Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / prior-mra-mria-comparison-memo.docx
prior-mra-mria-comparison-memo.docx
Parties
HARKNESS LLP
Drayton Mercer LLP
Thornfield Consulting Group LLC
Veridian Analytics Inc
Counsel History Drayton Mercer LLP
Pope LLP
NovaPay Technologies Inc
FairLend Digital LLC
Dates
February 20, 2025
January 15, 2025
February 10, 2025
March 16, 2025
February 5, 2025
May 15, 2025
February 15, 2026
December 31, 2024
March 1, 2025
April 15, 2025
Amounts
$74.3
$127.4
$14.5
$42.5
$57.0
$38.7
$29.4
$412
$18.2
$4.1
Obligations
Vivian Castellano, was engaged by BRB on February 10, 2025, following receipt of OCC non-objection on February 5, 2025; • Submission of a Comprehensive Remediation Action Plan to the OCC by May 15, 2025; • Full program implementation and remediation completion by February 15, 2026, at which time BRB must submit a self-certification of compliance
BRB is required to submit a Comprehensive Remediation Action Plan to the OCC by May 15, 2025
The Consent Order requires full implementation of all required corrective actions by February 15, 2026, at which time BRB must submit a written self-certification of compliance to the OCC
BRB must submit an interim SAR backlog status report to the OCC by March 31, 2025
The 2,400-alert backlog must be fully cleared — meaning all alerts must be reviewed, investigated, and dispositioned, with SARs filed as appropriate — by June 30, 2025
BRB must remediate 50% of the identified CDD/EDD-deficient accounts (approximately 23,500 accounts) by July 15, 2025, and must achieve 100% remediation (all 47,000 accounts) by January 15, 2026