Full text
Full text shows the first 300 of 326 pages; the complete document is the PDF above.
KAREN ELIZABETH CHRISTIAN
+1 202.887.4265/fax: +1 202.887.4288
kchristian@akingump.com
June 11, 2021
VIA E-MAIL
The Honorable James E. Clyburn
Chairman
Select Subcommittee on the Coronavirus Crisis
U.S. House of Representatives
2157 Rayburn House Office Building
Washington, D.C. 20515
Dear Chairman Clyburn,
On behalf of BlueVine Inc., (“BlueVine,” or “the Company”), we write in response to
your letter dated May 27, 2021 (“the Letter”), in which you requested certain documents and
information. BlueVine appreciates the importance of the Select Subcommittee on the
Coronavirus Crisis’ (“the Subcommittee”) inquiry into waste, fraud, and abuse in the Paycheck
Protection Program (“PPP”) and, as discussed with your staff, is committed to assisting the
Subcommittee in its inquiry.
As part of its commitment to empowering small businesses by facilitating access to
financing and providing innovative and customized banking solutions, BlueVine assisted in
providing emergency Paycheck Protection Program (“PPP”) funds to qualified small businesses
that were devastated by the pandemic. We have provided herein certain information as an initial
response to the Subcommittee’s requests as we continue to gather additional requested
information and material. As discussed with your staff, we will supplement this response with
additional responsive material on a rolling basis.
BlueVine
BlueVine is a private financial technology company founded in 2013 and headquartered
in Redwood City, California. Since its inception, BlueVine has been dedicated to serving the
financial needs of small businesses by providing them with critical financial services through its
banking and lending partners.
Banking services and financing offered by traditional financial institutions often are not
available to, or do not meet the needs of, small businesses and their owners. Many small
Robert S. Strauss Tower | 2001 K Street, N.W. | Washington, DC 20006-1037 | 202.887.4000 | fax 202.887.4288 | akingump.com
June 11, 2021
Page 2
businesses are simply underserved by traditional financial institutions in terms of general
accessibility. Additionally, many products offered by traditional financial institutions do not
meet the needs of many small businesses because of minimum balance requirements, transaction
and overdraft fees, and the inability to fully transact remotely.
BlueVine’s “all-in-one” digital platform is tailored to help small businesses address their
banking, lending, and payment needs through products such as business checking accounts, lines
of credit, and invoice financing. To suit small business’ needs and challenges, BlueVine’s
business checking account has no monthly fees or minimum balance requirements and offers
unlimited transactions. BlueVine’s lending products provide small businesses with access to
capital for their ongoing business needs and growth. More information about BlueVine’s various
products for small businesses can be found here: https://www.bluevine.com.
Since its founding, BlueVine is proud to have assisted tens of thousands of small
businesses and their owners with financing and banking products to help them achieve their cash
management and financial goals.
BlueVine’s Compliance System
It is important to emphasize that although BlueVine is not a bank, the Company does not
operate in a regulatory void and maintains a robust compliance management system, which
includes comprehensive regulatory and risk processes and procedures. BlueVine’s risk and
compliance teams are staffed by experienced personnel from the banking and financial
technology industries.
As a third-party provider to banks and lenders, and by virtue of those contractual
relationships, BlueVine is obligated to adhere to its partners’ applicable regulatory requirements
and frameworks which are guided by, among other things, Federal Deposit Insurance
Corporation (“FDIC”) guidelines for third-party bank providers and other relevant regulatory
requirements, including but not limited to privacy protections and the Equal Credit Opportunity
Act. This includes comprehensive monitoring, oversight, and audits by its bank partners. In
addition, pursuant to its contractual obligations with its bank partners, BlueVine has
implemented robust compliance policies and procedures related to the Bank Secrecy Act
(“BSA”) and its implementing regulations, including Anti-money Laundering (“AML”), Know
Your Customer (“KYC”) and Know Your Business (“KYB”) requirements, OFAC screening,
and beneficial ownership requirements. This involves, among other things, recognizing and
reporting questionable or suspicious activity to its bank partners and assisting in any fraud
investigations the banks may initiate. Ultimately, however, under the BSA, fraud reporting,
June 11, 2021
Page 3
including the ultimate determination as to whether to file a Suspicious Activity Report (“SAR”),
rests solely with the bank. It also is important to underscore that BlueVine’s bank partners
regularly review and approve BlueVine’s compliance and risk policies and procedures, and can
direct BlueVine to make changes in these policies, including any underwriting policies, both
before engaging BlueVine to provide third-party services and throughout the course of the
business relationship.
BlueVine’s Participation in the Paycheck Protection Program
The bipartisan Paycheck Protection Program, which was created by the Coronavirus Aid,
Relief, and Economic Security Act (“CARES Act”) along with other programs, was intended to
provide relief to small businesses so that they could stay open and keep their employees on
payroll during the COVID-19 pandemic. These PPP loans were fully guaranteed by the Small
Business Administration (“SBA”) for eligible businesses and 100 percent of the loan could be
forgiven if the loan proceeds were used for eligible business expenses, such as payroll,
continuation of employee health benefits, rent, and utilities. Because of these features, the
program generated intense interest among all kinds of businesses, but specifically from the
owners of small businesses and sole proprietorships that were experiencing severe economic
difficulty during the pandemic.
Initially, as the Subcommittee is aware, the PPP was subject to some criticism for failing
to prioritize assistance to small businesses and underserved communities and for its confusing
requirements. For instance, many small businesses and sole proprietorships without established
traditional banking relationships had difficulty accessing PPP funds in the first round of funding
(“Round One”) as some larger banks elected to first focus on processing PPP applications for
those businesses that were already bank customers. Further, the eligibility requirements
established by the CARES Act and its implementing regulations and guidance were different
from the criteria that borrowers typically are required to meet in a commercial banking/loan
context, in light of the program’s intent to provide eligible businesses with widespread access to
quick relief and also due to the program’s focus on payroll expenses. These significant
deviations from a traditional lending environment, and the fact that guidance from the SBA to
applicants and participating lenders (and third-party providers) was revised and updated
frequently over the course of the PPP rounds, created significant hurdles for all involved in the
PPP program. This all occurred against the backdrop of a global pandemic.
The stated goals of the PPP compelled the government and its industry partners to swiftly
provide access to capital and liquidity to as many small businesses as possible, thereby allowing
their employees to weather the pandemic and the associated economic challenges. As
June 11, 2021
Page 4
BlueVine’s mission and core business prior to the pandemic focused on the needs of small
businesses and sole proprietorships, which are often underserved and do not have access to
traditional banking relationships, the Company worked tirelessly to assist them in navigating the
PPP process. In addition, BlueVine’s online platform allowed for tremendous reach to these
businesses at a time when doing business in person or through typical processes was constrained
by the pandemic.
BlueVine’s Role as a Service Provider in the PPP
For PPP, BlueVine was retained to provide services to two banks, Cross River Bank and
Celtic Bank Corporation (which in turn served as the direct SBA lenders). As a service provider,
BlueVine verified, processed, and supported PPP loan applications on behalf of its bank partners
in both PPP Round One and in the second round (“Round Two”).1 In this role, BlueVine was
responsible for (1) creating, enhancing, and revising an online dashboard through which it
collected applications of small businesses; (2) verifying the identity of the applicants and their
owner or owners, including through AML, KYC, and KYB processes; (3) processing and
reviewing the documents and attestations provided by PPP applicants to determine whether the
applicant had satisfied the PPP’s requirements; (4) providing customer support to applicants via
email, phone, and/or social media; (5) creating various educational materials for PPP applicants
relating to eligibility, rights and obligations, SBA guidance updates, forgiveness, eligibility
periods, and required documentation, among other topics; and (6) assisting with providing
forgiveness services, if applicable. Assuming an applicant met the requirements based on the
materials provided, and that BlueVine’s verification and processes were also satisfied, BlueVine
then forwarded the application by an Application Programming Interface (“API”) to one of its
partner banks.
Once the application left BlueVine and was in the hands of the partner banks, the SBA
lender banks submitted the application to the SBA for a final review and determination. Because
the SBA had visibility into all applications submitted by all PPP participating lenders, the SBA
was able to conduct certain reviews for PPP eligibility or potentially fraudulent activity (such as
duplicative applications through different banks and service providers) that banks and/or service
providers, like BlueVine, could not. Once SBA’s review was complete, SBA issued a number to
the lender and the applicant needed to execute a note with the lender (here, Celtic Bank or Cross
1
Near the beginning of PPP Round Two, BlueVine considered participating as a lender and
funded/originated six PPP loans as a trial to ensure that its processes were prepared. Ultimately, however, BlueVine
acted only as a service provider for both bank lenders, as it had in PPP Round One.
June 11, 2021
Page 5
River Bank) and complete any other lender-requested documentation, all of which took place on
the BlueVine platform. The lender then reviewed the executed notes and other documentation and
distributed the funds to the financial institution designated by the applicant. If SBA rejected the
application, that determination was sent to the participating lender.
BlueVine Technology and Review Processes
Throughout the program, BlueVine used its advanced technology for verification and
processing of applications. In addition, given the complexity of the program, the changing
guidelines, and the significant confusion on the part of PPP applicants, BlueVine personnel also
worked directly on a significant portion of the applications funded by the SBA, via a manual
review of the documents provided by applicants, staff work to verify the identity of the applicant,
customer support and interaction to help applicants navigate the process, or a combination of these
tasks. While this review process is labor intensive, BlueVine and its employees took very seriously
their commitment to compliance and their mission of helping small businesses. It was an all-hands
effort and the Company worked around the clock to support the program and assure access to
capital for eligible businesses. To that end, of the approximate 1.67 million applications that were
submitted to BlueVine as part of the PPP, only approximately 22 percent were ultimately approved
and funded.2 The fact that, after diligent review and processing of these applications, BlueVine
rejected a significant portion of the applications it received reflects BlueVine’s dedication to
compliance.
BlueVine successfully carried out the mission of the PPP to provide relief to small
businesses impacted by the pandemic. Over the course of its participation in the program,
BlueVine was able to help more than 300,000 small businesses receive $8.9 billion in PPP loans,
approximately 75 percent of which were sole proprietorships.
***
Again, BlueVine is committed to assisting the Subcommittee in its investigation and
appreciates the conversation we have had with your staff. We expect to supplement this response
with additional information in a rolling production in the near future.
2
The term “applications” includes all completions of the application flow including, but not limited to,
applications where an applicant did not complete assigned tasks (and were therefore rejected), an applicant elected
not to fund its approved loan, or was otherwise rejected.
June 11, 2021
Page 6
Production of this information is not intended to constitute a waiver of the attorney-client,
attorney work product, or any other applicable rights or privileges in this or any other forum.
BlueVine expressly reserves its rights in this regard. Information and data produced in connection
with this inquiry may also contain material non-public information that should be kept
confidential. Notwithstanding our request that such information be kept confidential, we would
ask that staff provide us with reasonable notice and an opportunity to be heard before the Select
Subcommittee discloses any such information or data to any third parties.
Sincerely,
Karen E. Christian
Raphael A. Prober
Counsel for BlueVine Inc.
KAREN ELIZABETH CHRISTIAN
+1 202.887.4265/fax: +1 202.887.4288
kchristian@akingump.com
August 20, 2021
The Honorable James E. Clyburn
Chairman
Select Subcommittee on the Coronavirus Crisis
U.S. House of Representatives
2157 Rayburn House Office Building
Washington, D.C. 20515
Dear Chairman Clyburn:
On behalf of BlueVine Inc. (“BlueVine” or “the Company”), we write in further response
to your letter dated May 27, 2021 (“the Letter”), in which you requested certain documents and
information. BlueVine previously submitted responses to the Select Subcommittee on the
Coronavirus Crisis (“the Subcommittee”) on June 11 and July 8, 2021, which included detailed
written responses to the Subcommittee’s questions. As BlueVine has stated in those responses,
the Company appreciates the importance of the Subcommittee’s inquiry into waste, fraud, and
abuse in the Paycheck Protection Program (“PPP” or “program”) and, as discussed with your staff,
is committed to assisting the Subcommittee in its inquiry.
Today, BlueVine is providing certain documents to supplement the information it provided
previously to the Subcommittee relating to its processes and procedures for reviewing PPP
applications. These documents include illustrative training materials for its employees as they
prepared to process applications and assist applicants in accessing the PPP; documents
demonstrating the PPP application steps; policies and procedures relating to fraud detection and
prevention and documents showing how they were incorporated into the application process; and
materials relating to tracking certain questionable activity or potential fraud. These materials are
marked BV_SSCC_0000002 through BV_SSCC_0000377 and BV_SSCC_0000379 through
BV_SSCC_0000391. In addition, BlueVine is producing additional information to supplement
the response the Company provided on July 8, 2021, to narrative request 4. That information is
provided at BV_SSCC_0000378.
Robert S. Strauss Tower | 2001 K Street, N.W. | Washington, DC 20006-1037 | 202.887.4000 | fax 202.887.4288 | akingump.com
August 20, 2021
Page 2
***
As the Subcommittee considers the information provided today and in previous
productions, it is important to keep in mind the different roles and related regulatory obligations
of the parties involved in reviewing and/or processing PPP applications. For example, as BlueVine
stated in its first response to the Subcommittee, BlueVine is not a bank and not a financial
institution. It was also not a PPP lender.1
During PPP, BlueVine served as a third-party technology provider to two banks, Celtic
Bank Corporation and Cross River Bank, both of which are FDIC-insured institutions chartered in
Utah and New Jersey, respectively, and were Small Business Administration (“SBA”) lenders.
Celtic Bank’s ongoing relationship with BlueVine preceded the PPP; Celtic is currently the
originator for commercial lines of credit offered by BlueVine to small businesses and has been
doing so since February 2018. Separately, and in addition to that relationship, BlueVine was asked
by Celtic Bank, in both PPP rounds, to process both applications for PPP loans and for PPP loan
forgiveness. During PPP Round Two, BlueVine was Celtic Bank’s exclusive service provider for
those purposes. BlueVine served as a third-party provider to Cross River Bank in both PPP rounds
as well, but it is BlueVine’s understanding that Cross River also had multiple partnerships with
other third-party providers during PPP.
As a third-party provider, the work BlueVine performs for a bank is defined by an
agreement with that institution. In its June 11 response, BlueVine described the types of services
it performed during PPP pursuant to its agreements with Celtic Bank and Cross River Bank. These
services included, among other things, developing all aspects of the online application dashboard,
processing and reviewing documents and information provided by PPP applicants, and providing
customer service support to PPP applicants. In addition to the banks’ review, oversight, and
approval of the foregoing, the banks served as the SBA lenders and, among other things, submitted
various lender forms (e.g., Form 1502, which is required in order to receive lender fees from the
SBA), and, as lenders, are the beneficiaries of the PPP loan guarantees.
By virtue of these third-party contracts with its bank partners, and as explained in the
Company’s June 11 response, BlueVine is obligated to undertake certain efforts aimed at
1
As explained in BlueVine’s June 11 submission, near the beginning of PPP Round Two, BlueVine considered
participating as a lender and funded/originated six PPP loans as a trial to ensure that its processes were prepared.
Ultimately, however, BlueVine acted only as a service provider for both bank lenders, as it had in PPP Round One.
August 20, 2021
Page 3
identifying and rooting out potential fraud, including compliance policies and procedures related
to the Bank Secrecy Act (“BSA”) and its implementing regulations, including Anti-money
Laundering (“AML”), Know Your Customer (“KYC”) and Know Your Business (“KYB”)
requirements, OFAC screening, and beneficial ownership requirements. In its July 8 response,
BlueVine described in detail the types of policies and procedures it has implemented to review and
process PPP applications on behalf of Cross River Bank and Celtic Bank, including those relating
to AML, KYC, KYB and fraud detection and prevention. As part of the five core elements, or
“pillars,” of an effective BSA and AML program as established by the Financial Crimes
Enforcement Network (“FinCEN”), BlueVine’s bank partners should regularly review these
compliance and risk policies and procedures and can direct BlueVine to make changes. Similarly,
BlueVine’s bank partners also run tests and monitor their third party provider’s adherence to these
policies and procedures.
