[sheet: Instructions]
Section | Content
Purpose | This template is a standardized risk assessment tool prepared by Calderwood & Harkness LLP (C&H Matter No. 1045-00002) for use by Belmont Ridge Bank National Association (OCC Charter No. 48271; FDIC Certificate No. 31845) in evaluating the BSA/AML and sanctions risk profiles of each of its 14 active Banking-as-a-Service (BaaS) fintech partners. It is designed for quarterly completion as part of BRB's enhanced BaaS compliance oversight framework, in accordance with the requirements of OCC Consent Order No. OCC-2025-003 (effective January 15, 2025).
Frequency | Quarterly (Q1: Jan–Mar; Q2: Apr–Jun; Q3: Jul–Sep; Q4: Oct–Dec). Initial baseline assessments to be completed by March 31, 2025 for all 14 active partners.
Responsible Parties | Primary: Warren Ashby, Head of Fintech Partnerships / BaaS Division, in coordination with Thomas Ikeda, BSA Officer / AML Program Director, and Patricia Langston, Chief Compliance Officer. Review/Approval: Compliance Committee (Chair: James Rutherford). Oversight: Calderwood & Harkness LLP (Philip Hartmann, Responsible Partner) and Thornfield Consulting Group LLC (Dr. Vivian Castellano, Managing Director).
Scoring Methodology | Each risk category is scored on a 1–5 scale: 1 = Low Risk, 2 = Low-Moderate Risk, 3 = Moderate Risk, 4 = Moderate-High Risk, 5 = High Risk. The Overall Risk Rating is the weighted average of all category scores, rounded to one decimal place, then mapped to a tier: 1.0–1.9 = Low; 2.0–2.9 = Low-Moderate; 3.0–3.4 = Moderate; 3.5–4.4 = Moderate-High; 4.5–5.0 = High. Partners rated Moderate-High or High require Enhanced Due Diligence (EDD) and escalated reporting to the Compliance Committee monthly.
Regulatory Context | This assessment supports remediation of Consent Order deficiency categories including: (i) inadequate OFAC sanctions screening for BaaS transaction flows, (ii) deficient SAR filing timeliness and quality, (iii) insufficient CDD/EDD for high-risk customers onboarded through fintech partners, and (iv) board-level oversight deficiencies. BaaS-related SARs represented 54.8% of all SARs filed by BRB in CY 2024 (2,108 of 3,847 total). Total BaaS transaction volume in CY 2024 was approximately $74.3 billion, generating $127.4 million in revenue to BRB.
Distribution | Completed assessments are to be provided to the Compliance Committee, Audit Committee (Chair: Margaret Dao), Risk Committee (Chair: Arthur Connelly), the BSA Officer, the Chief Compliance Officer, Calderwood & Harkness LLP, and Thornfield Consulting Group LLC. Completed assessments should also be maintained in BRB's regulatory examination files for OCC review.
Definitions | BaaS = Banking-as-a-Service; BSA = Bank Secrecy Act; AML = Anti-Money Laundering; CDD = Customer Due Diligence; EDD = Enhanced Due Diligence; SAR = Suspicious Activity Report; CTR = Currency Transaction Report; OFAC = Office of Foreign Assets Control; MSB = Money Services Business; PEP = Politically Exposed Person; TMS = Transaction Monitoring System; CMP = Civil Money Penalty.
Completion Instructions | For each BaaS partner, the Assessor should: (1) review all available data including transaction volumes, SAR filings, CDD/EDD compliance status, OFAC screening results, and geographic exposure; (2) assign a score of 1–5 for each of the 8 risk categories using the criteria defined in the Risk Category Definitions sheet; (3) document supporting notes for each score; (4) verify the weighted average calculation; and (5) submit the completed assessment to the Reviewer for sign-off. All assessments must be completed within 30 days of quarter-end.
Escalation Procedures | If any partner receives an Overall Risk Rating of Moderate-High (3.5–4.4) or High (4.5–5.0), the Assessor must immediately notify the BSA Officer (Thomas Ikeda) and the Chief Compliance Officer (Patricia Langston). Enhanced Due Diligence must be initiated within 15 business days, and a written report must be submitted to the Compliance Committee within 30 calendar days. Partners rated High for two consecutive quarters must be referred for potential relationship termination review.
