PURSUANT TO THE FINCEN SETTLEMENT, FOR A PERIOD OF TWO YEARS, U.S. BANK WILL PROVIDE FINCEN WITH ANNUAL REPORTS IDENTIFYING REMEDIAL ACTIONS U.S. BANK HAS TAKEN TO ADDRESS PRIOR DEFICIENCIES IN ITS BSA/AML PROGRAM AND DESCRIBING INDEPENDENT TESTING CONDUCTED ON THE BANK'S BSA FUNCTIONS. U.S. BANK ALSO AGREED TO COOPERATE WITH FINCEN IN ITS RELATED INVESTIGATIONS AND TO CONTINUE ITS COMMITMENT TO IMPROVE ITS BSA/AML PROGRAM AND TRANSACTION MONITORING. U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $70,000,000.
Other filed details
Description of allegations — filed text
U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") WILLFULLY FAILED TO MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING ("AML") PROGRAM AND TO REPORT SUSPICIOUS TRANSACTIONS RELEVANT TO A POSSIBLE VIOLATION OF LAW OR REGULATIONS.
Sanction detail — filed text
PURSUANT TO A STIPULATION AND ORDER OF SETTLEMENT AND DISMISSAL (THE "FINCEN SETTLEMENT"), U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR FACTS AND CONDUCT PROVIDED IN A STATEMENT OF FACTS BY THE FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN") AND AGREED TO PAY A PENALTY OF $185 MILLION, WHICH WILL BE DEEMED SATISFIED BY A PAYMENT OF $70 MILLION TO THE TREASURY DEPARTMENT AND PAYMENT BY U.S. BANCORP OF ITS PAYMENT OBLIGATION UNDER THE DEFERRED PROSECUTION AGREEMENT WITH THE UNITED STATES.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANK NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINANCIAL CRIMES ENFORCEMENT NETWORK
2.
Principal Sanction:
Other
Other Sanctions:
STIPULATION AND ORDER OF SETTLEMENT AND DISMISSAL
3.
Date Initiated (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1:18-CV-01358
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") WILLFULLY FAILED TO MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING ("AML") PROGRAM AND TO
REPORT SUSPICIOUS TRANSACTIONS RELEVANT TO A POSSIBLE VIOLATION OF LAW OR REGULATIONS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 70,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
PURSUANT TO A STIPULATION AND ORDER OF SETTLEMENT AND DISMISSAL (THE "FINCEN SETTLEMENT"), U.S. BANK NATIONAL ASSOCIATION
("U.S. BANK") ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR FACTS AND CONDUCT PROVIDED IN A STATEMENT OF FACTS BY THE
FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN") AND AGREED TO PAY A PENALTY OF $185 MILLION, WHICH WILL BE DEEMED SATISFIED
BY A PAYMENT OF $70 MILLION TO THE TREASURY DEPARTMENT AND PAYMENT BY U.S. BANCORP OF ITS PAYMENT OBLIGATION UNDER THE
DEFERRED PROSECUTION AGREEMENT WITH THE UNITED STATES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
PURSUANT TO THE FINCEN SETTLEMENT, FOR A PERIOD OF TWO YEARS, U.S. BANK WILL PROVIDE FINCEN WITH ANNUAL REPORTS IDENTIFYING
REMEDIAL ACTIONS U.S. BANK HAS TAKEN TO ADDRESS PRIOR DEFICIENCIES IN ITS BSA/AML PROGRAM AND DESCRIBING INDEPENDENT TESTING
CONDUCTED ON THE BANK'S BSA FUNCTIONS. U.S. BANK ALSO AGREED TO COOPERATE WITH FINCEN IN ITS RELATED INVESTIGATIONS AND TO
CONTINUE ITS COMMITMENT TO IMPROVE ITS BSA/AML PROGRAM AND TRANSACTION MONITORING. U.S. BANK PAID A CIVIL MONEY PENALTY IN THE
AMOUNT OF $70,000,000.Show 10 more source blocks
regulatory · block 6U.S. BANK NATIONAL ASSOCIATIONPDF pages 54–55
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY
- Monetary/Fine Amount — filed text
- $ 75,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000 TO THE OCC.
Other filed details
Description of allegations — filed text
U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") FAILED TO ADOPT AND IMPLEMENT AN ADEQUATE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM AND FAILED TO FILE ALL NECESSARY SUSPICIOUS ACTIVITY REPORTS RELATED TO SUSPICIOUS CUSTOMER ACTIVITY.
