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We are a member-centric, one-stop shop for financial services that, through our Lending and Financial Services products, allows members to borrow, save, spend, invest and protect their money.
−Removed: We refer to our customers as “members”.
+Added: We refer to our customers as “members” and “clients”.
Our mission is to help our members achieve financial independence in order to realize their ambitions.
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Everything we do today is geared toward helping our members “Get Your Money Right” and we strive to innovate and build ways for our members to achieve this goal.
+Added: In order to help achieve our mission, we offer personal loans, student loans, home loans and related servicing.
+Added: We offer a variety of financial services products, such as SoFi Money, SoFi Credit Card, SoFi Invest and SoFi Relay, that provide more daily interactions with our members, as well as lending as a service which helps a broader range of borrowers to find lending solutions.
+Added: We offer products and capabilities, such as SoFi At Work, that are designed to appeal to enterprises.
+Added: We have also made strategic acquisitions to further expand our platform capabilities for enterprises, which we believe will deepen our participation in the entire technology ecosystem powering digital financial services.
We have built a social area within our digital native application, which we refer to as the member home feed.
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_________________
−Removed: (1) Composed of in-school loans and student loan refinancing.
−Removed: (2) Our SoFi Invest service is composed of three products:
−Removed: active investing accounts, robo-advisory accounts and digital assets accounts.
−Removed: SoFi Invest also includes our brokerage accounts through 8 Limited in Hong Kong.
−Removed: Recent Acquisitions
−Removed: In February 2022, we closed the Bank Merger, after which we became a bank holding company and Golden Pacific began operating as SoFi Bank.
−Removed: We believe operating a national bank allows us to provide members and prospective members broader and more competitive options across their financial services needs and lowers our cost of asset-backed financing relative to alternative sources of funding (by utilizing deposits held at SoFi Bank to fund our loans).
−Removed: We also believe that operating as a national bank enables us to offer lower interest rates on loans to members as well as offer higher interest rates on deposit accounts.
−Removed: See “SoFi Bank” herein for additional information on the Bank Merger.
+Added: (1) Lending as a service includes referred loans which are originated by a third-party partner to which we provide pre-qualified borrower referrals, certain loans which we originate and subsequently sell to a third-party partner, and certain loans associated with our Lantern Credit financial services marketplace platform.
SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
−Removed: In March 2022, we closed the Technisys Merger, which added a cloud-native digital and core banking platform with an existing footprint of clients into our technology platform offerings.
−Removed: We believe that the combination of the Technisys core banking platform with our existing technology platform offerings provides an end-to-end vertically integrated technology stack, which we expect will meet the expanding needs of our existing clients and attract new clients.
−Removed: See Note 2 to the Notes to Consolidated Financial Statements for additional information on our business combinations.
+Added: TABLE OF CONTENT S
We have created an innovative financial services platform designed to offer best-in-class products to meet the broad objectives of our members and the lifecycle of their financial needs.
Our platform offers our members (as defined under Part II, Item 7.
−Removed: “Key Business Metrics” ) a suite of financial products and services, enabling them to borrow, save, spend, invest and protect their finances across one integrated platform.
+Added: “ Key Business Metrics ”) a suite of financial products and services, enabling them to borrow, save, spend, invest and protect their finances across one integrated platform, as well as personal financial management tools and benefits to complement our products.
Our aim is to create a best-in-class, integrated financial services platform that will generate a virtuous cycle whereby positive member experiences will lead to new product adoption by existing members and enhanced profitability for each additional product by lowering overall member acquisition costs and increasing the lifetime value of our members.
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In addition to benefiting our members, our products and capabilities are also designed to appeal to enterprises, such as financial services institutions that subscribe to our enterprise services and have become interconnected with the SoFi platform.
−Removed: We have continued to expand our platform capabilities for enterprises through our acquisition of Galileo in 2020, which provides technology platform services to financial and non-financial institutions and which has allowed us to vertically integrate across more of our financial services, and the Technisys Merger in the first quarter of 2022, through which we added a cloud-native digital and core banking platform into our technology platform offerings and expanded our technology platform services to a broader international market.
−Removed: We believe that these expansions will deepen our participation in the entire technology ecosystem powering digital financial services, allowing us to not only reduce costs to operate our member-centric business, but also deliver increasing value to our enterprise customers.
