Title Date Scope
Nomura Securities International 07-15-2019 The SEC brought an enforcement action against Nomura Securities for failing to supervise statements to customers while negotiating sales of commercial and residential mortgage-backed securities. Nomura traders misrepresented the bids and offers being provided, as well as the prices at which their firm bought and sold and the spreads the firm earned intermediating. Several senior traders also trained, coached, and directed junior traders at the firm to engage in misconduct. Victims include an entity that received TARP bailout funds. Nomura Securities is repaying $24.9 million to reimburse customers and a $1.5 million penalty as part of the action, which was brought under the following securities law: 15 U.S.C. § 78o(b)(4)(E). The action also required Nomura Securities to improve surveillance procedures and internal controls.
PWC 03-12-2019 A U.S. district court found PWC (PricewaterhouseCoopers) was negligent in its external audits of Colonial Bank, which was part of a massive $2.9 billion fraud scheme uncovered by SIGTARP. The trial determined that the accounting firm did not design its audits in a manner that would allow it to detect fraud. PWC paid $335 million as part of the resulting enforcement action with the Federal Deposit Insurance Corporation. The federal court found that the accounting firm failed to following professional auditing standards, including federal law 15 U.S.C. §§ 7201, et seq., Sarbanes-Oxley Act of 2002, and SEC regulations. The action also prohibited PWC from denying its liability related to audits. The court judgment, enforcement action, and resulting penalty -- one the largest ever for malpractice by an accounting firm -- drew national attention to audit quality. SIGTARP discovered the fraud scheme after Colonial Bank had been approved for but had not yet received a $553 million bailout. As a result of SIGTARP’s investigation, the bank did not receive the funds. At the time, it was one of the largest mortgage lenders in the nation.
Martin Enterprises 10-05-2018 The Justice Department brought an enforcement action against Martin Enterprises for fraudulent submission of demolition claims in Fort Wayne, Indiana, under TARP’s Hardest Hit Fund Blight Elimination Program. Martin Enterprises, who received more than $1 million in TARP as the contractor in the program in Fort Wayne, dumped dirt contaminated with construction debris into the demolition hole and falsely billed the TARP program as if it had filled the hole with clean fill dirt. Martin Enterprises paid $61,016 as part of the action, which was brought under the following federal law: 31 U.S.C. §§ 3729, et seq., Federal False Claims Act. Martin also paid the City of Fort Wayne $800,000 for the cost to excavate and remove all of the construction debris and replace it with approved fill dirt, and for other damages. Martin has since ceased operations.
Merrill Lynch 06-12-2018 The SEC brought an enforcement action against Merrill Lynch, which was bought by Bank of America in 2008, for failing to reasonably supervise its employees. Some convinced customers to overpay for residential mortgage-backed securities by deceiving them about the price the financial services firm paid to acquire the securities. Merrill Lynch traders also charged mark-ups that bore no reasonable relationship to the prevailing market prices. Merrill Lynch made a $10.5 million payment to customers and paid a $5.2 million penalty as part of the action, which was brought under the following federal law: 15 U.S.C. § 78o(b). Leading up to the action Merrill Lynch enhanced its policies prohibiting false or misleading statements. It also developed new analytical processes, surveillance, and training. Merrill Lynch and Bank of America received $10 billion and $45 billion bailouts from TARP, respectively.
Crowe Horwath 04-03-2018 The Federal Deposit Insurance Corporation brought an enforcement action against Crowe Horwath for its serious misconduct related to its internal auditing of mortgage lender Taylor Bean & Whitaker, which collapsed under a massive $2.9 billion fraud scheme uncovered by SIGTARP The FDIC alleged malpractice, gross negligence, and negligent misrepresentation by Crowe in failing to detect the fraud at the mortgage lender. Crowe Horwath paid $60 million as part of the action, which was brought under federal laws 15 U.S.C. §§ 7201, et seq., Sarbanes-Oxley Act of 2002 and internal auditing standards. SIGTARP discovered the fraud scheme after Colonial Bank had been approved for but had not yet received a $553 million bailout. As a result of SIGTARP’s investigation, the bank did not receive the funds. Taylor Bean & Whitaker and Colonial Bank failed in part because of the fraud. At the time, Taylor Bean & Whitaker was one of the largest mortgage lenders in the nation.
