2022-CFPB-0004-Bank of America N.A. - Consent Order

Date: 2025-10-17

Summary

A Consumer Financial Protection Bureau consent order in the administrative proceeding In the Matter of Bank of America, N.A., File No. 2022-CFPB-0004, issued July 14, 2022 and filed on October 17, 2025 as Document 591-102 in Case 3:21-md-02992-GPC-MSB, where it is labeled exhibit DX 42. The Bureau identifies violations concerning unemployment insurance benefit prepaid debit cardholders who filed notices of error about alleged unauthorized EFTs, citing 12 U.S.C. §§ 5531(a) and (c), 5536(a)(1)(B) and 15 U.S.C. §§ 1693f and 1693g. The Bureau finds that from September 28, 2020 the bank used an automated Fraud Filter to determine no error had occurred and froze or blocked accounts. The respondent consented without admitting or denying the findings, and the order is signed by Rohit Chopra as Director of the Bureau.

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DX 42
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UNITED STATES OF AMERICA
CONSUMER FINANCIAL PROTECTION BUREAU

ADMINISTRATIVE PROCEEDING
File No. 2022-CFPB-0004

In the Matter of:

CONSENT ORDER

BANK OF AMERICA, N.A.

The Consumer Financial Protection Bureau (Bureau) has reviewed the

administration of unemployment insurance benefit prepaid debit cards by Bank of

America, N.A. (Respondent, as defined below) and has identified the following

law violations in connection with Respondent’s treatment of unemployment

insurance benefit recipients who filed notices of error concerning alleged

unauthorized electronic fund transfers (EFTs): (1) Respondent engaged in unfair

acts or practices by determining no error had occurred and freezing cardholder

accounts based solely on the results of Respondent’s automated Fraud Filter, in

violation of Sections 1031 and 1036 of the Consumer Financial Protection Act of

2010 (CFPA), 12 U.S.C. §§ 5531(a) and (c), 5536(a)(1)(B); (2) Respondent failed

to conduct reasonable investigations of unemployment insurance benefit prepaid
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debit cardholders’ notices of error, in violation of Sections 908 and 909 of the

Electronic Fund Transfer Act (EFTA), 15 U.S.C. §§ 1693f and 1693g, and Section

1005.11 of Regulation E; and (3) Respondent engaged in abusive acts or practices

by retroactively applying its automated Fraud Filter to reverse permanent credits

for unemployment insurance benefit prepaid debit cardholders whose notices of

error Respondent had previously investigated and paid, in violation of Sections

1031 and 1036 of the CFPA, 12 U.S.C. §§ 5531(a) and (d)(2)(B), 5536(a)(1)(B).

The Bureau has also identified that: (4) Respondent engaged in unfair acts or

practices by impeding unemployment insurance benefit prepaid debit cardholders’

efforts to file notices of error and seek liability protection from unauthorized EFTs,

in violation of Sections 1031 and 1036 of the CFPA, 12 U.S.C. §§ 5531(a) and (c),

5536(a)(1)(B); and (5) Respondent failed to timely investigate and resolve

unemployment insurance benefit prepaid debit cardholders’ notices of error

concerning alleged unauthorized EFTs, in violation of EFTA, 15 U.S.C. §

1693f(a), (c), and Section 1005.11(c)(2)-(3) of Regulation E. Under Sections 1053

and 1055 of the Consumer Financial Protection Act of 2010 (CFPA), 12 U.S.C. §§

5563, 5565, the Bureau issues this Consent Order (Consent Order).

Jurisdiction
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1. The Bureau has jurisdiction over this matter under Sections 1053 and 1055

of the CFPA, 12 U.S.C. §§ 5563 and 5565, and Section 918(a)(5) of EFTA,

15 U.S.C. § 1693o(a)(5).

II.

Stipulation

2. Respondent has executed a “Stipulation and Consent to the Issuance of a

Consent Order,” dated July 13, 2022 (Stipulation), which is incorporated by

reference and is accepted by the Bureau. By this Stipulation, Respondent has

consented to the issuance of this Consent Order by the Bureau under

Sections 1053 and 1055 of the CFPA, 12 U.S.C. §§ 5563, 5565, without

admitting or denying any of the findings of fact or conclusions of law, except

that Respondent admits the facts necessary to establish the Bureau’s

jurisdiction over Respondent and the subject matter of this action.

III.

Definitions

3. The following definitions apply to this Consent Order:

a. “Affected Consumers” means a consumer who during the Relevant

Period: (1) qualified for and received government unemployment

insurance benefit payments electronically through prepaid debit cards

issued by Respondent; (2) filed a notice of error concerning alleged
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unauthorized EFTs with Respondent; and (3) for whom Respondent

incorrectly determined, based solely on the results of Respondent’s Fraud

Filter, that no error occurred, and, as a result, Respondent (i) denied the

consumer’s error claim or reversed permanent credits previously granted

to the consumer and (ii) froze or, after March 17, 2021, blocked the

consumer’s unemployment insurance benefit prepaid debit card account.

b. “Board” means Respondent’s duly-elected and acting Board of Directors

or a committee thereof.

c. “Consequential Harm” means the financial harm Affected Consumers

incurred due to the time their unemployment insurance benefit prepaid

debit card account remained frozen or blocked after Respondent

incorrectly determined that no error occurred on the consumer’s

unemployment insurance benefit prepaid debit card account, based solely

on the results of Respondent’s Fraud Filter.

d. “EDD” means the California Employment Development Department.

e. “EDD Cardholder” means a consumer who received an EDD Prepaid

Debit Card.

f. “EDD Prepaid Debit Cards” means Respondent-issued and Respondent-

administered unemployment insurance benefit prepaid debit cards linked

to individual EDD Prepaid Debit Card Accounts.
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g. “EDD Prepaid Debit Card Accounts” means depository accounts

maintained by Respondent for the Prepaid Card Unemployment

Insurance Benefits Program and holding unemployment insurance and

other public benefits from EDD for consumers.

h. “Effective Date” means the date on which the Consent Order is entered

on the administrative docket.

i. “Electronic Fund Transfer” or “EFT” means “any transfer of funds, other

than a transaction originated by check, draft, or similar paper instrument,

which is initiated through an electronic terminal, telephonic instrument,

or computer or magnetic tape so as to order, instruct, or authorize a

financial institution to debit or credit an account.” 15 U.S.C. § 1693a(7).