Version History | v1.0 — Prepared by Calderwood & Harkness LLP, February 2025. Approved by Philip Hartmann, Partner, Calderwood & Harkness LLP, and Patricia Langston, Chief Compliance Officer, Belmont Ridge Bank NA.
[sheet: Risk Category Definitions]
Risk Category | Weight (%) | Description | Score 1 — Low | Score 2 — Low-Moderate | Score 3 — Moderate | Score 4 — Moderate-High | Score 5 — High
Transaction Type & Complexity | 15% | Nature and complexity of transaction types processed through BRB's charter (wire, ACH, card, P2P, lending, deposits). Higher complexity and cross-border transactions increase risk. | Single domestic transaction type; low complexity | Primarily domestic; limited transaction types | Multiple domestic transaction types; some cross-border | Multiple transaction types including cross-border wires and ACH; complex payment flows | Highly complex multi-channel flows including international wires, P2P, and nested payment arrangements
Transaction Volume (Annual $) | 15% | Dollar volume of transactions processed through BRB in the assessment period. Reference: Total BaaS volume CY 2024 was $74.3B across 14 partners. | < $500M | $500M – $2B | $2B – $10B | $10B – $30B | > $30B
Transaction Count (Annual) | 10% | Number of individual transactions processed through BRB's systems. Higher volumes increase screening and monitoring burden. | < 1M transactions | 1M – 5M transactions | 5M – 15M transactions | 15M – 30M transactions | > 30M transactions
Customer Base Size & Type | 10% | Number and nature of end-user accounts; consumer vs. business; presence of high-risk customer types (MSBs, PEPs, high-net-worth, foreign nationals). | < 50,000 accounts; low-risk consumer only | 50,000 – 250,000 accounts; primarily low-risk consumer | 250,000 – 1M accounts; mix of consumer and small business | 1M – 3M accounts; significant business or high-risk segments | > 3M accounts or significant high-risk customer segments
Geographic Exposure | 10% | Geographic distribution of partner's customer base and transaction flows; domestic vs. international; presence of OFAC-sanctioned or high-risk jurisdictions. | Exclusively domestic; no high-risk state exposure | Primarily domestic; minimal international exposure | Domestic with some international transactions; no sanctioned jurisdictions | Significant international exposure; some high-risk jurisdictions | Substantial international exposure; transactions involving or near OFAC-sanctioned jurisdictions
OFAC Sanctions Risk | 15% | Risk of sanctions exposure based on transaction type, geography, customer base, and historical screening performance. Reference: BRB's OFAC screening gap affected approximately 12% of NovaPay transactions in CY 2023 (~3.8M of 31.7M unscreened). | No international exposure; fully domestic consumer product | Limited international exposure; no known screening gaps | Some international exposure; screening gaps identified but remediated | International exposure with identified screening gaps or near-misses; remediation in progress | Significant international exposure; material screening gaps identified; transactions involving high-risk corridors or jurisdictions
Historical SAR Activity | 15% | Volume and trend of SARs filed related to the partner's customer base and transaction activity. Reference: BaaS-related SARs were 2,108 of 3,847 total BRB SARs in CY 2024 (54.8%). | 0–10 SARs in trailing 12 months | 11–50 SARs in trailing 12 months; stable or declining trend | 51–200 SARs in trailing 12 months | 201–500 SARs in trailing 12 months; increasing trend | > 500 SARs in trailing 12 months or significant year-over-year increase
