FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
) ORDER OF PROHIBITION FROM
RYAN QARANA, individually and as institution- ) FURTHER PARTICIPATION and
affiliated party ) ORDER TO PAY
of )
)
BANK OF ENGLAND ) FDIC-23-0052e
ENGLAND, ARKANSAS ) FDIC-23-0053k
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 784280 )
)

Ryan Qarana (Respondent) and Respondent’s counsel were advised of the right to receive

a Notice of Intention to Prohibit from Further Participation and Notice of Assessment

(collectively, Notices) detailing Respondent’s violations of law and unsafe and unsound

practices, for which an Order of Prohibition from Further Participation (Prohibition Order) and

Order to Pay a civil money penalty (Order to Pay) (collectively, Orders) may be issued under 12

U.S.C. § 1818(e) and (i).

Respondent was further advised of the right to a hearing on the Notices under 12 U.S.C. §

1818(e) and (i) and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under

those provisions on November 27, 2023, and consented to the issuance of the Orders by entering

into a Stipulation and Consent to the Issuance of an Order of Prohibition from Further

Participation and Order to Pay (Consent Agreement) with a representative of the Federal Deposit

Insurance Corporation’s (FDIC) Legal Division.

 The FDIC determined, and Respondent neither admits nor denies, the following:

1. While serving as Assistant Branch Manager of the Bloomfield, Michigan loan

production office of the Bank of England, England, Arkansas (Bank) from at least January 2019

to August 2019, Respondent engaged in violations of Section 5 of the Federal Trade

Commission Act, 15 U.S.C. § 45(a) (Section 5) and engaged or participated in unsafe or unsound

practices by failing to ensure that loan officers in the Bloomfield, Michigan loan production

office complied with Section 5; specifically by misrepresenting or failing to ensure that loan

officers did not misrepresent: (1) available loan prices for mortgage loans, (2) that consumers

could skip two months of their mortgage payments, and (3) the loan production office’s

affiliation with the Department of Veterans Affairs.

2. Respondent’s violation of laws and unsafe and unsound practices caused financial

loss or other damage to the Bank.

3. Respondent’s violation of laws and unsafe and unsound practices demonstrated

Respondent’s willful disregard for the safety or soundness of the Bank.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C. §

1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER OF PROHIBITION FROM FURTHER PARTICIPATION

4. Ryan Qarana is prohibited from:

a. participating in any manner in the conduct of the affairs of any financial

institution or organization listed in 12 U.S.C. § 1818(e)(7)(A);

b. soliciting, procuring, transferring, attempting to transfer, voting, or

attempting to vote any proxy, consent, or authorization with respect to any voting rights in any

financial institution enumerated in 12 U.S.C. § 1818(e)(7)(A);

2
 c. violating any voting agreement previously approved by the appropriate

Federal banking agency; or

d. voting for a director or serving or acting as an institution-affiliated party.

5. The Prohibition Order is effective upon issuance and will remain effective and

enforceable until the FDIC and any “appropriate Federal financial institutions regulatory

agency,” defined at 12 U.S.C. § 1818(e)(7)(D), decide in writing to modify, terminate, suspend,

or set aside the Prohibition Order under 12 U.S.C. § 1818(e)(7)(B).

6. The Prohibition Order is enforceable under 12 U.S.C. § 1818(i), and any violation

of the Prohibition Order may result in additional penalties under 12 U.S.C. § 1818(j).

7. The Prohibition Order does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

ORDER TO PAY

8. By reason of Respondent’s actions listed in paragraph 1, a $100,000 civil money

penalty (CMP) is assessed against Ryan Qarana under 12 U.S.C. § 1818(i)(2) and is effective

upon issuance. Respondent must pay the CMP to the Treasury of the United States.

9. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

10. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

11. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

3
Issued under delegated authority.

Dated: January 12, 2024.

_/s/_________________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

4
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
RAMY ZOMA, individually and )
as an institution-affiliated party ) ORDER TO PAY
of )
) FDIC-23-0061k
BANK OF ENGLAND )
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1829934 )
)
)

Ramy Zoma (Respondent) was advised of the right to receive a Notice of Assessment

(Notice) detailing Respondent’s violations of law for which an Order to Pay a civil money

penalty (Order to Pay) may be issued under 12 U.S.C. § 1818(i).

