Payment Law Advisor Legal Commentary and Resources for the Payment Industry

UDAAP Enforcement Action Database

PLA presents below a database of enforcement actions that include allegations of unfair, deceptive, or abusive acts or practices (UDAAP) in connection with consumer financial products. The database focuses on enforcement actions by the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and the Federal Trade Commission. PLA intends the database to facilitate analysis of the themes and patterns in these agencies’ UDAAP enforcement actions.

We’ve sorted the actions by agency in the sequence indicated above. (Some actions involved multiple federal and/or state regulators, but for simplicity they’re grouped under the CFPB, FDIC, OCC or FTC.) The comments column offers data about selected issues such as whether the action involves claims of abusive practices.

A couple of disclaimers: first, although we’ll be supplementing the database from time to time, it’s not currently comprehensive. Second, while the PLA site has a search function, there’s no search function specifically for the database. If you’re on this page and need to search it, we’d recommend you use your browser’s “find” function.

We hope the database is useful and would welcome your feedback. Please contact us here with your suggestions.

The following resources, linked elsewhere on our site as well, may also be useful in this context:


Jump to: CFPB | FDIC | Fed | FTC | OCC

Consumer Financial Protection Bureau (CFPB)

Agency Date of Action Party Documents Activity Product/
Service
Comments
CFPB  12/16/16 Moneytree Press Release;
Consent Order
Deceptive marketing and debt collection Installment loans and check cashing
CFPB  12/08/16 American Advisors Press Release;
Consent Order
Deceptive marketing Reverse mortgages
CFPB  12/07/16 Reverse Mortgage Solutions Press Release;
Consent Order
Deceptive marketing Reverse mortgages
CFPB  12/07/16 Aegean Finanical Press Release;
Consent Order
Deceptive marketing Reverse mortgages
CFPB  11/16/16 Access Funding Press Release;
Complaint
Deceptive marketing Structured settlement factoring
CFPB  10/12/16 Northern Resolution Group, LLC Press Release;
Complaint
Debt Collection Consumer debt Joint action with the New York Department of Financial Services
CFPB  10/11/16 Navy Federal Credit Union Press Release;
Consent Order
Debt Collection Deposit accounts and loans
CFPB  09/27/16 Flurish Inc. d/b/a Lend Up Press Release;
Consent Order
Deceptive marketing Payday loans
CFPB  09/26/16 TMX Finance LLC Press Release;
Consent Order
Deceptive marketing Automobile title loans  Abusive
CFPB  09/20/16 Prime Marketing Holdings, LLC Press Release;
Consent Order
Deceptive marketing Credit repair services
CFPB  09/12/16 Bridgepoint Education, Inc. Press Release;
Consent Order
Deceptive marketing Student loans
CFPB  09/08/16 Wells Fargo Press Release;
Consent Order
Opening accounts without consent Credit cards, debit cards, deposit accounts, and online banking Abusive; Coordinated action with the OCC and City and County of Los Angeles
CFPB  08/25/16 First National Bank of Omaha Press Release;
Consent Order
Credit card add-on product sales and servicing Debt cancellation and credit monitoring
