Law360, New York (March 15, 2016, 10:56 AM EDT) -- At the close of February, the Office of the Comptroller of the Currency issued a revision of its internal policies and procedures guidance on civil money penalties (CMPs) in enforcement actions. OCC PPM 5000-7 (Rev) (Feb. 26, 2016) (the "CMP policy"). While much of the CMP policy is focused on reiterating established OCC enforcement processes and procedures, there are several key developments that national banks and federal savings associations (both OCC-regulated entities) — and the directors, officers, employees, major shareholders and vendors associated with them — should consider, such as a shift in the weight that the OCC will accord certain aggravating and mitigating factors when determining whether to bring a CMP action and how much of a penalty the OCC will seek, increased expectations for maintaining a robust internal compliance program, and a possible increase in CMP actions brought against specific insiders associated with an institution....