In its May 27 letter, the Subcommittee sought certain information relating to potential fraud
or other financial crime by applicants during the PPP. One of the principal ways that BlueVine
and its bank partners communicated about potential fraud or financial crime activity identified
during the PPP is through the process that may lead to a filing of a Suspicious Activity Report
(“SAR”). As part of its contractual obligations, when BlueVine recognized questionable or
suspicious activity during the PPP, or if BlueVine received an escalation from its bank partners
pertaining to an applicant for which suspicion existed (a “root client”), BlueVine pulled the
relevant information about that client, investigated it, and, if its fraud analysts determined the
activity appeared fraudulent, reported this information to its bank partner using a form the
Company refers to internally as a questionable activity report (“QAR”).2 A QAR is a template
form (pre-approved by the bank partner) that includes a descriptive narrative outlining the
questionable activity identified, the source of the escalation,3 and the results of the account review,
in addition to detailed information about the escalated applicant, and documentation that was
included in its application. In addition, prior to submitting a QAR, BlueVine investigated whether
other applicants that went through the BlueVine funnel had “shared elements” with the root client
and could potentially belong to the same suspicious activity (“clients identified as connected to
root client”). BlueVine’s fraud analysts were then required to review the clients that were identified
as connected to the root client and, to the extent fraudulent activity appeared to be confirmed, those
2
The term QAR is used for submissions to Celtic, while similar submissions to Cross River are referred to as
Incident Reports or IRs. The term QAR is used herein for both bank partners for ease of reference.
3
BlueVine tracks questionable or suspicious activity, whether escalated by a bank partner or flagged
internally, on an individual client basis.
August 20, 2021
Page 4
clients were added to the QAR reported to the bank partner. Once BlueVine submitted a QAR to
its bank partner, the bank partner needed to determine whether the findings described in the QAR
justified a SAR filing or not and proceed accordingly. Fraud reporting, and the decision and
responsibility to file a SAR with FinCEN, rests solely with the bank as a financial institution; for
this reason, BlueVine does not know if or when a SAR has been in fact filed with FinCEN based
on its QAR submission. Instead, its role in the process is supporting its bank partners’ regulatory
obligations by submitting the QARs and assisting in any other fraud investigations its bank
partners may initiate, any follow-up inquiries, and any other escalations from law enforcement.
As an example of this type of report, included in today’s production at BV_SSCC_0000359, and
BV_SSCC_0000362, and BV_SSCC_0000360 are templates of the approved QAR forms for
Celtic Bank and Cross River Bank that BlueVine completes.
In addition to the QAR process described above and the procedures detailed in BlueVine’s
July 8 submission, during the course of the PPP, BlueVine monitored and tracked data relating to
potential fraud, and, through the use of various methods, flagged suspicious activity, including
clients that shared significant elements with the initial “root client” for which suspicious activity
had been recognized. Once flagged in its system, BlueVine included information relating to
flagged customers in its machine learning tools, and not just in the QAR, such that these applicants
would be automatically rejected when applying again or with similar elements for PPP. These
tools were continuously reviewed and adjusted to ensure they were removing as many questionable
applications as quickly as possible while allowing as many eligible and legitimate applications to
proceed to the review and processing steps in the PPP application process.
Consistent with the overview set forth above describing how BlueVine, as a third-party
provider, supports its bank partners, BlueVine communicated often with Celtic and Cross River
over the course of the PPP to discuss the status of the program, including the relevant policies,
procedures, and application processes. At the outset of PPP, as part of due diligence, BlueVine
submitted a manual for its bank partners’ review outlining BlueVine’s KYC, KYB, and fraud
procedures.4 That document is produced today at BV_SSCC_0000105. In addition to these
policies, BlueVine submitted various documents to Celtic and Cross River for review and approval
showing the online application platform it developed for PPP, and each step in the application
process an applicant must complete for a PPP loan. Examples of PowerPoint presentations setting
4
As Celtic Bank served as a bank partner to BlueVine for its commercial lending products prior to PPP, Celtic
already was familiar with, and had approved, BlueVine’s AML and BSA procedures, which it reviewed on an
ongoing basis including periodic testing and monitoring of real examples .
August 20, 2021
Page 5
forth the BlueVine application process, or “flow,” provided to both Celtic and Cross River during
Round One are provided at BV_SSCC_0000138 and BV_SSCC_0000073. When the application
platform was updated, or when processes or procedures changed over the course of the PPP,
BlueVine provided updated versions of the applicable documents to its bank partners. For
example, BlueVine provided a “Program Overview” (BV_SSCC_0000042) between the first and
second PPP rounds; a revised PPP application flow for Round Two (BV_SSCC_0000172 and
BV_SSCC_0000002); and a presentation providing an overview of its fraud mitigation measures
prior to the launch of Round Two (BV_SSCC_0000029).5 Throughout both rounds of the PPP,
Cross River and Celtic respectively held meetings (at times as often as daily) with BlueVine to
monitor BlueVine’s performance and routinely asked BlueVine to provide data and other
information relating to the administration of the program.
In addition, BlueVine provided rigorous and comprehensive training to its employees to
educate them on the PPP and prepare them to assist applicants in completing the application
requirements as they attempted to access relief through the program. This included providing
training documents for employees to reference, offering presentations and holding training
sessions, and offering support from experienced risk officers when staff processing the
applications had questions. As examples of the training provided to BlueVine staff at the outset
of Round One, included in today’s production is a BlueVine PPP training manual
(BV_SSCC_0000363); training related to the CARES Act and the PPP (BV_SSCC_0000217 and
BV_0000241); and “Frequently Asked Questions” to assist customer support personnel in
responding to applicants’ questions (BV_SSCC_0000379). Similar training and associated
materials were provided during Round Two as well, such as presentations to train employees on
the process, examples of which are provided at BV_SSCC_0000329 and BV_SSCC_0000308 and
talking points to assist customer service personnel in responding to applicants’ questions
(BV_SSCC_0000281). With the frequent changes to the PPP and related guidance, such material
and training frequently were updated as well. Given that the AML and BSA procedures and
processes that BlueVine implemented during PPP were based on the procedures and processes it
had developed previously for its commercial business, BlueVine staff/employees had received
training relating to these functions at least on an annual basis. In addition, every new employee is
required to go through such training within the first 30 days of their employment with BlueVine.
While there is not a legal requirement to offer such training, as BlueVine is not a financial
5
All of the documents referenced in this paragraph are business confidential to BlueVine, as they reveal systems,
processes, policies, and procedures that are proprietary to the Company and, if disclosed, would cause significant
competitive harm to BlueVine. These documents have therefore been labeled accordingly.
August 20, 2021
Page 6
institution, BlueVine nonetheless requires its employees to complete AML/BSA training pursuant
to its pre-PPP contractual relationship with Celtic Bank. Celtic has been reviewing the courses
that BlueVine’s employees are obligated to attend and pass annually, including the training
platform, and monitors compliance with those training requirements.
In that regard, and as BlueVine explained in its July 8 response to the Subcommittee,
preventing and detecting fraud is an enterprise-wide commitment for BlueVine, and numerous
different types of employees (whether they are engineers, customer service support, compliance
personnel, risk, fraud, or legal and compliance team members) play a part. In order to assist the
Subcommittee in understanding the scope of BlueVine’s fraud detection efforts and the personnel
focused on these efforts, we are producing today at BV_SSCC_0000378 a chart showing BlueVine
staff whose work responsibilities were focused on AML and BSA duties both before and during
the PPP.
Once the PPP began, and due to the overwhelming needs of small business owners in
obtaining pandemic relief, BlueVine reassigned certain staff members from their regular work
responsibilities to jobs that included duties related to AML, BSA, and fraud detection in order to
assist in processing PPP applications. BlueVine tracked those reassignments for human resource
and accounting purposes. When BlueVine began tracking the reassignment of employees to PPP-
related work during Round One, BlueVine tracked the employee’s work by specific tasks. In
Round One, as it relates to AML, BSA, and fraud detection, BlueVine tracked on a weekly basis
the number of employees whose work related to three categories: “SBA Review,” meaning the
work performed prior to determining whether an applicant would receive a loan offer, including
KYB, KYC, AML, and identity verification; “SBA Verification,” which captured duties related to
loan amount calculation and the review of documents submitted as part of the application; and
“SBA Escalation,” which counted those BlueVine managers whose work involved helping
BlueVine agents make determinations on the data and documents provided by applicants. In 2021,
the way in which BlueVine tracked the allocation or re-assignment of its staff changed, as the
Company no longer separately tracked those employees who were performing “SBA Verification”
tasks, but instead included that number under “SBA Review,” as these employees received the
same training and the company could therefore shift these employees between “review” and
“verification” work as necessary. BlueVine continued to track those employees who worked on
“SBA Escalation” as it did in 2020. During PPP, those individuals working on "SBA Review" and
"SBA Verification" were trained to spot signs of potential fraud/AML/BSA concerns and either
escalate the application for additional review by an experienced analyst or reject the application.
August 20, 2021
Page 7
As the program progressed and BlueVine identified new trends and signs of potential concern,
additional training was continually provided.
In addition to those BlueVine staff who were assigned to specific teams during the PPP to
perform review, verification, and escalation tasks, other full-time BlueVine staff members, chiefly
in the risk (including, but not limited to, risk automation, payments, and fraud), and compliance
groups, performed work relating to or supporting BlueVine's AML, BSA, and fraud detection
processes, both before and during the PPP. In those cases where these employees were not
assigned to a specific review, verification, or escalation team, and therefore not counted in the data
described above, but whose work nonetheless supported the Company’s AML, BSA, and fraud
detection processes, BlueVine separately counted these staff and presented that data in the row
labeled “Additional Related Employees.”
Finally, in this chart, we have included a baseline count of BlueVine's employees whose
work related to AML, BSA, and fraud detection immediately preceding the PPP rounds. This row
has been labeled “Pre-PPP Headcount.” This figure has been presented, along with a percentage
change calculation, to illustrate the resources the Company dedicated to AML, BSA, and fraud
detection work during the PPP.
***
As previously mentioned, BlueVine remains committed to assisting the Subcommittee in
its inquiry. We will supplement this response with additional information if applicable.
Production of this information is not intended to constitute a waiver of the attorney-client,
attorney work product, or any other applicable rights or privileges in this or any other forum.
BlueVine expressly reserves its rights in this regard. Information and data produced in connection
with this inquiry contains confidential, proprietary, and commercially sensitive information about
BlueVine’s proprietary platform, review processes and tools used as well as its risk and compliance
processes and has been stamped accordingly. Should this information be made public or otherwise
disclosed, it would cause significant harm to the Company and its efforts to detect suspicious
activity and potential fraud in its programs. For this reason, BlueVine requests that such
information be kept confidential by the Subcommittee and its staff. Notwithstanding our request
that such information be kept confidential, we would ask that staff provide us with reasonable
August 20, 2021
Page 8
notice and an opportunity to be heard before the Select Subcommittee discloses any such
information or data to any third parties.
Sincerely,
Karen Elizabeth Christian
Raphael A. Prober
Counsel for BlueVine Inc.
Enclosures via FTP link
September 6, 2022
Select Subcommittee on the Coronavirus Crisis
Committee on Oversight and Reform
U.S. House of Representatives
Washington, D.C. 20515
Dear :
On behalf of our client, Celtic Bank Corporation (“Celtic”), this letter and the
accompanying materials respond to the questions in your e-mail of August 10, 2022, in follow
up to Celtic’s various earlier responses to the May 27, 2021, letter from Chairman Clyburn to Mr.
Reese Howell, Jr., of Celtic. As you know, Celtic has cooperated extensively with the
Subcommittee’s requests, including producing numerous documents, responding to the
Subcommittee’s questions with detailed information, and providing a briefing for the
Subcommittee staff by senior Celtic officials. The information below responds to the questions
in your August 10 e-mail and is provided to the best of our current understanding.
Partner Review and Responsibilities. You asked about the process of reviewing
applications received by Celtic after being reviewed by Celtic’s partner Bluevine. The framing of
the question does not accurately reflect the application review process, and we therefore
appreciate the opportunity to provide additional information. Via its partnership with Bluevine,
Celtic contracted with Bluevine for the processing and review of PPP loan applications,
including for fraud detection. Bluevine therefore conducted the review of loan applications, and
loan applications forwarded to Celtic by Bluevine would have already been through the process
undertaken by Bluevine, pursuant to its contract with Celtic. Because Celtic contracted with
Bluevine for loan processing and fraud detection, loans processed through Bluevine would not
have been re-reviewed by Celtic. Notably, though, Celtic performed auditing and other oversight
of Bluevine to ensure that Bluevine was fulfilling its contractual obligations regarding loan
processing and fraud detection.
For the Subcommittee’s awareness, Celtic engaged in additional activities to detect and
report fraud. For example, Celtic understood that its partners used both automated tools and
manual reviews to screen PPP applications for potential fraud. Fraud identified before the
funding of a loan would have resulted in the loan application not being funded. Where potential
fraud was identified after funding, Celtic participated in the review process. Celtic and Bluevine
worked together in this process, with the fraud teams from both companies meeting frequently
to discuss individual cases as well as trends related to fraud. As noted in the April 21, 2022,
briefing, Celtic increased staffing resources to support its extensive efforts to identify, review,
report, and attempt recovery in PPP fraud cases.
September 6, 2022
Page 4
Please let me know if you have any questions concerning Celtic’s response, including the
information and documents provided today.
Sincerely,
Brian D. Smith
cc:
KAREN ELIZABETH CHRISTIAN
+1 202.887.4265/fax: +1 202.887.4288
kchristian@akingump.com
September 9, 2022
The Honorable James E. Clyburn
Chairman
Select Subcommittee on the Coronavirus Crisis
U.S. House of Representatives
2157 Rayburn House Office Building
Washington, D.C. 20515
Dear Chairman Clyburn:
On behalf of BlueVine Inc. (“BlueVine” or “the Company”), we write in response to
additional follow-up questions from your staff sent on July 29, 2022. As we have stated
previously, BlueVine appreciates the importance of the Select Subcommittee on the Coronavirus
Crisis’ (“the Subcommittee”) inquiry into waste, fraud, and abuse in the Paycheck Protection
Program (“PPP” or “the program”) and remains committed to assisting the Subcommittee in its
inquiry. BlueVine was grateful for the opportunity to provide a briefing to the Select
Subcommittee staff on July 26, 2022, to discuss its participation in the PPP. This is BlueVine’s
twelfth submission in its response to the Subcommittee’s inquiry.
The staff follow-up questions of July 29 relate both to BlueVine’s briefing before
Subcommittee staff on July 26 and BlueVine’s July 22, 2022 written response to the Committee.
We address these questions below.
1. How many PPP loan applications did BlueVine submit to Celtic and Cross River,
respectively?
In total, BlueVine submitted approximately 100,000 applications to Celtic Bank and
355,000 applications to Cross River Bank.
2. Please confirm how the following contractual items originated, including which
party requested the provisions and for what reason (if one was provided):
Robert S. Strauss Tower | 2001 K Street, N.W. | Washington, DC 20006-1037 | 202.887.4000 | fax 202.887.4288 | akingump.com
The Honorable James E. Clyburn
September 9, 2022
Page 2
a. July 2020 amendment to Cross River contract to require BlueVine to
submit at least 50% of its loan applications to Cross River
(BV_SSCC_0001134).
b. The exclusivity provision in Cross River’s 2021 contract
(BV_SSCC_0001077).
c. Provide any additional details on why the contracts with the banks
included only loans of $2 million and below (BV_SSCC_0001088;
BV_SSCC_0001095).
BlueVine negotiated the services it would provide and the fees for those services with its
bank partners, Celtic Bank and Cross River Bank. With respect to Questions 2(a) and (b), it is
BlueVine’s understanding that Cross River Bank wanted to ensure it would receive a sufficient
number of applications in return for the fees it paid BlueVine for its services during the PPP.