Respondent was further advised of the right to a hearing on the Notice under § 1818(i)

and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those

provisions on August 30, 2023, and consented to the issuance of an Order to Pay by entering into

a Stipulation and Consent to the Issuance of an Order to Pay (Consent Agreement) with a

representative of the Federal Deposit Insurance Corporation’s (FDIC) Legal Division.

The FDIC determined, and Respondent neither admits nor denies the following:

1. From January 2019 to May 2019, Respondent engaged in violations of Section 5

of the Federal Trade Commission Act, 15 U.S.C. § 45(a) (Section 5), by misrepresenting to

consumers Respondents and the Bank’s affiliation with the Department of Veteran Affairs.
 2. As described in paragraph 1, Respondent engaged or participated in violations of

law.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C. §

1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER TO PAY

3. By reason of Respondent’s actions listed in paragraph 1, a $2,500 CMP is

assessed against Ramy Zoma under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must immediately pay the CMP to the Treasury of the United States.

4. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

5. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

6. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

Issued under delegated authority.

Dated: January 12, 2024.

__/s/_________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

2
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
Oday Sessi, an institution-affiliated party of ) PERSONAL CONSENT ORDER
)
BANK OF ENGLAND ) FDIC-23-0089b
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1799001 )
)
)

Oday Sessi (Respondent) and Respondent’s counsel were advised of the Respondent’s

right to receive a Notice of Intention to Seek a Cease and Desist Order (Notice) detailing

Respondent’s violations of laws for which an Order To Cease and Desist (Personal Consent

Order) may be issued under 12 U.S.C. § 1818(b).

Respondent was further advised of the right to a hearing on the Notice under 12 U.S.C. §

1818(b) and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those

provisions on October 4, 2023, and consented to the issuance of the Personal Consent Order by

entering into a Stipulation to The Issuance of a Personal Consent Order (Consent Agreement)

with a representative of the FDIC’s Legal Division.

The FDIC determined and Respondent neither admits nor denies the following:

1. The FDIC determined, and Respondent neither admits nor denies, that from

approximately October 2018 to December 2019, Respondent engaged in violations of Section 5

of the Federal Trade Commission Act, 15 U.S.C. § 45(a) (Section 5), by misrepresenting his and

the Bank’s affiliation with the Department of Veterans Affairs (“VA”) in the course of taking
applications for originating VA mortgage loans. These representations were false and

misleading in violation of Section 5.

2. As described in paragraph 1, Respondent engaged or participated in violations of

law.

The FDIC accepts the Consent Agreement and issues the following:

PERSONAL CONSENT ORDER

Respondent must cease and desist from, and take affirmative action, as follows:

3. Prior to accepting any position that would cause Respondent to become an

institution-affiliated party (IAP) of an insured depository institution specified in 12 U.S.C.

§ 1818(e)(7)(A), Respondent shall complete at least 24 hours of training through an outside

third-party provider that is deemed acceptable by the Regional Director of the FDIC's Dallas

Regional Office. The training must cover the topics of ethics and compliance with mortgage-

related laws and regulations. Respondent must submit documentation to demonstrate successful

completion of this training requirement no later than 15 days after completion of at least 24 hours

of training to the FDIC’s Dallas Regional Office at: David E. Wright, Deputy Regional Director,

Federal Deposit Insurance Corporation, 600 North Pearl Street, Suite 700, Dallas, Texas 75201.

4. Respondent must not violate Section 5 of the Federal Trade Commission Act.

5. When Respondent is employed by an insured depository institution (IDI) or

otherwise becomes an IAP under 12 U.S.C. § 1813(u), Respondent must follow the written

policies and procedures of that IDI. If Respondent is affiliated with an IDI whose written

policies and procedures are more stringent than the provisions of this Personal Consent Order,

Respondent must adhere to the IDI’s written policies and procedures.

2
 6. Within 10 calendar days of the date of this Personal Consent Order, Respondent

must provide a copy of this Personal Consent Order to the Chairman of the Board of Directors of

any IDI of which Respondent is an IAP.

7. Before accepting any position causing Respondent to become an IAP, Respondent

must provide a copy of this Personal Consent Order to: (i) the Chairman of the Board of

Directors of the IDI, or (ii) a senior executive manager of the IDI, provided that the official was

approved in writing by the Regional Director, FDIC Dallas Regional Office, for this purpose.

8. Within 10 calendar days of satisfying the requirements of paragraphs 6 and 7,

Respondent must provide a written certification of Respondent’s compliance to the Regional

Director, FDIC Dallas Regional Office.