Deloitte & Touche 02-28-2018 The Justice Department brought an enforcement action against Deloitte & Touche for violations related to its audits of mortgage lender Taylor, Bean & Whitaker, which collapsed under a massive $2.9 billion fraud scheme uncovered by SIGTARP The mortgage lender’s financial statements failed to reflect its severe financial distress while it was engaging in a long-running fraud scheme. Deloitte’s audits knowingly deviated from applicable auditing standards and, therefore, failed to detect the fraud. Deloitte & Touche paid $149.5 million as part of the enforcement action, which was brought under the following federal law: 31 U.S.C. §§ 3729, et seq., Federal False Claims Act. In August 2009, the Federal Housing Administration and Ginnie Mae acted to stop Taylor, Bean & Whitaker’s mortgage issuing and servicing. That year the lender declared bankruptcy and effectively ceased operations. The fraud scheme led to the failure of Colonial Bank, which was set to receive $553 million from TARP until SIGTARP discovered the fraud. Prior to its shutdown, Taylor, Bean & Whitaker was one of the largest mortgage lenders in the nation.
RBS Securities 10-25-2017 The Justice Department brought an enforcement action against RBS Securities for failure to supervise trading of residential mortgage-backed securities and collateralized loan obligations. The purpose of the underlying fraud was to increase its profits on trades at the expense of victim customers. RBS employees acted with the knowledge, encouragement and participation of RBS supervisors or its compliance-related personnel. Victimized customers included entities who received TARP bailout funds. RBS Securities paid $44.1 million as part of this action and agreed to close the trading group at issue and take steps to better prevent and detect future fraud as part of the action.
Wilmington Trust 10-10-2017 The Justice Department brought an enforcement action against Wilmington Trust for false statements it made to the SEC, the Federal Reserve, and investors as it spiraled downward and was ultimately acquired in a fire sale acquisition by M&T Bank. During this time, Wilmington Trust submitted false monthly reports to its regulators regarding the quality of its loan portfolio and made false securities filings even as it raised capital. Wilmington Trust paid $44 million as part of the action, which was brought under the following federal criminal and civil laws: 18 U.S.C. § 1001, False statements or entries generally; 15 U.S.C. § 78, Securities Fraud; 18 U.S.C. § 1348, Securities Fraud; 18 U.S.C. § 1005, False Bank entries, reports, and transactions; 18 U.S.C. § 1350, Failure of corporate officers to certify financial reports; 18 U.S.C. § 371, Conspiracy to commit offense or to defraud United States. The actions also required Wilmington Trust, which received a $330 million TARP bailout, to overhaul its practices. Wilmington Trust paid $16 million for false and misleading loan disclosures as part of a separate action by the SEC, which was brought under the following sections of the Securities Act: §§17(a)(2) and 17(a)(3); Exchange Act §§13(a), 13(b)(2)(A-B) and Rules 13a-1, 13a-11, 13a-13, 12b-20. 
Ally Financial 11-21-2016 The Justice Department brought an enforcement action against Ally Financial, formerly GMAC, for its serious misconduct related to the packaging, securitization, marketing, sale, and issuance of residential mortgage-backed securities. Ally admits that it failed to inform investors about deficiencies and material changes to its underwriting and diligence process, in connection with the securitization of 40,000 toxic subprime mortgage loans. Ally paid $52 million as part of the action, which was brought under the following laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act; 18 U.S.C. §§ 1961, et seq., RICO; and 18 U.S.C. § 1345, the Injunctions Against Fraud Act. The action requires Ally, which received a $17.2 billion bailout from TARP, to permanently shut down its broker-dealer, Ally Securities.
Goldman Sachs 04-11-2016 The Justice Department brought an enforcement action against Goldman Sachs for its serious misconduct related to the packaging, securitization, marketing, sale and issuance of residential mortgage-backed securities. Many of these toxic securities at issue were traded in a taxpayer funded bailout program that was designed to unlock frozen credit markets during the financial crisis. Goldman Sachs admitted that it made false and misleading representations to prospective investors about the characteristics of the loans it securitized and the ways in which Goldman Sachs would protect investors from harm. Goldman Sachs employees knew that, for certain loan pools, significant percentages of the loans reviewed did not conform to the representations made to investors about the pools of loans to be securitized, and Goldman Sachs also received certain negative information regarding the originators’ business practices. Goldman Sachs is paying $5.06 billion as part of the action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act; 18 U.S.C. §§ 1961, et seq., RICO; and 18 U.S.C. § 1345, the Injunctions Against Fraud Act. Goldman Sachs received a $10 billion bailout from TARP.
