Ideas, Highlights & Regulatory Updates

What Community Banks Should Do in the First 90 Days After a Consent Order

By Victor B. George, JD · April 2026 · 8 min read

Receiving a consent order is one of the most consequential events in a community bank’s history. Whether it comes from the OCC, FDIC, or Federal Reserve, the order signals that your regulators have lost confidence in your institution’s ability to self-correct. The first 90 days do not have to be perfect — but they have to demonstrate intent, structure, and momentum.

I’ve led remediation programs across multiple consent order engagements, some spanning three-plus years. Here is what I’ve seen distinguish institutions that close their orders efficiently from those that stay stuck in prolonged supervisory relationships.

1. Stand Up a Dedicated Remediation Office Within 30 Days

The single biggest mistake community banks make is treating the consent order as an extension of the existing compliance department’s workload. It isn’t. Remediation requires dedicated resourcing, separate governance, and a single accountable owner who reports directly to the board.

Within the first 30 days, establish a Remediation Management Office (RMO). This body should own the master remediation plan, all workstream reporting, regulatory correspondence tracking, and exam preparation.

2. Map Every Finding to a Root Cause

Consent orders cite symptoms. Your job is to diagnose causes. A bank that closes a finding by updating a policy without addressing the people, training, or system issue that created the deficiency will watch the same finding resurface in the next exam.

For every article and finding, conduct structured root cause analysis. The remediation plan should trace from finding → root cause → corrective action → sustainable control.

3. Establish Regulatory Communication Rhythm

One of the most valuable things you can do in the first 90 days is establish a predictable, structured communication cadence with your examiner-in-charge. Submit progress reports on schedule, flag slippage before you’re asked about it, and never let the regulator learn bad news from someone other than you.

Regulators reward transparency. They punish surprises. A well-structured status report submitted monthly — even when the news is mixed — rebuilds trust faster than silence punctuated by polished reports.

4. Don’t Deprioritize Validation

Many banks pour resources into building remediation and then run out of steam on validation. Regulators do not close findings based on completion of action items — they close findings based on validated evidence that the corrective action is effective and sustainable.

Build independent validation into the remediation plan from day one. The validation structure should be designed and resourced before the first remediation deliverables are due.

5. Brief Your Board — Honestly and Often

The board is accountable to the regulator. That accountability only works if the board is genuinely informed. Within the first 90 days, establish a reporting cadence with: current state of all remediation workstreams, red/yellow/green status per article, honest risk assessments, and escalation protocols for material issues.

The 90-Day Posture

At the end of 90 days, regulators should see: a structured remediation office, a detailed plan with milestones, evidence you understand root causes, a communication rhythm, and a validation framework that will produce credible closure packages. You don’t need to have solved everything. You need to demonstrate that you have the architecture to solve it.

That’s the difference between institutions that exit enforcement actions in two years and those that stay in them for five.