Sanction detail — filed text
PURSUANT TO A CONSENT ORDER FOR A CIVIL MONEY PENALTY (THE "OCC ORDER"), THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") REQUIRED U.S. BANK TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANK NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
OFFICE OF THE COMPTROLLER OF THE CURRENCY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-2018-84
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") FAILED TO ADOPT AND IMPLEMENT AN ADEQUATE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING
COMPLIANCE PROGRAM AND FAILED TO FILE ALL NECESSARY SUSPICIOUS ACTIVITY REPORTS RELATED TO SUSPICIOUS CUSTOMER ACTIVITY.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 75,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
PURSUANT TO A CONSENT ORDER FOR A CIVIL MONEY PENALTY (THE "OCC ORDER"), THE OFFICE OF THE COMPTROLLER OF THE CURRENCY
("OCC") REQUIRED U.S. BANK TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000 TO THE OCC.regulatory · block 7U.S. BANCORP INVESTMENTS, INC.PDF pages 55–57
- Advisory affiliate name — filed text
- U.S. BANCORP INVESTMENTS, INC.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 17868 This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANCORP INVESTMENTS, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 8U.S. BANK NATIONAL ASSOCIATIONPDF pages 57–59
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- CONSUMER FINANCIAL PROTECTION BUREAU
- Monetary/Fine Amount — filed text
- $ 37,500,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
ON JULY 28, 2022, THE CFPB ISSUED A CONSENT ORDER THAT ASSESSED A $37.5 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK AND ORDERED RESTITUTION (REDRESS) TO AFFECTED CONSUMER ACCOUNTS. THE CFPB ALSO REQUIRED U.S. BANK TO IMPLEMENT A COMPLIANCE PLAN DESIGNED TO ENSURE THAT U.S. BANK'S CONDUCT COMPLIES WITH ALL APPLICABLE FEDERAL CONSUMER FINANCIAL LAWS AND TERMS OF THE CONSENT ORDER. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN.
Other filed details
Description of allegations — filed text
THE CFPB IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO OPENING OF CREDIT CARD, LINE OF CREDIT AND DEPOSIT ACCOUNTS WITHOUT CUSTOMER PERMISSION IN VIOLATION OF SECTION 1601 OF THE TRUTH IN LENDING ACT, SECTION 1681B(F) OF THE FAIR CREDIT REPORTING ACT, SECTION 4301 OF THE TRUTH IN SAVINGS ACT, AND SECTIONS 5531 AND 5536 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010, WHICH PROHIBIT "UNFAIR, DECEPTIVE, OR ABUSIVE" ACTS OR PRACTICES. DURING THE PERIOD FROM JANUARY 2010 THROUGH DECEMBER 2020, U.S. BANK EMPLOYEES OPENED ACCOUNTS WITHOUT CONSUMERS' KNOWLEDGE AND CONSENT. THESE ACTS OR PRACTICES INVOLVED A SMALL PERCENTAGE OF U.S. BANK'S NEW ACCOUNTS.
Sanction detail — filed text
ON AUGUST 2, 2022, U.S. BANK PAID A $37.5 MILLION CIVIL MONEY PENALTY TO THE CFPB AS REQUIRED UNDER THE CONSENT ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CONSUMER FINANCIAL PROTECTION BUREAU 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION TO AFFECTED CONSUMERS; UNDERTAKINGS TO IMPLEMENT A COMPLIANCE PLAN DESIGNED TO ENSURE THAT U.S. BANK'S CONDUCT COMPLIES WITH ALL APPLICABLE FEDERAL CONSUMER FINANCIAL LAWS AND TERMS OF THE CONSENT ORDER. 3. Date Initiated (MM/DD/YYYY): 07/28/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2022-CFPB-0006 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: BANKING - CREDIT CARDS, LINES OF CREDIT AND DEPOSIT ACCOUNTS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE CFPB IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO OPENING OF CREDIT CARD, LINE OF CREDIT AND DEPOSIT ACCOUNTS WITHOUT CUSTOMER PERMISSION IN VIOLATION OF SECTION 1601 OF THE TRUTH IN LENDING ACT, SECTION 1681B(F) OF THE FAIR CREDIT REPORTING ACT, SECTION 4301 OF THE TRUTH IN SAVINGS ACT, AND SECTIONS 5531 AND 5536 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010, WHICH PROHIBIT "UNFAIR, DECEPTIVE, OR ABUSIVE" ACTS OR PRACTICES. DURING THE PERIOD FROM JANUARY 2010 THROUGH DECEMBER 2020, U.S. BANK EMPLOYEES OPENED ACCOUNTS WITHOUT CONSUMERS' KNOWLEDGE AND CONSENT. THESE ACTS OR PRACTICES INVOLVED A SMALL PERCENTAGE OF U.S. BANK'S NEW ACCOUNTS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 07/28/2022 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 37,500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: U.S. BANK WAS REQUIRED TO OBTAIN A DETERMINATION OF NON-OBJECTION FROM THE CFPB FOR A COMPLIANCE PLAN DESIGNED TO ENSURE THAT U.S. BANK, WHEN OPENING NEW ACCOUNTS FOR CONSUMERS, COMPLIES WITH ALL APPLICABLE FEDERAL CONSUMER FINANCIAL LAWS AND TERMS OF THE CONSENT ORDER. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON AUGUST 2, 2022, U.S. BANK PAID A $37.5 MILLION CIVIL MONEY PENALTY TO THE CFPB AS REQUIRED UNDER THE CONSENT ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON JULY 28, 2022, THE CFPB ISSUED A CONSENT ORDER THAT ASSESSED A $37.5 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK AND ORDERED RESTITUTION (REDRESS) TO AFFECTED CONSUMER ACCOUNTS. THE CFPB ALSO REQUIRED U.S. BANK TO IMPLEMENT A COMPLIANCE PLAN DESIGNED TO ENSURE THAT U.S. BANK'S CONDUCT COMPLIES WITH ALL APPLICABLE FEDERAL CONSUMER FINANCIAL LAWS AND TERMS OF THE CONSENT ORDER. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN.
regulatory · block 9U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, N.A.)PDF pages 59–61
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, N.A.)
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC)
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B.
Other filed details
Description of allegations — filed text
ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B.
Sanction detail — filed text
ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, N.A.) (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) 2. Principal Sanction: Cease and Desist Other Sanctions: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. 3. Date Initiated (MM/DD/YYYY): 09/20/2021 Exact Explanation If not exact, provide explanation: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. 4. Docket/Case Number: AA-ENF-2021-34 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 09/20/2021 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B.
regulatory · block 10U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, NATIONAL ASSOCIATION)PDF pages 61–63
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, NATIONAL ASSOCIATION)
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
Other filed details
Description of allegations — filed text
ON MAY 10, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST MUFG UNION BANK, NATIONAL ASSOCIATION (WHICH MERGED INTO U.S. BANK NATIONAL ASSOCIATION ON MAY 26, 2023) FOR ENGAGING IN DECEPTIVE PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO THE MARKETING AND FULFILLMENT OF CERTAIN RETAIL PRODUCTS AND SERVICES.
Sanction detail — filed text
ON MAY 8, 2023, MUFG UNION BANK, NATIONAL ASSOCIATION PAID THE CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (SUCCESSOR IN INTEREST TO MUFG UNION BANK, NATIONAL ASSOCIATION) (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OFFICE OF THE COMPTROLLER OF THE CURRENCY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/10/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AA-ENF-2023-7 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Banking Products (Other than CD(s)) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON MAY 10, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST MUFG UNION BANK, NATIONAL ASSOCIATION (WHICH MERGED INTO U.S. BANK NATIONAL ASSOCIATION ON MAY 26, 2023) FOR ENGAGING IN DECEPTIVE PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO THE MARKETING AND FULFILLMENT OF CERTAIN RETAIL PRODUCTS AND SERVICES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 05/10/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 15,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON MAY 8, 2023, MUFG UNION BANK, NATIONAL ASSOCIATION PAID THE CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
regulatory · block 11U.S. BANK NATIONAL ASSOCIATIONPDF pages 63–65
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- CONSUMER FINANCIAL PROTECTION BUREAU
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
Other filed details
Description of allegations — filed text
ON DECEMBER 19, 2023, THE CONSUMER FINANCIAL PROTECTION BUREAU ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR ACTS OR PRACTICES IN VIOLATION OF THE CONSUMER FINANCIAL PROTECTION BUREAU ACT OF 2010 WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS.