+Added: We have continued to expand our platform capabilities for enterprises through strategic acquisitions, including:
+Added: (i) our acquisition of Galileo in 2020, which provides technology platform services to financial and non-financial institutions and which has allowed us to vertically integrate across more of our financial services, and (ii) the Technisys Merger in the first quarter of 2022, through which we added a cloud-native digital and core banking platform into our technology platform offerings and expanded our technology platform services to a broader international market.
+Added: These expansions have deepened our participation in the entire technology ecosystem powering digital financial services, allowing us to not only reduce costs to operate our member-centric business, but also deliver increasing value to our enterprise customers.
While our enterprises are not considered members, they are important contributors to the growth of the SoFi platform, and also have their own constituents who might benefit from our products in the future.
−Removed: In February 2022, we closed the Bank Merger, pursuant to which we acquired all of the outstanding equity interests in Golden Pacific Bancorp, Inc.
−Removed: and its wholly-owned subsidiary, Golden Pacific Bank, a national bank.
−Removed: Upon closing the Bank Merger, we became a bank holding company and Golden Pacific began operating as SoFi Bank.
+Added: In February 2022, we closed the Bank Merger, pursuant to which we became a bank holding company and began operating as SoFi Bank.
Golden Pacific’s community bank business continues to operate as a division of SoFi Bank.
−Removed: As a bank holding company, we offer SoFi Checking and Savings accounts through SoFi Bank.
−Removed: We are originating all new loan applications within SoFi Bank and transferred SoFi Credit Card and the majority of other lending products to SoFi Bank.
−Removed: We intend to continue to explore other products for SoFi Bank over time.
+Added: As a bank holding company, we offer checking and savings accounts and credit cards through SoFi Bank.
+Added: We are originating all new loan applications within SoFi Bank, and we intend to continue to explore other products for SoFi Bank over time.
The key current and expected financial benefits to us of operating a national bank include:
−Removed: (i) lowering our cost to fund loans, as we can utilize deposits held at SoFi Bank to fund loans, which have a lower borrowing cost of funds than our warehouse and securitization financing model, (ii) increasing our flexibility to hold loans on our balance sheet for longer periods, thereby enabling us to earn interest on these loans for a longer period, (iii) supporting origination volume growth by providing an alternative financing option, while also maintaining our warehouse capacity, and (iv) through deposits, providing us with meaningful member data that can allow us to better serve their financial needs.
+Added: (i) lowering our cost to fund loans, as we can utilize deposits held at SoFi Bank to fund loans, which have a lower borrowing cost of funds than our warehouse and securitization financing model, (ii) increasing our flexibility to hold loans on our balance sheet for longer periods, thereby enabling us to earn interest on these loans for a longer period, (iii) supporting origination volume growth by providing an alternative financing option, while also maintaining our warehouse capacity, and (iv) through deposits, providing us with meaningful member data that can allow us to better serve our members’ financial needs.
See Part I, Item 1A.
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International Operations
−Removed: While we primarily operate in the United States, we expanded into Hong Kong with our acquisition of 8 Limited (an investment business) in 2020, we gained clients in Canada, Mexico and Colombia with our acquisition of Galileo in 2020, and we further expanded into Latin America with the Technisys Merger in 2022.
−Removed: SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
+Added: While we primarily operate in the United States, we also operate internationally in Latin America and Canada, largely through our Technology Platform segment, as well as in Hong Kong through SoFi Holdings (Hong Kong) Limited (an investment business).
Our Differentiation
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(2) Selection — Given the digital nature of our products, the permutations of features and services that can be made available to our members across their needs to borrow, save, spend, invest and protect are significant.
−Removed: We will continue to iterate, learn and innovate to broaden our selection in the same way we did this year by providing our members with competitive interest rates on checking and savings accounts, options trading, “Pay in 4” (a buy now, pay later product), and SoFi Plus membership benefits.
+Added: We will continue to iterate, learn and innovate to broaden our selection in the same way we did this year by providing our members with
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: competitive interest rates on checking and savings accounts, options trading, “Pay in 4” (a buy now, pay later product), and SoFi Plus membership benefits.
(3) Content — Our financial education, insights, research content, actionable tools and advice are designed to provide meaningful value for our members.
