as a director or officer of an institution—for violations of laws or regulations. For the most egregious cases, when institutions commit illegal acts or repeatedly fail to comply with laws or regulations, the Federal prudential banking agencies also have the authority, and duty, to take more serious actions, such as limit the activities or functions of a bank, permanently bar culpable bank officials from working again in the banking industry, terminate Federal deposit insurance for a bank, appoint a receiver to unwind the bank or revoke the bank’s national charter. (8) Despite these important statutory powers, the Federal prudential banking agencies continue to rely on enforcement tools such as consent orders, cease and desist orders, and civil money penalties, even in instances when an institution’s violations have demonstrated unsafe or unsound business practices and past supervisory and enforcement actions have not sufficiently deterred illegal practices. (9) The failure of the Federal prudential banking agencies to exercise statutorily provided enforcement authorities—such as revoking a bank’s national charter or terminating its Federal deposit insurance—on institutions that have demonstrated a pattern or practice of unsafe or unsound banking practices related to repeat violations of Federal consumer financial laws or regulations, has resulted in insufficient regulatory oversight that has allowed institutions to continue to engage in inappropriate and illegal business practices harming millions of consumers. (10) Unlike small community banks that serve consumers in their local communities, megabanks (as identified as global systemically important bank holding companies) are comparatively extremely large and serve millions of consumers. Whereas Federal prudential banking agencies have demonstrated an ability to take enforcement actions against small community banks, including for violations of Federal consumer financial law, the same has not been demonstrated to be true of megabanks. While the Dodd-Frank Act