On December 8, the Oregon Department of Consumer and Business Services (DCBS) entered a consent order assessing a potential $1.56 million in redress — $900,000 in restitution and $660,000 in civil penalties, suspended for three years — with two companies for alleged excessive interest charges under a bank partnership model. DCBS alleged the companies charged, contracted for, or received interest rates above statutory limits on at least 806 consumer loans to Oregon residents, even though such loans were made by an out-of-state state-chartered bank pursuant to a bank partnership model.

Additionally, one of the companies was found to be an unlicensed consumer lender. DCBS found that the companies also permitted prohibited terms in loan agreements, including excessive attorney fee provisions, hold harmless clauses, and unauthorized powers of attorney. Under the consent order, among other obligations, the companies must amend or void certain loan provisions and provide $900,000 in pro-rata refunds to affected borrowers according to a redress plan. Additionally, the $660,000 civil penalty will be waived in three years provided the companies comply with all terms in the order, including restitution and refraining from further violations; otherwise, the full penalty will be immediately due and owing.