Umpqua Bank
In May 2021, the FDIC imposed a $1.8 million civil money penalty against a bank for unfair or deceptive acts or practices (UDAP) violations in connection with commercial debt collection. The source references this enforcement action but does not provide the specific bank name in the available excerpt. While this action is related to UDAP rather than third-party risk management specifically, UDAP enforcement against banks is a common vector through which BaaS and fintech partnership activities come under regulatory scrutiny. The fine signals the FDIC's willingness to pursue meaningful penalties for consumer protection violations. Further verification against FDIC enforcement databases is needed to identify the specific institution involved.
Verified from source: The FDIC announced a settlement with Umpqua Bank requiring payment of a $1.8 million civil money penalty for UDAP violations related to collection practices on commercial equipment financing offered by the bank's wholly-owned subsidiary, including charging undisclosed collection fees and engaging in excessive collection calls.
- FDIC actively pursuing UDAP enforcement actions that could apply to BaaS-facilitated lending and collections
- Banks partnering with fintechs must ensure collection practices by third parties comply with UDAP standards