Sanction detail — filed text
ON DECEMBER 20, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE CONSUMER FINANCIAL PROTECTION BUREAU. THE ORDER ALSO REQUIRES U.S. BANK NATIONAL ASSOCIATION TO PROVIDE $5.7 MILLION IN REDRESS TO CONSUMERS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CONSUMER FINANCIAL PROTECTION BUREAU 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/19/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023-CFPB-0019 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Banking Products (Other than CD(s)) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON DECEMBER 19, 2023, THE CONSUMER FINANCIAL PROTECTION BUREAU ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR ACTS OR PRACTICES IN VIOLATION OF THE CONSUMER FINANCIAL PROTECTION BUREAU ACT OF 2010 WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 12/19/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 15,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: THE ORDER ALSO REQUIRES U.S. BANK NATIONAL ASSOCIATION TO PROVIDE $5.7 MILLION IN REDRESS TO CONSUMERS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON DECEMBER 20, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE CONSUMER FINANCIAL PROTECTION BUREAU. THE ORDER ALSO REQUIRES U.S. BANK NATIONAL ASSOCIATION TO PROVIDE $5.7 MILLION IN REDRESS TO CONSUMERS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
regulatory · block 12U.S. BANK NATIONAL ASSOCIATIONPDF pages 65–67
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
Other filed details
Description of allegations — filed text
ON DECEMBER 19, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS.
Sanction detail — filed text
ON DECEMBER 13, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANK NATIONAL ASSOCIATION (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OFFICE OF THE COMPTROLLER OF THE CURRENCY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/19/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AA-ENF-2023-64 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Banking Products (Other than CD(s)) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON DECEMBER 19, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 12/19/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 15,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON DECEMBER 13, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.
regulatory · block 13U.S. BANK NATIONAL ASSOCIATIONPDF pages 67–68
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION
- Monetary/Fine Amount — filed text
- $ 6,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE MONETARY FINE HAS BEEN PAID AND USBNA IS COMPLYING WITH THE ORDERED UNDERTAKINGS.
Other filed details
Description of allegations — filed text
ON MARCH 19, 2024, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ISSUED AN ADMINISTRATIVE ORDER FINDING THAT U.S. BANK, N.A. ("USBNA") VIOLATED CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, WHICH REQUIRE A CFTC REGISTRANT TO MAINTAIN ALL WRITTEN COMMUNICATIONS RELATED TO, AND TO PROVIDE DILIGENT SUPERVISION OF, ITS BUSINESS AS A CFTC REGISTRANT. IN ADDITION,THE CFTC FOUND THAT THE USE OF UNAUTHORIZED COMMUNICATION METHODS BY USBNA EMPLOYEES VIOLATED USBNA'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS.
Sanction detail — filed text
USBNA PAID A FINE OF $6,000,000 ON MARCH 27, 2024, AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE REVIEW OF USBNA'S SUPERVISORY, COMPLIANCE, AND OTHER POLICIES AND PROCEDURES RELATED TO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANK NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALT(IES) / FINES, UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY):
03/19/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
24-03
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 19, 2024, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ISSUED AN ADMINISTRATIVE ORDER FINDING THAT U.S. BANK, N.A.
("USBNA") VIOLATED CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, WHICH REQUIRE A CFTC REGISTRANT TO
MAINTAIN ALL WRITTEN COMMUNICATIONS RELATED TO, AND TO PROVIDE DILIGENT SUPERVISION OF, ITS BUSINESS AS A CFTC REGISTRANT. IN
ADDITION,THE CFTC FOUND THAT THE USE OF UNAUTHORIZED COMMUNICATION METHODS BY USBNA EMPLOYEES VIOLATED USBNA'S OWN POLICIES
AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/19/2024
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 6,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
USBNA PAID A FINE OF $6,000,000 ON MARCH 27, 2024, AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE REVIEW OF
USBNA'S SUPERVISORY, COMPLIANCE, AND OTHER POLICIES AND PROCEDURES RELATED TO THE PRESERVATION OF ELECTRONIC
COMMUNICATIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MONETARY FINE HAS BEEN PAID AND USBNA IS COMPLYING WITH THE ORDERED UNDERTAKINGS.regulatory · block 14U.S. BANK NATIONAL ASSOCIATIONPDF pages 69–70
- Advisory affiliate name — filed text
- U.S. BANK NATIONAL ASSOCIATION
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION.
- Monetary/Fine Amount — filed text
- $ 325,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON SEPTEMBER 4, 2025, THE CFTC ORDERED THAT USB SHALL CEASE AND DESIST FROM VIOLATING SECTION 4R(A)(1) AND (3) OF THE ACT, 7 U.S.C. § 6R(A)(1), (3); AND SECTIONS 45.3(B), 45.4, AND 45.13(A), 17 C.F.R. §§ 45.3(B), 45.4, 45.13(A) (2024) OF THE REGULATIONS AND PAY A CMP OBLIGATION IN THE AMOUNT OF THREE HUNDRED TWENTY-FIVE THOUSAND DOLLARS ($325,000) WITHIN TWENTY (20) BUSINESS DAYS OF SEPTEMBER 4, 2025. THE CMP OBLIGATION WAS PAID ON SEPTEMBER 19, 2025.