With respect to Question 2(c), as BlueVine has referenced in previous responses, the
Company was focused on serving the small business community, both during PPP and in its
commercial business. BlueVine and its banking partners anticipated that larger businesses that
were entitled to PPP loans of $2 million or more based on their payroll data were more likely to
have existing relationships with traditional financial institutions and would not need the assistance
of BlueVine. In addition, BlueVine and its banking partners acknowledged that servicing large
businesses that were entitled to $2 million or more would likely require a more involved process,
similar to how the SBA established a safe harbor for loans up to $2 million.
3. Are there any reasons for the significant increase in BlueVine’s revenue from its
work with Cross River, as compared to Celtic, in 2021, other than Celtic’s decision
to stop offering PPP loans to new customers?
Celtic Bank’s decision to only offer second draw PPP loans in 2021 played a primary role
in BlueVine’s revenue increase from Cross River Bank, as compared to Celtic Bank. In addition,
SBA’s decision to change the fee structure for PPP loans in 2021, effectively increasing the fees
provided to lenders for originating smaller dollar amount loans, also played a meaningful role
because, as noted above and in prior responses, Bluevine served small and very small businesses
with a median loan amount of less than $25,000.
The Honorable James E. Clyburn
September 9, 2022
Page 3
4. Please confirm that SBA did not engage in direct oversight and direct
communication with BlueVine regarding BlueVine’s role as a loan processor for
bank partners, particularly with regard to BlueVine’s fraud controls.
To BlueVine’s knowledge, the Small Business Administration’s (SBA) only engagement
with the Company related to contacts by the Office of Inspector General (OIG) seeking
information or documents about specific applicants to assist in its investigations. Any questions
from the SBA about BlueVine’s systems and processes were limited to that context.
5. Please confirm whether SBA inquired about BlueVine’s fraud controls during the
direct lender approval process.
To BlueVine’s knowledge, the Company was not contacted by the SBA relating to its fraud
controls as part of the direct lender application process.
6. How many applications reviewed by BlueVine were subject to the holistic manual
reviews by fraud investigators and similar experts? How many received the other
form of manual review, which we understand to be a partial review to verify a
piece of information as a supplement to BlueVine’s automatic review process?
Of the 1.491 million applications that BlueVine processed,1 BlueVine estimates that
approximately 65,000 applications received the type of holistic manual reviews performed by the
fraud team as described during the July 26 briefing, and approximately 747,000 received some
other form of human review (as defined in the Company’s previous responses).
7. Please confirm whether PPP applicants who submitted data to BlueVine have the
option to remove themselves from BlueVine’s databases, and if so, what that
process looks like.
Yes. BlueVine follows applicable state and federal laws for processing its customers’
requests to have their information deleted from BlueVine’s systems and/or to opt out of sale or
marketing offerings, including without limitation California Consumer Privacy Act requirements.
1
The 1.491 million applications processed by BlueVine does not include the additional 185,926 applications that
BlueVine deemed “unqualified” based on the basic eligibility requirements set by the SBA.
The Honorable James E. Clyburn
September 9, 2022
Page 4
Consistent with applicable laws, certain limited data is retained in BlueVine’s system for
security/fraud detection and reporting purposes.
8. Please provide us with a copy of BlueVine’s policy document(s) that address
restrictions on loans to employees or owners of BlueVine.
BlueVine’s policies restrict the availability of loans to employees or owners. For example,
BlueVine’s employment letter provides that all employees must avoid conflicts of interest. Exhibit
D to the employment letter lists certain situations that present potential conflicts of interest that
should be avoided, including “Borrowing from or lending to employees, customers, or suppliers.”
We are providing today at BV_SSCC_0005317 this exhibit to the employment letter. Further,
BlueVine’s underwriting policy for its line of credit products states that “Businesses owned by
family members of existing BlueVine employees will not be funded.” An excerpt of the relevant
language from the underwriting policy is provided at BV_SSCC_0005319.
9. With respect to BlueVine’s response to Narrative Request 3, what was the
technical change in 2020-2021 that caused BlueVine to lose its data on rejections
from 2020?
BlueVine did not lose any data on rejections. Rather, BlueVine’s database did not include
a “search field” that would have allowed it to track all rejection reasons centrally until July 2020.
10. With respect to BlueVine’s response to Narrative Request 5, what alternative
timestamps or data relating to PPP application processing times are available to
BlueVine?
BlueVine’s database captured some date information as it related to the status of a PPP
application, meaning, when an application moved through certain stages of the application process,
the database captured the date the application entered that stage. For example, BlueVine tracked
the date an application was submitted to the SBA, the date an application was approved by the
SBA, and the date a PPP loan was finally funded, to name a few. The time stamps collected by
BlueVine’s database, however, do not allow for an accurate measurement of the time it took for
BlueVine to process a PPP application. For example, in certain situations an applicant may remain
in one processing stage indefinitely, such as when an applicant never completed all of the
application requirements or when an applicant applied near the end of the program and was not
approved before funding ran out. Further, in some cases, BlueVine’s processing of an application
began prior to the customer fully completing an application, such as when the applicant had
The Honorable James E. Clyburn
September 9, 2022
Page 5
outstanding tasks to complete before the application can be approved. Using this data to calculate
a processing time is further complicated by the fact that, over the course of the PPP, certain time
stamp fields in BlueVine’s database were adjusted to capture different points in the application
process, such that the same time stamp field would capture time stamps of different events in the
application process, depending on the date. For example, at one stage in the program, the time
stamp showing when a document was “submitted” could have been used to mark the time
processing began. However, the same “submitted” time stamp was later updated to instead capture
when tasks were raised for a client. As such, the definitions for the different time stamps evolved
throughout the program, making it impossible to accurately calculate the requested average.
11. With respect to BlueVine’s response regarding audits, does BlueVine have a copy
of the Celtic audit from 2021?
With respect to the 2021 audit performed on behalf of Celtic Bank, to clarify, this was an
audit of the commercial loan product BlueVine offers in partnership with Celtic Bank, not of the
PPP platform. The audit included a review of the Compliance Management System design and
execution, the AML/BSA program, the Model Risk Management program, the Information
Security program, and transactional testing.
***
As previously mentioned, BlueVine remains committed to assisting the Subcommittee in
its inquiry.
Production of this information is not intended to constitute a waiver of the attorney-client,
attorney work product, or any other applicable rights or privileges in this or any other forum.
BlueVine expressly reserves its rights in this regard. Information and data produced in connection
with this inquiry contains confidential, proprietary, and commercially sensitive information about
BlueVine’s risk and compliance processes. Should this information be made public or otherwise
disclosed, it would cause significant harm to the Company and its efforts to detect suspicious
activity in its programs. Accordingly, BlueVine requests that such information be kept
confidential by the Subcommittee and its staff. Notwithstanding our request that such information
be kept confidential, we would ask that staff provide us with reasonable notice and an opportunity
to be heard before the Subcommittee discloses any such information or data to any third parties.
The Honorable James E. Clyburn
September 9, 2022
Page 6
Sincerely,
Karen Elizabeth Christian
Raphael A. Prober
Counsel for BlueVine Inc.
BV-Approved
Completed Applications (SBA- SBA Approved
Year-Week Applications** submitted) Applications Funded Loans
2021-19 2 0 0 0
2021-18 18,693 2,864 2,320 2,136
2021-17 52,576 14,782 12,668 12,289
2021-16 52,319 16,872 14,960 14,590
2021-15 56,028 18,889 16,882 16,474
2021-14 49,964 15,403 13,437 13,118
2021-13 54,133 15,641 13,652 13,257
2021-12 63,548 20,334 17,562 17,018
2021-11 50,908 16,785 14,376 13,968
2021-10 57,848 15,143 13,026 12,664
2021-9 72,515 14,195 12,226 11,897
2021-8 59,280 14,760 12,892 12,511
2021-7 42,649 12,748 11,043 10,739
2021-6 43,356 13,604 11,700 11,345
2021-5 53,175 17,720 15,263 14,799
2021-4 56,666 19,085 16,389 15,795
2021-3 76,777 27,818 23,522 22,841
2021-2 28,427 4,861 2,913 2,811
2020-40 1 0 0
2020-39 9 0 0
2020-38 21 0 0
2020-37 34 0 0
2020-36 37 0 0
2020-35 68 0 0
2020-34 112 0 0
2020-33 362 0 0
2020-32 85,404 13,346 13,154
2020-31 47,520 9,448 9,276
2020-30 36,605 9,060 8,894
2020-29 34,902 9,769 9,626
2020-28 33,884 8,533 8,360
2020-27 49,427 9,522 9,166
2020-26 45,492 11,164 10,984
2020-25 25,867 6,249 6,183
2020-24 19,780 5,825 5,707
2020-23 17,484 7,370 7,211
2020-22 14,958 6,604 6,414
2020-21 18,678 7,847 7,578
2020-20 22,742 8,743 8,419
2020-19 34,013 12,068 11,589
2020-18 65,939 20,433 19,322
2020-17 43,438 10,858 10,163
2020-16 5,674 1,777 1,582
Total 1,491,315 383,447 371,880
**As explained in BlueVine's July 9, 2021 letter to the Subcommittee, the number of applications listed for each week does not include applications that
were deemed unqualified by BlueVine, as this data is not maintained by BlueVine on a week-to-week basis. The total number of unqualified applications
was 185,926. Unqualified applications plus the number of applications listed here is 1,677,241.
Confidential and Proprietary BV_SSCC_0000001
2019 Trainings
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Anti-money Laundering
1/23/2019 AA Operations (AML) 7/21/2020 69 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 AD Legal (FCRA) Refresher 10/17/2019 77 Yes Completed 10/31/2019
1/23/2019 AD Legal Fair Lending Overview 11/12/2020 65 Yes Completed 10/31/2019
1/23/2019 AD Legal Bank Secrecy Act 11/2/2020 80 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AD Legal (AML) 10/26/2020 75 Yes Completed 10/31/2019
1/23/2019 AD Legal Zdnu Unplugged: Privacy 10/22/2019 72 Yes Completed 10/31/2019
1/23/2019 AD Legal Unplugged: Phishing 11/12/2020 70 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 AD Legal Lending Overview 10/22/2019 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AD Legal or Abusive Acts or 11/12/2020 77 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 AD Legal Guidelines 10/22/2019 81 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 AD Legal Awareness 10/22/2019 100 Yes Completed 10/31/2019
Handling Consumer
2/2/2019 AD Legal Complaints 10/17/2019 93 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/2/2019 AD Legal (FCRA) Refresher 10/17/2019 77 Yes Completed 10/31/2019
Zdnu Unfair, Deceptive
or Abusive Acts or
Practices for the
2/2/2019 AD Legal Financial Institution 10/17/2019 69 Yes Completed 10/31/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 AD Legal Refresher 10/17/2019 62 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 AD Legal Your Customer 10/23/2019 81 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 AD Legal Lending Overview 10/22/2019 80 Yes Completed 12/1/2019
BV: Servicemembers Civil
2/2/2019 AD Legal Relief Act (SCRA) 10/18/2019 61 Yes Completed 10/31/2019
Risk BV - Information Security
10/21/2019 AD Operations Awareness 10/23/2019 100 Yes Completed 1/19/2020
1/23/2019 AF Collections Fair Lending Overview 12/8/2020 67 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004094
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
1/23/2019 AF Collections Bank Secrecy Act 12/8/2020 73 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AF Collections (AML) 12/8/2020 81 Yes Completed 10/31/2019
1/23/2019 AF Collections Unplugged: Phishing 12/8/2020 90 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AF Collections or Abusive Acts or 12/8/2020 65 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 AF Collections Practices Act (FDCPA) 12/8/2020 60 Yes Completed 10/31/2019
Enterprise Customer Identification
2/1/2019 AH Underwriting Program (CIP) 11/1/2020 98 Yes Completed 10/31/2019
Understanding the FFIEC
Enterprise Final Guidance on Social
2/1/2019 AH Underwriting Media 10/31/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Enterprise Foreign Assets Control
2/1/2019 AH Underwriting (OFAC) 11/1/2020 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/1/2019 AH Underwriting (FCRA) Refresher 10/31/2020 100 Yes Completed 10/31/2019
Enterprise Unplugged: Suspicious
2/1/2019 AH Underwriting Activity Reports 11/1/2020 100 Yes Completed 10/31/2019
Enterprise FSC - Identifying Identity
2/1/2019 AH Underwriting Theft - Review of Red 11/1/2020 100 Yes Completed 10/31/2019
Enterprise
2/1/2019 AH Underwriting FSC - Frauds and Scams 11/1/2020 100 Yes Completed 10/31/2019
Enterprise
1/23/2019 AH Underwriting Fair Lending Overview 11/1/2020 98 Yes Completed 10/31/2019
Enterprise
1/23/2019 AH Underwriting Bank Secrecy Act 10/31/2020 98 Yes Completed 10/31/2019
Enterprise Anti-money Laundering
1/23/2019 AH Underwriting (AML) 10/31/2020 98 Yes Completed 10/31/2019
Enterprise
1/23/2019 AH Underwriting Zdnu Unplugged: Privacy 10/22/2019 100 Yes Completed 10/31/2019
Enterprise
1/23/2019 AH Underwriting Unplugged: Phishing 10/31/2020 100 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
1/23/2019 AH Underwriting Lending Overview 10/22/2019 100 Yes Completed 10/31/2019
Enterprise FSC - Unfair, Deceptive,
1/23/2019 AH Underwriting or Abusive Acts or 10/31/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004095
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu FSC - Security of
Enterprise Customer Information
1/23/2019 AH Underwriting Guidelines 10/29/2019 98 Yes Completed 10/31/2019
Enterprise BV - Information Security
1/23/2019 AH Underwriting Awareness 10/29/2019 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/2/2019 AH Underwriting (FCRA) Refresher 10/30/2019 100 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Know
2/2/2019 AH Underwriting Your Customer 10/31/2019 100 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
2/2/2019 AH Underwriting Lending Overview 10/22/2019 100 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 AH Operations Program (CIP) 10/6/2020 75 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 AH Operations Media 10/6/2020 83 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 AH Operations (OFAC) 10/6/2020 83 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 AH Operations (FCRA) Refresher 10/6/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 AH Operations Activity Reports 10/6/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 AH Operations Theft - Review of Red 10/6/2020 75 Yes Completed 10/31/2019
Risk
2/1/2019 AH Operations FSC - Frauds and Scams 10/6/2020 72 Yes Completed 10/31/2019
Risk
1/23/2019 AH Operations Fair Lending Overview 10/15/2020 65 Yes Completed 10/31/2019
Risk
1/23/2019 AH Operations Bank Secrecy Act 10/12/2020 76 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 AH Operations (AML) 10/9/2020 77 Yes Completed 10/31/2019
Risk
1/23/2019 AH Operations Unplugged: Phishing 10/16/2020 70 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 AH Operations or Abusive Acts or 10/15/2020 77 Yes Completed 10/31/2019
Risk
1/23/2019 AK Strategies Fair Lending Overview 10/8/2020 73 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004096
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 AK Strategies Bank Secrecy Act 10/8/2020 80 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 AK Strategies (AML) 10/8/2020 81 Yes Completed 10/31/2019
Risk
1/23/2019 AK Strategies Unplugged: Phishing 10/8/2020 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 AK Strategies or Abusive Acts or 10/8/2020 81 Yes Completed 10/31/2019
1/23/2019 AL Data Science Fair Lending Overview 10/14/2020 100 Yes Completed 10/31/2019
1/23/2019 AL Data Science Bank Secrecy Act 10/12/2020 80 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AL Data Science (AML) 10/12/2020 98 Yes Completed 10/31/2019
1/23/2019 AL Data Science Unplugged: Phishing 10/12/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AL Data Science or Abusive Acts or 10/25/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 AL Data Science Lending Overview 9/26/2019 90 Yes Completed 12/1/2019
Back Office
1/23/2019 AL Operations Fair Lending Overview 11/2/2020 60 Yes Completed 10/31/2019
Back Office
1/23/2019 AL Operations Bank Secrecy Act 11/2/2020 60 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 AL Operations (AML) 11/2/2020 65 Yes Completed 10/31/2019
Back Office
1/23/2019 AL Operations Zdnu Unplugged: Privacy 11/6/2019 66 Yes Completed 10/31/2019
Back Office
1/23/2019 AL Operations Unplugged: Phishing 11/2/2020 70 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
