OCC Enforcement Agreement

The OCC has published an enforcement agreement with First Consumers National Bank of Beaverton, Oregon (a location most noted for being the world headquarters of Nike.) The case involved fees imposed in a credit card program. The remedy is customer restitution amounting to more than $1 million.

First Consumers National Bank is required to make two types of customer refunds. First, they must reimburse customers for membership fees charged for a period of time when the card program was not available for the consumer's use.

Second, the bank must refund any overlimit fees charged as a result of the member fee. The overlimit reimbursement is expected to be more than $255,000. Fairness in fee income is a clear message in this enforcement action.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 9, 9/03