CDD/EDD Compliance Status | 10% | Adequacy of customer due diligence and enhanced due diligence documentation for the partner's customer accounts held at BRB. Reference: 47,000 high-risk accounts lacked adequate CDD/EDD as of OCC examination (Sept 2024), primarily BaaS-onboarded. | 100% CDD/EDD compliant; no deficiencies identified | > 95% compliant; minor documentation gaps | 90–95% compliant; remediation underway | 75–90% compliant; significant gaps; active remediation required | < 75% compliant; material CDD/EDD deficiencies
[sheet: Partner Assessment]
Partner # | Partner Legal Name | Partner Short Name | Entity Type | Jurisdiction | CEO / Primary Contact | Address | Onboarding Year | Product / Service Description | End-User Account Count | Annual Transaction Volume — $ | % of Total BaaS Volume (%) | Annual Loan Originations via BRB — $ | Assessment Period | Assessment Date | Assessor Name | Transaction Type & Complexity — Score (1–5) | Transaction Type & Complexity — Notes | Transaction Volume ($) — Score (1–5) | Transaction Volume ($) — Notes | Transaction Count — Score (1–5) | Transaction Count — Notes | Customer Base Size & Type — Score (1–5) | Customer Base Size & Type — Notes | Geographic Exposure — Score (1–5) | Geographic Exposure — Notes | OFAC Sanctions Risk — Score (1–5) | OFAC Sanctions Risk — Notes | Historical SAR Activity — Score (1–5) | Historical SAR Activity — Notes | CDD/EDD Compliance Status — Score (1–5) | CDD/EDD Compliance Status — Notes | Weighted Average Score | Overall Risk Rating Tier | EDD Required? (Yes/No) | Escalation to Compliance Committee Required? (Yes/No) | Reviewer Name | Reviewer Title | Review Date | Comments / Action Items
1 | NovaPay Technologies Inc. | NovaPay | Corporation | Delaware | Ethan Garrison, CEO | 450 Mission Street, Suite 1200, San Francisco, CA 94105 | 2021 | Consumer payments and P2P transfer application | 2100000 | 30500000000 | 41% | N/A | Q1 2025 | 5 | P2P and consumer payments; wire and ACH flows; high complexity due to volume and cross-border P2P functionality | 5 | $30.5B in CY 2024; largest BaaS partner by volume (41% of total $74.3B) | 5 | 31.7M transactions in CY 2023; highest count among BaaS partners | 4 | Approximately 2.1 million end-user accounts; consumer-focused but high volume | 3 | Domestic focus with some international P2P corridors | 5 | OFAC screening gap identified: approximately 3,800,000 transactions (12.0% of 31.7M) were unscreened in CY 2023; primary driver of Consent Order OFAC finding | 5 | Significant contributor to BaaS-related SARs; NovaPay-related SARs tracked separately; estimated >500 SARs in trailing 12 months | 5 | Material CDD/EDD deficiencies identified among NovaPay-onboarded accounts within the 47,000 high-risk account remediation population; estimated <75% compliant | 4.7 | High | Yes | Yes | Remediate OFAC screening gap; complete CDD/EDD for NovaPay-onboarded high-risk accounts; implement enhanced transaction monitoring; monthly escalation reporting required
2 | FairLend Digital LLC | FairLend | Limited Liability Company | Delaware | Aisha Okonkwo, CEO | 100 Summer Street, Suite 800, Boston, MA 02110 | 2022 | Online small-business lending platform | N/A | 20804000000 | 28% | 1400000000 | Q1 2025 | 3 | Small-business lending; loan originations processed through BRB charter; moderate complexity | 5 | 28% of total BaaS volume; approximately $20.8B in CY 2024 ($74.3B × 28%) | 3 | Estimated 8M–12M transactions annually based on lending volume | 4 | Business customers; small-business lending inherently carries higher risk (MSB, beneficial ownership complexity) | 2 | Primarily domestic small-business lending | 3 | Some international beneficial owners among small business applicants; no material screening gaps identified but remediation monitoring ongoing | 4 | FairLend-related SARs estimated at 201–500 in trailing 12 months; increasing trend due to business lending fraud patterns | 4 | FairLend-onboarded accounts included in the CDD/EDD remediation population; approximately 75–90% compliant; approximately $1.4B in loan originations through BRB in FY 2024 | 3.6 | Moderate-High | Yes | Yes | Complete CDD/EDD for FairLend-onboarded accounts; review lending origination BSA controls; enhance beneficial ownership verification procedures
