Banker to ISO: “While some of your merchants . . . have return rates of 15-25%, others are now at 40, 50, and even 60% consistently. I understand that these companies (merchants) can still make good money with such [high insufficient fund returns rates], since they are charging APRs of 1500-1800%, but I don’t think we make enough money to take on the extra risk and monitoring that would come with accepting those extreme ratios.”
Banker to colleagues: “Such return rates would make it appear that “we don’t know our customers and we don’t do due diligence and risk grade them properly.”
Banker via internal email: “You don’t think there’s huge potential liability for ignoring the fact that certain transactions could potentially be illegal, and not doing the due diligence and monitoring to ensure they aren’t? . . . I’m not sure ‘don’t ask/ don’t tell’ is going to be a reasonable defense, if a state comes after one of our originators.”
It Wasn’t.