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We believe that developing a relationship with our members and gaining their trust is central to our success as a financial services platform.
−Removed: Moreover, we believe that some of the current frictions faced by other financial institutions are caused by a disjointed and non-seamless product experience, a lack of digital acquisition, subpar mobile web products instead of digital native apps and incomplete product offerings to meet a customer’s holistic financial needs.
−Removed: Through our mobile technology and continuous effort to improve our financial services products, we are seeking to build a financial services platform that members can access for all of their financial services needs.
+Added: Moreover, we believe that some of the current frictions faced by other financial institutions are caused by a disjointed and non-seamless product experience, a lack of digital customer acquisition, subpar mobile web products instead of digital native apps and incomplete product offerings to meet a customer’s holistic financial needs.
+Added: Through our mobile technology and continuous effort to improve our financial services products, we are seeking to build a financial services platform that can support all of our members’ financial services needs throughout their lifetime.
Our strategy, which is rooted in what we refer to as our “Financial Services Productivity Loop”, is centered around building trust and a lifetime relationship with our members, which we believe will help build a sustainable competitive advantage.
−Removed: SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
Financial Services Productivity Loop
In order to deliver on our strategy, we must develop best-in-class unit economics and best-in-class products that build trust and reliability between our members and our platform.
−Removed: Our acquisition of SoFi Bank was also an important step in continuing to build best-in-class unit economics and best-in-class products, as it has enabled us to offer additional products and achieve lower cost of funding.
−Removed: When we do this on a member’s first product, and they later consider using an additional product, we believe they are more likely to start with our platform and we have a higher chance that they will select one of our products to meet their other financial needs.
+Added: Our acquisition of SoFi Bank was also an important step in continuing to build best-in-class unit economics and best-in-class products, as it has enabled us to achieve lower cost of funding through deposits, and improved unit economics and engagement on SoFi Money.
+Added: When we do this on a member’s first product, and they later consider using an additional product, we believe they are more likely to start with our platform and we have a
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: higher chance that they will select one of our products to meet their other financial needs.
This results in delivering more revenue per member with no second member acquisition costs, resulting in higher lifetime value per member.
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Lending, Technology Platform and Financial Services.
−Removed: Below is a discussion of our segments and their primary products.
+Added: Below is a discussion of our segments and their primary products and non-product offerings.
Lending Segment
−Removed: We offer personal loans, student loans and home loans and related servicing.
+Added: We offer personal loans, student loans, home loans and related servicing.
We believe that our market opportunity within each of these lending channels is significant.
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We operate in the student loan refinance space, with a focus on prime and super-prime school loans, as well as the “in-school” lending space, which allows members to borrow funds while they attend school.
−Removed: We offer flexible loan sizes and repayment options, competitive rates and, in most cases, the ability to lock in an interest rate for funding at a later
−Removed: SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
+Added: We offer flexible loan sizes, repayment options and competitive rates.
Within student loan refinancing, we generally offer loan sizes of $5,000 or higher, subject to legal and/or licensing requirements, with terms generally ranging from 5 to 20 years.
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We regularly update the annual percentage rates offered on our fixed and variable-rate student loans.
−Removed: We offer agency and non-agency loans for members purchasing a home or refinancing an existing mortgage.
−Removed: For our home loan products, we offer competitive rates, flexible down payment options for as little as 3%, a close on time guarantee, and educational tools and calculators.
−Removed: We generally offer loan sizes of $100,000 to $726,200 for one-unit properties in conforming normal cost areas (with exceptions for loan sizes less than $100,000 considered on a case-by-case basis), up to $1,089,300 for conforming high cost areas (Government-Sponsored Enterprises, or “GSEs”, eligible loans above the normal conforming limit, which is determined by county) and up to $3,000,000 for jumbo loans (loans in the jumbo loan program).
+Added: We offer agency, non-agency and, beginning in the second quarter of 2023, certain government loans (e.g., VA and Federal Housing Administration loans) for members purchasing a home or refinancing an existing mortgage.
+Added: For our home loan products, we offer competitive rates, flexible down payment options for as little as 3% (or 0% for VA loans), a close on time guarantee, and educational tools and calculators.