j. “Enforcement Director” means the Assistant Director of the Office of

Enforcement for the Consumer Financial Protection Bureau, or his or her

delegate.

k. “Error Resolution Investigation” means the procedures and duties

required of financial institutions as described in 12 C.F.R. § 1005.11.

l. “Fraud Filter” means the automated fraud detection process that

Respondent used to investigate unemployment insurance benefit prepaid

card notices of error between September 28, 2020 and June 8, 2021.
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m. “OCC Consent Order” means the Consent Order issued by the Office of

the Comptroller of the Currency against Respondent on July 14, 2022.

n. “Prepaid Card Unemployment Insurance Benefits Program” means the

program through which Respondent issued and administered prepaid

debit cards and associated accounts containing unemployment insurance

benefits granted to consumers in certain states.

o. “Regional Director” means the Regional Director for the Southeast

Region for the Office of Supervision for the Consumer Financial

Protection Bureau, or his or her delegate.

p. “Related Consumer Action” means a private action by or on behalf of

one or more consumers or an enforcement action by another

governmental agency brought against Respondent based on substantially

the same facts as described in Section IV of this Consent Order.

q. “Relevant Period” means March 1, 2020 to June 8, 2021.

r. “Respondent” means Bank of America, N.A. and its successors and

assigns.

IV.

Bureau Findings and Conclusions

The Bureau finds the following:
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4. Respondent is a national bank headquartered in Charlotte, North Carolina

with branches and ATMs located in 38 states and the District of Columbia.

As of December 31, 2021, Respondent had $2.5 trillion in consolidated

assets, which makes it an insured depository institution with assets greater

than $10,000,000,000 within the meaning of 12 U.S.C. § 5515(a).

5. Respondent is a “covered person” under 12 U.S.C. § 5481(6) because it

“engages in offering or providing a consumer financial product or service,”

including by engaging in deposit-taking activities, transmitting or

exchanging funds, or otherwise acting as a custodian of funds or any

financial instrument for use by consumers primarily for personal, family, or

household purposes. 12 U.S.C. § 5481(15)(A)(iv).

6. Respondent is a “financial institution” under EFTA and Regulation E

because it is a national bank holding consumer deposit accounts. 15 U.S.C. §

1693a(9).

7. During the Relevant Period, Respondent had contracts with 12 states,

including California, to deliver unemployment insurance and other

government benefit payments to consumers through prepaid debit cards and

accounts.

8. For each consumer deemed eligible by the relevant state unemployment

agency who elected to receive their benefit payments through a prepaid debit
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card during the Relevant Period, the state notified Respondent, funded a

prepaid debit card account with Respondent, and Respondent issued a

prepaid debit card to the consumer.

9. In each of those states, Respondent was responsible for loading

unemployment and other government benefit payments onto prepaid debit

cards and for servicing consumers’ prepaid debit card accounts.

10. The onset of the COVID-19 pandemic in March 2020 led to a surge in

consumers seeking unemployment insurance benefits. These programs

provide a temporary partial wage or income replacement for consumers who,

through no fault of their own, have lost their jobs. Payments are made

directly to unemployed consumers, so that consumers can continue to pay

for the necessities of life while they search for work. The national

unemployment rate in April 2020 was 14.7%, and it remained at

significantly elevated levels through 2020. Millions of consumers were

newly unemployed. They sought the benefits to which they were legally

entitled via Respondent’s prepaid debit cards.

Respondent’s Strategy for Prepaid Debit Cardholders Filing Notices of Error
and Seeking Liability Protection

11. When notified by a consumer of an error such as an unauthorized EFT on

their account, a financial institution must investigate the alleged error,
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determine whether an error has occurred, and report the results of its

investigation and determination to the consumer pursuant to the

requirements in Sections 908 and 909 of EFTA, 15 U.S.C. §§ 1693f and

1693g, and Section 1005.11 of Regulation E.

12. From January 2020 until late-September 2020, upon receiving a notice of

error from an unemployment insurance benefit prepaid debit cardholder

concerning alleged unauthorized EFTs, Respondent would conduct an

investigation that could include, among other steps: comparing the location

of the transaction with the consumer’s residence or habitual transactions;

accessing ATM camera footage (if the alleged unauthorized activity

occurred at a Respondent ATM); and contacting the cardholder for further

information.

13. Following a surge in notices of error filed by unemployment insurance

benefit prepaid debit cardholders nationwide throughout the summer of

2020, Respondent changed its practices for investigating unemployment

insurance benefit prepaid debit cardholder notices of error.

14. Under its new strategy, which Respondent implemented on September 28,

2020 for all of its state unemployment insurance benefit prepaid programs,

Respondent only ran cardholders’ notices of error concerning alleged

unauthorized EFTs through its newly developed automated Fraud Filter, and
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for notices of error that met any indicator used by the Fraud Filter ceased

taking the steps described in Paragraph 12, above, as part of its investigation.

15. Beginning on September 28, 2020, for notices of error submitted by

unemployment insurance benefit prepaid debit cardholders concerning

alleged unauthorized EFTs that met any of the three indicators used by

Respondent’s new Fraud Filter, Respondent automatically determined that

no error had occurred.

16. Between September 28, 2020 and June 8, 2021, for notices of error

submitted by unemployment insurance benefit prepaid debit cardholders

concerning alleged unauthorized EFTs that met any of the three indicators

used by Respondent’s Fraud Filter, along with determining no error had

occurred, Respondent froze or, after March 17, 2021, blocked the

consumer’s prepaid debit card account.

17. The only exception was from October 4, 2020 through December 2, 2020,

when unemployment insurance benefit prepaid debit card accounts flagged

by Respondent’s new Fraud Filter were not frozen as Respondent had

intended. After Respondent discovered the issue, it froze those flagged

unemployment insurance benefit prepaid debit card accounts on or about

December 17, 2020, excluding accounts where a reconsideration request
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from a consumer was pending or where Respondent had reversed its initial

determination that no error had occurred.

18. A consumer whose unemployment insurance benefit prepaid debit card

account is frozen cannot access the government benefits in their account.

19. Respondent also will not accept new benefits payments for deposit into a

frozen unemployment insurance benefit prepaid debit card account.

20. When Respondent blocks an unemployment insurance benefit prepaid debit

card, no transactions are permitted. But unlike an account freeze,

Respondent permits cardholders with blocks on their unemployment

insurance benefit prepaid debit card to verify their identity directly with

Respondent. Upon verification, Respondent releases the block, and the

unemployment insurance benefit prepaid debit card becomes usable again.