9. If Respondent believes that the Personal Consent Order provisions are fulfilled,

Respondent may request termination of the Personal Consent Order by submitting a letter with

supporting materials to the Regional Director, FDIC Dallas Regional Office. The FDIC may

request additional information to review the termination request. The decision to deny the

request and retain this Personal Consent Order as is, modify it, or terminate it, is at the FDIC’s

discretion.

10. This Personal Consent Order is enforceable and effective under 12 U.S.C. §

1818(i) for 5 years from the date of this Personal Consent Order, except to the extent that any

provision is modified, terminated, suspended, or set aside by the FDIC.

11. This Personal Consent Order does not waive any right, power, or authority of the

United States; federal, state, or local agencies; or the FDIC as Receiver.

3
Issued under delegated authority.

Dated: January 12, 2024.

_/s/___________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

4
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
JANEL ZAITONA, individually and as )
institution-affiliated party ) ORDER TO PAY
of )
) FDIC-23-0058k
BANK OF ENGLAND )
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1689247 )
)
)

Janel Zaitona (Respondent) was advised of the right to receive a Notice of Assessment

(Notice) detailing Respondent’s violations of law for which an Order to Pay a civil money

penalty (Order to Pay) may be issued under 12 U.S.C. § 1818(i).

Respondent was further advised of the right to a hearing on the Notice under § 1818(i)

and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those

provisions on September 8, 2023, and consented to the issuance of an Order to Pay by entering

into a Stipulation and Consent to the Issuance of an Order to Pay (Consent Agreement) with a

representative of the Federal Deposit Insurance Corporation’s (FDIC) Legal Division.

The FDIC determined, and Respondent neither admits nor denies, the following:

1. From January 2019 through August 2019, Respondent engaged in deceptive acts

or practices in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a)

(Section 5), by luring consumers to apply for mortgage loans with low, unavailable loan prices

that would not be honored and subsequently increasing the price before closing the loan.
Furthermore, the FDIC determined, and Respondent neither admits nor denies, that from at least

January 2019 to October 2019, Respondent engaged in violations of Section 5 by

misrepresenting to consumers that they could skip two months of mortgage payments and by

misrepresenting to consumers the Bank’s affiliation with the Department of Veteran’s Affairs.

2. As described in paragraph 1, Respondent engaged or participated in violations of

law.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C.

§ 1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER TO PAY

3. By reason of Respondent’s actions listed in paragraph 1, a $1,000 CMP is

assessed against Janel Zaitona under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must immediately pay the CMP to the Treasury of the United States.

4. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

5. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

6. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

Issued under delegated authority.

Dated: January 12, 2024.

_/s/__________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

2
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
MARLA ABDULNOOR, individually and as )
institution-affiliated party ) ORDER TO PAY
of )
) FDIC-23-0057k
BANK OF ENGLAND )
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1662502 )
)
)

Marla Abdulnoor (Respondent) was advised of the right to receive a Notice of

Assessment (Notice) detailing Respondent’s violations of law for which an Order to Pay a civil

money penalty (Order to Pay) may be issued under 12 U.S.C. § 1818(i).

Respondent was further advised of the right to a hearing on the Notice under § 1818(i)

and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those

provisions on October 2, 2023, and consented to the issuance of an Order to Pay by entering into

a Stipulation and Consent to the Issuance of an Order to Pay (Consent Agreement) with a

representative of the Federal Deposit Insurance Corporation’s (FDIC) Legal Division.

The FDIC determined, and Respondent neither admits nor denies, the following:

1. From January 2019 through August 2019, Respondent engaged in deceptive acts

or practices in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a)

(Section 5), by luring consumers to apply for mortgage loans with low, unavailable loan prices

that would not be honored and subsequently increasing the price before closing the loan.
Furthermore, the FDIC determined, and Respondent neither admits nor denies, that from at least

January 2019 to October 2019, Respondent engaged in violations of Section 5 by

misrepresenting to consumers that they could skip two months of mortgage payments.

2. As described in paragraph 1, Respondent engaged or participated in violations of

law.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C.

§ 1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER TO PAY

3. By reason of Respondent’s actions listed in paragraph 1, a $35,000 CMP is

assessed against Marla Abdulnoor under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must immediately pay the CMP to the Treasury of the United States.

4. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

5. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

6. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

Issued under delegated authority.

