Fifth Third's four-products-per-customer goal bred 124,000 zombie accounts

From at least 2010 until at least 2017, Fifth Third Bank set branch employees a cross-sell goal of four products per customer, plus point-based targets whose values tracked the revenue each product generated. Performance ratings and sometimes continued employment depended on hitting the goals, thousands of employees could not reach them, and the bank did not tell customers its staff were working to quotas. Cross-selling brought Fifth Third more than $10 million a year.

The pressure produced accounts no one authorized. The CFPB's amended complaint counted 124,000+ deposit accounts since 2010 funded with $100 or less and drained back to zero within 90 days, 218,000+ credit cards issued but never activated, and 48,000+ online-banking enrollments on bank email addresses — 1,400 with zero logins. Employees even funded new accounts with their own money, then reimbursed themselves from it. The bank's own 2013 review found a 37% error rate obtaining signatures on its Early Access product, 19,000 of which were opened and closed unused the same day.

The CFPB filed suit under seal on March 9, 2020; the case moved to the Southern District of Ohio and became public in April 2021. After four years of motions, the parties moved for entry of a stipulated final judgment on July 9, 2024, which Judge Douglas R. Cole entered on July 18, 2024. Without admitting the allegations, Fifth Third agreed to pay a $15 million civil penalty, fund a redress plan for customers with accounts opened from 2010 through 2016, adopt a compliance plan, and keep policies barring product-specific sales goals that foster unauthorized openings.

The order also bars Fifth Third from telling any consumer it is acting in the customer's best interest unless it has reasonably confirmed a recommendation suits that customer, and states the complaint's allegations are taken as true with collateral estoppel effect. The same settlement included a separate consent order over a discontinued auto-lending program that added collateral protection insurance to car loans.

$15M civil penalty under the July 2024 stipulated judgment, plus a redress plan for unauthorized accounts opened from 2010 through 2016

Performance ratings and jobs were tied to a four-products-per-customer quota that thousands of employees could not meet honestly, so some manufactured the volume instead.

Point values were set by the revenue each product generated, which paid employees for opening products rather than for customers actually using them.

Controls were weaker than the incentives: applications and enrollments could go through with bank email addresses, missing signatures, and accounts nobody ever logged into.

The abuse left a measurable fingerprint — tiny funded accounts drained within 90 days — yet the bank lived with it from 2010 through 2016 rather than resetting the quota system.

Fifth Third kept the program even after its 2013 internal review found a 37% signature error rate on Early Access applications.

Sales quotas work until they exceed what honest selling can deliver; then staff manufacture the numbers, and the incentive design itself becomes the fraud.

The stipulated final judgment, entered July 18, 2024, requires Fifth Third to complete its redress plan within a year of the CFPB approving it, with the bank's internal audit department validating execution. Fifth Third's 10-Q discloses the $15 million penalty and notes the bank settled without admitting the allegations. The case stands as the CFPB's bookend to the wave of quota-driven fake-account scandals that began with Wells Fargo.