CFPB  08/22/16 Wells Fargo Press Release;
Consent Order
Loan servicing Student loans
CFPB  07/14/16 Santander Bank, N.A. Press Release;
Consent Order
Deceptive marketing Overdraft
CFPB  06/06/16 Intercept Corporation Complaint;
Press Release
Processing improper
transactions
Payment
processor
CFPB 05/11/16 All American Check Cashing Complaint;
Press Release
Deceptive marketing;
fee disclosures
Payday loans and
check cashing
Abusive
CFPB 04/25/16 New Century Financial Services Consent Order;
Press Release
Debt collection Debt collection
CFPB 04/25/16 Pressler and Pressler Consent Order;
Press Release
Debt collection Debt collection
CFPB 04/21/16 Davit Gasparyan (T3Leads) Complaint;
Press Release
Deceptive marketing Payday loan lead sales Abusive
CFPB 04/21/16 Dmitry Fomichev (T3Leads) Complaint;
Press Release
Deceptive marketing Payday loan lead sales  Abusive
CFPB 03/30/16 Student Aid Institute, Inc. Consent Order;
Press Release
Debt collection/
Settlement
Debt settlement
services
CFPB  03/02/16 Dwolla, Inc. Consent Order;
Press Release
Deceptive
marketing;
data security
Money
transmission
CFPB 02/23/16 Faloni & Associates, LLC Consent Order;
Stipulation and Consent;
Press Release
Debt collection Credit card debt
CFPB 02/23/16 Solomon & Solomon, P.C. Consent Order;
Stipulation and Consent;
Press Release
Debt collection Credit card debt
CFPB 02/23/16 Citibank, N.A., Department
Stores National Bank, and
CitiFinancial
Servicing, LLC.
Consent Order;
Press Release
Debt collection Credit card debt
CFPB 02/23/16 Citibank, N.A. Consent Order;
Press Release
Debt sales Credit card debt
CFPB 01/21/16 Y King S Corp
dba Herbies Auto
Sales
Consent Order;
Press Release
Deceptive marketing Auto loans Abusive
CFPB 12/17/15 Interstate Auto Group, Inc. DBA CarHop Consent Order;
Press Release
Credit reporting inaccuracies Auto loans
CFPB 12/17/15 Lead Publisher Consent Order;
Press Release
Reckless support of UDAAP violation Payday loan lead sales
CFPB 12/17/15 D and D
Marketing, Inc. DBA T3Leads
Complaint;
Press Release
Deceptive marketing Payday loan lead sales Abusive
CFPB 12/16/15 EZCorp, Inc. Consent Order;
Press Release
Debt collection Debt collection \ payday loans
CFPB 12/8/2015 Collecto, Inc. Complaint;
Press Release;
Stipulated Final
Judgment and
Order
Debt collection Cell phone debt
CFPB 11/18/15 Integrity Advance, LLC Brief in Support
of Motion to
Dismiss;
Notice of
Charges;
Press Release
Deceptive marketing Payday loans Admin
proceeding
CFPB 10/29/15 Student Financial Resource Center and College Financial Advisory Complaint;
Press Release
Deceptive marketing Student financial aid counseling
CFPB 10/01/15 Westlake Services, LLC & Wilshire Consumer Credit, LLC Consent Order;
Press Release
Debt collection Auto Loans
CFPB 09/28/15 Fifth Third Bank Consent Order;
Press Release
Deceptive marketing Credit card debt protection
CFPB 09/15/15 World Law Group Complaint;
Preliminary Injunction;
Press Release
Illegal collection of fees Debt settlement services
CFPB 09/09/15 Portfolio Recovery Associates Consent Order Debt Collection Debt collection
CFPB 09/09/15 Encore Capital Group Consent Order, Press Release Debt Collection Debt collection
