Ms. Amy Thompson, Director of the Office of Communications, is a senior executive at the FDIC. LinkedIn https://www.linkedin.com/in/amycantu
Upon reviewing Ms. Thompson’s OGE ethics forms, I noticed that she appears to have violated 5 CFR § 3201.103. Namely, Ms. Thompson reports that she has made numerous purchases and sales of financial holding companies (FHC), bank holding companies (BHC), and at least one Savings & Loan Holding Company (SNLHC), nearly all of which hold FDIC-insured institutions. Together, I refer to these entities as “Potentially Prohibited Financial Holdings” (PPFH). Based on ethics forms filed in 2022 and 2023, Ms. Thompson traded in and out of numerous Potentially Prohibited Financial Holdings at least eighteen (18) times.
The timing of many of these trades is suspicious, and being a senior executive and director of an office at the FDIC that is responsible for communications, including final approval and publication of all FDIC press releases and information, gives her direct and indirect insight into the performance of these Potentially Prohibited Financial Holdings. Moreover, many of the trades occur around times of information ingestion, discrimination, and analysis within the FDIC that Ms. Thompson is likely privy to or has indirect knowledge of.
Aside for very limited exceptions, 5 CFR § 3201.103(a)(4) prohibits any employee, spouse of an employee, or minor child of an employee from acquiring, owning, or controlling, directly or indirectly, security of any of the following a financial holding company that is subject to FRB supervision or, per 5 CFR § 3201.103(a)(5)(i) a company that owns or controls an FDIC-insured bank or savings association.
Strangely, her 2020 and 2021 Ethics forms make no mention of any Potentially Prohibited Financial Holdings, and from a review of the ethics form, her campaign of trading and appearing to profit from trading Potentially Prohibited Financial Holdings began in mid-2021. Therefore, these potentially illegal activities began well into her career at the FDIC.
According to her own ethics forms, she made the following transactions.
Ms. Thompson’s Ethics Filings
File: Thompson, Amy — General 278s — Annual — 278–2020–2020–05–15.pdf
FDIC Amy C Thompson Insider Trading Bank Stocks – General 278s – Annual – 278 – 2020 – 2020-05-15 |…
Upon reviewing Ms. Thompson’s OGE ethics forms, I noticed that she appears to have violated 5 CFR § 3201.103. Namely…
No bank/financial holding compamny trading.
File: Thompson, Amy — General 278s — Annual — 278–2021–2021–05–16.pdf
FDIC Amy C Thompson Insider Trading Bank Stocks – General 278s – Annual – 278 – 2021 – 2021-05-16 |…
Upon reviewing Ms. Thompson’s OGE ethics forms, I noticed that she appears to have violated 5 CFR § 3201.103. Namely…
No bank/financial holding compamny trading.
File: Thompson, Amy — General 278s — Annual — 278–2022–2022–05–07.pdf
FDIC Amy C Thompson Insider Trading Bank Stocks – General 278s – Annual – 278 – 2022 – 2022-05-07 |…
Upon reviewing Ms. Thompson’s OGE ethics forms, I noticed that she appears to have violated 5 CFR § 3201.103. Namely…
- Line: 9 Citizens Financial Group, Inc. (Rhode Island) (CFG) Purchase 07/27/2021 $1,001 — $15,000
- Line: 14 JPMorgan Chase & Co. (JPM) Purchase 07/27/2021 $1,001 — $15,000
- Line: 33 Bank of America Corp. (BAC) Purchase 08/04/2021 $1,001 — $15,000
- Line: 49 State Street Corp. (STT) Purchase 10/14/2021 $1,001 — $15,000
- Line: 50 State Street Corp. (STT) Purchase 11/26/2021 $1,001 — $15,000
- Line: 64 Synchrony Financial (SYF) Sale 12/20/2021 $1,001 — $15,000
- Line: 65 Synchrony Financial (SYF) Purchase 09/20/2021 $1,001 — $15,000
- Line: 70 Synchrony Financial (SYF) Purchase 07/26/2021 $1,001 — $15,000
File: Thompson, Amy — General 278s — Annual — 278–2023–2023–05–13.pdf
FDIC Amy C Thompson Insider Trading Bank Stocks – General 278s – Annual – 278 – 2023 – 2023-05-13 |…
Upon reviewing Ms. Thompson’s OGE ethics forms, I noticed that she appears to have violated 5 CFR § 3201.103. Namely…
- Line: 7 State Street Corp. (STT) Sale 05/05/2022 $1,001 — $15,000
- Line: 18 Citigroup, Inc. © Purchase 05/18/2022 $1,001 — $15,000
- Line: 42 Bank of America Corp. (BAC) Sale 06/27/2022 $1,001 — $15,00
- Line: 57 Citigroup, Inc. © Sale 06/27/2022 $1,001 — $15,000
- Line: 76 Synchrony Financial (SYF) Purchase 01/21/2022 $1,001 — $15,000
- Line: 79 Regions Financial Corp. (RF) Purchase 03/08/2022 $1,001 — $15,000
- Line: 80 Synchrony Financial (SYF) Sale 03/08/2022 $1,001 — $15,000
- Line: 85 Regions Financial Corp. (RF) Sale 06/22/2022 $1,001 — $15,000
- Line: 86 JPMorgan Chase & Co. (JPM) Sale 06/22/2022 $1,001 — $15,000
- Line: 87 Citizens Financial Group, Inc. (Rhode Island) (CFG) Sale 06/22/2022 $1,001 — $15,000
Entities Ms. Thompson Traded
SYNCHRONY FINANCIAL (RSSD ID: 4504654) is a Savings & Loan Holding Company regulated by the FRB/FRS.
STATE STREET CORPORATION (RSSD ID: 1111435) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least one FDIC-insured institution, State Street Bank and Trust Company (FDIC Cert #: 14).
CITIZENS FINANCIAL GROUP, INC. of Rhode Island (RSSD ID: 1132449) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least one FDIC-insured institution CITIZENS BANK, NATIONAL ASSOCIATION (FDIC Cert #: 57957) which is regulated by the OCC.
CITIZENS FINANCIAL GROUP, INC. of Missouri (RSSD ID: 1099784) is a Bank Holding Company regulated by the FRB/FRS. The BHC holds at least one FDIC-insured institution, CITIZENS BANK (FDIC Cert #: 14488), regulated by FDIC.
BANK OF AMERICA CORPORATION (RSSD ID: 1073757) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least two FDIC-insured institutions, BANK OF AMERICA CALIFORNIA, NATIONAL ASSOCIATION (FDIC Cert #: 25178), regulated by the OCC and Bank of America, National Association (FDIC Cert #: 3510), regulated by the OCC.
JPMORGAN CHASE & CO. (RSSD ID: 1039502) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least two FDIC-insured institutions, JPMORGAN CHASE BANK, DEARBORN (FDIC Cert #: 21761), regulated by the FRB, and JPMORGAN CHASE BANK, NATIONAL ASSOCIATION (FDIC Cert #: 628), regulated by the OCC.
CITIGROUP INC. (RSSDID: 1951350) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least one FDIC-insured institution, Citibank, National Association (FDIC Cert #: 7213), regulated by the OCC.
REGIONS FINANCIAL CORPORATION (RSSDID: 3242838) is a Financial Holding Company (Domestic) regulated by the FRB/FRS. The FHC holds at least one FDIC-insured institution, REGIONS BANK, State Member Bank (FDIC Cert #: 12368), regulated by the FRB.
