First Fed Bank

Port Angeles, WA 2021--2023 Community Banks / Credit Unions

FDIC Udaap Truth In Lending Respa Regulation E Unsafe Unsound Practices False Fdic Insurance Representations

Penalty

Outcome

First Fed Bank entered an FDIC consent order in November 2023 for unsafe and unsound banking practices, UDAAP violations, and violations of TILA, RESPA, and Reg E arising from its joint venture with Quin Ventures Inc. — which deceptively marketed non-optional debt cancellation products as "unemployment insurance" and enrolled ineligible consumers while misrepresenting fees — with First Fed proactively ending the Quin partnership in 2022 and remediating all affected customers.

Details

First Fed Bank — FDIC Consent Order: Quin Ventures Joint Venture Violations (2023)

Outcome: First Fed Bank of Port Angeles, Washington entered an FDIC consent order in November 2023 for unsafe and unsound banking practices, Unfair Deceptive or Abusive Acts and Practices (UDAAP) violations, and violations of the Truth in Lending Act, the Real Estate Settlement Procedures Act, and the Electronic Fund Transfers Act arising from its joint venture with Quin Ventures Inc., which had marketed debt cancellation products as if they were insurance and enrolled ineligible consumers.

First Fed Bank entered a joint venture in 2021 with POM Peace of Mind, Inc. to found Quin Ventures, Inc. — a fintech focused on financial wellness and lifestyle protection. Through a marketing and banking services agreement, Quin promoted digital financial wellness products and First Fed Bank provided the underlying banking services. The arrangement was intended to serve consumers nationwide through a digital platform.

The FDIC's examination found that through this joint venture, First Fed Bank engaged in deceptive and unfair acts and practices in violation of the Consumer Financial Protection Act. The core deception involved credit products that included mandatory, non-optional debt cancellation features: Quin and First Fed marketed these products in ways that implied the debt cancellation component was unemployment insurance — a materially false characterization. Additionally, the bank and Quin approved consumers who did not actually qualify for the debt cancellation feature, while misrepresenting the fees that consumers would be charged for those products.

The violations encompassed multiple federal consumer protection statutes: the Truth in Lending Act (disclosure requirements), RESPA (settlement procedures), and the Electronic Fund Transfers Act (Regulation E). The consent order also addressed a violation of the FDI Act provision prohibiting false or misleading representations about FDIC deposit insurance coverage.

First Fed Bank proactively terminated its Quin partnership in 2022, provided full remediation to all affected customers, and continued strengthening its internal controls — factors that likely contributed to the FDIC imposing a consent order without a civil money penalty.

Primary Source: FDIC Consent Order — First Fed Bank and Quin Ventures (November 2023)

How Crucible Prevents This

Crucible's pre-tool-check hook would require documented product compliance review — including UDAAP, TILA, RESPA, and Reg E analysis — before any new fintech joint venture product feature could be deployed. The instinct-observer would detect consumer complaint patterns indicating confusion between debt cancellation products and insurance. The quality-gate would flag any product marketing that described debt cancellation features using insurance terminology without proper disclosure.

Source: FDIC Consent Order — First Fed Bank and Quin Ventures (November 2023)

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