A spokesman for the bank objects to my characterization that the bank was hit by a $33 million “fine” for overdraft charges by the federal Office of the Controller of the Currency. The spokesman says that Woodforest entered into a “civil agreement” to pay a $1 million civil pentalty and to set up a $32 million fund for rebates to customers. The OCC has received the $1 million civil penalty. The spokesman characterized this as a $33 million “enforcement action” by the OCC rather than a fine. He also objected to my characterization of the enforcement action as a “large” penalty. (Wells Fargo, for instance, is facing a class action lawsuit that could involve several hundred million dollars.) I would simply say that Woodforest took a $33 million hit from OCC. Readers can judge for themselves what is “large.” The corporate structure of Woodforest is that Woodforest Financial Group Inc. is the parent of Woodforest Financial Services, Inc., whose president is Sen. Williams, and is also the parent of Woodforest National Bank. The spokesman said that Mr. Williams is not on the board of Woodforest National Bank, nor is he in the chain of command of the bank. (I said that Mr. Williams was “associated” with the bank.” The bank and the financial services company are associated only insofar as they are similarly situated subsidiaries of the same parent company.)