Dated: January 12, 2024.

__/s/________________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

2
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
) ORDER OF PROHIBITION FROM
JASMINE JONNA, individually and as ) FURTHER PARTICIPATION and
institution-affiliated party ) ORDER TO PAY
of )
)
BANK OF ENGLAND ) FDIC-23-0054e
ENGLAND, ARKANSAS ) FDIC-23-0055k
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1222074 )
)

Jasmine Jonna (Respondent) was advised of the right to receive a Notice of Intention to

Prohibit from Further Participation and Notice of Assessment (collectively, Notices) detailing

Respondent’s violations of law and unsafe and unsound practices for which an Order of

Prohibition from Further Participation (Prohibition Order) and Order to Pay a civil money

penalty (Order to Pay) (collectively, Orders) may be issued under 12 U.S.C. § 1818(e) and (i).

Respondent was further advised of the right to a hearing on the Notices under 12 U.S.C.

§ 1818(e) and (i) and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights

under those provisions on December 31, 2023, and consented to the issuance of the Orders by

entering into a Stipulation and Consent to the Issuance of an Order of Prohibition from Further

Participation and Order to Pay (Consent Agreement) with a representative of the Federal Deposit

Insurance Corporation’s (FDIC) Legal Division.

 The FDIC determined, and Respondent neither admits nor denies, the following:

1. While serving as Sales Manager of the Bloomfield, Michigan, loan production

office of the Bank of England, England, Arkansas (Bank), in 2019. Respondent engaged in

violations of Section 5 of the Federal Trade Commission Act by misrepresenting available loan

prices for mortgage loans, misrepresenting to consumers that they could skip two months of their

mortgage payments, and misrepresenting the loan production office’s affiliation with the

Department of Veterans Affairs.

2. As described in paragraph 1, Respondent violated laws and engaged in unsafe and

unsound practices in connection with the Bank.

3. Respondent’s violation of laws and unsafe and unsound practices caused financial

loss or other damage to the Bank, and Respondent received financial gain.

4. Respondent’s violation of laws and unsafe and unsound practices demonstrated

Respondent’s willful or continuing disregard for the safety or soundness of the Bank.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C.

§ 1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER OF PROHIBITION FROM FURTHER PARTICIPATION

5. Jasmine Jonna is prohibited from:

a. participating in any manner in the conduct of the affairs of any financial

institution or organization listed in 12 U.S.C. § 1818(e)(7)(A);

b. soliciting, procuring, transferring, attempting to transfer, voting, or

attempting to vote any proxy, consent, or authorization with respect to any voting rights in any

financial institution enumerated in 12 U.S.C. § 1818(e)(7)(A);

 c. violating any voting agreement previously approved by the appropriate

Federal banking agency; or

d. voting for a director or serving or acting as an institution-affiliated party.

6. The Prohibition Order is effective upon issuance and will remain effective and

enforceable until the FDIC and any “appropriate Federal financial institutions regulatory

agency,” defined at 12 U.S.C. § 1818(e)(7)(D), decide in writing to modify, terminate, suspend,

or set aside the Prohibition Order under 12 U.S.C. § 1818(e)(7)(B).

7. The Prohibition Order is enforceable under 12 U.S.C. § 1818(i), and any violation

of the Prohibition Order may result in additional penalties under 12 U.S.C. § 1818(j).

8. The Prohibition Order does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

ORDER TO PAY

9. By reason of Respondent’s actions listed in paragraph 1, a $12,000 CMP is

assessed against Jasmine Jonna under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must pay the CMP to the Treasury of the United States.

10. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

11. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

12. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

Issued under delegated authority.

Dated: January 12, 2024.

__/s/______________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
)
LAMONT KENNEDY, individually and as ) PERSONAL CONSENT
institution-affiliated party ) ORDER
of )
)
BANK OF ENGLAND ) FDIC-23-0084b
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 784276 )
)

Lamont Kennedy (Respondent) was advised of the Respondent’s right to receive a Notice

of Intention to Seek a Cease and Desist Order (Notice) detailing Respondent’s violations of law

for which an Order To Cease and Desist (Personal Consent Order) may be issued under 12

U.S.C. § 1818(b).

Respondent was further advised of the right to a hearing on the Notice under 12 U.S.C.