CFPB 08/20/15 Pension Funding, LLC and Pension Income, LLC Complaint;
Consumer Advisory;
Press Release
Deceptive Marketing and Sales Pension advance loans Joint action with NYDFS; Abusive
CFPB 08/19/15 Springstone Financial, LLC Consent Order;
Press Release
Deceptive Marketing and Sales Deferred interest loans
CFPB 08/12/15 Citizens Financial Group Consent Order;
Press Release
Servicing misconduct Deposit account servicing Joint action with FDIC and OCC
CFPB 08/04/15 NDG Enterprise Complaint;
Press Release
Debt collection; loan origination Payday loans Abusive
CFPB 07/30/15 Residential Credit Solutions, Inc. Consent Order;
Press Release
Servicing misconduct Mortgage servicing
CFPB 07/28/15 Paymap Inc. Consent Order;
Press Release
Deceptive marketing Payment processing for biweekly mortgage payment product
CFPB 07/28/15 LoanCare, LLC Consent Order;
Press Release
Deceptive marketing Biweekly mortgage payment product
CFPB 07/23/15 Student Financial Aid Services, Inc. Complaint; Press Release;
Stipulated Final Judgment and Order
Unauthorized negative option enrollments and recurring payments Student financial aid counseling
CFPB 07/22/15 Discover Bank and Affiliates Consent Order; Press Release Improper cost disclosures and debt collection Student loans servicing
CFPB 07/21/15 Citibank, N.A., Department Stores National Bank, and Citicorp Credit Services, Inc. Consent Order; Press Release Credit card add-on product sales and servicing Debt protection and credit monitoring; expedited payments
CFPB 07/01/15 Intersections Inc. Complaint; Press Release; Stipulated Final Judgment and Order Credit card add-on product sales and servicing Credit monitoring
CFPB 07/01/15 Affinion Group Holdings, Inc. Complaint; Press Release; Stipulated Final Judgment and Order Credit card add-on product sales and servicing Credit monitoring
CFPB 06/17/15 Security National Automotive Acceptance Company Complaint; Press Release Debt collection Auto loans Abusive
CFPB 05/19/15 PayPal, Inc. and Bill Me Later, Inc. Complaint;
Cordray’s Remarks;
Press Release;
Stipulated Final Judgment
Marketing / Servicing Misconduct Digital wallet / installment loans
CFPB 05/12/15 Verizon Wireless Complaint;
Cordray’s Remarks;
Press Release;
Stipulated
Final Judgment and Order
Marketing / Servicing Misconduct Wireless telephone services / payment processing / add-on products
CFPB 05/11/15 Nationwide Biweekly
Administration, Inc.
and
Loan Payment
Administration LLC
Complaint;
Press Release
Marketing Biweekly
mortgage
payment
product
Abusive
CFPB 04/28/15 Regions Bank Consent Order;
Consumer Advisory;
Press Release;
Cordray’s Remarks
Marketing/
Overdraft
Opt-in
Overdraft;
Deposit
Advance
CFPB 04/21/15 Green Tree Servicing, LLC Stipulated Order for Permanent Injunction and Monetary Judgment Servicing Misconduct Mortgages Joint Action with FTC
CFPB 04/20/15 Fort Knox National Company,
et al.
Consent Order Undisclosed fees Payment processing (military allotments)
CFPB 04/14/15 S/W Tax
Loans, Inc.
et al.
Stipulated Final Judgment and Order Marketing / Undisclosed Kickbacks Tax Refund Anticipation Loans Joint Action with Navajo Nation
CFPB 04/08/15 Universal
Debt & Payments Solutions,
LLC et al.
Complaint Debt Collection
/ Settlement
Various
debts
