Corruption was rampant at that bank. Did you believe it was rampant?
given past commitments that have not been kept that the bank has a heavy burden of proof that they mean what they say
My own belief is that part of the reason has been a culture, but the other part is that there has been just a lack of accountability.
Well, these words are the benefit of hindsight. Given what you knew then, should you not have taken enforcement action?
No.
The Subcommittee investigation found that in some instances, the conclusion memos of exams at HBUS were a lot stronger than the supervisory ...
The oversight function is critically important and that is our responsibility, to bring about accountability through oversight.
Why should banks open accounts for bearer share corporations?
I agree with that and I also agree that Congress has responsibility, too, in our oversight.
Are the bank's deficiencies in how it is monitoring for suspicious activity a problem as far as the OCC is concerned?
Now, another article of the consent order required that the bank retain one or more independent consultants to conduct an independent review...