1/23/2019 AL Operations Lending Overview 11/6/2019 70 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 AL Operations or Abusive Acts or 11/2/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Back Office Customer Information
1/23/2019 AL Operations Guidelines 11/6/2019 74 Yes Completed 10/31/2019
Back Office BV - Information Security
1/23/2019 AL Operations Awareness 11/6/2019 100 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
2/2/2019 AL Operations Lending Overview 11/6/2019 70 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 AM Operations (FCRA) Refresher 9/25/2019 85 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004097
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Fair Credit Reporting Act
2/2/2019 AM Operations (FCRA) Refresher 9/25/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 AM Operations Your Customer 10/1/2019 81 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 AM Operations Lending Overview 9/25/2019 80 Yes Completed 12/1/2019
Risk BV - Information Security
9/16/2019 AM Operations Awareness 10/1/2019 100 Yes Completed 12/15/2019
1/23/2019 AM Risk Analytics Fair Lending Overview 11/16/2020 76 Yes Completed 10/31/2019
1/23/2019 AM Risk Analytics Bank Secrecy Act 11/15/2020 64 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AM Risk Analytics (AML) 11/15/2020 79 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AM Risk Analytics or Abusive Acts or 11/16/2020 65 Yes Completed 10/31/2019
Risk Customer Identification
2/1/2019 AO Operations Program (CIP) 10/27/2020 83 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 AO Operations Media 10/27/2020 83 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 AO Operations (OFAC) 10/23/2020 91 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 AO Operations (FCRA) Refresher 10/27/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 AO Operations Activity Reports 10/23/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 AO Operations Theft - Review of Red 10/27/2020 89 Yes Completed 10/31/2019
Risk
2/1/2019 AO Operations FSC - Frauds and Scams 10/23/2020 97 Yes Completed 10/31/2019
Risk
1/23/2019 AO Operations Fair Lending Overview 10/22/2020 82 Yes Completed 10/31/2019
Risk
1/23/2019 AO Operations Bank Secrecy Act 10/22/2020 80 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 AO Operations (AML) 10/22/2020 88 Yes Completed 10/31/2019
Risk
1/23/2019 AO Operations Zdnu Unplugged: Privacy 10/22/2019 86 Yes Completed 10/31/2019
Risk
1/23/2019 AO Operations Unplugged: Phishing 10/22/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004098
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
1/23/2019 AO Operations Lending Overview 10/22/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 AO Operations or Abusive Acts or 10/22/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 AO Operations Guidelines 10/23/2019 93 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 AO Operations Awareness 10/23/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 AO Operations (FCRA) Refresher 10/23/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 AO Operations Your Customer 10/23/2019 94 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 AO Operations Lending Overview 10/22/2019 100 Yes Completed 12/1/2019
1/23/2019 AS Collections Fair Lending Overview 10/6/2020 95 Yes Completed 10/31/2019
1/23/2019 AS Collections Bank Secrecy Act 9/3/2020 98 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AS Collections (AML) 9/3/2020 96 Yes Completed 10/31/2019
1/23/2019 AS Collections Zdnu Unplugged: Privacy 9/17/2019 83 Yes Completed 10/31/2019
1/23/2019 AS Collections Unplugged: Phishing 10/6/2020 90 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 AS Collections Lending Overview 9/17/2019 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AS Collections or Abusive Acts or 9/3/2020 88 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 AS Collections Guidelines 9/17/2019 98 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 AS Collections Awareness 10/8/2019 100 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 AS Collections Practices Act (FDCPA) 9/1/2020 83 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 AS Collections Lending Overview 9/17/2019 80 Yes Completed 12/1/2019
1/23/2019 AS Legal Fair Lending Overview 10/12/2020 80 Yes Completed 10/31/2019
1/23/2019 AS Legal Bank Secrecy Act 10/6/2020 76 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AS Legal (AML) 10/6/2020 81 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004099
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
1/23/2019 AS Legal Zdnu Unplugged: Privacy 10/24/2019 62 Yes Completed 10/31/2019
1/23/2019 AS Legal Unplugged: Phishing 10/6/2020 70 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 AS Legal Lending Overview 10/24/2019 60 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AS Legal or Abusive Acts or 10/14/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 AS Legal Guidelines 10/24/2019 79 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 AS Legal Awareness 10/24/2019 100 Yes Completed 10/31/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 AS Legal Refresher 10/24/2019 67 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 AS Legal Lending Overview 10/24/2019 60 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 AS Operations Program (CIP) 7/1/2020 90 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 AS Operations Media 8/10/2020 89 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 AS Operations (OFAC) 4/6/2020 91 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 AS Operations (FCRA) Refresher 7/1/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 AS Operations Activity Reports 4/6/2020 70 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 AS Operations Theft - Review of Red 7/1/2020 92 Yes Completed 10/31/2019
Risk
2/1/2019 AS Operations FSC - Frauds and Scams 4/6/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 AS Operations Fair Lending Overview 4/3/2020 82 Yes Completed 10/31/2019
Risk
1/23/2019 AS Operations Bank Secrecy Act 4/3/2020 96 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 AS Operations (AML) 4/3/2020 94 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004100
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 AS Operations Zdnu Unplugged: Privacy 10/3/2019 79 Yes Completed 10/31/2019
Risk
1/23/2019 AS Operations Unplugged: Phishing 4/3/2020 80 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 AS Operations Lending Overview 10/3/2019 90 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 AS Operations or Abusive Acts or 4/3/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 AS Operations Guidelines 10/7/2019 86 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 AS Operations Awareness 10/8/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 AS Operations (FCRA) Refresher 10/8/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 AS Operations Your Customer 10/15/2019 81 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 AS Operations Lending Overview 10/3/2019 90 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 AS Operations (FCRA) Refresher 10/29/2019 100 Yes Completed 10/31/2019
Risk
1/23/2019 AS Operations Zdnu Unplugged: Privacy 10/29/2019 97 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 AS Operations Lending Overview 10/29/2019 90 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 AS Operations Guidelines 10/29/2019 93 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 AS Operations Awareness 10/29/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 AS Operations (FCRA) Refresher 10/29/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 AS Operations Your Customer 10/30/2019 94 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 AS Operations Lending Overview 10/29/2019 90 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 AT Operations (FCRA) Refresher 7/12/2019 69 Yes Completed 10/31/2019
Risk
1/23/2019 AT Operations Zdnu Unplugged: Privacy 7/11/2019 86 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004101
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
1/23/2019 AT Operations Lending Overview 7/11/2019 90 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 AT Operations Guidelines 7/12/2019 84 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 AT Operations Awareness 7/12/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 AT Operations (FCRA) Refresher 7/12/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 AT Operations Your Customer 10/8/2019 94 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 AT Operations Lending Overview 7/11/2019 90 Yes Completed 12/1/2019
Customer Identification
2/1/2019 AZ Compliance Program (CIP) 10/31/2020 93 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 AZ Compliance Media 10/31/2020 67 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 AZ Compliance (OFAC) 10/31/2020 83 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 AZ Compliance (FCRA) Refresher 10/31/2020 100 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 AZ Compliance Activity Reports 10/31/2020 80 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 AZ Compliance Theft - Review of Red 10/31/2020 92 Yes Completed 10/31/2019
2/1/2019 AZ Compliance FSC - Frauds and Scams 10/31/2020 83 Yes Completed 10/31/2019
1/23/2019 AZ Compliance Fair Lending Overview 10/30/2020 73 Yes Completed 10/31/2019
1/23/2019 AZ Compliance Bank Secrecy Act 10/30/2020 73 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 AZ Compliance (AML) 10/30/2020 83 Yes Completed 10/31/2019
1/23/2019 AZ Compliance Unplugged: Phishing 10/31/2020 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 AZ Compliance or Abusive Acts or 10/31/2020 85 Yes Completed 10/31/2019
Handling Consumer
9/3/2019 AZ Compliance Complaints 10/30/2019 100 Yes Completed 12/2/2019
BV - Information Security
9/3/2019 AZ Compliance Awareness 9/5/2019 100 Yes Completed 12/2/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004102
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Handling Consumer
2/2/2019 AZ Compliance Complaints 10/30/2019 100 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/2/2019 AZ Compliance (FCRA) Refresher 9/6/2019 100 Yes Completed 10/31/2019
Zdnu Unfair, Deceptive
or Abusive Acts or
Practices for the
2/2/2019 AZ Compliance Financial Institution 10/30/2019 85 Yes Completed 10/31/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 AZ Compliance Refresher 9/6/2019 64 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 AZ Compliance Your Customer 10/30/2019 81 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 AZ Compliance Lending Overview 9/5/2019 80 Yes Completed 12/1/2019
BV: Servicemembers Civil
2/2/2019 AZ Compliance Relief Act (SCRA) 10/30/2019 67 Yes Completed 10/31/2019
Back Office
1/23/2019 BM Operations Fair Lending Overview 10/31/2020 78 Yes Completed 10/31/2019
Back Office
1/23/2019 BM Operations Bank Secrecy Act 10/31/2020 82 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 BM Operations (AML) 10/31/2020 85 Yes Completed 10/31/2019
Back Office
1/23/2019 BM Operations Unplugged: Phishing 11/1/2020 70 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 BM Operations or Abusive Acts or 11/1/2020 73 Yes Completed 10/31/2019
Risk Customer Identification
2/1/2019 BT Operations Program (CIP) 4/1/2020 90 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 BT Operations Media 4/2/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 BT Operations (OFAC) 4/1/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 BT Operations (FCRA) Refresher 4/2/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 BT Operations Activity Reports 4/1/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004103
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk FSC - Identifying Identity
2/1/2019 BT Operations Theft - Review of Red 4/1/2020 83 Yes Completed 10/31/2019
Risk
2/1/2019 BT Operations FSC - Frauds and Scams 4/1/2020 90 Yes Completed 10/31/2019
Risk
1/23/2019 BT Operations Fair Lending Overview 10/1/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 BT Operations Bank Secrecy Act 10/1/2020 91 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 BT Operations (AML) 4/2/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 BT Operations Zdnu Unplugged: Privacy 3/17/2019 100 Yes Completed 10/31/2019
Risk
1/23/2019 BT Operations Unplugged: Phishing 10/6/2020 90 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 BT Operations Lending Overview 3/17/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 BT Operations or Abusive Acts or 10/6/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 BT Operations Guidelines 3/17/2019 100 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 BT Operations Awareness 5/10/2019 100 Yes Completed 10/31/2019
Risk 2019 BV - Information
1/23/2019 BT Operations Security Awareness 4/15/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 BT Operations (FCRA) Refresher 3/17/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 BT Operations Your Customer 3/17/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 BT Operations Lending Overview 3/17/2019 100 Yes Completed 12/1/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 CA Legal Refresher 10/29/2019 72 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 CA Legal Lending Overview 10/24/2019 80 Yes Completed 12/1/2019
BV - Information Security
8/19/2019 CA Legal Awareness 10/28/2019 100 Yes Completed 11/17/2019
Zdnu Unplugged: Fair
2/2/2019 CA Legal Lending Overview 10/24/2019 80 Yes Completed
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004104
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
1/23/2019 CK Collections Fair Lending Overview 10/26/2020 100 Yes Completed 10/31/2019
1/23/2019 CK Collections Bank Secrecy Act 10/26/2020 100 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 CK Collections (AML) 10/29/2020 100 Yes Completed 10/31/2019
1/23/2019 CK Collections Unplugged: Phishing 10/29/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 CK Collections or Abusive Acts or 10/26/2020 100 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 CK Collections Practices Act (FDCPA) 10/20/2020 78 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 CV Legal (AML) 5/12/2020 96 Yes Completed 10/31/2019
Handling Consumer
10/7/2019 CV Legal Complaints 12/17/2019 100 Yes Completed 1/5/2020
BV - Information Security
10/7/2019 CV Legal Awareness 10/17/2019 100 Yes Completed 1/5/2020
Zdnu Unplugged: Fair
2/2/2019 CV Legal Lending Overview 12/16/2019 80 Yes Completed 12/1/2019
Zdnu Unplugged: Fair
2/2/2019 CV Legal Lending Overview 12/16/2019 80 Yes Completed
1/23/2019 DB Collections Zdnu Unplugged: Privacy 10/24/2019 62 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 DB Collections Lending Overview 10/24/2019 80 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 DB Collections Guidelines 10/29/2019 70 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 DB Collections Awareness 10/29/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 DB Collections Lending Overview 10/24/2019 80 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 DG Operations Program (CIP) 10/26/2020 93 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 DG Operations Media 10/26/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 DG Operations (OFAC) 10/26/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 DG Operations (FCRA) Refresher 10/26/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004105
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Unplugged: Suspicious
2/1/2019 DG Operations Activity Reports 10/26/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 DG Operations Theft - Review of Red 10/26/2020 86 Yes Completed 10/31/2019
Risk
2/1/2019 DG Operations FSC - Frauds and Scams 10/26/2020 97 Yes Completed 10/31/2019
Risk
1/23/2019 DG Operations Fair Lending Overview 10/21/2020 98 Yes Completed 10/31/2019
Risk
1/23/2019 DG Operations Bank Secrecy Act 10/15/2020 91 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 DG Operations (AML) 10/14/2020 94 Yes Completed 10/31/2019
Risk
1/23/2019 DG Operations Unplugged: Phishing 10/16/2020 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 DG Operations or Abusive Acts or 10/21/2020 100 Yes Completed 10/31/2019
Back Office
1/23/2019 DL Operations Fair Lending Overview 10/31/2020 96 Yes Completed 10/31/2019
Back Office
1/23/2019 DL Operations Bank Secrecy Act 10/31/2020 60 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 DL Operations (AML) 10/30/2020 98 Yes Completed 10/31/2019
Back Office
1/23/2019 DL Operations Unplugged: Phishing 10/31/2020 100 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 DL Operations or Abusive Acts or 10/31/2020 96 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
2/2/2019 DL Operations Lending Overview 10/18/2019 70 Yes Completed 12/1/2019
1/23/2019 DN Data Science Fair Lending Overview 10/19/2020 100 Yes Completed 10/31/2019
1/23/2019 DN Data Science Bank Secrecy Act 10/19/2020 91 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 DN Data Science (AML) 10/19/2020 98 Yes Completed 10/31/2019
1/23/2019 DN Data Science Zdnu Unplugged: Privacy 9/26/2019 97 Yes Completed 10/31/2019
1/23/2019 DN Data Science Unplugged: Phishing 10/12/2020 90 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 DN Data Science Lending Overview 9/26/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 DN Data Science or Abusive Acts or 10/19/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004106
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu FSC - Security of
Customer Information
1/23/2019 DN Data Science Guidelines 9/26/2019 98 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 DN Data Science Awareness 9/26/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 DN Data Science Lending Overview 9/26/2019 100 Yes Completed 12/1/2019
Enterprise Fair Credit Reporting Act
2/1/2019 DS Underwriting (FCRA) Refresher 10/14/2019 85 Yes Completed 10/31/2019
Enterprise
1/23/2019 DS Underwriting Zdnu Unplugged: Privacy 7/19/2019 72 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