CFPB 04/09/15 RMK Financial Corporation Consent Order;
Press Release;
Stipulation and Consent to the Issuance
Marketing Mortgages
CFPB 03/30/15 National Corrective Group, Inc. Complaint;
Press Release;
Stipulated Final Judgment
Debt Collection
/ Settlement
Various debts
CFPB 02/12/15 Flagship Financial Group, LLC Consent Order;
Press Release;
Stipulation and Consent to the Issuance
Marketing Mortgages
CFPB 02/12/15 American Preferred Lending, Inc. Consent Order;
Press Release;
Stipulation and Consent to the Issuance
Marketing Mortgages
CFPB 02/12/15 All Financial Services, LLC Complaint;
Press Release
Marketing Mortgages
CFPB 02/10/15 Newday Financial, LLC Consent Order;
Press Release;
Stipulation and Consent to Issuance
Marketing Mortgages
CFPB 02/04/15 Continental Finance Company, LLC Consent Order;
Press Release;
Stipulation and Consent to Issuance
Marketing Credit cards
CFPB 02/03/15 Union Workers Credit Services, Inc. Press Release;
Stipulated Final Judgment and Order
Marketing Credit cards
CFPB 12/18/14 Freedom
Stores, Inc.
Complaint;
Stipulated Final Judgment and Consent Order;
Press Release;
Blog Post
Debt
Collection/
Settlement
Installment
loans
Abusive
CFPB 12/17/14 Union Workers
Credit Services
Complaint;
Press Release
Marketing Credit Cards
CFPB 12/17/14 Sprint Complaint;
Cordray’s Remarks ;
Press Release (Settlement);
Press Release;
Request for Motions on Settlement Approval;
Stipulated Final Judgment Order
Deceptive
Marketing of
add-on
products/
Debt
Collection/
Settlement
Premium
text
messages
CFPB 12/11/14 Student Loan
Processing
US
Complaint;
Consumer Advisory;
Press Release
Debt
Collection/
Settlement
Student loan
debt relief
CFPB 12/11/14 College
Education
Services LLC
Complaint;
Stipulated Final Judgment and Order;
Consumer Advisory
Press Release
Marketing;
Debt
Collection/
Settlement
Student loan
debt relief
Abusive
CFPB 11/19/14 DriveTime
Automotive
Group, Inc.
and DT
Acceptance
Corp.
Consent Order;
Press Release
Debt
Collection/
Settlement
& Credit
Reporting
Auto loans
CFPB 10/09/14 M&T Bank Consent Order;
Press Release
Marketing Checking
accounts
CFPB 09/29/14 Flagstar
Bank,
F.S.B.
Consent Order,
Press Release
Customer
service
Mortgage
servicing;
Mortgage
loss
mitigation
CFPB 09/25/14 US Bank,
N.A.
Consent Order,
Press Release
Billing Credit
cards;
Identity
theft
protection;
Add-on
products
Two-step
enrollment
CFPB 09/16/14 Corinthian
Colleges
Complaint for
Pemanent
Injunction
& Other Relief
,
Default
Judgment
& Order
Predatory
lending
Private
student
loans
CFPB 09/08/14 Hydra
Financial
Complaint for
Pemanent
Injunction &
Other Relief
Billing
and
collections
Payday
loans
CFPB 08/25/14 Global
Client
Solutions
Consent Order,
Press Release,
Complaint
Debt
settlement/
collection
Debt-relief
programs
CFPB 08/20/14 First
Investors
Financial
Services
Group,
Inc.
Consent Order,
Press Release
Credit
reporting inaccuracies
Auto
Loans
CFPB 08/14/14 USA
Discounters
Stipulated Final
Judgment
and Consent
Order
;
Press Release
Marketing Retail
install-
ment
loans;
Add-on
products
CFPB 08/12/14 Amerisave Consent Order,
Press Release
Marketing Mortgages;
Appraisals
CFPB 07/29/14 Rome
Finance
Co., Inc.
Consent Order,
Press Release
Marketing Retail
installment
loans
