On November 14, 2022, the FDIC issued an Order to Pay Civil Money Penalty (FDIC-22-0049k) to Willamette Valley Bank for several violations of the laws and regulations. The Bank consented to the issuance of the order from the FDIC without admitting or denying the violations of law or regulation.

In the consent order, the FDIC alleges that Willamette Valley Bank:

Entered into mortgage lead generation arrangements with the operator of a real estate website and the operator of an online loan marketplace that were used to facilitate and disguise referral payments for mortgage business;
Made deceptive and misleading representations in three of the Bank’s prescreened offers of credit; and
Obtained the consumer reports of former loan clients with recent credit inquiries without a legally permissible purpose.

The FDIC ordered the bank to pay $425,000.00 to the Treasury as civil money penalty. In addition, the Bank is prohibited from seeking or accepting indemnification from any third party for the civil money penalty assessed and paid in this matter.

The consent order can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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