1/23/2019 DS Underwriting Lending Overview 7/19/2019 80 Yes Completed 10/31/2019
Zdnu FSC - Security of
Enterprise Customer Information
1/23/2019 DS Underwriting Guidelines 8/21/2019 91 Yes Completed 10/31/2019
Enterprise BV - Information Security
1/23/2019 DS Underwriting Awareness 8/21/2019 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/2/2019 DS Underwriting (FCRA) Refresher 10/14/2019 85 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Know
2/2/2019 DS Underwriting Your Customer 10/16/2019 75 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
2/2/2019 DS Underwriting Lending Overview 7/19/2019 80 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 DY Operations Program (CIP) 10/30/2020 98 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 DY Operations Media 10/30/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 DY Operations (OFAC) 10/29/2020 91 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 DY Operations (FCRA) Refresher 10/30/2020 77 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 DY Operations Activity Reports 10/25/2020 80 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 DY Operations Theft - Review of Red 10/30/2020 94 Yes Completed 10/31/2019
Risk
2/1/2019 DY Operations FSC - Frauds and Scams 10/29/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004107
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 DY Operations Fair Lending Overview 10/31/2020 96 Yes Completed 10/31/2019
Risk
1/23/2019 DY Operations Bank Secrecy Act 10/31/2020 93 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 DY Operations (AML) 10/30/2020 92 Yes Completed 10/31/2019
Risk
1/23/2019 DY Operations Zdnu Unplugged: Privacy 8/7/2019 100 Yes Completed 10/31/2019
Risk
1/23/2019 DY Operations Unplugged: Phishing 10/31/2020 70 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 DY Operations Lending Overview 8/7/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 DY Operations or Abusive Acts or 10/31/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 DY Operations Guidelines 8/7/2019 100 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 DY Operations Awareness 8/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 DY Operations (FCRA) Refresher 8/7/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 DY Operations Your Customer 8/7/2019 94 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 DY Operations Lending Overview 8/7/2019 100 Yes Completed 12/1/2019
1/23/2019 EA Data Science Zdnu Unplugged: Privacy 9/26/2019 97 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 EA Data Science Lending Overview 9/26/2019 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 EA Data Science Guidelines 9/26/2019 98 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 EA Data Science Awareness 9/26/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 EA Data Science Lending Overview 9/26/2019 100 Yes Completed 12/1/2019
1/23/2019 EM Data Science Fair Lending Overview 10/21/2020 100 Yes Completed 10/31/2019
1/23/2019 EM Data Science Bank Secrecy Act 10/21/2020 93 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 EM Data Science (AML) 10/21/2020 98 Yes Completed 10/31/2019
1/23/2019 EM Data Science Unplugged: Phishing 10/21/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004108
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
FSC - Unfair, Deceptive,
1/23/2019 EM Data Science or Abusive Acts or 10/21/2020 100 Yes Completed 10/31/2019
Risk Customer Identification
2/1/2019 EP Operations Program (CIP) 11/2/2020 88 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 EP Operations Media 11/2/2020 83 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 EP Operations (OFAC) 11/2/2020 87 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 EP Operations (FCRA) Refresher 11/2/2020 69 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 EP Operations Activity Reports 11/2/2020 60 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 EP Operations Theft - Review of Red 11/2/2020 89 Yes Completed 10/31/2019
Risk
2/1/2019 EP Operations FSC - Frauds and Scams 11/2/2020 90 Yes Completed 10/31/2019
Risk
1/23/2019 EP Operations Fair Lending Overview 10/30/2020 82 Yes Completed 10/31/2019
Risk
1/23/2019 EP Operations Bank Secrecy Act 10/29/2020 91 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 EP Operations (AML) 10/20/2020 92 Yes Completed 10/31/2019
Risk
1/23/2019 EP Operations Zdnu Unplugged: Privacy 5/24/2019 79 Yes Completed 10/31/2019
Risk
1/23/2019 EP Operations Unplugged: Phishing 10/31/2020 80 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 EP Operations Lending Overview 5/24/2019 90 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 EP Operations or Abusive Acts or 10/31/2020 81 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 EP Operations Guidelines 10/7/2019 79 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 EP Operations Awareness 10/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 EP Operations (FCRA) Refresher 10/15/2019 69 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004109
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Know
2/2/2019 EP Operations Your Customer 10/20/2019 81 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 EP Operations Lending Overview 5/24/2019 90 Yes Completed 12/1/2019
Customer Identification
2/1/2019 FB Compliance Program (CIP) 10/29/2020 85 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 FB Compliance Media 10/30/2020 78 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 FB Compliance (OFAC) 10/29/2020 91 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 FB Compliance (FCRA) Refresher 10/29/2020 100 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 FB Compliance Activity Reports 10/29/2020 90 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 FB Compliance Theft - Review of Red 10/30/2020 86 Yes Completed 10/31/2019
2/1/2019 FB Compliance FSC - Frauds and Scams 10/29/2020 83 Yes Completed 10/31/2019
1/23/2019 FB Compliance Fair Lending Overview 10/27/2020 85 Yes Completed 10/31/2019
1/23/2019 FB Compliance Bank Secrecy Act 10/27/2020 89 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 FB Compliance (AML) 10/27/2020 88 Yes Completed 10/31/2019
1/23/2019 FB Compliance Unplugged: Phishing 10/29/2020 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 FB Compliance or Abusive Acts or 10/28/2020 77 Yes Completed 10/31/2019
Handling Consumer
8/5/2019 FB Compliance Complaints 8/13/2019 87 Yes Completed 11/3/2019
BV - Information Security
8/5/2019 FB Compliance Awareness 8/22/2019 100 Yes Completed 11/3/2019
Handling Consumer
2/2/2019 FB Compliance Complaints 8/13/2019 87 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/2/2019 FB Compliance (FCRA) Refresher 8/9/2019 100 Yes Completed 10/31/2019
Zdnu Unfair, Deceptive
or Abusive Acts or
Practices for the
2/2/2019 FB Compliance Financial Institution 9/9/2019 85 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004110
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 FB Compliance Refresher 8/9/2019 67 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 FB Compliance Your Customer 9/9/2019 88 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 FB Compliance Lending Overview 8/13/2019 100 Yes Completed 12/1/2019
BV: Servicemembers Civil
2/2/2019 FB Compliance Relief Act (SCRA) 9/10/2019 94 Yes Completed 10/31/2019
1/23/2019 GC Data Science Fair Lending Overview 10/29/2020 87 Yes Completed 10/31/2019
1/23/2019 GC Data Science Bank Secrecy Act 10/28/2020 82 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 GC Data Science (AML) 5/29/2020 96 Yes Completed 10/31/2019
1/23/2019 GC Data Science Unplugged: Phishing 10/26/2020 90 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 GC Data Science or Abusive Acts or 10/29/2020 88 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 GC Data Science Lending Overview 10/8/2019 80 Yes Completed 12/1/2019
Fair Credit Reporting Act
2/1/2019 GD Collections (FCRA) Refresher 6/5/2019 85 Yes Completed 10/31/2019
1/23/2019 GD Collections Fair Lending Overview 9/23/2020 64 Yes Completed 10/31/2019
1/23/2019 GD Collections Bank Secrecy Act 9/22/2020 64 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 GD Collections (AML) 9/22/2020 71 Yes Completed 10/31/2019
1/23/2019 GD Collections Zdnu Unplugged: Privacy 6/5/2019 62 Yes Completed 10/31/2019
1/23/2019 GD Collections Unplugged: Phishing 9/24/2020 60 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 GD Collections Lending Overview 6/12/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 GD Collections or Abusive Acts or 9/24/2020 65 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 GD Collections Guidelines 8/6/2019 74 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 GD Collections Awareness 8/6/2019 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004111
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Fair Debt Collection
2/2/2019 GD Collections Practices Act (FDCPA) 10/9/2020 68 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/2/2019 GD Collections (FCRA) Refresher 6/5/2019 85 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 GD Collections Your Customer 10/3/2019 81 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 GD Collections Lending Overview 6/12/2019 100 Yes Completed 12/1/2019
Risk
1/23/2019 GH Strategies Fair Lending Overview 11/1/2020 75 Yes Completed 10/31/2019
Risk
1/23/2019 GH Strategies Bank Secrecy Act 11/1/2020 69 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 GH Strategies (AML) 11/1/2020 69 Yes Completed 10/31/2019
Risk
1/23/2019 GH Strategies Zdnu Unplugged: Privacy 7/18/2019 69 Yes Completed 10/31/2019
Risk
1/23/2019 GH Strategies Unplugged: Phishing 11/1/2020 80 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 GH Strategies Lending Overview 7/18/2019 90 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 GH Strategies or Abusive Acts or 11/1/2020 69 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 GH Strategies Guidelines 7/18/2019 86 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 GH Strategies Awareness 7/18/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 GH Strategies Lending Overview 7/18/2019 90 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 GR Operations Program (CIP) 10/23/2020 65 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 GR Operations Media 10/31/2020 83 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 GR Operations (OFAC) 10/23/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 GR Operations (FCRA) Refresher 10/31/2020 85 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004112
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Unplugged: Suspicious
2/1/2019 GR Operations Activity Reports 10/23/2020 60 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 GR Operations Theft - Review of Red 10/31/2020 64 Yes Completed 10/31/2019
Risk
2/1/2019 GR Operations FSC - Frauds and Scams 10/23/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 GR Operations Fair Lending Overview 10/22/2020 64 Yes Completed 10/31/2019
Risk
1/23/2019 GR Operations Bank Secrecy Act 10/22/2020 62 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 GR Operations (AML) 10/22/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 GR Operations Zdnu Unplugged: Privacy 7/28/2019 93 Yes Completed 10/31/2019
Risk
1/23/2019 GR Operations Unplugged: Phishing 10/23/2020 90 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 GR Operations Lending Overview 7/28/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 GR Operations or Abusive Acts or 10/23/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 GR Operations Guidelines 8/5/2019 84 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 GR Operations Awareness 7/28/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 GR Operations (FCRA) Refresher 9/22/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 GR Operations Your Customer 10/18/2019 88 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 GR Operations Lending Overview 7/28/2019 100 Yes Completed 12/1/2019
1/23/2019 IL Data Science Fair Lending Overview 10/17/2020 95 Yes Completed 10/31/2019
1/23/2019 IL Data Science Bank Secrecy Act 10/17/2020 98 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 IL Data Science (AML) 10/16/2020 96 Yes Completed 10/31/2019
1/23/2019 IL Data Science Unplugged: Phishing 10/17/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 IL Data Science or Abusive Acts or 10/17/2020 92 Yes Completed 10/31/2019
1/23/2019 IS Data Science Fair Lending Overview 10/24/2020 100 Yes Completed 10/31/2019
1/23/2019 IS Data Science Bank Secrecy Act 10/24/2020 98 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004113
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Anti-money Laundering
1/23/2019 IS Data Science (AML) 10/24/2020 96 Yes Completed 10/31/2019
1/23/2019 IS Data Science Zdnu Unplugged: Privacy 10/21/2019 100 Yes Completed 10/31/2019
1/23/2019 IS Data Science Unplugged: Phishing 10/24/2020 90 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 IS Data Science Lending Overview 10/21/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 IS Data Science or Abusive Acts or 10/24/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 IS Data Science Guidelines 10/21/2019 93 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 IS Data Science Awareness 10/21/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 IS Data Science Lending Overview 10/21/2019 100 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 JB Operations Program (CIP) 10/8/2020 80 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 JB Operations Media 10/8/2020 67 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 JB Operations (OFAC) 10/8/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 JB Operations (FCRA) Refresher 10/8/2020 69 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 JB Operations Activity Reports 10/8/2020 60 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 JB Operations Theft - Review of Red 10/8/2020 86 Yes Completed 10/31/2019
Risk
2/1/2019 JB Operations FSC - Frauds and Scams 10/8/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 JB Operations Fair Lending Overview 10/7/2020 76 Yes Completed 10/31/2019
Risk
1/23/2019 JB Operations Bank Secrecy Act 10/6/2020 78 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 JB Operations (AML) 7/1/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 JB Operations Unplugged: Phishing 10/8/2020 80 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004114
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk FSC - Unfair, Deceptive,
1/23/2019 JB Operations or Abusive Acts or 10/8/2020 69 Yes Completed 10/31/2019
Risk BV - Information Security
6/3/2019 JB Operations Awareness 6/14/2019 100 Yes Completed 9/1/2019
Risk Fair Credit Reporting Act
2/2/2019 JB Operations (FCRA) Refresher 6/14/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 JB Operations Your Customer 6/14/2019 63 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 JB Operations Lending Overview 6/13/2019 90 Yes Completed 12/1/2019
Back Office
1/23/2019 JG Operations Fair Lending Overview 10/31/2020 75 Yes Completed 10/31/2019
Back Office
1/23/2019 JG Operations Bank Secrecy Act 10/31/2020 91 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 JG Operations (AML) 10/31/2020 88 Yes Completed 10/31/2019
Back Office
1/23/2019 JG Operations Zdnu Unplugged: Privacy 10/30/2019 83 Yes Completed 10/31/2019
Back Office
1/23/2019 JG Operations Unplugged: Phishing 10/31/2020 70 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
1/23/2019 JG Operations Lending Overview 10/30/2019 80 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 JG Operations or Abusive Acts or 10/31/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Back Office Customer Information
1/23/2019 JG Operations Guidelines 10/30/2019 86 Yes Completed 10/31/2019
Back Office BV - Information Security
1/23/2019 JG Operations Awareness 10/30/2019 100 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
2/2/2019 JG Operations Lending Overview 10/30/2019 80 Yes Completed 12/1/2019
1/23/2019 JT Data Science Fair Lending Overview 10/30/2020 95 Yes Completed 10/31/2019
1/23/2019 JT Data Science Bank Secrecy Act 10/30/2020 91 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 JT Data Science (AML) 10/29/2020 88 Yes Completed 10/31/2019
1/23/2019 JT Data Science Unplugged: Phishing 10/30/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 JT Data Science or Abusive Acts or 10/30/2020 92 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 JT Data Science Lending Overview 10/28/2019 90 Yes Completed 12/1/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004115
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Fair Credit Reporting Act
2/1/2019 KB Operations (FCRA) Refresher 10/2/2019 77 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 KB Operations (FCRA) Refresher 10/2/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 KB Operations Your Customer 10/3/2019 88 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 KB Operations Lending Overview 9/25/2019 60 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 KK Operations Program (CIP) 10/28/2020 78 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 KK Operations Media 10/28/2020 83 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 KK Operations (OFAC) 10/26/2020 91 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 KK Operations (FCRA) Refresher 10/28/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 KK Operations Activity Reports 10/26/2020 70 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 KK Operations Theft - Review of Red 10/28/2020 89 Yes Completed 10/31/2019
Risk
2/1/2019 KK Operations FSC - Frauds and Scams 10/26/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 KK Operations Fair Lending Overview 10/25/2020 75 Yes Completed 10/31/2019
Risk
1/23/2019 KK Operations Bank Secrecy Act 10/25/2020 78 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 KK Operations (AML) 10/25/2020 71 Yes Completed 10/31/2019
Risk
1/23/2019 KK Operations Zdnu Unplugged: Privacy 10/22/2019 72 Yes Completed 10/31/2019