§ 1818(b) and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under

those provisions on November 17, 2023, and consented to the issuance of the Personal Consent

Order by entering into a Stipulation and Consent to the Issuance of a Personal Consent Order

(Consent Agreement) with a representative of the FDIC’s Legal Division.

The FDIC determined and Respondent neither admits nor denies the following:

1. From at least January 2019 through August 2019, Respondent, in his capacity as a

mortgage loan officer of Bank of England, England, Arkansas (the Bank), engaged in deceptive

acts or practices in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. 45(a)
(Section 5), by luring consumers to apply for mortgage loans with low, unavailable loan prices

that would not be honored and subsequently increasing the price before closing the loan.

Furthermore, the FDIC determined that from at least January 2019 to October 2019, Respondent

engaged in violations of Section 5 by misrepresenting to consumers that they could skip two

months of mortgage payments if they refinanced their mortgage loan with the Bank.

2. As described in paragraph 1, Respondent violated Section 5.

The FDIC accepts the Consent Agreement and issues the following:

PERSONAL CONSENT ORDER

Respondent must cease and desist from, and take affirmative action, as follows:

3. Within 180 days of the date of this Personal Consent Order, Respondent must

complete at least 24 hours of training through an outside third-party provider that is deemed

acceptable by the Regional Director of the FDIC's Dallas Regional Office. The training must

cover the topics of compliance with mortgage-related regulations, Section 5, and ethical lending

practices.

4. Respondent must not violate Section 5 of the Federal Trade Commission Act or

mortgage-related regulations.

5. Prior to accepting any position that would cause Respondent to become an

institution-affiliated party (IAP) of an insured depository institution (IDI) specified in 12 U.S.C.

§ 1818(e)(7)(A), Respondent shall ensure he has all applicable registrations and/or licenses

required by law for that position.

6. When Respondent is employed by an IDI or otherwise becomes an IAP under 12

U.S.C. § 1813(u), Respondent must follow the written policies and procedures of that IDI. If

Respondent is affiliated with an IDI whose written policies and procedures are more stringent

2
than the provisions of this Personal Consent Order, Respondent must adhere to the IDI’s written

policies and procedures.

7. Before accepting any position causing Respondent to become an IAP, Respondent

must provide a copy of this Personal Consent Order to: (i) the Chairman of the Board of

Directors of the IDI, or (ii) a senior executive manager of the IDI, provided that the official was

approved in writing by the Regional Director, FDIC Dallas Regional Office, for this purpose.

8. Within 10 calendar days of satisfying the requirements of paragraph 7,

Respondent must provide a written certification of Respondent’s compliance to the Regional

Director, FDIC Dallas Regional Office.

9. If Respondent believes that the Personal Consent Order provisions are fulfilled,

Respondent may request termination of the Personal Consent Order by submitting a letter with

supporting materials to the Regional Director, FDIC Dallas Regional Office. The FDIC may

request additional information to review the termination request. The decision to deny the

request and retain this Personal Consent Order as is, modify it, or terminate it, is at the FDIC’s

discretion.

10. This Personal Consent Order is effective immediately.

11. The provisions of this Personal Consent Order are enforceable under 12 U.S.C.

§ 1818(i) for 5 (five) years from the date of this Personal Consent Order, except to the extent that

any provision is modified, terminated, suspended, or set aside by the FDIC.

12. This Personal Consent Order does not waive any right, power, or authority of the

United States; federal, state, or local agencies; or the FDIC as Receiver.

3
Issued under delegated authority.

Dated: January 12, 2024.

_/s/___________________________________
G. Chris Finnegan
Senior Deputy Director
Division of Depositor and Consumer Protection

4
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
SALAM YALDO, individually and )
as an institution-affiliated party ) ORDER TO PAY
of )
) FDIC-23-0059k
BANK OF ENGLAND )
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 1707926 )
)
)

Salam Yaldo (Respondent) was advised of the right to receive a Notice of Assessment

(Notice) detailing Respondent’s violation of law for which an Order to Pay a civil money penalty

(Order to Pay) may be issued under 12 U.S.C. § 1818(i).

Respondent was further advised of the right to a hearing on the Notice under § 1818(i)

and 12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those

provisions on September 22, 2023, and consented to the issuance of an Order to Pay by entering

into a Stipulation and Consent to the Issuance of an Order to Pay (Consent Agreement) with a

representative of the Federal Deposit Insurance Corporation’s (FDIC) Legal Division.

