On April 17, the OCC announced enforcement actions against three institution-affiliated parties, alleging in the first instance fund misappropriation, in the second Paycheck Protection Program fraud, and in the last embezzlement. According to the OCC, the term “institution-affiliated party,” or IAP, is defined in 12 U.S.C. 1813(u) and includes bank directors, officers, employees and controlling shareholders. Orders of prohibition prohibit an individual from any participation in the affairs of a bank or other institution as defined in 12 U.S.C. 1818(e)(7).

No enforcement actions against national banks or federal savings associations were announced.