Morgan Stanley 02-11-2016 The Justice Department brought an enforcement action against Morgan Stanley for its serous misconduct related to the marketing, sale and issuance of residential mortgage-backed securities. Morgan Stanley admitted that it failed to disclose critical information to prospective investors about the quality of the mortgage loans underlying its securities, and about its due diligence practices. Morgan Stanley paid $2.6 billion as part of the action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act; 18 U.S.C. §§ 1961, et seq., RICO; and 18 U.S.C. § 1345, the Injunctions Against Fraud Act. The action also required the bank, which received a $10 billion bailout from TARP, to improve its credit and compliance due diligence practices.
Fifth Third Bank 10-06-2015 The Justice Department brought an enforcement action against Fifth Third for failing to self-report timely that approximately 1,400 mortgage loans it originally certified as eligible for Federal Housing Administration (FHA) insurance were in fact defective and not eligible for insurance—resulting in millions of dollars of losses. Fifth Third paid $85 million as part of the enforcement action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 42 U.S.C § 1320a-7a; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; the Civil Monetary Penalties Law; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act. The action also required Fifth Third, which received at $3.4 billion bailout from TARP, to reform its business practices and terminate the employment of responsible players. The SEC brought an additional enforcement action against Fifth Third for improperly accounting for commercial real estate loans in the midst of the financial crisis. Fifth Third failed to write down the value of loans it held on its books, and as a result, the bank didn’t show its true losses on those loans in the records it used to apply for TARP funds. Fifth Third paid an additional $6.5 million as part the action, which was brought under the following laws: Securities Act §§17(a)(2) and 17(a)(3), and Exchange Act §§13(a), 13(b)(2)(A-B) and Rule 13a-13 of the Exchange Act.
General Motors 09-17-2015 The Justice Department brought an enforcement action against General Motors for criminally concealing an ignition switch defect that led to driver and passenger deaths and injuries. General Motors did not recall the part and correct the defect for less than one dollar per vehicle. Instead, it concealed the defect for years from consumers and regulators. General Motors admitted criminal conduct and paid a $900 million penalty as part of the action, which was brought under the following federal laws: 18 U.S.C. § 1001, Statements or entries generally; and 18 U.S.C. § 1343, Wire Fraud. The action required General Motors, which received an $11 billion bailout from TARP, to make changes to prevent future fraud to and consent to monitoring. This case also brought industry-wide changes. GM's federal regulator revised its recall practices. Auto manufacturers now respond more quickly respond to recall defective auto parts. Vehicle recalls skyrocketed from 25 million in 2013 to more than 60 million from 2014 to 2018.
Bank of America 08-21-2014 The Justice Department brought an enforcement action against Bank of America and its subsidiaries, Countrywide Financial Corporation and Merrill Lynch, for packaging, originating, marketing, selling, structuring, arranging, and issuing billions of dollars of residential mortgage-backed securities without disclosing to investors key facts about the quality of the securitized loans. When the securities collapsed, investors suffered billions of dollars in losses. Bank of America paid $5 billion as part of the action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act; 18 U.S.C. §§ 1961, et seq., RICO; and 18 U.S.C. § 1345, the Injunctions Against Fraud Act. The action also required the bank, which received a $45 billion bailout from TARP, to undertake remedial measures and be subject to the oversight of an independent monitor.
Regions Bank 07-25-2014 The Federal Reserve brought an enforcement action against Regions Bank for misconduct related to the bank’s reporting of $168 million in non-accrual loans The Federal Reserve alleged control, procedure, and process deficiencies and for providing inaccurate, incomplete, and misleading information to examiners. Regions Bank payed a $46 million penalty as part of the action, which was brought under 12 U.S.C. §§1813, 1818, et. seq., of the FDI Act, and §§ 5-2, 5-3, et. seq., of the Code of Alabama, 1975.  The enforcement action was issued with the Alabama Department of Banking, which is assessing Regions Bank a $5 million penalty, and in conjunction with actions by the Securities and Exchange Commission.  The actions require the bank to revise its code of conduct, create a new organizational structure, standardize risk ratings, enhance credit review, restructure risk management, increase governance, and enhance loan analytics.