Abusive
CFPB 07/26/14 Clausen &
Cobb
Management
Company,
Inc.
Complaint for
Pemanent
Injunction &
Other Relief
; Press Release
Debt
settlement/
collection
Mortgage
assistance
relief
services;
Debt-relief
programs
CFPB 07/26/14 The
Mortgage
Law
Group
Complaint;
Press Release
Debt
settlement/
collection
Mortgage
assistance
relief
services;
Debt-relief
programs
CFPB 07/26/14 Hoffman
Law
Group
Complaint for Permanent Injunction & Other Relief;
Press Release
Debt
settlement/
collection
Mortgage
assistance
relief
services;
Debt-relief
programs
CFPB 07/14/14 Frederick
J.
Hanna &
Associates
Complaint;
Press Release
Debt
collection
Various
debts
CFPB 07/10/14 Ace Cash
Express
Consent Order;
Press Release
Debt
collection
Payday
loans
Abusive
CFPB 06/19/14 GE
Capital/
Synchrony
Bank
Consent Order;
Press Release
Marketing Credit
cards;
Add-on
products;
Payment
protection
CFPB 06/17/14 SunTrust
Mortgage,
Inc.
Consent Judgment
(Proposed)
;
Complaint;
Press Release
Systemic
mortgage
servicing
misconduct
including
robo-signing
and
illegal
foreclosure
practices
Mortgage
lending;
Mortgage
servicing
CFPB 04/09/14 Bank of
America,
N.A.;
and
FIA Card
Services,
N .A.
Consent Order;
Press Release
Marketing;
Billing
Credit
cards;
Payment
protection;
Identity
theft
monitoring
Two-step
enrollment
CFPB 02/26/14 ITT
Educat-
ional
Services,
Inc.
Complaint for
Injunctive
Relief and
Damages
;
Press Release
Marketing;
Predatory
lending
Private
student
loans
Abusive
CFPB 12/24/13 American
Express
Travel
Related
Services
Company
Consent Order;
Press Release
Marketing Credit cards;
Payment
protection;
Identity
theft
monitoring
Two-step
enrollment
CFPB 12/24/13 American
Express
Centurion
Bank
Consent Order;
Press Release
Marketing Credit
cards;
Payment
protection;
Identity
theft
monitoring
Two-step
enrollment
CFPB 12/24/13 American
Express
Bank,
FSB
Consent Order;
Press Release
Marketing Credit
cards;
Payment
protection;
Identity
theft
monitoring
CFPB 12/19/13 Ocwen
Financial
Corp-
oration;
Ocwen
Loan
Servicing,
LLC
Consent Judgment
(Proposed &
Entered);
Press Release
;
Cordray’s Remarks
Systemic
mortgage
servicing
misconduct
including
robo-signing
and
illegal
foreclosure
practices
Mortgage
lending;
Mortgage
servicing
CFPB 12/10/13 GE Capital
Retail
Bank,
Care-
Credit
LLC
Consent Order;
Press Release
Marketing Credit
cards
CFPB 11/20/13 Cash America
Inter-
national,
Inc.
Consent Order;
Press Release
Debt
collection
Payday
loans
CFPB 09/18/13 JPMorgan
Chase
Bank,
N.A.;
Chase
Bank
USA,
N.A.
Consent Order;
Press Release
Billing Credit
cards;
Identity
theft
protection;
Add-on
products
Two-step
enrollment
CFPB 08/20/13 Morgan
Drexen,
Inc.
Complaint for
Permanent
Injunction &
Other Relief
;
Press Release
Debt
Collection/
Settlement
Debt-relief
CFPB 06/26/13 U.S.
Bank
National
Association
Consent Order;
Press Release
Marketing Auto
loans;
Vehicle
service
contracts;
GAP
insurance;
Add-on
products
CFPB 06/25/13 Dealers’
Financial
Services,
LLC
Consent Order;
Press Release
Marketing Auto
loans;
Vehicle
service
contracts;
GAP
insurance;
Add-on
products
CFPB 06/07/13 American
Debt
Settlement
Solutions,
Inc.
Stipulated Final Judgment and Order;
Complaint;
Press Release
Debt
settlement/
collection
Debt-
relief
programs

