FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / fairlend-compliance-remediation-letter.docx
fairlend-compliance-remediation-letter.docx · 1045-00002

Parties

AND EMAIL FairLend Digital LLC
FairLend Digital LLC
Harkness LLP
Thornfield Consulting Group LLC
NovaPay Technologies Inc
VaultEdge Inc
BaaS Partners Inc
BRB's SA

Dates

February 19, 2025
January 15, 2025
February 15, 2026
March 1, 2025
June 14, 2022
July 15, 2025
January 15, 2026
November 1, 2025
August 1, 2025
October 1, 2025

Amounts

$74.3
$20.8
$1.4

Obligations

The purpose of this letter is threefold: (1) to notify FairLend of certain significant regulatory developments affecting BRB that bear directly on the BaaS partnership between BRB and FairLend; (2) to outline the enhanced cooperation, data sharing, and compliance commitments that BRB requires of FairLend as a BaaS partner operating under BRB's national bank charter; and (3) to set forth the timeline within which FairLend must demonstrate compliance with these requirements and provide formal written acknowledgment of its commitments
Specific Demands and Required Commitments In light of the foregoing, BRB hereby makes the following specific demands and sets forth the following required commitments with which FairLend must comply
FairLend is required to respond to all BRB data requests related to the CDD/EDD remediation effort within five (5) business days of receipt of each such request
Any request from BRB's BSA/AML team, compliance department, or outside advisors for data or documentation in connection with the remediation shall be treated by FairLend as a priority matter requiring prompt attention
Where BRB determines that additional information or documentation is required for a particular customer account, FairLend shall use its best efforts to obtain such information or documentation from the customer in a timely manner, and shall promptly transmit all collected materials to BRB
Going forward, FairLend is required to implement any enhanced onboarding procedures specified by BRB