21. Before implementing the Fraud Filter on September 28, 2020, Respondent

knew, or should have known, that the Fraud Filter would, in certain cases,

incorrectly determine that no error had occurred.

22. Likewise, before implementing the Fraud Filter, Respondent knew, or

should have known, that not all unemployment insurance benefit prepaid

accounts meeting its Fraud Filter indicators would be fraudulent and

therefore should be frozen. Indeed, in an internal September 2020

presentation, Respondent acknowledged, “Fraudulent determinations would
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require a detailed review of specific accounts, which given the volume, is

unmanageable.”

23. For notices of error meeting any of its Fraud Filter indicators, Respondent

continued with its nationwide strategy of automatically determining no error

occurred and freezing the cardholder’s unemployment insurance benefit

prepaid debit card account based solely on the Fraud Filter from September

28, 2020 to March 17, 2021.

24. Consumers whose unemployment insurance benefit prepaid debit card

accounts Respondent froze through its Fraud Filter went weeks, and in some

cases months, without access to their unemployment insurance benefits.

25. Some consumers whose prepaid debit card accounts Respondent froze

incurred late fees and interest charges on their other accounts, and also

missed phone and utility bill payments. Some consumers with frozen prepaid

debit card accounts also faced other financial impacts, including foreclosure,

eviction, and car repossession.

26. Beginning on March 18, 2021, for notices of error for which it determined

no error had occurred based solely on the results of its Fraud Filter,

Respondent blocked the cardholder’s unemployment insurance benefit

prepaid debit card, rather than freezing the cardholder’s account.
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27. For notices of error submitted by over 100,000 unemployment insurance

benefit prepaid debit cardholders concerning alleged unauthorized EFTs that

met one or more of the Fraud Filter indicators, Respondent continued to rely

solely on the results of its Fraud Filter to determine no error had occurred

until June 8, 2021.

Respondent’s Strategy as Applied to EDD Cardholders

28. Eligible California consumers may receive their EDD unemployment

insurance benefit payments through a check mailed by EDD or through EDD

Prepaid Debit Cards and EDD Prepaid Debit Card Accounts.

29. During the Relevant Period, most eligible California consumers received

their EDD unemployment insurance benefit payments through EDD Prepaid

Debit Cards and Accounts.

30. From September 28, 2020 to March 17, 2021, for EDD Cardholders whose

notices of error Respondent determined no error occurred through its Fraud

Filter, Respondent sent denial notices reflecting Respondent’s determination

that the EDD Cardholder’s Account or notice of error had been the subject

of fraudulent or suspicious activity. Respondent’s denial notices failed to

mention that Respondent had also frozen the consumer’s EDD Prepaid Debit

Card Account.
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31. Beginning in December 2020 and continuing to March 17, 2021,

Respondent sent an additional letter notifying affected EDD Cardholders of

their account freeze several days after the EDD Prepaid Debit Card Account

freeze had gone into effect. In some cases, Respondent failed to notify

affected EDD Cardholders that their EDD Prepaid Debit Card Accounts had

been frozen at all.

32. EDD Cardholders seeking to file a notice of error with Respondent to seek

liability protection spent hours a day on the phone attempting to notify

Respondent that their EDD Prepaid Debit Card Account had been subject to

unauthorized EFTs.

33. EDD Cardholders whose EDD Prepaid Debit Card Accounts Respondent

froze based solely on its Fraud Filter spent hours a day on the phone with

Respondent attempting to seek information regarding how to regain access

to their frozen Account. Along with long hold times, Cardholders with EDD

Prepaid Debit Card Accounts frozen as a result of the Fraud Filter were

subject to disconnections, transfers, and inaccurate information from

Respondent and its vendor agents, including that their Accounts had been

frozen at the direction of EDD rather than by Respondent.

34. From September 28, 2020 to March 17, 2021, Respondent generally required

EDD Cardholders with frozen EDD Prepaid Debit Card Accounts to reverify
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their identity through EDD (rather than with Respondent) to regain access to

their Account.

35. Respondent knew, or should have known, that EDD would not be able to

handle the burden of quickly reverifying eligible EDD Cardholders whose

EDD Prepaid Debit Card Accounts Respondent had frozen through its new

strategy beginning on September 28, 2020.

36. During the summer of 2020, Respondent met with EDD dozens of times,

often weekly, and was in telephone or email contact even more often.

37. In July 2020, EDD had approximately 1,400 staff to handle an average of

6.7 million consumer calls per week. In August 2020, EDD was answering

and resolving only 1% of incoming calls.

38. Respondent did not inform EDD that it would be using a Fraud Filter and

freezing unemployment insurance benefit prepaid debit card accounts before

implementing that strategy on September 28, 2020.

39. Until March 18, 2021, the only exception to Respondent’s requirement that

EDD Cardholders reverify their identity through EDD to regain access to

their frozen EDD Prepaid Debit Card Account was limited to Cardholders

who filed a complaint asserting a particular hardship with Respondent

through a state or congressional representative, a legal aid group or private

attorney, or the media that reached the attention of Respondent’s executives.
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Findings and Conclusions as to Respondent’s Strategy in California (Unfair
Practice)

40. Sections 1031 and 1036 of the CFPA prohibit a “covered person” from

engaging in any “unfair, deceptive, or abusive act or practice” in connection

with any transaction with a consumer for a consumer financial product or

service, or the offering of a consumer financial product or service. 12 U.S.C.

§§ 5531(a), 5536(a)(1)(B).

41. An act or practice is unfair if it causes or is likely to cause substantial injury

to consumers, which is not reasonably avoidable by consumers, and such

substantial injury is not outweighed by countervailing benefits to consumers

or to competition. 12 U.S.C. § 5531(c).

42. From September 28, 2020 to March 17, 2021, Respondent automatically

determined, without any further investigation, that no error had occurred for

any EDD Cardholder notice of error concerning alleged unauthorized EFTs

that met any of the three indicators in Respondent’s Fraud Filter. During

most of this period, when Respondent determined no error had occurred

through its Fraud Filter, Respondent also froze the cardholder’s EDD

Prepaid Debit Card Account.

43. This caused substantial injury to consumers. Not only did Respondent,

through its Fraud Filter, incorrectly and automatically determine no error

had occurred for tens of thousands of EDD Cardholders who had filed
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notices of error, but Respondent also froze those cardholders’ EDD Prepaid

Debit Card Accounts (except as stated in Paragraph 17), meaning those EDD

Cardholders could not receive or access the unemployment insurance benefit

funds in their Accounts.