Risk
1/23/2019 KK Operations Unplugged: Phishing 10/26/2020 90 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 KK Operations Lending Overview 10/22/2019 90 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 KK Operations or Abusive Acts or 10/25/2020 77 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004116
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 KK Operations Guidelines 10/22/2019 77 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 KK Operations Awareness 10/22/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 KK Operations (FCRA) Refresher 10/22/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 KK Operations Your Customer 10/22/2019 88 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 KK Operations Lending Overview 10/22/2019 90 Yes Completed 12/1/2019
Back Office Fair Credit Reporting Act
2/1/2019 KL Operations (FCRA) Refresher 10/30/2019 100 Yes Completed 10/31/2019
Back Office
1/23/2019 KL Operations Fair Lending Overview 11/2/2020 98 Yes Completed 10/31/2019
Back Office
1/23/2019 KL Operations Bank Secrecy Act 10/31/2020 96 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 KL Operations (AML) 10/31/2020 98 Yes Completed 10/31/2019
Back Office
1/23/2019 KL Operations Zdnu Unplugged: Privacy 10/30/2019 76 Yes Completed 10/31/2019
Back Office
1/23/2019 KL Operations Unplugged: Phishing 11/3/2020 100 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
1/23/2019 KL Operations Lending Overview 10/30/2019 80 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 KL Operations or Abusive Acts or 11/3/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Back Office Customer Information
1/23/2019 KL Operations Guidelines 10/30/2019 84 Yes Completed 10/31/2019
Back Office BV - Information Security
1/23/2019 KL Operations Awareness 10/30/2019 100 Yes Completed 10/31/2019
Back Office Fair Credit Reporting Act
2/2/2019 KL Operations (FCRA) Refresher 10/30/2019 100 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Know
2/2/2019 KL Operations Your Customer 10/30/2019 100 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
2/2/2019 KL Operations Lending Overview 10/30/2019 80 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 KL Operations Program (CIP) 10/26/2020 95 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004117
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 KL Operations Media 10/28/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 KL Operations (OFAC) 10/26/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 KL Operations (FCRA) Refresher 10/27/2020 92 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 KL Operations Activity Reports 10/26/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 KL Operations Theft - Review of Red 10/27/2020 97 Yes Completed 10/31/2019
Risk
2/1/2019 KL Operations FSC - Frauds and Scams 10/26/2020 97 Yes Completed 10/31/2019
Risk
1/23/2019 KL Operations Fair Lending Overview 10/26/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 KL Operations Bank Secrecy Act 10/26/2020 76 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 KL Operations (AML) 10/26/2020 81 Yes Completed 10/31/2019
Risk
1/23/2019 KL Operations Zdnu Unplugged: Privacy 10/7/2019 72 Yes Completed 10/31/2019
Risk
1/23/2019 KL Operations Unplugged: Phishing 10/26/2020 90 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 KL Operations Lending Overview 10/7/2019 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 KL Operations or Abusive Acts or 10/26/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 KL Operations Guidelines 10/7/2019 70 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 KL Operations Awareness 10/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 KL Operations (FCRA) Refresher 10/7/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 KL Operations Your Customer 10/7/2019 63 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 KL Operations Lending Overview 10/7/2019 80 Yes Completed 12/1/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004118
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Customer Identification
2/1/2019 KN Operations Program (CIP) 10/6/2020 68 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 KN Operations Media 10/6/2020 94 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 KN Operations (OFAC) 10/6/2020 87 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 KN Operations (FCRA) Refresher 10/6/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 KN Operations Activity Reports 10/6/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 KN Operations Theft - Review of Red 10/6/2020 72 Yes Completed 10/31/2019
Risk
2/1/2019 KN Operations FSC - Frauds and Scams 10/6/2020 72 Yes Completed 10/31/2019
Risk
1/23/2019 KN Operations Fair Lending Overview 10/7/2020 62 Yes Completed 10/31/2019
Risk
1/23/2019 KN Operations Bank Secrecy Act 10/7/2020 71 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 KN Operations (AML) 10/7/2020 60 Yes Completed 10/31/2019
Risk
1/23/2019 KN Operations Zdnu Unplugged: Privacy 10/7/2019 66 Yes Completed 10/31/2019
Risk
1/23/2019 KN Operations Unplugged: Phishing 10/7/2020 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 KN Operations Lending Overview 10/7/2019 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 KN Operations or Abusive Acts or 10/7/2020 62 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 KN Operations Guidelines 10/7/2019 65 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 KN Operations Awareness 10/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 KN Operations (FCRA) Refresher 10/7/2019 85 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 KN Operations Your Customer 10/7/2019 69 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004119
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
2/2/2019 KN Operations Lending Overview 10/7/2019 80 Yes Completed 12/1/2019
Back Office
1/23/2019 KO Operations Fair Lending Overview 10/31/2020 84 Yes Completed 10/31/2019
Back Office
1/23/2019 KO Operations Bank Secrecy Act 10/31/2020 84 Yes Completed 10/31/2019
Back Office Anti-money Laundering
1/23/2019 KO Operations (AML) 10/31/2020 83 Yes Completed 10/31/2019
Back Office
1/23/2019 KO Operations Unplugged: Phishing 10/31/2020 100 Yes Completed 10/31/2019
Back Office FSC - Unfair, Deceptive,
1/23/2019 KO Operations or Abusive Acts or 10/31/2020 96 Yes Completed 10/31/2019
Back Office Zdnu Unplugged: Fair
2/2/2019 KO Operations Lending Overview 9/9/2019 80 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 KV Operations Program (CIP) 10/27/2020 78 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 KV Operations Media 10/27/2020 61 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 KV Operations (OFAC) 10/27/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 KV Operations (FCRA) Refresher 10/27/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 KV Operations Activity Reports 10/27/2020 70 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 KV Operations Theft - Review of Red 10/27/2020 92 Yes Completed 10/31/2019
Risk
2/1/2019 KV Operations FSC - Frauds and Scams 10/27/2020 79 Yes Completed 10/31/2019
Risk
1/23/2019 KV Operations Fair Lending Overview 10/27/2020 73 Yes Completed 10/31/2019
Risk
1/23/2019 KV Operations Bank Secrecy Act 10/27/2020 82 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 KV Operations (AML) 10/27/2020 73 Yes Completed 10/31/2019
Risk
1/23/2019 KV Operations Zdnu Unplugged: Privacy 10/16/2019 79 Yes Completed 10/31/2019
Risk
1/23/2019 KV Operations Unplugged: Phishing 10/27/2020 80 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004120
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
1/23/2019 KV Operations Lending Overview 10/16/2019 60 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 KV Operations or Abusive Acts or 10/27/2020 69 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 KV Operations Guidelines 10/16/2019 81 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 KV Operations Awareness 10/16/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 KV Operations (FCRA) Refresher 10/16/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 KV Operations Your Customer 10/25/2019 75 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 KV Operations Lending Overview 10/16/2019 60 Yes Completed 12/1/2019
1/23/2019 LD Data Science Fair Lending Overview 10/15/2020 100 Yes Completed 10/31/2019
1/23/2019 LD Data Science Bank Secrecy Act 10/15/2020 96 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 LD Data Science (AML) 10/15/2020 94 Yes Completed 10/31/2019
1/23/2019 LD Data Science Zdnu Unplugged: Privacy 9/26/2019 97 Yes Completed 10/31/2019
1/23/2019 LD Data Science Unplugged: Phishing 10/15/2020 80 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 LD Data Science Lending Overview 9/26/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 LD Data Science or Abusive Acts or 10/15/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 LD Data Science Guidelines 9/26/2019 98 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 LD Data Science Awareness 9/26/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 LD Data Science Lending Overview 9/26/2019 100 Yes Completed 12/1/2019
Enterprise Customer Identification
2/1/2019 LM Underwriting Program (CIP) 11/2/2020 83 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004121
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Understanding the FFIEC
Enterprise Final Guidance on Social
2/1/2019 LM Underwriting Media 11/1/2020 94 Yes Completed 10/31/2019
Unplugged: Office of
Enterprise Foreign Assets Control
2/1/2019 LM Underwriting (OFAC) 11/2/2020 96 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/1/2019 LM Underwriting (FCRA) Refresher 11/2/2020 100 Yes Completed 10/31/2019
Enterprise Unplugged: Suspicious
2/1/2019 LM Underwriting Activity Reports 11/1/2020 90 Yes Completed 10/31/2019
Enterprise FSC - Identifying Identity
2/1/2019 LM Underwriting Theft - Review of Red 11/2/2020 94 Yes Completed 10/31/2019
Enterprise
2/1/2019 LM Underwriting FSC - Frauds and Scams 11/2/2020 86 Yes Completed 10/31/2019
Enterprise
1/23/2019 LM Underwriting Fair Lending Overview 11/1/2020 85 Yes Completed 10/31/2019
Enterprise
1/23/2019 LM Underwriting Bank Secrecy Act 11/1/2020 91 Yes Completed 10/31/2019
Enterprise Anti-money Laundering
1/23/2019 LM Underwriting (AML) 11/1/2020 90 Yes Completed 10/31/2019
Enterprise
1/23/2019 LM Underwriting Zdnu Unplugged: Privacy 10/27/2019 97 Yes Completed 10/31/2019
Enterprise
1/23/2019 LM Underwriting Unplugged: Phishing 11/1/2020 90 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
1/23/2019 LM Underwriting Lending Overview 10/27/2019 100 Yes Completed 10/31/2019
Enterprise FSC - Unfair, Deceptive,
1/23/2019 LM Underwriting or Abusive Acts or 11/1/2020 88 Yes Completed 10/31/2019
Zdnu FSC - Security of
Enterprise Customer Information
1/23/2019 LM Underwriting Guidelines 10/27/2019 93 Yes Completed 10/31/2019
Enterprise BV - Information Security
1/23/2019 LM Underwriting Awareness 10/27/2019 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/2/2019 LM Underwriting (FCRA) Refresher 10/27/2019 100 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Know
2/2/2019 LM Underwriting Your Customer 10/27/2019 94 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
2/2/2019 LM Underwriting Lending Overview 10/27/2019 100 Yes Completed 12/1/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004122
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Customer Identification
2/1/2019 LM Operations Program (CIP) 10/6/2020 80 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 LM Operations Media 8/27/2020 67 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 LM Operations (OFAC) 10/6/2020 65 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 LM Operations (FCRA) Refresher 8/27/2020 77 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 LM Operations Activity Reports 10/6/2020 60 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 LM Operations Theft - Review of Red 8/27/2020 69 Yes Completed 10/31/2019
Risk
2/1/2019 LM Operations FSC - Frauds and Scams 10/6/2020 76 Yes Completed 10/31/2019
Risk
1/23/2019 LM Operations Fair Lending Overview 10/7/2020 69 Yes Completed 10/31/2019
Risk
1/23/2019 LM Operations Bank Secrecy Act 10/7/2020 62 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 LM Operations (AML) 10/7/2020 75 Yes Completed 10/31/2019
Risk
1/23/2019 LM Operations Unplugged: Phishing 10/6/2020 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 LM Operations or Abusive Acts or 10/6/2020 81 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 LM Operations (FCRA) Refresher 10/24/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 LM Operations Your Customer 10/23/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 LM Operations Lending Overview 10/24/2019 80 Yes Completed 12/1/2019
Enterprise Customer Identification
2/1/2019 LO Underwriting Program (CIP) 10/6/2020 80 Yes Completed 10/31/2019
Understanding the FFIEC
Enterprise Final Guidance on Social
2/1/2019 LO Underwriting Media 10/6/2020 72 Yes Completed 10/31/2019
Unplugged: Office of
Enterprise Foreign Assets Control
2/1/2019 LO Underwriting (OFAC) 10/6/2020 96 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004123
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Enterprise Fair Credit Reporting Act
2/1/2019 LO Underwriting (FCRA) Refresher 10/6/2020 69 Yes Completed 10/31/2019
Enterprise Unplugged: Suspicious
2/1/2019 LO Underwriting Activity Reports 10/6/2020 70 Yes Completed 10/31/2019
Enterprise FSC - Identifying Identity
2/1/2019 LO Underwriting Theft - Review of Red 10/6/2020 86 Yes Completed 10/31/2019
Enterprise
2/1/2019 LO Underwriting FSC - Frauds and Scams 10/6/2020 79 Yes Completed 10/31/2019
Enterprise
1/23/2019 LO Underwriting Fair Lending Overview 10/7/2020 73 Yes Completed 10/31/2019
Enterprise
1/23/2019 LO Underwriting Bank Secrecy Act 10/7/2020 87 Yes Completed 10/31/2019
Enterprise Anti-money Laundering
1/23/2019 LO Underwriting (AML) 10/6/2020 83 Yes Completed 10/31/2019
Enterprise
1/23/2019 LO Underwriting Unplugged: Phishing 10/6/2020 70 Yes Completed 10/31/2019
Enterprise FSC - Unfair, Deceptive,
1/23/2019 LO Underwriting or Abusive Acts or 10/7/2020 85 Yes Completed 10/31/2019
Enterprise BV - Information Security
3/18/2019 LO Underwriting Awareness 6/13/2019 100 Yes Completed 6/16/2019
Enterprise Fair Credit Reporting Act
2/2/2019 LO Underwriting (FCRA) Refresher 6/13/2019 69 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Know
2/2/2019 LO Underwriting Your Customer 6/13/2019 88 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
2/2/2019 LO Underwriting Lending Overview 6/13/2019 70 Yes Completed 12/1/2019
1/23/2019 LS Data Science Fair Lending Overview 10/25/2020 93 Yes Completed 10/31/2019
1/23/2019 LS Data Science Bank Secrecy Act 10/25/2020 93 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 LS Data Science (AML) 10/8/2020 90 Yes Completed 10/31/2019
1/23/2019 LS Data Science Zdnu Unplugged: Privacy 9/26/2019 97 Yes Completed 10/31/2019
1/23/2019 LS Data Science Unplugged: Phishing 10/25/2020 90 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 LS Data Science Lending Overview 9/26/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 LS Data Science or Abusive Acts or 10/25/2020 88 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004124
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu FSC - Security of
Customer Information
1/23/2019 LS Data Science Guidelines 9/26/2019 98 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 LS Data Science Awareness 9/26/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 LS Data Science Lending Overview 9/26/2019 100 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 LZ Operations (FCRA) Refresher 9/24/2019 77 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 LZ Operations (FCRA) Refresher 9/24/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 LZ Operations Your Customer 9/24/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 LZ Operations Lending Overview 10/1/2019 70 Yes Completed 12/1/2019
Customer Identification
2/1/2019 ML Risk Analytics Program (CIP) 10/25/2020 95 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 ML Risk Analytics Media 10/25/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 ML Risk Analytics (OFAC) 10/25/2020 96 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 ML Risk Analytics (FCRA) Refresher 10/25/2020 100 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 ML Risk Analytics Activity Reports 10/25/2020 100 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 ML Risk Analytics Theft - Review of Red 10/22/2020 100 Yes Completed 10/31/2019
2/1/2019 ML Risk Analytics FSC - Frauds and Scams 10/25/2020 100 Yes Completed 10/31/2019
1/23/2019 ML Risk Analytics Fair Lending Overview 10/22/2020 98 Yes Completed 10/31/2019
1/23/2019 ML Risk Analytics Bank Secrecy Act 10/22/2020 100 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 ML Risk Analytics (AML) 10/25/2020 90 Yes Completed 10/31/2019
1/23/2019 ML Risk Analytics Unplugged: Phishing 10/25/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 ML Risk Analytics or Abusive Acts or 10/25/2020 96 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 ML Risk Analytics Your Customer 10/2/2019 88 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004125
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Unplugged: Fair
2/2/2019 ML Risk Analytics Lending Overview 9/25/2019 100 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 MM Operations (FCRA) Refresher 5/2/2019 92 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 MM Operations (FCRA) Refresher 5/2/2019 92 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 MM Operations Your Customer 10/16/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 MM Operations Lending Overview 10/16/2019 70 Yes Completed 12/1/2019
Enterprise Customer Identification
2/1/2019 MM Underwriting Program (CIP) 10/30/2020 90 Yes Completed 10/31/2019
