The Consumer Financial Protection Bureau issued a consent order on 31 October 2024 against VyStar Credit Union, headquartered in Jacksonville, Florida, requiring the institution to pay a $1.5 million civil money penalty for violations of the Consumer Financial Protection Act. The enforcement action stems from an online and mobile banking platform migration that VyStar launched in May 2022, which left many of its approximately 850,000 members unable to carry out fundamental financial transactions for an extended period following the rollout.

VyStar, which holds approximately $14.7 billion in assets, deployed a new digital banking platform in May 2022. After the transition, members found it difficult or impossible to check account balances, transfer funds, pay bills, or access other essential banking features. Some capabilities remained unavailable for more than six months after the initial launch date. Families and households incurred direct financial costs — including fees — as a consequence of their prolonged inability to manage their accounts through the institution's digital channels.

PLANNING AND IMPLEMENTATION FOUND TO VIOLATE CONSUMER PROTECTION LAW

The CFPB concluded that VyStar's planning and implementation of the system conversion violated consumer financial protection law. The bureau found that the credit union had not adequately tested the new platform before deployment and had failed to establish contingency measures of sufficient robustness to protect members in the event that the launch encountered serious difficulties.

Beyond the $1.5 million civil money penalty, the consent order required VyStar to establish a governance committee specifically tasked with overseeing future banking system projects. The order also mandated that VyStar ensure all affected consumers were made whole for the financial losses they incurred as a direct result of the platform failure.