The FDIC determined, and Respondent neither admits nor denies, the following:

1. From January 2019 through August 2019, Respondent engaged in deceptive acts

or practices in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a)

(Section 5), by luring consumers to apply for mortgage loans with low, unavailable loan prices
that would not be honored and subsequently increasing the price before closing the loan.

Furthermore, the FDIC determined, and Respondent neither admits nor denies, that from at least

January 2019 to October 2019, Respondent engaged in violations of Section 5 by

misrepresenting to consumers that they could skip two months of mortgage payments. In

addition, the FDIC determined, and Respondent neither admits nor denies, that from at least

January 2019 to January 2020, Respondent engaged in violations of Section 5 by misrepresenting

to consumers his and the Bank’s affiliation with the Department of Veterans Affairs.

2. As described in paragraph 1, Respondent engaged or participated in violations of

law.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C. §

1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER TO PAY

3. By reason of Respondent’s actions listed in paragraph 1, a $15,000 CMP is

assessed against Salam Yaldo under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must immediately pay the CMP to the Treasury of the United States.

4. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

5. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will

take action to collect the amount due if Respondent fails to make payment.

6. The Order to Pay does not waive any right, power, or authority of the United

States; federal, state, or local agencies; or the FDIC as Receiver.

2
Issued under delegated authority.

Dated: January 12, 2024.

_/s/__________________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection

3
 FEDERAL DEPOSIT INSURANCE CORPORATION

WASHINGTON, D.C.

)
In the Matter of: )
)
Zach Jabro, individually and as an institution- ) ORDER TO PAY
affiliated party of )
) FDIC-23-0056k
BANK OF ENGLAND )
ENGLAND, ARKANSAS )
)
(INSURED STATE NONMEMBER BANK) )
)
Respondent’s NMLS UI# 784269 )
)

Zack Jabro (Respondent) was advised of the right to receive a Notice of Assessment

(Notice) detailing Respondent’s violations of law for which an Order to Pay a civil money penalty

(Order to Pay) may be issued under 12 U.S.C. § 1818(i).

Respondent was further advised of the right to a hearing on the Notice under § 1818(i) and

12 C.F.R. Part 308, subparts A & B. Respondent waived certain rights under those provisions on

October 9, 2023, and solely for the purpose of this proceeding and without admitting or denying

any failure to manage, monitor of oversee sales operations; any unsafe or unsound banking

practices; or breaches of fiduciary duty, Respondent consented to the issuance of an Order to Pay

by entering into a Stipulation and Consent to the Issuance of an Order to Pay (Consent Agreement)

with a representative of the Federal Deposit Insurance Corporation’s (FDIC) Legal Division.

The FDIC determined, and Respondent neither admits nor denies, the following:

1. From at least January 2019 through January 2020, Respondent, as the Branch

Manager of the Bank of England’s Bloomfield, Michigan branch, failed in certain respects to

manage, monitor, and oversee the sales operations of the branch.

 2. As described in paragraph 1, the Respondent recklessly engaged in certain unsafe

and unsound banking practices by failing to manage, monitor and oversee the sales operations of

the branch. The Respondent breached certain duties of care to the Bank of England (Bank) to

oversee the operations of the branch and to ensure compliance with laws and regulations.

3. Respondent’s practices set forth in paragraphs 1 and 2 caused or is likely to cause

more than a minimal loss to the Bank and/or resulted in pecuniary gain or other benefit to

Respondent.

After considering the civil money penalty (CMP) mitigating factors under 12 U.S.C.

§ 1818(i)(2)(G), the FDIC accepts the Consent Agreement and issues the following:

ORDER TO PAY

4. By reason of Respondent’s actions listed in paragraphs 1 and 2, a $110,000 CMP

is assessed against Zack Jabro under 12 U.S.C. § 1818(i)(2) and is effective upon issuance.

Respondent must immediately pay the CMP to the Treasury of the United States.

5. Respondent may not seek or accept indemnification from any insured depository

institution for the CMP assessed in this matter.

6. The Order to Pay is enforceable under 12 U.S.C. § 1818(i), and the FDIC will take

action to collect the amount due if Respondent fails to make payment.

7. The Order to Pay does not waive any right, power, or authority of the United States;

federal, state, or local agencies; or the FDIC as Receiver.

Issued under delegated authority.

Dated: January 12, 2024.

_/s/________________________
G. Chris Finnegan,
Senior Deputy Director
Division of Depositor and Consumer Protection