SunTrust Mortgage 07-03-2014 The Justice Department brought an enforcement action against SunTrust Mortgage for making material misrepresentations and omissions to borrowers in Home Affordable Modification Program (HAMP) solicitations, failing to process applications in a timely fashion, and for lying to the Treasury Department about the reasons why it denied homeowners. As a result of SunTrust’s mismanagement of HAMP, thousands of homeowners who applied for a HAMP modification with SunTrust suffered serious financial harm. SunTrust Mortgage paid $320 million as part of the action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 18 U.S.C. §§ 1961, et seq., RICO; 12 U.S.C. § 27, Real Estate Settlement Procedures Act; 15 U.S.C. § 1681, Fair Credit Reporting Act; 15 U.S.C. § 1692, Fair Debt Collection Practices Act; 15 U.S.C. §§ 1601, et seq., the Truth in Lending Act; 15 U.S.C. §§ 1691, et seq., The Equal Credit Opportunity Act; 15 U.S.C. §§ 6801, et seq., Gramm-Leach-Bliley Act. The action also required SunTrust Mortgage to implement corporate remedial measures aimed at preventing future problems, including increasing loss mitigation staff, auditing its mortgage modification process and engaging in semi-annual compliance monitoring. SunTrust, the owner of SunTrust Mortgage, received a $4.85 billion bailout from TARP.
Jefferies 03-12-2014 The Justice Department brought an enforcement action against Jefferies for failure to supervise sales practices that increased the profitability of certain residential mortgage-backed security trades. Jefferies employees misrepresented the seller’s asking price to the buyer and misrepresented the buyer’s asking price to the seller. Jefferies employees also concealed that securities were being sold from Jefferies’s inventory in order to charge buyers an extra commission to which Jefferies was not entitled. Ultimately, six of eight managers of federal taxpayer TARP funds were overcharged. Jefferies paid $25 million as part of the action, which was brought under the following federal securities laws: Section 17(a) and 17(a)(2), of the Securities Act and Section 10(b) and Section 15(b)(4)(E) of the Exchange Act. The action also required Jefferies to retain an independent compliance consultant to conduct a review of Jefferies’s policies and procedures for detecting and preventing fraud in connection with the purchase or sale of the securities at issue.
Western Asset Management 01-27-2014 The SEC and the Department of Labor brought enforcement actions against Western Asset Management Co. for engaging in cross-trading that favored some clients over others and concealed investor losses. Western Asset Management Co managed an entity that received TARP bailout funds. Western Asset Management Co. paid $21 million as part of the actions, which were brought under the following federal securities laws: 15 U.S.C. §§ 80b-206(2),(4) of the Investment Advisers Act of 1940; Rule 206(4)-7; aiding and abetting and causing violations of 15 U.S.C. §§ 80a-17(a)(1) and 17(a)(2) of the Investment Company Act of 1940. The actions also required Western Asset Management Co. to be censure and submit to oversight by a compliance consultant to address the violations.
JP Morgan Chase 11-19-2013 The Justice Department brought an enforcement action against JP Morgan Chase for serious misconduct related to the packaging, marketing, sale, and issuance of residential mortgage-backed securities by the bank and two companies it acquired: Bear Stearns, and Washington Mutual. Employees knew, but did not disclose, that the loans making up the derivative securities were substandard and did not comply with underwriting guidelines. JP Morgan Chase paid $13 billion as part of the action, which was brought under the following federal laws: 12 U.S.C. § 1833a, FIRREA; 31 U.S.C. §§ 3729, et seq., Federal False Claims Act; 31 U.S.C. §§ 3801, et seq., the Program Fraud Civil Remedies Act; 18 U.S.C. §§ 1961, et seq., RICO; and 18 U.S.C. § 1345, the Injunctions Against Fraud Act. The action also required the bank, which received a $25 billion bailout from TARP, to overhaul its derivatives securities practices.
Anchor Bank 08-14-2013 The Securities and Exchange Commission  brought an enforcement action against Anchor Bank for intentionally or recklessly making material misstatements in its financial filings Departing from Generally Accepted Accounting Principles and corporate policy, Anchor changed the way in which it recorded loans that resulted in losses being understated by $51 million and net charges-offs by $52.9 million. The action was brought under §§10(b), 13(a), 13(b)(2)(A-B), of the Exchange Act, and permanently enjoins Anchor from further securities law violations.  Anchor BanCorp Wisconsin, Inc., the parent company of AnchorBank, received $110 million TARP bailout.