Other filed details
Description of allegations — filed text
AS A REGISTERED SWAP DEALER AND REPORTING COUNTERPARTY, U.S. BANK NATIONAL ASSOCIATION ("USB") HAS SWAP REPORTING OBLIGATIONS UNDER THE COMMODITY EXCHANGE ACT (THE "ACT") AND COMMODITY FUTURES TRADING COMMISSION (CFTC) REGULATIONS (THE "REGULATIONS"). DURING THE RELEVANT PERIOD, USB REPORTED INACCURATE VALUATION DATA TO ITS SWAP DATA REPOSITORY (SDR) INVOLVING VARIOUS FOREIGN EXCHANGE ("FX") PRODUCTS AND INTEREST RATE SWAPS ("IRS"). THIS SDR REPORTING BY USB WAS NOT CUSTOMER FACING AND DID NOT IMPACT ANY OF ITS PUBLIC REPORTING REQUIREMENTS. USB'S INACCURATE REPORTS STEMMED FROM TWO ERRORS IN ITS METHODOLOGY FOR CALCULATING REPORTABLE SWAP VALUATION DATA. BECAUSE CERTAIN SWAPS REQUIRE NUMEROUS REPORTS TO AN SDR DAILY OVER A SWAP'S LIFETIME, THESE TWO ERRORS RESULTED IN USB'S REPORTING OF INACCURATE VALUATION DATA IN A SINGLE SWAP DATA FIELD IN NEARLY 10 MILLION SWAP DATA REPORTS ARISING FROM APPROXIMATELY 80,000 UNIQUE SWAPS.
Sanction detail — filed text
USB WAS REQUIRED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF THREE HUNDRED TWENTY-FIVE THOUSAND DOLLARS ($325,000) ("CMP OBLIGATION"), WITHIN TWENTY (20) BUSINESS DAYS OF SEPTEMBER 4, 2025, PLUS ANY POST-JUDGMENT INTEREST. THE CMP OBLIGATION WAS PAID ON SEPTEMBER 19, 2025.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANK NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
COMMODITY FUTURES TRADING COMMISSION.
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALTIES/FINES AND CERTAIN OTHER CONDITIONS AND UNDERTAKINGS.
3.
Date Initiated (MM/DD/YYYY):
09/04/2025
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
25-06
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
FX PRODUCTS AND INTEREST RATE SWAPS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AS A REGISTERED SWAP DEALER AND REPORTING COUNTERPARTY, U.S. BANK NATIONAL ASSOCIATION ("USB") HAS SWAP REPORTING OBLIGATIONS
UNDER THE COMMODITY EXCHANGE ACT (THE "ACT") AND COMMODITY FUTURES TRADING COMMISSION (CFTC) REGULATIONS (THE "REGULATIONS").
DURING THE RELEVANT PERIOD, USB REPORTED INACCURATE VALUATION DATA TO ITS SWAP DATA REPOSITORY (SDR) INVOLVING VARIOUS FOREIGN
EXCHANGE ("FX") PRODUCTS AND INTEREST RATE SWAPS ("IRS"). THIS SDR REPORTING BY USB WAS NOT CUSTOMER FACING AND DID NOT IMPACT
ANY OF ITS PUBLIC REPORTING REQUIREMENTS. USB'S INACCURATE REPORTS STEMMED FROM TWO ERRORS IN ITS METHODOLOGY FOR CALCULATING
REPORTABLE SWAP VALUATION DATA. BECAUSE CERTAIN SWAPS REQUIRE NUMEROUS REPORTS TO AN SDR DAILY OVER A SWAP'S LIFETIME, THESE
TWO ERRORS RESULTED IN USB'S REPORTING OF INACCURATE VALUATION DATA IN A SINGLE SWAP DATA FIELD IN NEARLY 10 MILLION SWAP DATA
REPORTS ARISING FROM APPROXIMATELY 80,000 UNIQUE SWAPS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/04/2025
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 325,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
USB WAS REQUIRED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF THREE HUNDRED TWENTY-FIVE THOUSAND DOLLARS ($325,000)
("CMP OBLIGATION"), WITHIN TWENTY (20) BUSINESS DAYS OF SEPTEMBER 4, 2025, PLUS ANY POST-JUDGMENT INTEREST. THE CMP
OBLIGATION WAS PAID ON SEPTEMBER 19, 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 4, 2025, THE CFTC ORDERED THAT USB SHALL CEASE AND DESIST FROM VIOLATING SECTION 4R(A)(1) AND (3) OF THE ACT, 7 U.S.C. §
6R(A)(1), (3); AND SECTIONS 45.3(B), 45.4, AND 45.13(A), 17 C.F.R. §§ 45.3(B), 45.4, 45.13(A) (2024) OF THE REGULATIONS AND PAY A CMP
OBLIGATION IN THE AMOUNT OF THREE HUNDRED TWENTY-FIVE THOUSAND DOLLARS ($325,000) WITHIN TWENTY (20) BUSINESS DAYS OF SEPTEMBER
4, 2025. THE CMP OBLIGATION WAS PAID ON SEPTEMBER 19, 2025.civil judicial · block 1PDF pages 71–72
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANK NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
UNITED STATES COMMODITY FUTURES TRADING COMMISSION (CFTC)
2.
