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OCC order for a civil money penalty, Bank of America, N.A., AA-ENF-2022-22

Cited in: Pondera's 1.1 Million Flags · The Filter That Froze California

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                                                                                   #2022-024

                          UNITED STATES OF AMERICA
                        DEPARTMENT OF THE TREASURY
                OFFICE OF THE COMPTROLLER OF THE CURRENCY


In the Matter of:                                              )
                                                               )
Bank of America, N.A.                                          )          AA-ENF-2022-22
Charlotte, North Carolina                                      )
                                                               )

                                      CONSENT ORDER

       WHEREAS, the Office of the Comptroller of the Currency (“OCC”) has supervisory

authority over Bank of America, N.A., Charlotte, North Carolina (“Bank”);

       WHEREAS, the OCC intends to initiate civil money penalty proceedings against the

Bank pursuant to 12 U.S.C. § 1818(i), through the issuance of a Notice of Assessment of a Civil

Money Penalty, related to: (1) the administration of the Bank’s prepaid cards for unemployment

benefits, specifically engagement in (i) unsafe or unsound practice(s), including deficiencies in

its risk management, operational processes and controls, internal audit, and investigation and

resolution of consumer claims of unauthorized transactions; and (ii) unfair and deceptive

practices in violation(s) of Section 5 of the Federal Trade Commission Act (“FTC Act”), 15

U.S.C. § 45(a)(1); and (2) engaging in unsafe or unsound practices related to deficiencies in its

enterprise-wide complaints risk management framework;

       WHEREAS, in the interest of cooperation and to avoid additional costs associated with

administrative and judicial proceedings with respect to the above matter, the Bank, by and

through its duly elected and acting Board of Directors (“Board”), consents to the issuance of this

Consent Order (“Order”), by the OCC through the duly authorized representative of the

Comptroller of the Currency (“Comptroller”); and

       NOW, THEREFORE, pursuant to the authority vested in the OCC by Section 8(i) of the
Federal Deposit Insurance Act, as amended, 12 U.S.C. § 1818(i), the OCC hereby orders that:

                                          ARTICLE I

                                       JURISDICTION

        (1)     The Bank is an “insured depository institution” as that term is defined in

 12 U.S.C. § 1813(c)(2).

        (2)     The Bank is a national banking association within the meaning of 12 U.S.C.

§ 1813(q)(1)(A), and is chartered and examined by the OCC. See 12 U.S.C. § 1 et seq.

        (3)     The OCC is the “appropriate Federal banking agency” as that term is defined in

12 U.S.C. § 1813(q) and is therefore authorized to initiate and maintain this civil money penalty

action against the Bank pursuant to 12 U.S.C. § 1818(i).

                                          ARTICLE II

                               COMPTROLLER’S FINDINGS

       The Comptroller finds, and the Bank neither admits nor denies, the following:

       (1)     For several years, the Bank issued and administered prepaid debit cards to

distribute unemployment insurance benefits (“UI Prepaid Cards”) to consumers that were loaded

with benefit funds issued by certain states, hereinafter referred to as the Unemployment Benefits

Prepaid Card Program (“Program”).

       (2)     In March 2020, millions became unemployed and Congress enacted the

Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which created the new

Pandemic Unemployment Assistance (“PUA”) benefit. The CARES Act and PUA expanded

unemployment benefits eligibility and provided greater benefit amounts than previously

available. As a result, the size of the Program increased substantially (from under one million

unique cards loaded in January 2020 to over six million in July 2020), as did the volume of



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benefits issued by the states and loaded onto UI Prepaid Cards (from approximately $1 billion in

January 2020 to over $27 billion in July 2020). Along with the increases in Program participants

and benefits, the Program experienced an increase in fraud, including with respect to

unauthorized transaction claims.

       (3)    The Bank failed to establish effective risk management over the Program, and,

beginning in 2020, denied or delayed many consumers’ access to unemployment benefits when

consumers filed or attempted to file UI Prepaid Card unauthorized transaction claims.