3 | VaultEdge Inc. | VaultEdge | Corporation | Delaware | Marcus Tan, CEO | 2200 Ross Avenue, Suite 3600, Dallas, TX 75201 | 2023 | Digital savings and neobanking platform | 870000 | 13374000000 | 18% | N/A | Q1 2025 | 3 | Deposit accounts; savings products; moderate complexity; ACH and card transactions | 4 | 18% of total BaaS volume; approximately $13.4B in CY 2024 ($74.3B × 18%) | 3 | Estimated 6M–10M transactions annually | 3 | Approximately 870,000 deposit accounts; consumer-focused neobanking; some high-net-worth segments | 2 | Primarily domestic digital banking; minimal international exposure | 3 | Limited international exposure; some screening gaps identified in early onboarding period but largely remediated | 3 | Estimated 51–200 SARs in trailing 12 months; stable trend | 4 | VaultEdge-onboarded accounts included in CDD/EDD remediation population; estimated 75–90% compliant | 3.2 | Moderate | No | No | Complete CDD/EDD for VaultEdge-onboarded accounts; continue monitoring SAR trends; validate OFAC screening coverage
4 | SwiftCard Financial Inc. | SwiftCard | Corporation | Nevada | Diana Morales, CEO | 3900 Paradise Road, Suite 200, Las Vegas, NV 89169 | 2021 | Prepaid debit card program | 320000 | 2800000000 | 3.8% | N/A | Q1 2025
5 | Greenline Payments LLC | Greenline | Limited Liability Company | California | Robert Chiang, CEO | 1999 Harrison Street, Suite 1400, Oakland, CA 94612 | 2022 | Small business payment processing and merchant acquiring | 45000 | 1900000000 | 2.6% | N/A | Q1 2025
6 | Beacon Savings Corp. | Beacon | Corporation | Delaware | Laura Whitfield, CEO | 200 Vesey Street, Suite 2400, New York, NY 10281 | 2023 | High-yield savings and CD product platform | 195000 | 1500000000 | 2.0% | N/A | Q1 2025
7 | TrueNorth Lending Inc. | TrueNorth | Corporation | Utah | Kevin Sorensen, CEO | 111 South Main Street, Suite 500, Salt Lake City, UT 84111 | 2023 | Consumer personal loan origination platform | N/A | 1200000000 | 1.6% | 850000000 | Q1 2025
8 | Pivo Financial Technologies LLC | Pivo | Limited Liability Company | Delaware | Samantha Reeves, CEO | 800 Boylston Street, Suite 1500, Boston, MA 02199 | 2024 | Embedded finance API platform for e-commerce | 110000 | 800000000 | 1.1% | N/A | Q1 2025
9 | Crestline Digital Banking Inc. | Crestline | Corporation | Georgia | James Oduya, CEO | 3344 Peachtree Road NE, Suite 1800, Atlanta, GA 30326 | 2022 | Digital checking accounts targeting underbanked communities | 280000 | 650000000 | 0.9% | N/A | Q1 2025
10 | Apex Payroll Solutions LLC | Apex Payroll | Limited Liability Company | Texas | Christine Navarro, CEO | 1700 Pacific Avenue, Suite 3100, Dallas, TX 75201 | 2023 | Payroll processing and earned wage access platform | 38000 | 520000000 | 0.7% | N/A | Q1 2025
11 | HarborPoint Wealth Technologies Inc. | HarborPoint | Corporation | New York | Gregory Altman, CEO | 55 Water Street, Suite 4200, New York, NY 10041 | 2024 | Digital wealth management and cash management accounts | 22000 | 380000000 | 0.5% | N/A | Q1 2025
12 | Bridgeway Student Finance LLC | Bridgeway | Limited Liability Company | Delaware | Natalie Park, CEO | 1200 17th Street NW, Suite 600, Washington, DC 20036 | 2024 | Student loan refinancing and education savings accounts | N/A | 250000000 | 0.3% | 180000000 | Q1 2025
13 | QuickSettle Payments Inc. | QuickSettle | Corporation | Florida | David Herrera, CEO | 701 Brickell Avenue, Suite 1600, Miami, FL 33131 | 2023 | Real-time B2B payments and invoicing platform | 15000 | 230000000 | 0.3% | N/A | Q1 2025
14 | Kova Crypto Services LLC | Kova | Limited Liability Company | Wyoming | Tyler Richardson, CEO | 152 N. 3rd Street, Suite 200, Cheyenne, WY 82001 | 2024 | Crypto-to-fiat on/off ramp and custody account services | 18000 | 196000000 | 0.3% | N/A | Q1 2025
