The estimated scope of USAA Bank's MLA violations was uncovered following an internal review by a consulting firm retained by USAA, which the OCC, the bank's primary regulator, mandated as part of its January 2019 consent order, according to the whistleblower. The consent order marked the first time the OCC publicly cited the bank for engaging in "unsafe or unsound banking practices, including those relating to the bank's compliance management system, risk governance framework, and information technology program." Under its consent order, the OCC mandated the bank to enlist the help of a consulting firm to conduct a "six-year lookback," going back to 2013, to uncover all its violations of law, said Lenn Ferrer, a former director of compliance at USAA Bank before he was terminated in March 2020 after internally blowing the whistle.