Abusive

CFPB 12/21/12 Payday
Loan
Debt
Solutions
Stipulated Final Judgment and Order; Blog Debt
settlement/
collection
Debt-
relief
programs
CFPB 12/03/12 National
Legal
Help
Center
Complaint for Permanent Injunction and Other Relief;
Press Release
Upfront
fees;
Marketing
Mortgage
assistance
relief
services;
Debt-
relief
programs
CFPB 10/01/12 American
Express
Bank,
FSB
Consent Order;
Stipulation;
Fact Sheet;
Press Release
Marketing;
Debt
Collection/
Settlement
Credit cards;
Promotional
benefits
CFPB 10/01/12 American
Express
Centurion
Bank
Consent Order;
Stipulation;
Fact Sheet;
Press Release
Marketing;
Debt
Collection/
Settlement
Credit
cards;
Promotional
benefits
CFPB 10/01/12 American
Express
Travel
Related
Services
Company
Consent Order;
Stipulation
Fact Sheet;
Press Release
Marketing;
Debt
Collection/
Settlement
Credit
cards;
Promotional
benefits
CFPB 09/24/12 Discover
Bank
Consent Order;
Fact Sheet;
Press Release
Marketing Credit
cards;
Payment
protection;
Identity
theft
protection;
Add-on
products
CFPB 07/17/12 Gordon
Law
Firm
Complaint for Permanent Injuction & Other Relief;
Press Release
Upfront
fees;
Marketing
Mortgage
assistance
relief
services;
Debt-relief
programs
CFPB 07/17/12 Capital
One
Bank,
N.A.
Consent Order,
Fact Sheet
Marketing Credit
cards;
Payment
protection;
Credit
monitoring;
Add-on
products

 

Federal Deposit Insurance Corporation (FDIC)

Agency Date of Action Party Documents Activity Product/
Service
Comments
FDIC 12/23/15 The Bancorp Bank Consent Order;
Press Release
Error resolution, account termination, and fees Prepaid card programs
FDIC 12/23/15 WEX Bank Consent Order Deceptive marketing Disbursement of student loan proceeds and checking accounts See separate FDIC and Fed actions against Higher One
FDIC 09/08/15 Comenity Bank, Comenity Capital Bank Consent Order 1; Consent Order 2;
Press Release
Deceptive marketing Credit card debt protection

 

Federal Reserve System (Fed)

Agency Date of Action Party Documents Activity Product/
Service
Comments
Fed 12/06/16 Customers Bank Press Release; Consent Order Deceptive marketing Student loans and deposit accounts
Fed 12/23/15 Higher One, Inc., as an institution-affiliated party
of Customers
Bank and a
former
institution
-affiliated party
of Cole Taylor
Bank
Consent Order Deceptive marketing Disbursement of student loan proceeds and checking accounts See separate FDIC actions against Higher One and WEX Bank

 

Federal Trade Commission (FTC)