Specifically, the Bank:

              (a)     applied an automated fraud filter between September 28, 2020 and June 8,

                      2021 to decision UI Prepaid Card error claims that met certain criteria

                      (“Fraud Filter”) without conducting a sufficient investigation to: (i) deny

                      many consumers’ claims of unauthorized transactions on their UI Prepaid

                      Cards, and (ii) “freeze” or “block” the UI Prepaid Card accounts

                      associated with the claims. Consumers with frozen or blocked accounts

                      could not access the unemployment benefits in their UI Prepaid Card

                      accounts until the Bank removed the freeze or block.

              (b)     failed to provide timely and full provisional or final credit to many

                      consumers entitled to such credits who reported unauthorized transactions

                      on their UI Prepaid Card accounts.

              (c)     retroactively applied the Fraud Filter to many consumers’ claims of

                      unauthorized transactions on their UI Prepaid Card accounts without

                      conducting further investigation and providing advance notice, which

                      incorrectly resulted in the reversal of provisional and final credits that the



                                                3
                      Bank previously provided to those consumers.

              (d)     impeded many consumers’ ability to regain access to their unemployment

                      benefits through the UI Prepaid Cards and to request reconsideration of

                      their unauthorized transaction claims as a result of operational

                      deficiencies.

              (e)     provided consumers deceptive disclosures and notices with respect to

                      liability for unauthorized transactions, processing of unauthorized

                      transaction claims, and account freezes and blocks.

       (4)    Overall, the Bank has the following deficiencies in its administration of the

Program:

              (a)     inadequate risk management practices in both the front-line units and

                      independent risk management, including ineffective oversight, risk

                      assessment, monitoring, and reporting;

              (b)     inadequate internal controls, including those relating to contract

                      management;

              (c)     inadequate oversight, risk management, and monitoring of UI Prepaid

                      Card unemployment benefits vendors (“Program Vendors”); and

              (d)     inadequate oversight and coverage by the Bank’s independent audit

                      function.

       (5)    In addition, the Bank failed to establish an effective enterprise-wide complaints

risk management framework that is commensurate with the Bank’s size, complexity, and risk

profile. Specifically, the complaint risk management framework lacks an effective:

              (a)     process to identify, measure, manage, and report complaints;



                                                4
               (b)    complaint resolution process; and

               (c)    quality assurance process.

         (6)   By reason of the deficiencies and conduct described in Paragraphs (2) through (5)

of this Article, the Bank engaged in unsafe or unsound practices and engaged in unfair and

deceptive practices in Section 5 of the FTC Act, 15 U.S.C. §45(a). These violations and practices

support actions against the Bank under 12 U.S.C. § 1818(b) and (i)(2)(B).

         (7)   The Bank has begun taking corrective actions and has committed to taking

necessary and appropriate steps to remedy the deficiencies identified by the OCC and to assist

and remediate harmed consumers.

                                        ARTICLE III

                        ORDER FOR A CIVIL MONEY PENALTY

         (1)   The Bank shall make payment of a civil money penalty in the total amount of one

hundred twenty-five million ($125,000,000) which shall be paid upon the execution of this

Order.

         (2)   Such payment shall be made by a wire transfer sent in accordance with

instructions provided by the OCC and the docket number of this case (AA-ENF-2022-22) shall

be entered on the wire confirmation. A photocopy of the wire confirmation shall be sent

immediately, by overnight delivery, to the Director of Enforcement and Compliance, Office of

the Comptroller of the Currency, 400 7 th Street, S.W., Washington, D.C. 20219.

                                         ARTICLE IV

                                          WAIVERS

         (1)   The Bank, by executing and consenting to this Order, waives:




                                               5
              (a)    any and all rights to the issuance of a Notice of Charges pursuant to

                     12 U.S.C. § 1818;

              (b)    any and all procedural rights available in connection with the issuance of

                     this Order;

              (c)    any and all rights to a hearing and a final agency decision pursuant to

                     12 U.S.C. § 1818 and 12 C.F.R. Part 19;

              (d)    any and all rights to seek any type of administrative or judicial review of

                     this Order;

              (e)    any and all claims for fees, costs, or expenses against the OCC, or any of

                     its officers, employees, or agents related in any way to this enforcement

                     matter or this Order, whether arising under common law or under the

                     terms of any statute, including, but not limited to, the Equal Access to

                     Justice Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412;

              (f)    any and all rights to assert these proceedings, the consent to and/or the

                     issuance of this Order, as the basis for a claim of double jeopardy in any

                     pending or future proceedings brought by the United States Department of

                     Justice or any other governmental entity; and

              (g)    any and all rights to challenge or contest the validity of this Order.

