Carver Bancorp in New York has entered into a formal agreement with the Office of the Comptroller of the Currency that includes mandates tied to the Bank Secrecy Act and commercial real estate.

The OCC found "unsafe and unsound banking practices" at Carver tied to BSA violations and issues with strategic and capital planning, board and management oversight and concentration risk management, according to a copy of the order attached to a Friday filing by the $754 million-asset company.

Carver must revise and "adopt a comprehensive written program of internal control policies and procedures" tied to the BSA, while also ensuring "adequate staffing" tied to its BSA program. Carver must also conduct an independent review of customer account and transaction activity to "determine whether the bank timely identified and reported suspicious activity."

The company is also required to prepare a written plan to address its concentrations in commercial real estate loans. Also, Carver much form a compliance committee and to prepare periodic reports detailing its progress complying with the formal agreement.

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