Principal Relief Sought:
Injunction
Other Relief Sought:
UNDERTAKING TO MAKE MONETARY CONTRIBUTION TO PEREGRINE FINANCIAL GROUP, INC. TRUSTEE
3.
Filing Date of Court Action (MM/DD/YYYY):
02/04/2015
Exact
Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types:
BANKING
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number):
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA EASTERN DIVISION; CASE NUMBER: 6:13-CV-2041-LRR
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
7.
Describe the allegations related to this civil action (your response must fit within the space provided):
PLAINTIFF CFTC ALLEGED VIOLATIONS OF SECTION 4D(B) OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. § 6D(B), AND REGULATION 1.20(A), 17 C.F.R. §
1.20(A). THOSE PROVISIONS ADDRESS SEGREGATION AND HANDLING OF FUTURES COMMISSION MERCHANT ("FCM") CUSTOMER FUNDS. PEREGRINE
FINANCIAL GROUP, INC. ("PEREGRINE"), AN FCM, WAS A U.S. BANK CUSTOMER AND HAD AN ACCOUNT AT U.S. BANK DESIGNATED TO HOLD CUSTOMER
SEGREGATED FUNDS. THE CFTC ALLEGED THAT U.S. BANK'S HANDLING OF THAT ACCOUNT DID NOT CONFORM TO STATUTORY AND REGULATORY
REQUIREMENTS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact
Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY):
02/04/2015
Exact
Explanation
If not exact, provide explanation:
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
U.S. BANK AGREED TO MAKE A ONE-TIME PAYMENT OF $18 MILLION TO THE PEREGRINE TRUSTEE, WHICH FUNDS WILL BE PAID TO PEREGRINE
CUSTOMERS HOLDING DOMESTIC FUTURES ACCOUNTS. IT IS NOT A SANCTION, FINE OR PENALTY.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE CONSENT ORDER PERMANENTLY ENJOINS U.S. BANK FROM VIOLATING SECTION 4D(B) OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. § 6D(B),
AND REGULATION 1.20(A), 17 C.F.R. § 1.20(A). ON FEBRUARY 11, 2015, PURSUANT TO THE CONSENT ORDER, U.S. BANK MADE A ONE-TIME
PAYMENT IN THE AMOUNT OF $18 MILLION TO THE COURT-APPOINTED TRUSTEE FOR PEREGRINE, WHICH PAYMENT REPRESENTS MONIES THAT
WILL BE PAID TO PEREGRINE CUSTOMERS HOLDING DOMESTIC FUTURES ACCOUNTS, AND NOT A FINE OR PENALTY.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided).
IN AGREEING TO THE ENTRY OF THE CONSENT ORDER, U.S. BANK ADMITTED NO WRONGDOING, AND THE COURT HAS MADE NO FINDING THAT U.S.
BANK COMMITTED ANY VIOLATION OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. § 6D(B), OR REGULATION 1.20(A), 17 C.F.R. § 1.20(A). PURSUANT TO
THE CONSENT ORDER, U.S. BANK'S PAYMENT OF $18 MILLION IS NOT A FINE OR PENALTY, AND THE MONIES SHALL BE PAID BY THE PEREGRINE
TRUSTEE TO PEREGRINE CUSTOMERS HOLDING DOMESTIC FUTURES ACCOUNTS.* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.