[sheet: Summary Dashboard]
Partner # | Partner Short Name | Onboarding Year | % of BaaS Volume (%) | Annual Transaction Volume — $ | End-User Accounts | Transaction Type & Complexity | Transaction Volume ($) | Transaction Count | Customer Base | Geographic Exposure | OFAC Sanctions Risk | Historical SAR Activity | CDD/EDD Compliance | Weighted Average Score | Overall Risk Rating Tier | EDD Required | Trend vs. Prior Quarter | Key Action Items
1 | NovaPay | 2021 | 41.0% | 30500000000 | 2100000 | 5 | 5 | 5 | 4 | 3 | 5 | 5 | 5 | 4.7 | High | Yes | N/A — Baseline | Remediate OFAC screening gap; complete CDD/EDD for NovaPay-onboarded high-risk accounts; implement enhanced transaction monitoring
2 | FairLend | 2022 | 28.0% | 20804000000 | N/A | 3 | 5 | 3 | 4 | 2 | 3 | 4 | 4 | 3.6 | Moderate-High | Yes | N/A — Baseline | Complete CDD/EDD for FairLend-onboarded accounts; review lending origination BSA controls; enhance beneficial ownership verification
3 | VaultEdge | 2023 | 18.0% | 13374000000 | 870000 | 3 | 4 | 3 | 3 | 2 | 3 | 3 | 4 | 3.2 | Moderate | No | N/A — Baseline | Complete CDD/EDD for VaultEdge-onboarded accounts; continue monitoring SAR trends
4 | SwiftCard | 2021 | 3.8% | 2800000000 | 320000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
5 | Greenline | 2022 | 2.6% | 1900000000 | 45000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
6 | Beacon | 2023 | 2.0% | 1500000000 | 195000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
7 | TrueNorth | 2023 | 1.6% | 1200000000 | N/A | N/A — Baseline | Complete baseline assessment by March 31, 2025
8 | Pivo | 2024 | 1.1% | 800000000 | 110000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
9 | Crestline | 2022 | 0.9% | 650000000 | 280000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
10 | Apex Payroll | 2023 | 0.7% | 520000000 | 38000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
11 | HarborPoint | 2024 | 0.5% | 380000000 | 22000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
12 | Bridgeway | 2024 | 0.3% | 250000000 | N/A | N/A — Baseline | Complete baseline assessment by March 31, 2025
13 | QuickSettle | 2023 | 0.3% | 230000000 | 15000 | N/A — Baseline | Complete baseline assessment by March 31, 2025
14 | Kova | 2024 | 0.3% | 196000000 | 18000 | N/A — Baseline | Complete baseline assessment by March 31, 2025; note elevated inherent risk due to crypto-to-fiat activity
TOTALS / AVG | All 14 Partners | 100.0% | 74304000000 | High: 1 | Mod-High: 1 | Moderate: 1 | Pending: 11 | EDD Required: 2 of 14 assessed | Complete all 14 baseline assessments by March 31, 2025; prioritize top 3 partners by volume
[sheet: Historical Tracker]
Partner # | Partner Short Name | Q1 2025 — Weighted Score | Q1 2025 — Rating Tier | Q2 2025 — Weighted Score | Q2 2025 — Rating Tier | Q3 2025 — Weighted Score | Q3 2025 — Rating Tier | Q4 2025 — Weighted Score | Q4 2025 — Rating Tier | Q1 2026 — Weighted Score | Q1 2026 — Rating Tier | Trend (Improving / Stable / Deteriorating) | Notes
1 | NovaPay | Baseline assessment to be completed by March 31, 2025. Highest priority due to 41% of BaaS volume and OFAC screening gap.
2 | FairLend | Baseline assessment to be completed by March 31, 2025. Second priority due to 28% of BaaS volume and lending risk.
3 | VaultEdge | Baseline assessment to be completed by March 31, 2025. Third priority due to 18% of BaaS volume.
4 | SwiftCard | Baseline assessment to be completed by March 31, 2025.
5 | Greenline | Baseline assessment to be completed by March 31, 2025.
6 | Beacon | Baseline assessment to be completed by March 31, 2025.
7 | TrueNorth | Baseline assessment to be completed by March 31, 2025.
8 | Pivo | Baseline assessment to be completed by March 31, 2025. New partner onboarded 2024.
9 | Crestline | Baseline assessment to be completed by March 31, 2025.
10 | Apex Payroll | Baseline assessment to be completed by March 31, 2025.
