If by that you mean penalties on named officers, or certain type for a specific group, that's an unConstitutional bill of attainder.
At this point, given the multiple counterexamples in the implementation of Obamacare, I have no faith that general legislation, or officially removing funding would work. Or rather, it won't work until it's once again thinkable to impeach the President. (I initially appended "or political appointees under him", but Obama's is hardly the first where staffers who can't be touched by the Congress are really running things.)
I don't mean "bill of attainder", I mean specific penalties for officials that do not follow the law. I didn't think that fit under "bill of attainder". I'm not talking about no trial, but no sovereign immunity from prosecution in failure of duty. I could be wrong at how that works since it isn't my area.
We're talking about essentially an abuse in "prosecutorial" discretion, who the FDIC targets and who it doesn't, for what reasons.
Now, to make this work, the FDIC examiners have to make explicit threats, and people at the banks need to be able to testify to this without the threat the FDIC will destroy the for that....
To actually make it stick, the DoJ would have to prosecute, and this DoJ certainly won't. But maybe the next would....
I think, it's going to have to come down to a non-Democratic Administration that actually has serious cojones. Which is unlikely, but possible, e.g. http://thefederalist.com/2014/11/11/the-nation-needs-preside... (jump down to the 2nd section, "The Throne Made of the Skulls of His Enemies" :-).
And you're very right about trying this now. We don't want to wait until we're only left with extralegal recourse, that will not end well.
At this point, I really worry because the next President seeing what the long line before him/her did, might just be worse in not following legislation. For example, there is no authority to delay implementation of laws, but I guess it will become the default.
Perhaps we would have been better off if the usual suspects hadn't turned a blind eye to the Administration's criminal behavior when it was only going after approved but entirely targets like payday loan companies and gun and ammo dealers. Dispensing with the rule of law turns out not to be so keen, yes?