Understanding the FFIEC
Enterprise Final Guidance on Social
2/1/2019 MM Underwriting Media 10/30/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Enterprise Foreign Assets Control
2/1/2019 MM Underwriting (OFAC) 10/29/2020 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/1/2019 MM Underwriting (FCRA) Refresher 10/30/2020 92 Yes Completed 10/31/2019
Enterprise Unplugged: Suspicious
2/1/2019 MM Underwriting Activity Reports 10/27/2020 80 Yes Completed 10/31/2019
Enterprise FSC - Identifying Identity
2/1/2019 MM Underwriting Theft - Review of Red 10/30/2020 100 Yes Completed 10/31/2019
Enterprise
2/1/2019 MM Underwriting FSC - Frauds and Scams 10/29/2020 90 Yes Completed 10/31/2019
Enterprise
1/23/2019 MM Underwriting Fair Lending Overview 10/28/2020 82 Yes Completed 10/31/2019
Enterprise
1/23/2019 MM Underwriting Bank Secrecy Act 10/28/2020 91 Yes Completed 10/31/2019
Enterprise Anti-money Laundering
1/23/2019 MM Underwriting (AML) 10/27/2020 94 Yes Completed 10/31/2019
Enterprise
1/23/2019 MM Underwriting Zdnu Unplugged: Privacy 10/24/2019 93 Yes Completed 10/31/2019
Enterprise
1/23/2019 MM Underwriting Unplugged: Phishing 10/27/2020 90 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
1/23/2019 MM Underwriting Lending Overview 10/24/2019 70 Yes Completed 10/31/2019
Enterprise FSC - Unfair, Deceptive,
1/23/2019 MM Underwriting or Abusive Acts or 10/29/2020 88 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004126
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu FSC - Security of
Enterprise Customer Information
1/23/2019 MM Underwriting Guidelines 10/24/2019 93 Yes Completed 10/31/2019
Enterprise BV - Information Security
1/23/2019 MM Underwriting Awareness 10/25/2019 100 Yes Completed 10/31/2019
Enterprise Fair Credit Reporting Act
2/2/2019 MM Underwriting (FCRA) Refresher 10/16/2019 92 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Know
2/2/2019 MM Underwriting Your Customer 10/30/2019 94 Yes Completed 10/31/2019
Enterprise Zdnu Unplugged: Fair
2/2/2019 MM Underwriting Lending Overview 10/24/2019 70 Yes Completed 12/1/2019
Customer Identification
2/1/2019 NA Risk Analytics Program (CIP) 10/25/2020 88 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 NA Risk Analytics Media 10/22/2020 94 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 NA Risk Analytics (OFAC) 10/25/2020 65 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 NA Risk Analytics (FCRA) Refresher 10/22/2020 69 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 NA Risk Analytics Activity Reports 10/25/2020 100 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 NA Risk Analytics Theft - Review of Red 10/25/2020 89 Yes Completed 10/31/2019
2/1/2019 NA Risk Analytics FSC - Frauds and Scams 10/25/2020 93 Yes Completed 10/31/2019
1/23/2019 NA Risk Analytics Fair Lending Overview 10/25/2020 100 Yes Completed 10/31/2019
1/23/2019 NA Risk Analytics Bank Secrecy Act 10/22/2020 87 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 NA Risk Analytics (AML) 10/22/2020 81 Yes Completed 10/31/2019
1/23/2019 NA Risk Analytics Zdnu Unplugged: Privacy 8/7/2019 100 Yes Completed 10/31/2019
1/23/2019 NA Risk Analytics Unplugged: Phishing 10/25/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 NA Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 NA Risk Analytics or Abusive Acts or 10/22/2020 69 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 NA Risk Analytics Guidelines 8/7/2019 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004127
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
BV - Information Security
1/23/2019 NA Risk Analytics Awareness 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 NA Risk Analytics Your Customer 8/7/2019 88 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 NA Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 12/1/2019
1/23/2019 NH Data Science Fair Lending Overview 10/12/2020 100 Yes Completed 10/31/2019
1/23/2019 NH Data Science Bank Secrecy Act 10/12/2020 100 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 NH Data Science (AML) 10/12/2020 100 Yes Completed 10/31/2019
1/23/2019 NH Data Science Zdnu Unplugged: Privacy 10/24/2019 100 Yes Completed 10/31/2019
1/23/2019 NH Data Science Unplugged: Phishing 10/12/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 NH Data Science Lending Overview 10/24/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 NH Data Science or Abusive Acts or 10/15/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 NH Data Science Guidelines 10/24/2019 81 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 NH Data Science Awareness 10/28/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 NH Data Science Lending Overview 10/24/2019 100 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 NS Operations Program (CIP) 10/22/2020 100 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 NS Operations Media 10/22/2020 61 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 NS Operations (OFAC) 10/26/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 NS Operations (FCRA) Refresher 10/25/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 NS Operations Activity Reports 10/26/2020 80 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 NS Operations Theft - Review of Red 10/25/2020 94 Yes Completed 10/31/2019
Risk
2/1/2019 NS Operations FSC - Frauds and Scams 10/22/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004128
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 NS Operations Fair Lending Overview 10/22/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 NS Operations Bank Secrecy Act 10/22/2020 100 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 NS Operations (AML) 10/22/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 NS Operations Zdnu Unplugged: Privacy 8/7/2019 83 Yes Completed 10/31/2019
Risk
1/23/2019 NS Operations Unplugged: Phishing 10/22/2020 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 NS Operations Lending Overview 8/7/2019 70 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 NS Operations or Abusive Acts or 10/22/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 NS Operations Guidelines 8/7/2019 100 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 NS Operations Awareness 8/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 NS Operations (FCRA) Refresher 8/7/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 NS Operations Your Customer 8/7/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 NS Operations Lending Overview 8/7/2019 70 Yes Completed 12/1/2019
1/23/2019 OK Risk Analytics Zdnu Unplugged: Privacy 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 OK Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 OK Risk Analytics Guidelines 8/7/2019 86 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 OK Risk Analytics Awareness 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 OK Risk Analytics Your Customer 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 OK Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 OR Operations Program (CIP) 10/22/2020 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004129
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 OR Operations Media 10/25/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 OR Operations (OFAC) 10/25/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 OR Operations (FCRA) Refresher 10/25/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 OR Operations Activity Reports 10/25/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 OR Operations Theft - Review of Red 10/25/2020 100 Yes Completed 10/31/2019
Risk
2/1/2019 OR Operations FSC - Frauds and Scams 10/25/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 OR Operations Fair Lending Overview 10/25/2020 98 Yes Completed 10/31/2019
Risk
1/23/2019 OR Operations Bank Secrecy Act 10/22/2020 98 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 OR Operations (AML) 10/25/2020 98 Yes Completed 10/31/2019
Risk
1/23/2019 OR Operations Zdnu Unplugged: Privacy 8/7/2019 100 Yes Completed 10/31/2019
Risk
1/23/2019 OR Operations Unplugged: Phishing 10/25/2020 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 OR Operations Lending Overview 8/7/2019 90 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 OR Operations or Abusive Acts or 10/25/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 OR Operations Guidelines 8/7/2019 100 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 OR Operations Awareness 8/7/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 OR Operations (FCRA) Refresher 8/7/2019 62 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 OR Operations Your Customer 8/7/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 OR Operations Lending Overview 8/7/2019 90 Yes Completed 12/1/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004130
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Customer Identification
2/1/2019 OW Risk Analytics Program (CIP) 10/22/2020 100 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 OW Risk Analytics Media 10/22/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 OW Risk Analytics (OFAC) 10/27/2020 100 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 OW Risk Analytics (FCRA) Refresher 10/22/2020 100 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 OW Risk Analytics Activity Reports 10/27/2020 100 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 OW Risk Analytics Theft - Review of Red 10/25/2020 100 Yes Completed 10/31/2019
2/1/2019 OW Risk Analytics FSC - Frauds and Scams 10/22/2020 97 Yes Completed 10/31/2019
1/23/2019 OW Risk Analytics Fair Lending Overview 10/22/2020 96 Yes Completed 10/31/2019
1/23/2019 OW Risk Analytics Bank Secrecy Act 10/22/2020 98 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 OW Risk Analytics (AML) 10/22/2020 100 Yes Completed 10/31/2019
1/23/2019 OW Risk Analytics Zdnu Unplugged: Privacy 10/17/2019 100 Yes Completed 10/31/2019
1/23/2019 OW Risk Analytics Unplugged: Phishing 10/22/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 OW Risk Analytics Lending Overview 10/17/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 OW Risk Analytics or Abusive Acts or 10/22/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 OW Risk Analytics Guidelines 10/17/2019 95 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 OW Risk Analytics Awareness 10/17/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 OW Risk Analytics Your Customer 10/17/2019 94 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 OW Risk Analytics Lending Overview 10/17/2019 100 Yes Completed 12/1/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004131
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Customer Identification
2/1/2019 PE Compliance Program (CIP) 10/30/2020 100 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 PE Compliance Media 10/30/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 PE Compliance (OFAC) 10/30/2020 93 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 PE Compliance (FCRA) Refresher 10/30/2020 89 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 PE Compliance Activity Reports 10/30/2020 91 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 PE Compliance Theft - Review of Red 10/30/2020 100 Yes Completed 10/31/2019
2/1/2019 PE Compliance FSC - Frauds and Scams 10/30/2020 95 Yes Completed 10/31/2019
1/23/2019 PE Compliance Fair Lending Overview 10/30/2020 77 Yes Completed 10/31/2019
1/23/2019 PE Compliance Bank Secrecy Act 10/30/2020 85 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 PE Compliance (AML) 10/30/2020 95 Yes Completed 10/31/2019
1/23/2019 PE Compliance Zdnu Unplugged: Privacy 10/25/2019 97 Yes Completed 10/31/2019
1/23/2019 PE Compliance Unplugged: Phishing 10/30/2020 90 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 PE Compliance Lending Overview 10/25/2019 70 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 PE Compliance or Abusive Acts or 10/30/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 PE Compliance Guidelines 10/25/2019 81 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 PE Compliance Awareness 10/25/2019 100 Yes Completed 10/31/2019
2019 BV - Information
1/23/2019 PE Compliance Security Awareness 4/18/2019 100 Yes Completed 10/31/2019
Handling Consumer
2/2/2019 PE Compliance Complaints 10/25/2019 93 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/2/2019 PE Compliance (FCRA) Refresher 10/25/2019 77 Yes Completed 10/31/2019
Zdnu Unfair, Deceptive
or Abusive Acts or
Practices for the
2/2/2019 PE Compliance Financial Institution 10/25/2019 69 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004132
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 PE Compliance Refresher 10/25/2019 62 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 PE Compliance Your Customer 10/30/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 PE Compliance Lending Overview 10/25/2019 70 Yes Completed 12/1/2019
BV: Servicemembers Civil
2/2/2019 PE Compliance Relief Act (SCRA) 10/25/2019 83 Yes Completed 10/31/2019
Risk Customer Identification
2/1/2019 QP Operations Program (CIP) 10/30/2020 100 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 QP Operations Media 10/30/2020 89 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 QP Operations (OFAC) 10/30/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 QP Operations (FCRA) Refresher 10/30/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 QP Operations Activity Reports 10/30/2020 80 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 QP Operations Theft - Review of Red 10/30/2020 94 Yes Completed 10/31/2019
Risk
2/1/2019 QP Operations FSC - Frauds and Scams 10/30/2020 83 Yes Completed 10/31/2019
Risk
1/23/2019 QP Operations Fair Lending Overview 10/31/2020 93 Yes Completed 10/31/2019
Risk
1/23/2019 QP Operations Bank Secrecy Act 10/31/2020 93 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 QP Operations (AML) 10/31/2020 94 Yes Completed 10/31/2019
Risk
1/23/2019 QP Operations Unplugged: Phishing 10/31/2020 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 QP Operations or Abusive Acts or 10/31/2020 96 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 QP Operations (FCRA) Refresher 10/17/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 QP Operations Your Customer 11/1/2019 94 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004133
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
2/2/2019 QP Operations Lending Overview 10/22/2019 100 Yes Completed 12/1/2019
1/23/2019 RY Legal Fair Lending Overview 10/19/2020 78 Yes Completed 10/31/2019
1/23/2019 RY Legal Bank Secrecy Act 10/16/2020 76 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 RY Legal (AML) 10/16/2020 79 Yes Completed 10/31/2019
1/23/2019 RY Legal Unplugged: Phishing 10/20/2020 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 RY Legal or Abusive Acts or 10/20/2020 92 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 RY Legal Lending Overview 3/6/2020 90 Yes Completed
Customer Identification
2/1/2019 SB Risk Analytics Program (CIP) 10/26/2020 98 Yes Completed 10/31/2019
Understanding the FFIEC
Final Guidance on Social
2/1/2019 SB Risk Analytics Media 10/26/2020 94 Yes Completed 10/31/2019
Unplugged: Office of
Foreign Assets Control
2/1/2019 SB Risk Analytics (OFAC) 10/25/2020 78 Yes Completed 10/31/2019
Fair Credit Reporting Act
2/1/2019 SB Risk Analytics (FCRA) Refresher 10/26/2020 100 Yes Completed 10/31/2019
Unplugged: Suspicious
2/1/2019 SB Risk Analytics Activity Reports 10/26/2020 100 Yes Completed 10/31/2019
FSC - Identifying Identity
2/1/2019 SB Risk Analytics Theft - Review of Red 10/26/2020 100 Yes Completed 10/31/2019
2/1/2019 SB Risk Analytics FSC - Frauds and Scams 10/26/2020 97 Yes Completed 10/31/2019
1/23/2019 SB Risk Analytics Fair Lending Overview 10/25/2020 96 Yes Completed 10/31/2019
1/23/2019 SB Risk Analytics Bank Secrecy Act 10/25/2020 91 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 SB Risk Analytics (AML) 10/25/2020 90 Yes Completed 10/31/2019
1/23/2019 SB Risk Analytics Zdnu Unplugged: Privacy 8/7/2019 100 Yes Completed 10/31/2019
1/23/2019 SB Risk Analytics Unplugged: Phishing 10/26/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 SB Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 SB Risk Analytics or Abusive Acts or 10/25/2020 92 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 SB Risk Analytics Guidelines 8/7/2019 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004134
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
BV - Information Security
1/23/2019 SB Risk Analytics Awareness 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 SB Risk Analytics Your Customer 8/7/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 SB Risk Analytics Lending Overview 8/7/2019 100 Yes Completed 12/1/2019
Risk
1/23/2019 SC Strategies Fair Lending Overview 10/22/2020 76 Yes Completed 10/31/2019
Risk
1/23/2019 SC Strategies Bank Secrecy Act 10/19/2020 80 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 SC Strategies (AML) 10/7/2020 77 Yes Completed 10/31/2019
Risk
1/23/2019 SC Strategies Zdnu Unplugged: Privacy 10/4/2019 76 Yes Completed 10/31/2019
Risk
1/23/2019 SC Strategies Unplugged: Phishing 10/26/2020 90 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 SC Strategies Lending Overview 10/4/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 SC Strategies or Abusive Acts or 10/26/2020 88 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 SC Strategies Guidelines 10/11/2019 70 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 SC Strategies Awareness 10/21/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 SC Strategies Lending Overview 10/4/2019 100 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 SL Operations (FCRA) Refresher 10/29/2019 92 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 SL Operations (FCRA) Refresher 10/29/2019 92 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 SL Operations Your Customer 10/29/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 SL Operations Lending Overview 10/29/2019 100 Yes Completed 12/1/2019
