Is an “Add-on Compliance Plan” a New Off-shoot of CFPB’s Omaha Settlement?
First National Bank of Omaha was hit with $27.75 million in restitution, plus $4.5 million in civil money penalties for what the CFPB is considers unfair or deceptive acts in connection with the marketing and sale of credit card add-on products. The order prohibits the bank from marketing any more such products until it submits an "Add-on Compliance Plan" to the CFPB and receives "a determination of non-objection." [8/29/16]