44. This substantial injury was not reasonably avoidable by EDD Cardholders.

During this period, Respondent generally required EDD Cardholders whose

Accounts were frozen through its strategy to reverify their identity through

EDD to regain access to their Accounts.

45. EDD Cardholders received conflicting and delayed information from

Respondent regarding the reasons for their EDD Prepaid Debit Card

Account freeze, and the steps they needed to take to unfreeze their Account.

46. This substantial injury was not outweighed by any countervailing benefits to

consumers or to competition.

47. As a result, Respondent engaged in unfair acts or practices, in violation of

Sections 1031 and 1036 of the CFPA. 12 U.S.C. §§ 5531(a) and (c),

5536(a)(1)(B).

Findings and Conclusions as to Respondent’s Retroactive Application of Its
Fraud Filter (Abusive Practice)

48. An act or practice is abusive if it, among other things, takes unreasonable

advantage of the inability of a consumer to protect their interests in selecting

or using a consumer financial product or service. 12 U.S.C. § 5531(d)(2)(B).
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49. In late September 2020 or early October 2020, Respondent also applied its

Fraud Filter to more than 11,000 notices of error concerning alleged

unauthorized EFTs submitted by EDD Cardholders between April 1, 2020

and September 27, 2020 for which Respondent had previously provided the

EDD Cardholder a permanent credit.

50. For those more than 11,000 notices of error, Respondent retroactively

determined that no error had occurred based on the results of its Fraud Filter,

and reversed those EDD Cardholders’ permanent credits.

51. Affected EDD Cardholders were unable to protect their interests because

they could not control how and when Respondent would investigate and

resolve their notices of error.

52. Until at least December 2021, Respondent did not correct its reversals of

these more than 11,000 previously-investigated-and-paid notices of error

without an EDD Cardholder’s request for reconsideration.

53. By reversing the permanent credits for EDD Cardholders who had already

received notice from Respondent that their error claim had been investigated

and paid, Respondent took unreasonable advantage of EDD Cardholders’

inability to protect their interests.
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54. As a result, Respondent engaged in abusive acts or practices, in violation of

Sections 1031 and 1036 of the CFPA. 12 U.S.C. §§ 5531(a) and (d)(2)(B),

5536(a)(1)(B).

Findings and Conclusions as to Respondent’s Failure to Conduct Reasonable
Error Resolution Investigations (EFTA and Regulation E)

55. Under EFTA, upon receiving notices of error, financial institutions may not

determine no error had occurred without conducting a “good faith

investigation of the alleged error” and without “a reasonable basis for

believing that the consumer’s account was not in error.” 15 U.S.C. §

1693f(e).

56. Further, under Regulation E, when conducting an Error Resolution

Investigation, a financial institution must conduct, at minimum, a “review of

its own records regarding [the] alleged error.” 12 C.F.R. § 1005.11(c)(4),

and the Error Resolution Investigation “must be reasonable,” 71 Fed. Reg.

1638, 1654 (Jan. 10, 2006).

57. From September 28, 2020 to June 8, 2021, Respondent used its Fraud Filter

to determine no error had occurred for approximately 188,000 notices of

error submitted by Affected Consumers nationwide concerning alleged

unauthorized EFTs, without any further investigation or considering any

other information relevant to Affected Consumers’ notices.
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58. As a result, Respondent violated the requirement to conduct a reasonable

Error Resolution Investigation under Sections 908 and 909 of EFTA, 15

U.S.C. §§ 1693f and 1693g, and Section 1005.11 of Regulation E.

Findings and Conclusions as to Respondent Impeding EDD Cardholders from
Filing Notices of Error and Seeking Liability Protection from Unauthorized
EFTs (Unfair Practices)

59. Throughout the Relevant Period, Respondent and EDD both directed EDD

Cardholders to contact Respondent to file a telephonic notice of error.

60. Throughout the Relevant Period, EDD Cardholders could not file notices of

error with Respondent online, through Respondent’s other (non-prepaid)

customer service divisions, or in person at Respondent’s branches.

61. EDD Cardholders who called for assistance after their EDD Prepaid Debit

Card Account was subject to unauthorized EFTs were required to navigate

Respondent’s prepaid call center divisions staffed by vendor agents.

62. Throughout the Relevant Period, Respondent represented on its EDD Debit

Card FAQ webpage that it would provide EDD Cardholders with “dedicated

customer service representatives” who are “available 24 hours a day, 7 days

a week” to help EDD Cardholders “investigate transactions.”

63. Respondent further advised consumers in its EDD Cardholder Agreement,

which Respondent mailed to all new EDD Cardholders, that “Telephoning is

the best way of keeping your possible losses down.”
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64. Under Respondent’s “Zero Liability” guarantee, which Respondent also

includes in its EDD Cardholder Agreement, Respondent represents that

EDD Cardholders will incur no liability for unauthorized use of their EDD

Prepaid Debit Card up to the amount of the unauthorized transactions,

provided they notify Respondent within a reasonable amount of time.

65. For much of 2020, EDD Cardholders faced long hold times when attempting

to file a notice of error with Respondent over the phone and take advantage

of Respondent’s “Zero Liability” guarantee for unauthorized use of

cardholders’ EDD Prepaid Debit Cards.

66. Throughout the Relevant Period, EDD Cardholders were required to first

speak with an agent in Respondent’s main prepaid call center before being

transferred to Respondent’s prepaid claims initiation division, which was the

only division authorized to accept EDD Cardholders’ notices of error over

the phone.

67. From May 1, 2020 to July 1, 2020, prepaid debit cardholders nationwide had

to wait on average nearly two hours to speak with an agent in Respondent’s

prepaid claims initiation division.

68. From September 1 to December 1, 2020, prepaid debit cardholders

nationwide had to wait on average over an hour to speak with an agent in

Respondent’s prepaid claims initiation division.
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69. Unlike Respondent’s main prepaid call center, throughout the Relevant

Period Respondent’s prepaid claims initiation division was not available 24

hours a day, 7 days a week, but instead kept the following business hours:

Monday to Friday, 5am PT to 7pm PT; Saturday, 6:30am PT to 5pm PT; and

closed on Sundays.

70. Through September 2020, Respondent’s prepaid claims initiation division

was still staffed by fewer than 300 vendor agents to assist unemployment

insurance benefit prepaid debit cardholders nationwide with filing their

notices of error.

