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the Bureau ultimately uses those funds, Respondent may not:
a.
Claim, assert, or apply for a tax deduction, tax credit, or any other tax
benefit for any civil money penalty paid under this Consent Order; or
b.
Seek or accept, directly or indirectly, reimbursement or
indemnification from any source, including but not limited to payment
made under any insurance policy, in relation to any civil money
penalty paid under this Consent Order.
66.
To preserve the deterrent effect of the civil money penalty in any Related
Consumer Action, Respondent may not argue that Respondent is entitled to,
nor may Respondent benefit by, any offset or reduction of any compensatory
monetary remedies imposed in the Related Consumer Action because of the
civil money penalty paid in this action or because of any payment that the
Bureau makes from the Civil Penalty Fund. If the court in any Related
Consumer Action offsets or otherwise reduces the amount of compensatory
monetary remedies imposed against Respondent based on the civil money
penalty paid in this action or based on any payment that the Bureau makes
from the Civil Penalty Fund, Respondent must, within 30 days after entry of
a final order granting such offset or reduction, notify the Bureau, and pay the
amount of the offset or reduction to the U.S. Treasury. Such a payment will
not be considered an additional civil money penalty and will not change the
amount of the civil money penalty imposed in this action.
2022-CFPB-0011 Document 1 Filed 12/20/2022 Page 22 of 32