+Added: For one-unit properties, we generally offer loan sizes of $75,000 to $766,550 for in conforming normal cost areas (with exceptions for smaller loan sizes considered on a case-by-case basis), up to $1,149,825 in conforming high cost areas (GSE-eligible loans above the normal conforming limit, which is determined by county).
+Added: For multi-unit properties, we offer loan sizes up to $2,211,600.
+Added: In addition, we offer loan sizes up to $3,000,000 for jumbo loans (loans in the jumbo loan program), up to $1,500,000 for VA loans, and up to $472,030 for Federal Housing Administration loans in most areas.
Our fixed rate home loans generally have terms of 10, 15, 20, 25 or 30 years.
−Removed: We recently began offering an adjustable rate mortgage product for conforming and jumbo loans, with a fixed rate for 5, 7 or 10 years followed by rate adjustments every six months for the remainder of the 30-year term.
+Added: We offer adjustable rate mortgage products for conforming and jumbo loans, with a fixed rate for 5, 7 or 10 years followed by rate adjustments every six months for the remainder of the 30-year term, and for VA and Federal Housing Administration loans, with a fixed rate for 5 years followed by rate adjustments every year for the remainder of the 30-year term.
We regularly update the annual percentage rates offered on our home loans.
Lending Model
−Removed: Although our lending business remains primarily a gain-on-sale model, whereby we seek to originate loans, recognize a gain from these loans and sell them into either our whole loan or securitization channels, operating SoFi Bank has also provided us with more flexibility to hold loans on our balance sheet for longer periods, thereby enabling us to earn interest on these loans for a longer period and to be selective in our sales arrangements.
+Added: We originate loans through our lending business, and have the option of pursuing a gain-on-sale origination model, whereby we seek to recognize a gain from these loans and sell them into either our whole loan or securitization channels, or holding loans on our balance sheet when advantageous.
+Added: This enables us to maximize our return and balance our risk by earning
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: interest on these loans for a longer period and to be selective in our sales arrangements.
+Added: We expect to benefit from the continued mix towards deposit funding through operating SoFi Bank.
We sell our whole loans primarily to large financial institutions, such as bank holding companies.
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In the case of both whole loan sales and securitizations, and with the exception of certain of our home loans, we also continue to retain servicing rights to our originated loans following transfer.
−Removed: We view servicing as an integral component of the Lending segment, as we believe our servicing function is an important asset because of the connection to the member it affords us throughout the life of the loan.
We directly service all of the personal loans that we originate.
We act as master servicer for, and rely on sub-servicers to directly service, all of our student loans and GSE conforming home loans.
−Removed: We believe this ongoing relationship with our members enhances the effectiveness of our Financial Services Productivity Loop by increasing member touchpoints and driving new product adoption by existing members.
+Added: We view servicing as an integral component of the Lending segment, as we believe our servicing function is an important asset because of the connection to the member it affords us throughout the life of the loan thereby enhancing the effectiveness of our Financial Services Productivity Loop by increasing member touchpoints and driving new product adoption by existing members.
We rely upon deposits, warehouse financing and our own capital to enable us to continue to expand our origination capabilities.
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Underwriting Process
−Removed: We have developed an extensive underwriting process across each lending product that is focused on willingness to pay (measured by credit attributes), ability to pay (measured through income verification), and stability (measured by debt service in relation to other loans).
+Added: We have developed an extensive underwriting process across each lending product that is focused on willingness to pay (measured by credit attributes and risk scores), ability to pay (measured through income and free cash flow), and stability (measured by credit experience).
A key element of our underwriting process is the ability to facilitate risk-based interest rates that we believe are appropriate for each loan using proprietary risk models through which we project quarterly loan performance, including expected losses and prepayments.
−Removed: The outcome of this process helps us determine a more data-driven, risk-adjusted interest rate that we can offer our members.
−Removed: Our personal loan and student loan underwriting models consider credit reports, industry credit and bankruptcy prediction models, custom credit assessment models, and debt capacity analysis, as indicated by borrower free cash flow.
+Added: We believe the outcome of this process helps us determine a more data-driven, risk-adjusted interest rate that we can offer our members.
+Added: Further, our data and monitoring tools enable us to implement risk mitigation strategies quickly and efficiently, including underwriting standard adjustments to adapt our operations to changing environments and expectations.
