[GRADE A1 — NYDFS Consent Order]
The consent order documents the following sequence:
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order documents that the Gratitude America request triggered the first external due diligence review since onboarding, and that the review was cancelled when the request was withdrawn. The sequence is consistent with either (a) deliberate obstruction of a review that might have uncovered problems, or (b) a legitimate withdrawal of a business request that coincidentally prevented a review. The consent order does not state which interpretation is correct. The regulatory finding is that the bank should have run the diligence review regardless of whether the account request was withdrawn.