71. Throughout 2020, certain EDD Cardholders remained on hold with

Respondent’s prepaid call center divisions for hours daily, over the course of

weeks, in attempts to file notices of error.

72. EDD Cardholders were also subject to transfers, dropped calls, and

misinformation from Respondent’s prepaid call center agents, all of which

further impeded their ability to successfully file notices of error with

Respondent.

73. EDD Cardholders could not reasonably avoid the harm caused by extensive

hold times, dropped calls, and misinformation from Respondent’s prepaid

call center agents because, among other reasons, Respondent directed EDD

Cardholders to file notices of error by contacting Respondent by phone.
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74. This substantial injury to EDD Cardholders was not outweighed by any

countervailing benefits to consumers or to competition.

75. As a result, Respondent engaged in unfair acts or practices, in violation of

Sections 1031 and 1036 of the CFPA. 12 U.S.C. §§ 5531(a) and (c),

5536(a)(1)(B).

Findings and Conclusions as to Respondent’s Failure to Timely Investigate
EDD Cardholders’ Notices of Error Concerning Alleged Unauthorized EFTs
(EFTA and Regulation E)

76. For timely-submitted consumer notices of error, EFTA requires financial

institutions to “investigate the alleged error, determine whether an error has

occurred, and report or mail the results of such investigation and

determination to the consumer within ten business days.” 15 U.S.C. §

1693f(a).

77. A financial institution may extend that 10-business-day investigation

deadline to 45 calendar days if it provisionally credits the consumer’s

account in the amount of the alleged error within 10 business days of

receiving the error notice. 15 U.S.C. § 1693f(c); 12 C.F.R. § 1005.11(c)(2).

78. This 45-day investigation deadline may be extended to 90 calendar days if a

notice of error involves an EFT that was not initiated within a state; resulted

from a point-of-sale debit card transaction; or occurred within 30 days of the

first deposit to the account. 12 C.F.R. § 1005.11(c)(3)(ii).
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79. This extended 90-day investigation deadline does not apply to transactions at

an ATM, including ATMs located at merchant locations. Official

Interpretation Comment 11(c)(3)-1, 12 C.F.R. Pt. 1005, Supp. I.

80. In certain instances, for notices of error concerning alleged unauthorized

EFTs submitted by EDD Cardholders during the Relevant Period,

Respondent failed to complete its investigation within 10 business days and

Respondent did not issue a provisional credit (or issued a provisional credit

after 10 business days).

81. In certain instances, for notices of error concerning alleged unauthorized

EFTs relating to ATM transactions submitted by EDD Cardholders during

the Relevant Period, Respondent failed to complete its investigation within

45 calendar days.

82. In certain instances, for notices of error concerning alleged unauthorized

EFTs submitted by EDD Cardholders during the Relevant Period,

Respondent failed to complete its investigation within 90 calendar days.

83. As a result, Respondent violated EFTA and Regulation E by failing to timely

investigate EDD Cardholders’ notices of error concerning alleged

unauthorized EFTs. 15 U.S.C. § 1693f(a), (c); 12 C.F.R. § 1005.11(c)(2)-(3).

CONDUCT PROVISIONS

V.
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IT IS ORDERED, under Sections 1053 and 1055 of the CFPA, that:

84. Respondent and its officers, agents, servants, employees, and attorneys

who have actual notice of this Consent Order, whether acting directly or

indirectly, may not violate Sections 1031 and 1036 of the CFPA, 12

U.S.C. §§ 5531 and 5536, Sections 908 and 909 of EFTA, 15 U.S.C. §§

1693f and 1693g, and Section 1005.11 of Regulation E, in connection with

administering unemployment insurance benefit prepaid debit cards and

accounts, including in connection with receiving, investigating, and

resolving notices of error submitted by unemployment insurance benefit

prepaid debit cardholders concerning alleged unauthorized EFTs.

85. Respondent and its officers, agents, servants, employees, and attorneys

who have actual notice of this Consent Order, whether acting directly or

indirectly, in connection with administering unemployment insurance

benefit prepaid debit cards and accounts, must take the following

affirmative actions:

a. Respondent must not determine no error occurred solely based on the

results of an automated fraud filter for notices of error submitted by

unemployment insurance benefit prepaid debit cardholders;
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b. Respondent must not freeze an unemployment insurance benefit prepaid

debit card account solely based on the results of an automated fraud

filter;

c. Respondent must, during the course of an Error Resolution Investigation,

reasonably consider all information relevant to the unemployment

insurance benefit prepaid debit cardholder’s notice of error, including,

but not limited to, information within Respondent’s own records;

d. Respondent must not condition access to an open EDD Prepaid Debit

Card Account for an existing EDD Cardholder on reverifying their

identity through EDD, and must allow EDD Cardholders to attempt to

verify their identity directly with Respondent, except in the cases where

(i) EDD disqualified the EDD Cardholder or requested that the EDD

Prepaid Debit Card Account be frozen, or (ii) reverification through EDD

is requested by EDD or is required by law;

e. Respondent must allow EDD Cardholders to attempt to reverify their

identity in order to unblock their EDD Prepaid Debit Card Account in

person at Respondent’s financial center branches. Respondent’s financial

center branches must have processes and procedures in place to facilitate

telephonic submission of notices of error by EDD Cardholders; and
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f. Respondent must conduct a risk assessment of its Prepaid Card

Unemployment Insurance Benefits Program, including an assessment of

risks associated with increased volumes of unemployment insurance

benefit prepaid debit cardholders in the future. This requirement may be

performed as part of the Program Risk Assessment required of

Respondent by Article V of the OCC Consent Order.

86. Respondent must provide the appropriate staffing and resources necessary

to comply with Paragraphs 87–89.

VI.

Compliance Plan

IT IS FURTHER ORDERED that:

87. Within 60 days of the Effective Date, Respondent must submit to the

Regional Director for review and determination of non-objection a

comprehensive compliance plan designed to ensure that Respondent’s

administration of unemployment insurance benefit prepaid debit cards and

accounts complies with all applicable laws that the Bureau enforces,

including Federal consumer financial laws, and the terms of this Consent

Order (Compliance Plan). The Compliance Plan must include, at a

minimum:
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a. detailed steps for addressing each action required by this Consent

Order as set forth in Paragraphs 84–85; and

b. specific timeframes and deadlines for implementation of the steps

described above.

