A U.S. banking regulator is considering whether to harden sanctions against lenders which abuse their clients or violate banking laws, according to a draft plan that was drawn up at the time of scandal at Wells Fargo.

Wells Fargo in September agreed to pay $190 million to settle charges that bank employees opened 2 million accounts without customers’ knowledge. The fraud continued for at least five years. Following the scandal, the Office of the Comptroller of the Currency waived its right to curb executive payouts, screen new leadership and other controls at Wells Fargo. In recent years, other national lenders such as Bank of America and Citibank have been granted exemptions similar to that Wells Fargo received.

Until a thorough, written policy is developed by the OCC, officials should refrain from granting relief from the toughest sanctions permitted, according to a memo dated November 18. An OCC spokesperson was not immediately available for comment. On Friday, the OCC voided the exemptions that it had originally granted Wells Fargo in a September settlement.