Those totals represent separate settlements reached with the -

*        Consumer Financial Protection Bureau,

*        Office of the Comptroller of the Currency,

*        Board of Governors of the Federal Reserve System,

*        Federal Deposit Insurance Corporation, and

*        Utah Department of Financial Institutions.

The settlements, announced on Monday, stem from ongoing examinations by the Utah Department of Financial Institutions, which were later joined by the FDIC and the CFPB. They determined that the bank violated federal law by, among other things:

• Misrepresenting to consumers that if they entered into an agreement to settle old debt that was no longer being reported to consumer reporting agencies, that settlement would nevertheless be reported to consumer reporting agencies and thereby improve the consumers' credit scores.
• Using settlement solicitations that implied that consumers who entered into settlement agreements to partially pay such debts would have the remaining balance of their debts forgiven, when in fact the balance remained a debt owed to American Express.
• Solicitations that misrepresented the points and awards consumers would receive upon enrollment in one of American Express' credit card products.

The Consent Order also requires the Bank to correct all violations, provide “clearly written” disclosures on debt collection statements, and to stop using deceptive credit card solicitations. In addition, the bank will improve its compliance management system and improve board oversight of affiliates and third-party service providers in order to adequately manage third-party risk. In agreeing to the Consent Order, American Express neither admits nor denies any liability.

The OCC also ordered the bank to establish an “effective vendor management program” to oversee the how products are to customers.

In a statement issued by American Express on Monday, the company said it has “developed remediation plans for each of the cited violations.” The required refunds, it said, are related to debt collection practices and late fee charges and impacted customers will soon be notified.

Reserves were established in previous quarters for a substantial portion of the fines and the estimated cardmember refunds, the company added. It is also “continuing its own internal reviews” and cooperating with regulators on their industry-wide review of add-on products.

The settlement also pertains to several of the company's subsidiaries, including American Express Centurion Bank, American Express Bank, FSB, and American Express Travel Related Services Company, Inc.

Similar actions by regulators in recent days have included -

*         $210 million in refunds agreed to by Capital One Bank in ult, and

*         the Sept. 24 announcement that Discover Bank would refund $200 million to 3.5 million customers, in addition to a $14 civil penalty, over charges it used deceptive and high-pressure sales tactics to sell “add-on” products for its credit cards.