88. The Regional Director will have the discretion to make a determination of

non-objection to the Compliance Plan or direct Respondent to revise it. If

the Regional Director directs Respondent to revise the Compliance Plan,

Respondent must revise and resubmit the Compliance Plan to the Regional

Director within 30 days.

89. After receiving notification that the Regional Director has made a

determination of non-objection to the Compliance Plan, Respondent must

implement and adhere to the steps, recommendations, deadlines, and

timeframes outlined in the Compliance Plan.

VII.

Role of the Board

IT IS FURTHER ORDERED that:

90. The Board, or a committee thereof, must review all submissions (including

plans, reports, programs, policies, and procedures) required by this

Consent Order prior to submission to the Bureau.
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91. Although this Consent Order requires Respondent to submit certain

documents for review or non-objection by the Regional Director or

Enforcement Director, the Board, or a committee thereof, will have the

ultimate responsibility for proper and sound management of Respondent

and for ensuring that Respondent complies with the laws that the Bureau

enforces, including Federal consumer financial laws and this Consent

Order.

92. In each instance that this Consent Order requires the Board to ensure

adherence to, or perform certain obligations of Respondent, the Board, or a

committee thereof, must:

a. Authorize whatever actions are necessary for Respondent to fully comply

with the Consent Order;

b. Require timely reporting by management to the Board on the status of

compliance obligations; and

c. Require timely and appropriate corrective action to remedy any material

non-compliance with Board directives related to this Section.

MONETARY PROVISIONS

VIII.

Order to Pay Redress

IT IS FURTHER ORDERED that:
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93. Respondent shall provide redress to Affected Consumers, which shall

include (i) compensation for the value of unauthorized EFTs alleged by

Affected Consumers in notices of error that Respondent incorrectly denied

through its Fraud Filter; (ii) compensation to Affected Consumers for

related Consequential Harm, as required by this Section; and (iii)

compensation to Affected Consumers through an individualized review

process, as required by this Section. Respondent will not be required to

pay redress to consumers meeting the definition of Affected Consumers as

of the Effective Date for whom (i) the state benefit granting agency has

determined or later determines should have been initially disqualified for

unemployment insurance benefit payments, or (ii) whose unemployment

insurance benefit prepaid debit card account is or becomes frozen,

blocked, or closed by Respondent at the request of the state benefit

granting agency, or due to suspected fraud, anti-money laundering, or

financial crimes inquiries or determinations made in conjunction with law

enforcement, or due to an independent legal requirement such as receipt of

legal process or orders.

94. Within 90 days of the Effective Date, Respondent must submit to the

Enforcement Director for review and non-objection a comprehensive

written plan for providing redress consistent with this Consent Order
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(Redress Plan). The Enforcement Director will have the discretion to make

a determination of non-objection to the Redress Plan or direct Respondent

to revise it. If the Enforcement Director directs Respondent to revise the

Redress Plan, Respondent must revise and resubmit the Redress Plan to the

Enforcement Director within 30 days. After receiving notification that the

Enforcement Director has made a determination of non-objection to the

Redress Plan, Respondent must implement and adhere to the steps,

recommendations, deadlines, and timeframes outlined in the Redress Plan.

95. The Redress Plan must include:

a. A description of the methodology Respondent will use to identify

Affected Consumers, including Affected Consumers who no longer have

active unemployment insurance benefit prepaid debit card accounts with

Respondent;

b. A description of the procedures and process Respondent will use to

remediate each Affected Consumer, which shall include: (i) calculating

the value of unauthorized EFTs alleged by Affected Consumers in

notices of error that Respondent incorrectly denied through its Fraud

Filter; (ii) calculating the lump sum Consequential Harm payment; and

(iii) an individualized review process administrated by an independent

third-party payment administrator that allows Affected Consumers to
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seek additional redress compensation by submitting evidence of financial

harm exceeding Consequential Harm-related payments;

c. A description of the methodology Respondent will use to calculate the

amount of remediation to be paid as Consequential Harm for each

Affected Consumer;

d. A description of the methodology Respondent will use to identify

compensable financial impacts to Affected Consumers for the purpose of

additional redress compensation exceeding Consequential Harm-related

payments in connection with the individualized review process;

e. A description of the type of supporting documentation that will be

required for Affected Consumers seeking additional financial redress

compensation exceeding Consequential Harm-related payments in

connection with the individualized review process;

f. A description of the procedures for issuing and tracking redress payments

to Affected Consumers;

g. A description of the plan for developing communications that will be sent

to notify Affected Consumers of their redress under the Redress Plan

(Redress Notification). The Redress Notification must include a

statement that the redress is being paid in accordance with terms of this

Consent Order;
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h. A description of the processes for handling any redress funds for

Affected Consumers that remain unclaimed; and

i. The procedures, deadlines, and timeframes for completing each step of

the Redress Plan, consistent with the terms of this Consent Order.

96. Following the implementation of the Redress Plan, Respondent must

submit a report that:

a. Identifies each Affected Consumer evaluated as part of the Redress Plan;

b. States the amount of redress Respondent provided to each Affected

Consumer for (i) notices of error that Respondent incorrectly denied; (ii)

Consequential Harm; and (iii) pursuant to the individualized review

process (if applicable);

97. Respondent must make reasonable attempts to obtain a current physical

address for any Affected Consumer (i) before sending any redress payment

required under this Section VIII and (ii) for a period of 360 days from the

date the redress was initially sent to the Affected Consumer upon receipt

of returned mail or failure to negotiate a check that is issued to the

consumer.

98. Respondent may not condition the payment of any redress to any Affected

Consumer under this Consent Order on that Affected Consumer waiving

any right.
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IX.

Order to Pay Civil Money Penalty

IT IS FURTHER ORDERED that:

99. Under § 1055(c) of the CFPA, 12 U.S.C. § 5565(c), by reason of the

violations of law described in Section IV of this Consent Order,

Respondent must pay a civil money penalty of $100 million to the Bureau.

100. Within 10 business days of the Effective Date, Respondent must pay the

civil money penalty by wire transfer to the Bureau or to the Bureau’s agent

in compliance with the Bureau’s wiring instructions.

101. The civil money penalty paid under this Consent Order will be deposited

in the Civil Penalty Fund of the Bureau as required by § 1017(d) of the

CFPA, 12 U.S.C. § 5497(d).

