Block → Required CFPB Redress Plan and allocation
must reserve funds for ordered redress
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
117 requires USD 75 m reserved or in segregated deposit within 10 calendar days; consumer redress capped at USD 120 m. If consumer redress is below USD 75 m, specified shortfall goes to CFPB, with possible further redress/Treasury residue. Neither figure proves cash received by consumers or actual reserve establishment. Financial details: value: 75,000,000; currency: USD; kind: ordered reserve or segregated-deposit obligation; not observed payment; period: Within 10 calendar days of order effective date
CFPB Enforcement Director role → Required CFPB Redress Plan and allocation
reviews for non-objection and may require revision
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
Block submits Redress Plan within 120 days; Director/delegate may require revision; Block must revise and resubmit within 15 days of that direction. Block must follow non-objected-to plan, with credit payment/non-credit commencement clock after non-objection and a post-completion report. Actual non-objection and completed distribution report not obtained.
July agreed redress credit and 2030 fallback → Required CFPB Redress Plan and allocation
credits payments under federal redress order
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Payments under docket 2025-CFPB-0001 satisfy state redress; July terms do not create a second independent consumer pool. Federal reserve/shortfall mechanics remain separate from proof of consumer receipt.