Regulatory footprint

RegulatorRelationshipLicense type / IDStatusStatus dateSource
FDICInsurancedeposit insurance / FDIC Cert. 5962InsuredAug 10, 2026Federal Deposit Insurance Corporation, retrieved Aug 10, 2026
FDICSupervisionprimary federal regulatorActiveAug 10, 2026Federal Deposit Insurance Corporation, retrieved Aug 10, 2026

Compliance obligations

BSA/AML

FDIC-insured depository institution subject to the Bank Secrecy Act, 31 U.S.C. 5311 et seq., and its implementing rules for banks at 31 C.F.R. Part 1020.

Source: Federal Deposit Insurance Corporation, retrieved Aug 10, 2026

OFAC sanctions

United States financial institution subject to the economic sanctions programs administered by the Office of Foreign Assets Control, 31 C.F.R. Chapter V.

Source: Federal Deposit Insurance Corporation, retrieved Aug 10, 2026

Fintech partnership program

Public sources document that this institution operates or has operated a banking-as-a-service / fintech partnership program. Program type(s) per the cited sources: cards, payments. Status: Active, under public enforcement remediation (as of Aug 18, 2026).

FDIC consent order (effective Feb 1, 2024) requiring third-party risk-management policies, an inventory of fintech relationships, and a CIP lookback of prepaid customers onboarded via third parties.

Regulator record · Feb 1, 2024

FDIC Consent Order, identifier FDIC-23-0110b per Banking Dive ↗

Direct FDIC order PDF URL not verified; identifier per Banking Dive. Characterization not independently verified against the primary document.

Fintech partners named in the cited sources: Cash App, Highnote, Qolo. Partner lists reflect only what the cited sources name and may be incomplete or historical.

Segment membership is compiled from the cited public sources; it is a statement of public record, not an assessment of any program. All documented fintech partner banks.

Enforcement history

Jul 27, 2015 · FDIC · Cease and Desist / Consent Orders

Terminated Nov 1, 2017.

The Federal Deposit Insurance Corporation issued a cease and desist / consent orders regarding Sutton Bank, dated 2015-07-27. The action was terminated on 2017-11-01.

Order document ↗

Source: Federal Deposit Insurance Corporation, retrieved Aug 11, 2026, snapshot 307da53793f0.

Nov 1, 2017 · FDIC · Cease and Desist / Consent Orders

No termination appears in the source record.

The Federal Deposit Insurance Corporation issued a cease and desist / consent orders regarding Sutton Bank, dated 2017-11-01. No termination of the action appears in the source record.

Order document ↗

Source: Federal Deposit Insurance Corporation, retrieved Aug 11, 2026, snapshot 307da53793f0.

Feb 1, 2024 · FDIC · Cease and Desist / Consent Orders

No termination appears in the source record.

The Federal Deposit Insurance Corporation issued a cease and desist / consent orders regarding Sutton Bank, dated 2024-02-01. No termination of the action appears in the source record.

Order document ↗

Source: Federal Deposit Insurance Corporation, retrieved Aug 11, 2026, snapshot 307da53793f0.

Compiled from FDIC enforcement decisions and orders, OCC enforcement actions as of Aug 11, 2026.

Filings

No filings captured yet.

Official records portals

Public record status

Record status

Record: 1 item(s) on record.

This reflects public government records only. It is not an assessment of any company's compliance program.

Profile status

Claim statusUnclaimed.
Validation statusNot independently validated.

Sources & corrections

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