On July 26, the Federal Reserve Board (Board) announced a settlement with a Kentucky-based bank for allegedly violating section 5 of the FTC Act regarding its offering of deposit account add-on products to consumers. According to the consent order, the bank marketed certain add-on products to accountholders, including an identity protection product, and represented that all benefits of the products would be effective upon enrollment when in actuality, certain benefits needed to be individually activated after enrollment. The Board alleges the bank charged the enrolled accountholders fixed monthly fees for the full benefits of the products without adequately disclosing to accountholders how to receive all the associated benefits. In addition to the $4.75 million the bank must pay in restitution, the consent order also requires the bank to, among other things (i) submit written plans to strengthen the oversight of the compliance management program and enhance the consumer compliance risk management program; (ii) hire an independent auditor to verify the restitution has been made; and (iii) submit quarterly progress reports regarding compliance with the consent order.