On February 8, the OCC issued Bulletin OCC 2013-7, which clarifies that the maximum amount of the OCC’s civil money penalties (CMP) as adjusted for inflation last fall apply to violations that occurred on or after December 6, 2012. The Bulletin also states that new flood insurance penalties that also were adopted last fall, apply to violations that occurred on or after July 6, 2012, and not to violations that occurred on or after December 6, 2012, as originally announced.