1/23/2019 SN Collections Fair Lending Overview 9/3/2020 78 Yes Completed 10/31/2019
1/23/2019 SN Collections Bank Secrecy Act 9/11/2020 84 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 SN Collections (AML) 9/14/2020 90 Yes Completed 10/31/2019
1/23/2019 SN Collections Unplugged: Phishing 8/31/2020 80 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004135
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
FSC - Unfair, Deceptive,
1/23/2019 SN Collections or Abusive Acts or 9/1/2020 92 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 SN Collections Practices Act (FDCPA) 8/28/2020 95 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 SN Collections Lending Overview 10/2/2019 70 Yes Completed 12/1/2019
Risk Fair Credit Reporting Act
2/1/2019 ST Operations (FCRA) Refresher 10/8/2019 77 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 ST Operations (FCRA) Refresher 10/8/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 ST Operations Your Customer 10/8/2019 81 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 ST Operations Lending Overview 10/16/2019 90 Yes Completed 12/1/2019
1/23/2019 TL Collections Fair Lending Overview 9/25/2020 69 Yes Completed 10/31/2019
1/23/2019 TL Collections Bank Secrecy Act 9/14/2020 76 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 TL Collections (AML) 9/8/2020 83 Yes Completed 10/31/2019
1/23/2019 TL Collections Unplugged: Phishing 10/5/2020 80 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 TL Collections or Abusive Acts or 10/2/2020 85 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 TL Collections Practices Act (FDCPA) 10/20/2020 75 Yes Completed 10/31/2019
Risk Customer Identification
2/1/2019 TL Operations Program (CIP) 10/27/2020 95 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 TL Operations Media 10/26/2020 61 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 TL Operations (OFAC) 10/27/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 TL Operations (FCRA) Refresher 10/27/2020 77 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 TL Operations Activity Reports 10/27/2020 60 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 TL Operations Theft - Review of Red 10/27/2020 100 Yes Completed 10/31/2019
Risk
2/1/2019 TL Operations FSC - Frauds and Scams 10/27/2020 93 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004136
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 TL Operations Fair Lending Overview 10/29/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 TL Operations Bank Secrecy Act 10/29/2020 100 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 TL Operations (AML) 10/29/2020 96 Yes Completed 10/31/2019
Risk
1/23/2019 TL Operations Zdnu Unplugged: Privacy 10/31/2019 62 Yes Completed 10/31/2019
Risk
1/23/2019 TL Operations Unplugged: Phishing 10/27/2020 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 TL Operations Lending Overview 10/31/2019 70 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 TL Operations or Abusive Acts or 10/29/2020 96 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 TL Operations Guidelines 10/31/2019 93 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 TL Operations Awareness 10/31/2019 100 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 TL Operations Lending Overview 10/31/2019 70 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 TL Operations Program (CIP) 10/23/2020 68 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 TL Operations Media 10/23/2020 89 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 TL Operations (OFAC) 10/23/2020 74 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 TL Operations (FCRA) Refresher 10/23/2020 69 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 TL Operations Activity Reports 10/23/2020 70 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 TL Operations Theft - Review of Red 10/23/2020 72 Yes Completed 10/31/2019
Risk
2/1/2019 TL Operations FSC - Frauds and Scams 10/23/2020 72 Yes Completed 10/31/2019
Risk
1/23/2019 TL Operations Fair Lending Overview 11/2/2020 65 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004137
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk
1/23/2019 TL Operations Bank Secrecy Act 11/2/2020 62 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 TL Operations (AML) 11/2/2020 69 Yes Completed 10/31/2019
Risk
1/23/2019 TL Operations Unplugged: Phishing 11/2/2020 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 TL Operations or Abusive Acts or 11/2/2020 62 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 TL Operations (FCRA) Refresher 9/4/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 TL Operations Your Customer 9/4/2019 69 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 TL Operations Lending Overview 8/20/2019 80 Yes Completed 12/1/2019
Risk BV - Information Security
8/19/2019 TL Operations Awareness 9/3/2019 100 Yes Completed 11/17/2019
1612 - Fair and
1/23/2019 TO Risk Responsible Banking 0 No Incomplete 10/31/2019
Zdnu Fair Credit
1/23/2019 TO Risk Reporting Act (FCRA) - E3 0 No Incomplete 10/31/2019
BOD - Unfair, Deceptive,
or Abusive Acts or
1/23/2019 TO Risk Practices for the 0 No Incomplete 10/31/2019
BOD - Fair Lending
1/23/2019 TO Risk Overview 0 No Incomplete 10/31/2019
Zdnu Customer Due
Diligence and Enhanced
1/23/2019 TO Risk Due Diligence (CDD/EDD) 0 No Incomplete 10/31/2019
1/23/2019 TO Risk Zdnu Check Fraud 0 No Incomplete 10/31/2019
Anti-Money Laundering
(AML) / Bank Secrecy Act
1/23/2019 TO Risk (BSA) - E3 0 No Incomplete 10/31/2019
1/23/2019 TO Risk Zdnu Wire Transfers 0 No Incomplete 10/31/2019
Zdnu Automated
1/23/2019 TO Risk Clearing House (ACH) 0 No Incomplete 10/31/2019
Zdnu Red Flags of
1/23/2019 TO Risk Identity Theft 0 No Incomplete 10/31/2019
Zdnu California
1/23/2019 TO Risk Consumer Privacy Act 0 No Incomplete 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004138
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Unplugged: Office
of Foreign Assets Control
1/23/2019 TO Risk (OFAC) 0 No Incomplete 10/31/2019
Zdnu Unplugged:
1/23/2019 TO Risk Suspicious Activity 0 No Incomplete 10/31/2019
BV - Information Security
1/23/2019 TO Risk Awareness 0 No Incomplete 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 TR Operations (FCRA) Refresher 10/8/2019 62 Yes Completed 10/31/2019
Risk
1/23/2019 TR Operations Zdnu Unplugged: Privacy 10/8/2019 79 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
1/23/2019 TR Operations Lending Overview 10/8/2019 60 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 TR Operations Guidelines 10/8/2019 88 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 TR Operations Awareness 10/8/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 TR Operations (FCRA) Refresher 10/8/2019 62 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 TR Operations Lending Overview 10/8/2019 60 Yes Completed 12/1/2019
1/23/2019 TT Collections Fair Lending Overview 10/26/2020 100 Yes Completed 10/31/2019
1/23/2019 TT Collections Bank Secrecy Act 10/26/2020 100 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 TT Collections (AML) 10/20/2020 96 Yes Completed 10/31/2019
1/23/2019 TT Collections Unplugged: Phishing 10/29/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 TT Collections or Abusive Acts or 10/26/2020 100 Yes Completed 10/31/2019
Fair Debt Collection
2/2/2019 TT Collections Practices Act (FDCPA) 10/20/2020 100 Yes Completed 10/31/2019
1/23/2019 VF Legal Fair Lending Overview 10/31/2020 75 Yes Completed 10/31/2019
1/23/2019 VF Legal Bank Secrecy Act 10/30/2020 67 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 VF Legal (AML) 10/30/2020 75 Yes Completed 10/31/2019
1/23/2019 VF Legal Zdnu Unplugged: Privacy 10/25/2019 69 Yes Completed 10/31/2019
1/23/2019 VF Legal Unplugged: Phishing 10/31/2020 70 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004139
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Unplugged: Fair
1/23/2019 VF Legal Lending Overview 10/25/2019 70 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 VF Legal or Abusive Acts or 10/31/2020 81 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 VF Legal Guidelines 10/28/2019 77 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 VF Legal Awareness 10/28/2019 100 Yes Completed 10/31/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 VF Legal Refresher 10/29/2019 79 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 VF Legal Lending Overview 10/25/2019 70 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 YC Operations Program (CIP) 10/25/2020 100 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 YC Operations Media 10/25/2020 100 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 YC Operations (OFAC) 10/25/2020 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 YC Operations (FCRA) Refresher 10/25/2020 100 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 YC Operations Activity Reports 10/25/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 YC Operations Theft - Review of Red 10/25/2020 100 Yes Completed 10/31/2019
Risk
2/1/2019 YC Operations FSC - Frauds and Scams 10/22/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 YC Operations Fair Lending Overview 10/22/2020 98 Yes Completed 10/31/2019
Risk
1/23/2019 YC Operations Bank Secrecy Act 10/22/2020 100 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 YC Operations (AML) 10/22/2020 100 Yes Completed 10/31/2019
Risk
1/23/2019 YC Operations Zdnu Unplugged: Privacy 10/17/2019 100 Yes Completed 10/31/2019
Risk
1/23/2019 YC Operations Unplugged: Phishing 10/22/2020 90 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004140
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
1/23/2019 YC Operations Lending Overview 10/17/2019 100 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 YC Operations or Abusive Acts or 10/22/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Risk Customer Information
1/23/2019 YC Operations Guidelines 10/17/2019 95 Yes Completed 10/31/2019
Risk BV - Information Security
1/23/2019 YC Operations Awareness 10/17/2019 100 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/2/2019 YC Operations (FCRA) Refresher 10/17/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 YC Operations Your Customer 10/17/2019 94 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Fair
2/2/2019 YC Operations Lending Overview 10/17/2019 100 Yes Completed 12/1/2019
Handling Consumer
11/15/2019 YC Data Science Complaints 1/23/2020 93 Yes Completed 2/13/2020
BV - Information Security
11/15/2019 YC Data Science Awareness 1/23/2020 100 Yes Completed 2/13/2020
1/23/2019 YC Data Science Fair Lending Overview 10/30/2020 98 Yes Completed 10/31/2019
1/23/2019 YC Data Science Bank Secrecy Act 10/30/2020 98 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 YC Data Science (AML) 10/30/2020 96 Yes Completed 10/31/2019
1/23/2019 YC Data Science Unplugged: Phishing 10/30/2020 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 YC Data Science or Abusive Acts or 10/30/2020 100 Yes Completed 10/31/2019
1/23/2019 YE Risk Analytics Zdnu Unplugged: Privacy 9/25/2019 72 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 YE Risk Analytics Lending Overview 9/25/2019 80 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 YE Risk Analytics Guidelines 9/25/2019 88 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 YE Risk Analytics Awareness 9/25/2019 100 Yes Completed 10/31/2019
Zdnu Unplugged: Know
2/2/2019 YE Risk Analytics Your Customer 10/2/2019 81 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 YE Risk Analytics Lending Overview 9/25/2019 80 Yes Completed 12/1/2019
1/23/2019 ZC Legal Zdnu Unplugged: Privacy 5/14/2019 83 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004141
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Unplugged: Fair
1/23/2019 ZC Legal Lending Overview 5/14/2019 60 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 ZC Legal Guidelines 5/14/2019 88 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 ZC Legal Awareness 5/14/2019 100 Yes Completed 10/31/2019
Zdnu Right to Financial
Privacy Act (RFPA)
2/2/2019 ZC Legal Refresher 5/14/2019 77 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 ZC Legal Lending Overview 5/14/2019 60 Yes Completed 12/1/2019
1/23/2019 ZG Data Science Fair Lending Overview 10/12/2020 76 Yes Completed 10/31/2019
1/23/2019 ZG Data Science Bank Secrecy Act 10/12/2020 91 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 ZG Data Science (AML) 10/12/2020 94 Yes Completed 10/31/2019
1/23/2019 ZG Data Science Unplugged: Phishing 10/12/2020 90 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 ZG Data Science or Abusive Acts or 10/15/2020 92 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
2/2/2019 ZG Data Science Lending Overview 10/30/2019 100 Yes Completed 12/1/2019
1/23/2019 ZN Data Science Fair Lending Overview 10/18/2020 96 Yes Completed 10/31/2019
1/23/2019 ZN Data Science Bank Secrecy Act 10/18/2020 93 Yes Completed 10/31/2019
Anti-money Laundering
1/23/2019 ZN Data Science (AML) 10/18/2020 98 Yes Completed 10/31/2019
1/23/2019 ZN Data Science Zdnu Unplugged: Privacy 9/26/2019 97 Yes Completed 10/31/2019
1/23/2019 ZN Data Science Unplugged: Phishing 10/18/2020 100 Yes Completed 10/31/2019
Zdnu Unplugged: Fair
1/23/2019 ZN Data Science Lending Overview 9/26/2019 100 Yes Completed 10/31/2019
FSC - Unfair, Deceptive,
1/23/2019 ZN Data Science or Abusive Acts or 10/18/2020 100 Yes Completed 10/31/2019
Zdnu FSC - Security of
Customer Information
1/23/2019 ZN Data Science Guidelines 9/26/2019 100 Yes Completed 10/31/2019
BV - Information Security
1/23/2019 ZN Data Science Awareness 9/26/2019 100 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004142
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Zdnu Unplugged: Fair
2/2/2019 ZN Data Science Lending Overview 9/26/2019 100 Yes Completed 12/1/2019
Risk Customer Identification
2/1/2019 ZT Operations Program (CIP) 10/23/2020 78 Yes Completed 10/31/2019
Understanding the FFIEC
Risk Final Guidance on Social
2/1/2019 ZT Operations Media 10/23/2020 67 Yes Completed 10/31/2019
Unplugged: Office of
Risk Foreign Assets Control
2/1/2019 ZT Operations (OFAC) 10/22/2020 91 Yes Completed 10/31/2019
Risk Fair Credit Reporting Act
2/1/2019 ZT Operations (FCRA) Refresher 10/23/2020 85 Yes Completed 10/31/2019
Risk Unplugged: Suspicious
2/1/2019 ZT Operations Activity Reports 10/22/2020 100 Yes Completed 10/31/2019
Risk FSC - Identifying Identity
2/1/2019 ZT Operations Theft - Review of Red 10/23/2020 83 Yes Completed 10/31/2019
Risk
2/1/2019 ZT Operations FSC - Frauds and Scams 10/23/2020 83 Yes Completed 10/31/2019
Risk
1/23/2019 ZT Operations Fair Lending Overview 10/22/2020 73 Yes Completed 10/31/2019
Risk
1/23/2019 ZT Operations Bank Secrecy Act 10/8/2020 78 Yes Completed 10/31/2019
Risk Anti-money Laundering
1/23/2019 ZT Operations (AML) 10/8/2020 77 Yes Completed 10/31/2019
Risk
1/23/2019 ZT Operations Unplugged: Phishing 10/22/2020 80 Yes Completed 10/31/2019
Risk FSC - Unfair, Deceptive,
1/23/2019 ZT Operations or Abusive Acts or 10/22/2020 92 Yes Completed 10/31/2019
Risk BV - Information Security
6/3/2019 ZT Operations Awareness 6/14/2019 100 Yes Completed 9/1/2019
Risk Fair Credit Reporting Act
2/2/2019 ZT Operations (FCRA) Refresher 10/2/2019 77 Yes Completed 10/31/2019
Risk Zdnu Unplugged: Know
2/2/2019 ZT Operations Your Customer 10/2/2019 63 Yes Completed 10/31/2019
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004143
Course Course Training
Completion Completion Program
Enroll Date Employee* Job Role Course Date Score Pass Status** Due Date
Risk Zdnu Unplugged: Fair
2/2/2019 ZT Operations Lending Overview 6/14/2019 80 Yes Completed 12/1/2019
*Employees have been identified by their initials for privacy purposes.
**Certain individuals listed herein might be marked "Incomplete" under "Course Completion Status" due to a short
duration of employment or due to the timing of their employment. For instance, if someone departs the Company
in early Q1, then that individual would not have completed trainings for that year. Moreover, certain individuals
included in the counts listed in BV_SSCC_0004092 might not be included herein due to length of employment or
timing of termination.
CONFIDENTIAL AND PROPRIETARY BV_SSCC_0004144
BlueVine
Risk Flex Line of Credit
Policy
February2019
This document should be reviewed at least once a quarter and approved by BlueVine’s Chief
Risk and Chief Compliance Officers. Material changes should be reported and approved by
third parties as advised by the legal department:
Role Name Approval Date
Chief Risk Officer
Chief Compliance Officer
1 | Page
CONFIDENTIAL & PROPRIETARY BV_SSCC_0005319
Additional requirements
• Bluevine shall file and maintain a UCC1 all-asset lien on any client with an
outstanding balance and a Flex CL of at least $35K
• UCC3 files supplied by client to prove BlueVine’s potential secured position must be
stamped by the relevant secretary of state
• Clients who sign up as a sole-proprietor that is found to have a registered
(incorporated) entity for the same business must switch to working with us
(contracts, PG etc.) under the incorporated entity, regardless of if we’ve identified
the registered entity prior to onboarding, during onboarding process or after the
client has already been onboarded.
• Ownership requirements definition:
○ A user can sign BV agreements if they are one of these confirmed roles:
▪ Majority Owner (must have highest or equal to highest stake in the
company)
▪ President
▪ CEO
○ This must be confirmed on TLO, SOS, or acceptable web presence (e.g.
Hoovers or company website or other external source. Personal LinkedIn not
acceptable).
○ For lower credit lines of $50K and under, we can also accept COO or CFO
and any owner or registered agent.
○ BlueVine will not fund businesses owned by family members of existing
BlueVine employees
○ Bluevine will not fund businesses that went through ownership change in
past 3 months
8 | Page
CONFIDENTIAL & PROPRIETARY BV_SSCC_0005320
Full text shows the first 300 of 326 pages; the complete document is the PDF above.