United Guaranty 04-05-2013 The Consumer Financial Protection Bureau brought an enforcement action against United Guaranty Corporation for its use of kickbacks and unreasonable fees through captive mortgage reinsurance arrangements entered into with lenders of residential mortgage loans. The government alleged that the illegal payments were disguised as reinsurance premiums and paid by United Guaranty to lenders in exchange for the referral of private mortgage insurance business. United Guaranty Corporation paid a $4.5 million penalty as part of the action, which was brought under the following federal laws: of 12 U.S.C. § 5564, Consumer Financial Protection Act of 2010; 12 U.S.C. §§ 2607, 2614, Real Estate Settlement Procedures Act. The action also included a permanent injunction action against the unlawful conduct, compliance monitoring and reporting. At the time of the alleged conduct, United Guaranty was part of American International Group which received a nearly $75 billion bailout from TARP.
AIG Property Casualty 09-30-2012 More than 50 states brought an enforcement action against Chartis (now named AIG Property Casualty) for providing blanket insurance forms directly to individual bank customers where the customer wanted accident/sickness policy forms. It also automatically enrolled customers in unwanted air-travel insurance policies. AIG Property Casualty paid $50 million as part of the action. The action also required the insurer to stop the aforementioned practices and address licensing issues with its producers, curb telemarketing, and revise its vendor management practices. AIG, the owner of AIG Property Casualty, received a nearly $70 billion bailout from TARP.
Imperial Holdings 04-30-2012 The Justice Department brought an enforcement action against Imperial Holdings for securities fraud and materially misrepresenting information in life insurance applications. Imperial Holdings life insurance agents facilitated or made key misrepresentations on applications where the carrier was likely to deny the policy. Imperial Holdings did not institute adequate controls to prevent fraud by agents, and facilitated or made misrepresentations to elderly consumers. The misrepresentations lured victims into stranger-originated life insurance policies, defrauding TARP-recipient insurance carriers. Imperial Holdings paid $8 million as part of the action. Defendants in the scheme were convicted or agreed to enforcement under the following charges: 18 U.S.C. § 1341 Mail Fraud; 18 U.S.C. § 1343 Wire Fraud; 18 U.S.C. § 1349 Conspiracy to Commit Fraud; 18 U.S.C. § 371 Conspiracy to commit offense or to defraud United States. Imperial terminated its premium finance business and disassociated responsible employees, including senior staff.
Countrywide and Bank of America 02-09-2012 The Justice Department brought an enforcement action against Countrywide, which Bank of America acquired in 2008, for its serious misconduct related to the origination of defective residential mortgage loans. Separately, Bank of America failed to determine the eligibility of homeowners to participate in the Home Affordable Modification Program (HAMP). Bank of America admitted that it was aware that many of the residential mortgage loans they made to borrowers were defective, and that many of the representations and warranties they made to Fannie Mae and Freddie Mac about the quality of the loans were inaccurate. Yet they failed to report the mortgage loans they had identified as defective to Fannie and Freddie. Bank of America paid $1 billion as part of a broader action, which was brought under federal laws including 31 U.S.C. §§ 3729, et seq., the Federal False Claims Act. The action also required the bank, which received a $45 billion bailout from TARP, to remedy its loan modification programs to help struggling homeowners.


1 -- The criminal convictions, civil judgments, and enforcement actions in the database occurred as result of SIGTARP investigations. Criminal defendants were prosecuted by the Justice Department and, in a small number of cases, state attorney generals. Civil judgments and enforcement actions were brought by the Justice Department, federal and state regulatory agencies, and state attorney generals based on wrongdoing investigated by SIGTARP.


2 -- Information is drawn from multiple sources, including federal and state judiciary case management, and electronic case files; civil enforcement filings; court-ordered monitors' reports; and other law enforcement agency press releases. As of September 30, 2019.


3 -- SIGTARP investigates violations of the law by insiders or outsiders at public financial institutions where Treasury became a securities investor in exchange for a TARP capital investment. We investigate violations of the law by any participant in a TARP program, including for example, those involved in mortgage-backed securities markets. We previously investigated illegal activity by insiders of financial institutions who unsuccessfully sought Treasury's investment through TARP.


4 -- Applied for but did not receive TARP funds.