Extract to table

The Consent Order imposes two mandatory milestones for CDD/EDD remediation: (a) 50% completion — encompassing no fewer than 23,500 accounts — must be achieved by July 15, 2025; and (b) 100% completion — encompassing all 47,000 accounts — must be achieved by January 15, 2026

Each account within the identified deficient population must be brought into compliance with the requirements of 31 C

While the individual exposure per partner is relatively modest, the aggregate population of 5,100 accounts is material and must be remediated within the same timeline and to the same standards as the larger partner segments

Category 4 accounts will require the most intensive remediation effort per account, as each overlapping deficiency must be independently addressed and documented

Under this framework, the fintech partner is responsible for the customer-facing communication and data collection, while BRB retains oversight responsibility and must validate the sufficiency of the collected documentation