Recently, the FDIC ordered two affiliated state nonmember banks to each pay a $1,000,000 civil monetary penalty (orders here and here). These penalties resolve claims of unfair practices related to their rewards programs and the processing of automatic payments. According to the orders, which were devoid of detail, the FDIC determined that the two banks engaged in unfair acts and practices prohibited under the FTC Act when they converted from an internal core system to an external core system that affected the processing of automatic payments related to their respective awards programs.