Recently, the CFPB terminated two consent orders against a national banking association.
On September 18, the CFPB terminated a consent order (2023-CFPB-0019) against the bank after determining it had fulfilled its obligations related to violations of the CFPA, the EFTA, and Regulation E from a consent order issued in December 2023. The consent order alleged issues related to the bank’s administration of unemployment insurance benefit prepaid debit cards. The CFPB dismissed the case stating the bank paid a $15 million civil money penalty, made required redress payments, and implemented injunctive relief to prevent future violations.
On August 21, the CFPB terminated a consent order (2022-CFPB-0006) against the same bank after confirming the bank fulfilled its obligations under the order, including payment of a $37.5 million civil money penalty, issuing redress payments, and that it has “taken steps to implement injunctive relief” to prevent future violations. The consent order, issued in July 2022, addressed violations of TILA and its Regulation Z, the FCRA, the Truth in Savings Act and its Regulation DD, and the CFPA related to the bank’s practices on opening deposit accounts, lines of credit, and accessing consumer reports.
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