102. Respondent, for all purposes, must treat the civil money penalty paid under

this Consent Order as a penalty paid to the government. Regardless of how

the Bureau ultimately uses those funds, Respondent may not:

a. Claim, assert, or apply for a tax deduction, tax credit, or any other tax

benefit for any civil money penalty paid under this Consent Order; or

b. Seek or accept, directly or indirectly, reimbursement or indemnification

from any source, including but not limited to payment made under any
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insurance policy, with regard to any civil money penalty paid under this

Consent Order.

103. To preserve the deterrent effect of the civil money penalty in any Related

Consumer Action, Respondent may not argue that Respondent is entitled

to, nor may Respondent benefit by, any offset or reduction of any

compensatory monetary remedies imposed in the Related Consumer

Action because of the civil money penalty paid in this action or because of

any payment that the Bureau makes from the Civil Penalty Fund. If the

court in any Related Consumer Action offsets or otherwise reduces the

amount of compensatory monetary remedies imposed against Respondent

based on the civil money penalty paid in this action or based on any

payment that the Bureau makes from the Civil Penalty Fund, Respondent

must, within 30 days after entry of a final order granting such offset or

reduction, notify the Bureau, and pay the amount of the offset or reduction

to the U.S. Treasury. Such a payment will not be considered an additional

civil money penalty and will not change the amount of the civil money

penalty imposed in this action.

Additional Monetary Provisions

IT IS FURTHER ORDERED that:
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104. In the event of any default on Respondent’s obligations to make payment

under this Consent Order, interest—computed under 28 U.S.C. § 1961, as

amended—will accrue on any outstanding amounts not paid from the date

of default to the date of payment, and will immediately become due and

payable.

105. Respondent must relinquish all dominion, control, and title to the funds

paid to the fullest extent permitted by law and no part of the funds may be

returned to Respondent.

106. Under 31 U.S.C. § 7701, Respondent, unless it already has done so, must

furnish to the Bureau its taxpayer-identification numbers, which may be

used for purposes of collecting and reporting on any delinquent amount

arising out of this Consent Order.

107. Within 30 days of the entry of a final judgment, consent order, or

settlement in a Related Consumer Action, Respondent must notify the

Enforcement Director of the final judgment, consent order, or settlement in

writing. That notification must indicate the amount of redress, if any, that

Respondent paid or is required to pay to consumers and describe the

consumers or classes of consumers to whom that redress has been or will

be paid.

COMPLIANCE PROVISIONS
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XI.

Reporting Requirements

IT IS FURTHER ORDERED that:

108. Respondent must notify the Bureau of any development that may affect

compliance obligations arising under this Consent Order, including but not

limited to a dissolution, assignment, sale, merger, or other action that

would result in the emergence of a successor company; the creation or

dissolution of a subsidiary, parent, or affiliate that engages in any acts or

practices subject to this Consent Order; the filing of any bankruptcy or

insolvency proceeding by or against Respondent; or a change in

Respondent’s name or address. Respondent must provide this notice, if

practicable, at least 30 days before the development, but in any case no

later than 14 days after the development.

109. Within 7 days of the Effective Date, Respondent must designate at least

one telephone number and email, physical, and postal addresses as points

of contact that the Bureau may use to communicate with Respondent.

110. Respondent must report any change in the information required to be

submitted under Paragraph 109 at least 30 days before the change or as

soon as practicable after the learning about the change, whichever is

sooner.
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111. Within 90 days of the Effective Date, and again one year after the

Effective Date, Respondent must submit to the Regional Director an

accurate written compliance progress report (Compliance Report) that has

been approved by the Board or a committee thereof, sworn to under

penalty of perjury, which, at a minimum:

a. Lists each applicable paragraph and subparagraph of the Order and

describes in detail the manner and form in which Respondent has

complied with each such paragraph and subparagraph of the Consent

Order;

b. Describes in detail the manner and form in which Respondent has

complied with the Redress Plan and Compliance Plan; and

c. Attaches a copy of each Order Acknowledgment obtained under Section

XII, unless previously submitted to the Bureau.

XII.

Order Distribution and Acknowledgment

IT IS FURTHER ORDERED that:

112. Within 7 days of the Effective Date, Respondent must submit to the

Enforcement Director an acknowledgment of receipt of this Consent

Order, sworn under penalty of perjury.
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113. Within 30 days of the Effective Date, Respondent must deliver a copy of

this Consent Order to each of its Board members and executive officers, as

well as to any managers, employees, service providers, or other agents and

representatives who have responsibilities related to the subject matter of

the Consent Order.

114. For 5 years from the Effective Date, Respondent must deliver a copy of

this Consent Order to any business entity resulting from any change in

structure referred to in Section XI, any future Board members and

executive officers, as well as to any managers, employees, service

providers, or other agents and representatives who will have

responsibilities related to the subject matter of the Consent Order before

they assume their responsibilities.

115. Respondent must secure a signed and dated statement acknowledging

receipt of a copy of this Consent Order, ensuring that any electronic

signatures comply with the requirements of the E-Sign Act, 15 U.S.C. §

7001 et seq., within 30 days of delivery, from all persons receiving a copy

of this Consent Order under this Section.

116. Within 90 days of the Effective Date, Respondent must provide the Bureau

with a list of all persons and their titles to whom this Consent Order was

delivered through that date under Paragraphs 112–114 and a copy of all
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signed and dated statements acknowledging receipt of this Consent Order

under Paragraph 115.

XIII.

Recordkeeping

IT IS FURTHER ORDERED that:

117. Respondent must create and retain the following business records:

a. All documents and records necessary to demonstrate full compliance with

each provision of this Consent Order, including all submissions to the

Bureau;

b. All documents and records pertaining to the Redress Plan, described in

Section VIII above;

c. All documents and records pertaining to the Compliance Plan, described

in Section VI above;

d. For each individual Affected Consumer:

i. the consumer’s name, address, and, if available to Respondent,

phone number, and email address;

ii. the date(s) the consumer submitted a notice of error concerning

alleged unauthorized EFTs that Respondent wrongly

determined no error occurred based solely on the results of

Respondent’s Fraud Filter;
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iii. the value of alleged unauthorized EFTs in the consumer’s

notice(s) of error that Respondent wrongly determined no error

occurred based solely on the results of Respondent’s Fraud

Filter; and

iv. the length of time that Respondent froze or blocked the

consumer’s unemployment insurance benefit prepaid debit card

account due to Respondent’s determination that no error

occurred based solely on the results of Respondent’s Fraud

Filter.

e. All consumer complaints and refund requests (whether received directly

or indirectly, such as through a third party) regarding Respondent’s

administration of unemployment insurance benefit prepaid debit cards

and accounts relating to government benefit payments, and any responses

to those complaints or requests.

f. Records showing, for each Respondent employee or agent providing

material services related to Respondent’s unemployment insurance

benefit prepaid debit card programs, that person’s name, telephone

number, email, physical, and postal address, job title or position, dates of

service, and, if applicable, the reason for termination.

g. Records showing, for each service provider providing services related to
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Respondent’s administration of unemployment insurance benefit prepaid

debit cards and accounts, the name of a point of contact, and that

person’s telephone number, email, physical, and postal address, job title

or position, dates of service, and, if applicable, the reason for termination.

