Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / securities-disclosure-obligations-memo.docx
securities-disclosure-obligations-memo.docx
Parties
HARKNESS LLP
NovaPay Technologies Inc
FinCEN's SA
BRB's SA
Thornfield Consulting Group LLC
Pope LLP
Pinnacle Compliance Solutions LLC
Brindoval Capital Partners LP
Dates
February 14, 2025
January 15, 2025
March 16, 2025
January 16, 2025
February 7, 2025
December 31, 2024
February 10, 2025
February 5, 2025
May 15, 2025
February 15, 2026
Amounts
$14,500,000
$42,500,000
$57,000,000
$47.82
$41.15
$6.67
$6,500,000
$400,000
$6,900,000
$127,400,000
Obligations
First, BRB is required to submit a Comprehensive Remediation Action Plan (the "Action Plan") to the OCC by May 15, 2025
The Action Plan must set forth detailed milestones, responsible personnel, resource allocations, and timelines for each remediation workstream
Given that FinCEN has reserved its enforcement rights and that no DOJ criminal referral has been precluded, the Company must maintain heightened vigilance for any indications that such actions are forthcoming
As such, the FY 2024 10-K must reflect the Consent Order as a subsequent event and must integrate disclosure of the Consent Order and its implications throughout the relevant sections of the filing
Item 1A — Risk Factors Item 1A of the FY 2024 10-K must be updated to include or expand risk factors addressing the Consent Order and its multifaceted implications
Item 7 — Management's Discussion and Analysis (MD&A) The MD&A section of the FY 2024 10-K must provide a thorough discussion of the Consent Order's financial impact and the known trends and uncertainties associated with the remediation program