11 | HarborPoint | Baseline assessment to be completed by March 31, 2025. New partner onboarded 2024; wealth management risk considerations.
12 | Bridgeway | Baseline assessment to be completed by March 31, 2025. New partner onboarded 2024.
13 | QuickSettle | Baseline assessment to be completed by March 31, 2025. B2B payments may carry elevated risk.
14 | Kova | Baseline assessment to be completed by March 31, 2025. New partner onboarded 2024; crypto-to-fiat inherently high-risk; close monitoring required.
[sheet: Reference Data]
Data Element | Value | Source / Notes
Total Active BaaS Partners | 14 | As of January 2025
Total BaaS Transaction Volume (CY 2024) | $74,300,000,000 | All 14 partners
BaaS Revenue to BRB (CY 2024) | $127,400,000 | Interchange, program fees, interest income
NovaPay — % of BaaS Volume | 41% | $30.5B of $74.3B
FairLend Digital — % of BaaS Volume | 28% | $20.8B of $74.3B
VaultEdge — % of BaaS Volume | 18% | $13.4B of $74.3B
Remaining 11 Partners — % of BaaS Volume | 13% | Collectively; $9.6B of $74.3B
NovaPay — End-User Accounts | 2,100,000 | Onboarded 2021
FairLend Digital — FY 2024 Loan Originations via BRB | $1,400,000,000 | Onboarded 2022
VaultEdge — Deposit Accounts | 870,000 | Onboarded 2023
NovaPay Unscreened Transactions (CY 2023) | 3,800,000 | 12.0% of 31.7M total NovaPay transactions; OFAC screening gap
Total SARs Filed (CY 2024) | 3,847 | All BRB SARs
BaaS-Related SARs (CY 2024) | 2,108 | 54.8% of total SARs (2,108 / 3,847)
Total SARs Filed (CY 2023) | 2,914 | Year-over-year increase of 32.0% (CY 2023 to CY 2024)
CTRs Filed (CY 2024) | 28,612 | All BRB CTRs
OFAC Screening Hits (CY 2024) | 14,320 | 12 true matches; 99.9% false-positive rate
Transaction Monitoring Alerts (CY 2024) | 41,500 | SAR conversion rate: 9.3% (3,847 / 41,500)
SAR Backlog (as of Sept 2024) | 2,400 alerts | Unreviewed at time of OCC examination
Average SAR Filing Time | 78 days | Regulatory expectation: ≤30 days
High-Risk Accounts Lacking CDD/EDD | 47,000 | Primarily fintech-onboarded
CDD/EDD 50% Remediation Milestone | 23,500 accounts by July 15, 2025 | Consent Order requirement
CDD/EDD 100% Remediation Milestone | 47,000 accounts by January 15, 2026 | Consent Order requirement
OFAC Screening Full Operational Date | November 1, 2025 | All BaaS channels
Veridian TMS Current Version | v.8.3 | Last validated March 2021; last tuned October 2022
Veridian TMS Upgrade Version | v.10.0 | UAT target: August 1, 2025
BSA/AML Department Headcount (Jan 2025) | 62 FTEs | Pre-remediation
Planned Post-Remediation Headcount | 77 FTEs | 62 + 15 new hires
Pinnacle Temporary Staff | 30 FTEs | 12-month remediation staffing
Consent Order No. | OCC-2025-003 | Effective January 15, 2025
OCC Examiner-in-Charge | Jonathan Frey, National Bank Examiner | OCC Northeastern District Office, 340 Madison Avenue, New York, NY 10017
FinCEN Liaison | Angela Drummond, Associate Director, Enforcement Division | Monitoring SAR filing remediation
BRB Total Assets (Q4 2024) | $38,700,000,000 | As of December 31, 2024
BRB Total Deposits (Q4 2024) | $29,400,000,000 | As of December 31, 2024
BRB Tier 1 Capital Ratio | 11.2% | As of December 31, 2024
BRB BSA/AML Budget (FY 2024) | $18,200,000 | Pre-remediation
Total Remediation Budget (excl. CMP) | $42,500,000 | Board-approved
Civil Money Penalty | $14,500,000 | Due March 16, 2025
Self-Certification Deadline | February 15, 2026 | Consent Order compliance