Agency Date of Action Party Documents Activity Product/
Service
Comments
FTC 05/30/16 Stark Law, LLC d/b/a Stark Recovery Press Release; Complaint Debt collection Payday loans
FTC 05/25/16 Good Business LLC Press Release; Complaint Deceptive marketing Home loan and student loan modification services
FTC 08/07/15 Sequoia One, LLC Press Release; Complaint Date brokering Payday loans
FTC 06/29/15 All Us Marketing LLC Press Release; Complaint Deceptive marketing Credit card interest rate reduction programs
FTC 05/31/15 Wealth Educators, Inc. Press Release; Complaint Marketing and performance Mortgage relief services
FTC 05/11/15 Unified Global Group Press Release; Complaint Debt Collection Consumer debt
FTC 05/11/15 The Primary Group Press Release; Complaint Debt Collection Consumer debt
FTC 05/11/15 Premier Debt Acquisitions Press Release; Complaint Debt Collection Consumer debt
FTC 07/22/13 AMG
Services,
Inc.
Stipulated Order for
Permanent
Injunction and
Judgment
Marketing;
Debt
collection
Payday
lending
FTC 01/31/12 Asset
Acceptance,
LLC
Consent Decree Mis-
representations;
Failure to disclose
Debt
collection
practices
FTC 09/16/11 Loan-
Pointe,
LLC
Final Order of
Judgment
and Permanent
Injunction
Mis-
representations;
improper
communication
with third
parties
Payday
lending;
Collection
activities
FTC 07/21/11 Swish
Marketing,
Inc.
Final Judgment and
Order for
Permanent Injunction
Marketing Payday
lending
FTC 07/29/10. RCA Credit
Servs.,
LLC
Amended Final
Judgment and
Permanent
Injunction
Marketing Credit
repair
services
FTC 12/28/09 Virtual
Works,
LLC
Final Judgment and
Order for Permanent
Injunction
Marketing Pre-paid
debit
cards
FTC 12/19/08 CompuCredit
and Jefferson
Capital
Systems
Stipulated Order for Permanent Injunction Mis-
representations
of
available
credit and debit
collection
program;
Failure to
disclose fees
and effect of
use of card on
available
credit
Consumer
credit
products and
related
financial
services;
Debit
collection
practices
FTC 11/12/08 Cash
Today,
Ltd.
Stipulated Final
Judgment and
Order for
Permanent
Injunction and
Other
Equitable Relief
as to certain
defendants
Debt
collection;
Harassment
Payday
loans
FTC 08/14/07 Kmart
Corp.
Consent Order Marketing;
Failure
to disclose
fees
Gift
cards
FTC 08/02/07 Fairbanks
Capital
Corp.
Modified
Stipulated
Final
Judgment and
Order
Failure to
timely
post payments;
force placed
casualty
insurance on
consumers’
homes;
failure to
disclose;
mis-
representation
of
amounts
owed and
fees
collected
Servicing
and
collection
of
mortgage
loans
FTC 03/08/07 Canada
Ltd.
Order for
Permanent
Injunction and
Final
Judgment
Telemarketing Advance
fee
credit
cards
FTC 09/25/06 Mortgages
Para
Hispanos.
com
Corp.
& Daniel
Moises
Goldberg
Stipulated Final
Judgment
and Order
for Permanent Injunction
Mis-
representations
of loan
terms
Mortgage
lending
services
FTC 05/03/06 Integrated
Credit
Solutions,
Inc.
Stipulated Final
Judgment
and Order
for Permanent
Injunction
Marketing Credit
counseling
FTC 12/18/05 Peoples
Credit
First,
LLC
Order Marketing Credit
card
direct
mail
solici-
tations
FTC 07/18/05 Check Investors Final Order for
Judgment and
Permanent
Injunction
as to certain
defendants
Mis-
representations
Debt
collection
practices
FTC 03/30/05 Debt
Management
Found.
Servs.,
Inc.
Stipulated Final
Judgment and Order
for Permanent
Injunction
and Other
Equitable Relief
Marketing Debt
manage-
ment
programs
FTC 02/23/05 Capital
City
Mortgage
Corp.
Settlement
Agreement,
Stipulated
Injunction,
Release, Final
Order
Mis-
representations
Mortgage
lending
services
FTC 11/03/04 First
American
Payment
Processing,
Inc.
Stipulated
Perment
Injunction and
Final Order
Marketing Payment
processing
FTC 08/13/04 Ranney,
Phillip
W.,
individ-
ually;
Armor
Mortgage
Amended
Permanent
Injunction
,
Order for
Judgment by
Default and
Permanent
Injunction
Marketing Mortgage
refinancing
FTC 06/23/04 Direct
Mktg.
Concepts
Appeal Marketing Weight
loss
cures
FTC 04/09/04 Bay
Area
Bus,
Council,
Inc.
Order for Permanent
Injunction with
Monetary Judgment
and Other Relief as to
certain defendants
Telemarketing;
Undisclosed
fees
Credit
card
sales
FTC 10/28/03 Stewart
Finance
Co.
Consent Order
for
Preliminary
Injunction:
Debtor &
Non-Debtor
Failure to
disclose;
mis-
representations
Personal
consumer
loans
FTC 03/13/00 DBC
Financial,
Inc.
Decision and Order Marketing;
Failure
to
disclose
Credit
card
fees
FTC 02/06/97 General
Motors
Corp.,
Am.
Honda
Motor Co.,
Mazda
Motor of
America,
Inc.
Mitsubishi
Motor
Sales of
America,
Inc.,
American
Isuzu
Motors,
Inc.
Consent Orders:

