Cross River Bank's Order also requires adequate oversight of its third-party providers a Compliance Management System that effectively identifies, addresses, monitors, and controls consumer protection risks associated with third-party activities and sufficient resources to oversee third-party relationships.
In addition to the payment of restitution to harmed consumers and civil money penalties, the FDIC Orders also require Cross River Bank and FFAM to take affirmative steps to ensure compliance with the FTC Act, as well as TILA and EFTA. Consumers who are eligible for relief under the settlement are not required to take any action to receive restitution. The restitution plan must be submitted to the FDIC for review and non-objection, and restitution calculations will be verified by an independent third-party. The FDIC Orders require Cross River Bank and FFAM to develop and implement a restitution plan that covers borrowers who, from 2013 to the present, received loans originated by the bank through FFAM, and were harmed by the practices identified as being unfair and deceptive. Misrepresenting that the consumers' creditworthiness would improve by obtaining a C+ Loan.Īs the originator of these loans, Cross River Bank is responsible for ensuring the C+ Loans program operates in compliance with all applicable laws.Misrepresenting to consumers that the C+ Loans would result in the settlement of all their debts within 30 to 45 days or 30 to 90 days, which was not true for nearly half of the consumers and.Failing to inform borrowers that certain major creditors will not negotiate debts with FDR and including related debt settlement fees into C+ Loans, when in fact, borrowers had to negotiate such debts themselves.Requiring borrowers to sign loan documents without knowing the essential terms and conditions of the loan.The FDIC determined that Cross River Bank and FFAM violated federal law prohibiting unfair and deceptive practices, by, among other things: Consumers are charged a settlement fee of up to 25 percent of each debt enrolled in FDR's program. C+ Loans were marketed as a way for consumers to quickly resolve their outstanding debts. C+ Loans are offered exclusively to consumers who contract with Freedom Debt Relief (FDR), a FFAM-affiliated debt settlement company. WHEREAS, FREEDOM FINANCIAL ASSET MANAGEMENT LLC., (Freedom Financial or Company) has been advised of its rights to Notice and Hearing pursuant to Massachusetts General Laws chapter 30A, section 10, and having waived those rights, entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER (Consent Agreement) with the Division o.
Additionally, the FDIC Orders assess civil money penalties of $641,750 against the bank, and $493,500 against FFAM.Ĭross River Bank originates C+ Loans, an unsecured debt consolidation loan product, through FFAM. Although the exact amount of restitution has not yet been finally determined, $20 million has been placed in a segregated account for the purpose of providing restitution to harmed consumers. The FDIC Orders require restitution to harmed consumers. In addition, the FDIC found the bank and FFAM violated the Truth in Lending Act (TILA) and Electronic Fund Transfer Act (EFTA).Īs part of the settlement, Cross River Bank and FFAM stipulated to the issuance of respective Consent Orders, Orders for Restitution, and Orders to Pay Civil Money Penalties (collectively, FDIC Orders).
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Some account types may not yet be available, processing times may vary.The Federal Deposit Insurance Corporation (FDIC) announced settlements with Cross River Bank, Teaneck, New Jersey, and its institution-affiliated party, Freedom Financial Asset Management, LLC (FFAM), San Mateo, California, for unfair and deceptive practices in violation of Section 5 of the Federal Trade Commission (FTC) Act related to the marketing and origination of Consolidation Plus Loans (C+ Loans). These testimonials may not represent the experience of others and are not a guarantee of results. For additional information about the promoting advisors’ conflicts of interest when expressing their views about Altruist or Altruist’s affiliates, please see the promoting advisors’ advisory program brochures, available at. For more details on program compensation and benefits and related conflicts of interest, please visit /RIA-testimonial. Fox) received compensation or other benefits from Altruist through the promoting advisors’ participation in one or more of Altruist’s various programs, which created a conflict of interest on the promoting advisors’ part and may have influenced the views expressed by the promoting advisors. As of the date of these testimonials, the promoting advisors (D. Neither Altruist nor its affiliates paid for these testimonials, but we do earn revenue from financial advisors who use our software, from assets invested through our broker-dealer (Altruist Financial LLC) and assets invested in models made available by our registered investment adviser (Altruist LLC). These testimonials were given by current clients or investors.
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