First Fed Bank
Port Angeles, Washington
On November 29, 2023, the FDIC issued a consent order against First Fed Bank, a subsidiary of First Northwest Bancorp, for unsafe or unsound banking practices, deceptive acts, and violations of the Federal Trade Commission Act related to its joint venture with Quin Ventures, a fintech financial wellness platform launched in 2021. Issues included misrepresenting credit products as unemployment insurance, approving unqualified consumers for credit, and providing inaccurate fee disclosures. Remedies required enhanced third-party oversight, board-level involvement in compliance, prior regulatory approval for new third-party agreements, review of marketing materials, and robust processes for consumer complaints and protection law compliance. The bank had already ended the Quin Ventures partnership in 2022 and provided customer remediation. First Fed committed to implementing internal controls without admitting wrongdoing.
Verified from source: The FDIC issued a consent order against First Fed Bank (subsidiary of First Northwest Bancorp) for unsafe or unsound banking practices and deceptive and unfair acts in connection with its joint venture with Quin Ventures, including misrepresenting credit products as unemployment insurance, approving unqualified consumers for debt cancellation features, and misrepresenting fees and benefits in violation of the FTC Act.
- Demonstrates FDIC willingness to pursue enforcement actions against banks for fintech partner misconduct even after the partnership has ended
- Signals heightened regulatory expectations for board-level oversight of fintech joint ventures
- Establishes precedent that banks must obtain prior regulatory approval before entering new third-party fintech agreements post-enforcement
- Reinforces that banks bear ultimate responsibility for consumer protection in BaaS and fintech partnership models
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