Marketing;
Failure to
disclose
Consumer
auto
leases
FTC Washington
Data
Resources
Order Direct
mail;
Telemarketing
activities
Consumer
mortgage
loan
modif-
ication
and
foreclosure
relief
services
FTC Neovi, Inc. Final Order for
Permanent
Injunction and
Other Equitable
Relief
Failure to
verify
person
requesting
checks;
unauthorized
check
draws
Check
creation
and
delivery
FTC Cyber-space.com Order Granting in
Part Plaintiff’s
Motion for Summary
Judgment and Denying
Defendants’ Motions for
Summary Judgment
Marketing Check
solicit-
ations
FTC Chase
Financial
Funding,
Inc.
Final Judgment and
Order for Permanent Injunction and
Other Equitable Relief
Marketing;
Failure to
disclose
Mortgage
lending

 

Office of the Comptroller of the Currency (OCC)

Agency Date of Action Party Documents Activity Product/
Service
Comments
OCC  09/06/16 First Niagra Bank Consent Order Deceptive disclosures Overdraft services
OCC  08/25/16 First National Bank of Omaha Press Release; Consent Order Unfair billing practices  Identify theft protection
OCC 04/13/16 HSBC Bank USA, N.A. Press Release; Consent Order Unfair billing practices Identify theft protection
OCC 08/12/2015 Citizens Bank, N.A. Press Release; Consent Order Deposit reconciliation practices Deposit accounts
OCC 07/21/15 Citibank, N.A. Press Release; Consent Order Unfair billing practices and deceptive marketing  Debt cancellation and credit monitoring
OCC 03/26/15 Santander Bank, N.A. Consent Order Unfair billing practices Identify theft protection
OCC 10/06/14 PNC Bank, N.A. Consent Order Unfair billing practices Identify theft protection
OCC 09/25/14 U.S. Bank, N.A. Consent Order; Press Release Unfair billing practices Identify theft protection
OCC 04/09/14 Bank of America, N.A. Consent Order; Press Release Unfair billing practices Identify theft protection
OCC 12/19/13 American
Express,
F.S.B.
Consent Order Billing
practices;
Marketing
Identity
protection
products
OCC 09/18/13 JPMorgan
Chase
Bank,
N.A. &
Chase
Bank
USA,
N.A.
Consent Order Billing
practices
Identity
protection
products
OCC 04/29/13 RBS
Citizens,
N.A.
Consent Order Failure to
disclose;
customer
agreements
Overdraft
protection
practices
OCC 07/17/12 Capital
One
Bank
(USA),
N.A.
Consent Order for Civil
Money Penalty
Marketing,
sales
and retention
practices;
billing
practices
Debt
cancell-
ation
and credit
and
identity
monitoring
products
OCC 04/24/08 Wachovia
Bank,
N.A.
Consent Order for Civil Money Penalty; FinCEN Assessment of Civil Money Penalty Telemarketing;
third party
payment
processors
Banking
fees
OCC 11/01/05 Home-
owners
Loan
Corp. and
The
Laredo
National
Bank
Agreement Mis-
representations/
failure to
disclose in
advertising
Loans
OCC 05/21/04 First
National
Bank of
Marin,
Las Vegas,
NV,
Stipulation and
Consent to
Issuance of
Consent Order
Marketing;
improper
lending
practices
Credit
cards
OCC 11/04/03 Clear Lake
National
Bank
Consent Order Duplicative
fees;
fees charged
for
services not
performed;
failure to
disclose
Tax
lien
loans
OCC 07/31/03 First
Consumers
National
Bank,
Beaverton,
Oregon
Agreement Failure to
disclose
Credit
cards
OCC 01/17/03 First
National
Bank
of
Brookings
Consent Order Marketing Credit
cards
OCC 06/28/00 Providian
National
Bank
Consent Order Marketing;
Failure
to
disclose
Credit
protection
program