                                         ARTICLE V

                                          CLOSING

       (1)     This Order is a settlement of the civil money penalty proceedings against the

Bank contemplated by the OCC, based on the unsafe or unsound practices and violations of law

described in the Comptroller’s Findings set forth in Article II of this Order. The OCC releases



                                               6
and discharges the Bank from all potential liability for a civil money penalty order that has been

or might have been asserted by the OCC based on the practices and/or violations described in

Article II of this Order, to the extent known to the OCC as of the effective date of this Order.

Nothing in this Order, however, shall prevent the OCC from:

              (a)     instituting enforcement actions other than a civil money penalty order

                      against the Bank based on the Comptroller’s Findings set forth in Article

                      II of this Order;

              (b)     instituting enforcement actions against the Bank based on any other

                      findings;

              (c)     instituting enforcement actions against institution-affiliated parties (as

                      defined by 12 U.S.C. § 1813(u)) based on the Comptroller’s Findings set

                      forth in Article II of this Order, or any other findings; or

              (d)     utilizing the Comptroller’s Findings set forth in Article II of this Order in

                      future enforcement actions against the Bank or its institution-affiliated

                      parties to establish a pattern or the continuation of a pattern.

       (2)     Nothing in this Order is a release, discharge, compromise, settlement, dismissal,

or resolution of any actions, or in any way affects any actions that may be or have been brought

by any other representative of the United States or an agency thereof, including, without

limitation, the United States Department of Justice.

       (3)     This Order is:

              (a)     an “order issued with the consent of the depository institution” within the

                      meaning of 12 U.S.C. § 1818(h)(2);




                                                 7
               (b)     an “effective and outstanding . . . order” within the meaning of 12 U.S.C.

                       § 1818(i)(1); and

               (c)     a “final order” within the meaning of 12 U.S.C. § 1818(i)(2) and (u).

        (4)     This Order is effective upon its issuance by the OCC, through the Comptroller’s

 duly authorized representative.

        (5)     This Order is not a contract binding on the United States, the United States

 Treasury Department, the OCC, or any officer, employee, or agent of the OCC and neither the

 Bank nor the OCC intends this Order to be a contract.

        (6)     No separate promise or inducement of any kind has been made by the OCC, or

 by its officers, employees, or agents, to cause or induce the Bank to consent to the issuance of

 this Order.

        (7)     The terms of this Order, including this paragraph, are not subject to amendment

 or modification by any extraneous expression, prior agreements, or prior arrangements between

 the parties, whether oral or written.



IN TESTIMONY WHEREOF, the undersigned, authorized by the Comptroller as his duly

authorized representative, has hereunto set her signature on behalf of the Comptroller.


 //s// Digitally Signed, Dated: 2022.07.14


 Tanya K. Smith
 Deputy Comptroller
 Large Bank Supervision




                                                8
IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of

Directors of the Bank of America, N.A., Charlotte, North Carolina have hereunto set their

signatures on behalf of the Bank.

 /s/                                                              07/12/22

 Brian T. Moynihan                                                Date

 /s/                                                              13 Jul, 2022

 Sharon L. Allen                                                  Date

 /s/                                                              13 Jul, 2022

 Frank P. Bramble, Sr.                                            Date

 /s/                                                              13 Jul, 2022

 Pierre J.P. de Weck                                              Date

 /s/                                                              07/13/2022

 Arnold W. Donald                                                 Date

 /s/                                                              13 Jul, 2022

 Linda P. Hudson                                                  Date

 /s/                                                              12 Jul, 2022

 Monica C. Lozano                                                 Date

 /s/                                                              12 Jul, 2022

 Lionel L. Nowell, III                                            Date

 /s/                                                              12 Jul, 2022

 Denise L. Ramos                                                  Date

 /s/                                                              13 Jul, 2022

 Clayton S. Rose                                                  Date




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/s/                     12 Jul, 2022

Michael D. White        Date

/s/                     13 Jul, 2022

Thomas D. Woods         Date

/s/                     12 Jul, 2022

R. David Yost           Date

/s/                     07/13/2022

Maria T. Zuber          Date




                   10


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