118. Respondent must make the documents identified in Paragraph 117

available to the Bureau upon the Bureau’s request.

XIV.

Notices

IT IS FURTHER ORDERED that:

119. Unless otherwise directed in writing by the Bureau, Respondent must

provide all submissions, requests, communications, or other documents

relating to this Consent Order in writing, with the subject line, “In re Bank

of America, N.A., File No. 2022-CFPB-0004,” and send them by

overnight courier or first-class mail to the below addresses and

contemporaneously by email to Enforcement_Compliance@cfpb.gov and

Southeastregion@cfpb.gov:

Regional Director, Bureau Southeast Region
Peachtree Summit Building
401 W. Peachtree Street
Atlanta, GA 30308

Assistant Director for Enforcement
Consumer Financial Protection Bureau
ATTENTION: Office of Enforcement
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1700 G Street, N.W.
Washington D.C. 20552

XV.

Cooperation with the Bureau

IT IS FURTHER ORDERED that:

120. Respondent must cooperate fully to help the Bureau determine the identity

and location of, and the amount of injury sustained by, each Affected

Consumer. Respondent must provide such information in its or its agents’

possession or control within 14 days of receiving a written request from

the Bureau.

XVI.

Compliance Monitoring

IT IS FURTHER ORDERED that:

121. Within 14 days of receipt of a written request from the Bureau,

Respondent must submit additional Compliance Reports or other requested

information, which must be made under penalty of perjury; provide sworn

testimony; or produce documents.

122. Respondent must permit Bureau representatives to interview any employee

or other person affiliated with Respondent who has agreed to such an
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interview regarding: (a) this matter; (b) anything related to or associated

with the conduct described in Section IV; or (c) compliance with the

Consent Order. The person interviewed may have counsel present.

123. Nothing in this Consent Order will limit the Bureau’s lawful use of civil

investigative demands under 12 C.F.R. § 1080.6 or other compulsory

process.

XVII.

Modifications to Non-Material Requirements

IT IS FURTHER ORDERED that:

124. Respondent may seek a modification to non-material requirements of this

Consent Order (e.g., reasonable extensions of time and changes to

reporting requirements) by submitting a written request to the Enforcement

Director.

125. The Enforcement Director may, in his or her discretion, modify any non-

material requirements of this Consent Order (e.g., reasonable extensions of

time and changes to reporting requirements) if he or she determines good

cause justifies the modification. Any such modification by the

Enforcement Director must be in writing.

ADMINISTRATIVE PROVISIONS

XVIII.
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IT IS FURTHER ORDERED that:

126. The provisions of this Consent Order do not bar, estop, or otherwise

prevent the Bureau from taking any other action against Respondent,

except as described in Paragraph 127 below. Further, for the avoidance of

doubt, the provisions of this Consent Order do not bar, estop, or otherwise

prevent any other person or governmental agency from taking any action

against Respondent.

127. The Bureau releases and discharges Respondent from all potential liability

for law violations that the Bureau has or might have asserted based on the

practices described in Section IV of this Consent Order, to the extent such

practices occurred before the Effective Date and the Bureau knows about

them as of the Effective Date. The Bureau may use the practices described

in this Consent Order in future enforcement actions against Respondent

and its affiliates, including, without limitation, to establish a pattern or

practice of violations or the continuation of a pattern or practice of

violations or to calculate the amount of any penalty. This release does not

preclude or affect any right of the Bureau to determine and ensure

compliance with the Consent Order, or to seek penalties for any violations

of the Consent Order.
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128. This Consent Order is intended to be, and will be construed as, a final

Consent Order issued under § 1053 of the CFPA, 12 U.S.C. § 5563, and

expressly does not form, and may not be construed to form, a contract

binding the Bureau or the United States.

129. This Consent Order will terminate on the later of 5 years from the

Effective Date or 5 years from the most recent date that the Bureau

initiates an action alleging any violation of the Consent Order by

Respondent, if such action is initiated within 5 years of the Effective Date.

If such action is dismissed or the relevant adjudicative body rules that

Respondent did not violate any provision of the Consent Order, and the

dismissal or ruling is either not appealed or upheld on appeal, then the

Consent Order will terminate as though the action had never been filed.

The Consent Order will remain effective and enforceable until such time,

except to the extent that any provisions of this Consent Order have been

amended, suspended, waived, or terminated in writing by the Bureau or its

designated agent.

130. Calculation of time limitations will run from the Effective Date and be

based on calendar days, unless otherwise noted.

131. Should Respondent seek to transfer or assign all or part of its operations

that are subject to this Consent Order, Respondent must, as a condition of
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sale, obtain the written agreement of the transferee or assignee to comply

with all applicable provisions of this Consent Order.

132. The provisions of this Consent Order will be enforceable by the Bureau.

For any violation of this Consent Order, the Bureau may impose the

maximum amount of civil money penalties allowed under Section 1055(c)

of the CFPA, 12 U.S.C. § 5565(c). In connection with any attempt by the

Bureau to enforce this Consent Order in federal district court, the Bureau

may serve Respondent wherever Respondent may be found and

Respondent may not contest that court’s personal jurisdiction over

Respondent.

133. This Consent Order and the accompanying Stipulation contain the

complete agreement between the parties. The parties have made no

promises, representations, or warranties other than what is contained in

this Consent Order and the accompanying Stipulation. This Consent Order

and the accompanying Stipulation supersede any prior oral or written

communications, discussions, or understandings.

134. Nothing in this Consent Order or the accompanying Stipulation may be

construed as allowing Respondent, its Board, officers, or employees to

violate any law, rule, or regulation.
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IT IS SO ORDERED, this 14th day of July, 2022.

t
____________________________
f
Rohit Chopra
Director
Consumer Financial Protection Bureau

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2022-CFPB-0004-Bank of America N.A. - Consent Order

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