On November 15, 2023, the CFPB ordered online lender Enova International Inc. to pay a $15 million penalty for widespread illegal conduct including withdrawing funds from customers’ bank accounts without their permission, making deceptive statements about loans, and cancelling loan extensions. In 2019, Enova paid a $3.2 million penalty to the CFPB and was ordered to cease its illegal conduct.

On November 13, 2023, the CFPB announced that 845 former Student Aid Institute (SAI) consumers will receive checks in the mail in response to a lawsuit filed against Frank Ronald Gebase Jr., the founder, owner, and operator of Processingstudentloans, a student loan debt-relief company that illegally withdrew hundreds of thousands of dollars from the bank accounts of former SAI consumers without their authorization. The total distribution amount is $240,994.00, and the money will come from the CFPB’s victims relief fund.

On November 13, 2023, the OCC announced that registration is open for its symposium on the tokenization of real-world assets and liabilities on February 8, 2024, at its headquarters in Washington, D.C. The symposium will include panel discussions among thought leaders, academics, community groups, and the banking industry on tokenization and is open to the public for in-person or virtual attendance.

VIDEO: Excluding a Reg Z Loan as Commercial

In this Compliance Clip (video), Adam talks about an amicus brief that the CFPB submitted to the courts regarding how Regulation Z applies to commercial loans. In particular, the opinion clarifies whether or not you can call a loan a “commercial loan” in order to exempt the loan from the requirements of Regulation Z. A transcript of this video is now available.

On November 8, 2023, the CFPB ordered Citi to pay $25.9 million in fines and consumer redress for intentionally and illegally discriminating against credit card applicants the bank identified as Armenian American. According to CFPB Director Rohit Chopra, Citi purposefully discriminated against applicants of Armenian descent, primarily based on the spelling of their last name, and stereotyped Armenians as prone to crime and fraud. Chopra also said that Citi illegally fabricated documents to cover up its discrimination.

On November 6, 2023, FinCEN and the BIS issued a new SAR key term to support financial institutions in reporting potential efforts to evade U.S. export controls beyond the Russia-related circumstances that were the focus of those prior two alerts. The new joint notice builds on the success of the two prior alerts issued jointly by the two agencies in generating suspicious activity reporting related to Russia-related export control evasion.