EX-10.3
from 10-Q
13 pages
Commonwealth of Pennsylvania Department of Banking and Securities : Commonwealth of Pennsylvania, : Docket No.: 240037 (Enf-Ord) Department of Banking and Securities, : Bureau of Bank Supervision : : V. : : Customers Bank : : Consent Order Whereas, Customers Bancorp, Inc., West Reading, Pennsylvania (“Bancorp”), a Bank Holding Company, Owns and Controls Customers Bank, Malvern, Pennsylvania (The “Bank,” and Collectively With Bancorp, the “Organization”), a State-Chartered Bank That Is a Member of the Federal Reserve System; Whereas, the Bureau of Bank Supervision (The “Bureau”) Is Primarily Responsible Within the Department for the Regulation and Supervision of the Bank; Whereas, Bancorp Has Pursued a Business Strategy That Involves Offering Banking Services to Digital Asset Customers (“Digital Asset Strategy”), and Also Operates an Instant Payments Platform That Allows Commercial Clients to Make Tokenized Payments Over a Distributed Ledger Technology System to Other Commercial Clients of the Bank (“Dollar Token Activities”); Whereas, the Most Recent Joint Examinations and Inspection of the Organization Conducted by the Federal Reserve Bank of Philadelphia (“Reserve Bank”) and the Bureau Identified Significant Deficiencies Related to the Bank’s Risk Management Practices and Compliance With the Applicable Laws, Rules, and Regulations Relating to Anti-Money Laundering (“Aml”), Including the Bank Secrecy Act (The “Bsa”) (31 U.S.C. § 5311 Et Seq.), Including the Rules and Regulations Issued Thereunder by the U.S. Department of the Treasury (31 C.F.R
12/34/56
EX-10.2
from 10-Q
14 pages
United States of America Before the Board of Governors of the Federal Reserve System Washington, D.C. Docket Nos. 24-020-Wa/Rb-Hc 24-020-Wa/Rb-Sm Whereas, Customers Bancorp, Inc., West Reading, Pennsylvania (“Bancorp”), a Bank Holding Company, Owns and Controls Customers Bank, Malvern, Pennsylvania (The “Bank,” and Collectively With Bancorp, the “Organization”), a State-Chartered Bank That Is a Member of the Federal Reserve System; Whereas, the Board of Governors of the Federal Reserve System (The “Board of Governors”) Is the Appropriate Federal Supervisor of Bancorp and the Bank; Whereas, Bancorp Has Pursued a Business Strategy That Involves Offering Banking Services to Digital Asset Customers (“Digital Asset Strategy”), and Also Operates an Instant Payments Platform That Allows Commercial Clients to Make Tokenized Payments Over a Distributed Ledger Technology System to Other Commercial Clients of the Bank (“Dollar Token Activities”); Written Agreement by and Among Customers Bancorp, Inc. West Reading, Pennsylvania Customers Bank Malvern, Pennsylvania and Federal Reserve Bank of Philadelphia Philadelphia, Pennsylvania
12/34/56
