Recently, the CFPB terminated four consent orders against two banks each after finding the banks fulfilled their obligations. The CFPB also terminated one consent order against a lender.

One termination against a lender:

On September 22, the CFPB terminated a consent order originally issued against a lender on January 31, 2017, for alleged violations of RESPA and Regulation X, as well as the FCRA. The action followed the respondent’s fulfillment of several obligations under the order, including implementing a redress plan, paying $265,000 in consumer redress, and changing its business practices in response to the violations.

Two terminations against a national bank:

On September 22, the CFPB terminated a consent order originally issued on October 27, 2020, for alleged violations of HMDA and its implementing regulation, Regulation C, and section 1036(a)(1)(A) of the CFPA related to erroneous mortgage-loan data reporting for 2016 and 2017. The respondent fulfilled several obligations under the order, including payment of a $200,000 civil money penalty and implementing a compliance plan to collect HMDA data accurately.

On September 22, the CFPB terminated a consent order originally issued on October 9, 2013, for alleged violations of HMDA and its implementing regulation, Regulation C, citing deficiencies in compliance systems related to HMDA requirements. The termination stated the bank had fulfilled its obligations under the order, including payment of a $34,000 civil money penalty.

Two more terminations against another national bank:

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.