+Added: Our personal loan and student loan underwriting models are typically based on credit reports, industry credit and bankruptcy prediction models, custom credit assessment models, and debt capacity analysis, as indicated by borrower free cash flow.
Our underwriting strategy utilizes an advanced risk model that provides refined risk separation.
Home loans originated by SoFi that are agency-conforming loans are subject to credit, debt service, and collateral eligibility established by GSEs.
−Removed: Home loans originated by us that are non-agency loans are subject to our credit criteria, which typically includes a minimum tri-bureau credit score, established credit history requirements, income verification, as well as maximum qualified mortgage limits on debt-to-income service and caps on loan-to-value based on an accredited appraisal.
+Added: Government loans, such as VA and Federal Housing Administration loans, are subject to the underwriting requirements established by the appropriate government agency.
+Added: In addition to these requirements, agency-conforming and government loans are subject to credit eligibility overlays imposed by SoFi as well as individual investor requirements.
+Added: Other non-agency loans originated by us, such as Jumbo loans, are subject to investor credit criteria, which typically includes a minimum tri-bureau credit score, established credit history requirements, income verification, as well as maximum limits on debt-to-income service and caps on loan-to-value based on an accredited appraisal.
We also leverage our data to provide existing members a streamlined application process through automation.
Across our loan products, existing members generally experience a higher approval rate than new members, subject to the existing member being in good standing on their existing products.
−Removed: SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
Technology Platform Segment
−Removed: Our Technology Platform segment consists of Galileo, which we acquired in May 2020, and Technisys, which we acquired in March 2022.
−Removed: Galileo is a provider of technology platform services to financial and non-financial institutions.
−Removed: Through Galileo, we provide services through a suite of program, event and authorization application programming interfaces for financial and non-financial institutions.
−Removed: Technisys is a cloud-native digital and core banking platform with financial services customers predominantly in Latin America.
−Removed: Through Technisys, we earn technology product and solutions revenue through sales of software licenses and provision of maintenance and support services related to those software licenses.
−Removed: We also provide additional technology solutions for our customers as their business needs evolve over time, which we refer to as “evolution labs.”
+Added: We provide technology platform services through a diversified suite of offerings which include an event and authorization platform accessed via application programming interfaces, a cloud-native digital and core banking platform and services related to both platforms.
+Added: Our customers include financial and non-financial institutions in North and Latin America.
+Added: We earn technology product and solutions revenue through the use of the platforms, either on a per use basis, or from overall license and maintenance fee service arrangements related to those respective platforms.
+Added: We also offer additional add-on technology solutions to support our clients and drive engagement, such as an AI-based virtual assistant for customers of banks and financial institutions, and a real-time payment risk platform to enhance payment fraud mitigation strategies for financial customers.
+Added: We continue to leverage investments made to integrate Galileo and Technisys and position the Technology Platform segment for diversified durable growth.
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
Financial Services Segment
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We offer a suite of financial services solutions, the most significant of which are discussed below.
−Removed: SoFi Checking and Savings
−Removed: SoFi Checking and Savings provides a digital banking experience.
−Removed: Following the Bank Merger, we began to allow members to convert their cash management accounts into SoFi Checking and Savings accounts held at SoFi Bank.
−Removed: We believe SoFi Checking and Savings accounts held at SoFi Bank are attractive to our members and prospective members because our digital banking platform allows members to spend, save and earn interest and rewards in flexible ways, all within our mobile application.
+Added: Checking and savings accounts provide a digital banking experience which allows members to spend, save and earn interest and rewards in flexible ways.
+Added: We believe SoFi Checking and Savings accounts held at SoFi Bank are attractive to our members and prospective members due to our differentiated offerings, including competitive interest rates, access to expanded FDIC insurance coverage of up to $2 million through our Insured Deposit Program and the convenience and benefits of being part of a cohesive, simplified financial ecosystem within our mobile platform.
SoFi Bank has also continued to expand its services.
−Removed: SoFi Money debit cards are issued by a third party bank, which also sponsored access to debit networks for payment transactions, funding transactions and associated settlement of funds under a sponsorship agreement with SoFi Securities.
−Removed: Further, the third party bank provided sponsorship and support for ACH, check, and wire transactions along with associated funds settlement.
−Removed: While we continue to engage the third party bank, in the fourth quarter of 2022, SoFi Bank gained direct access to debit networks and began to perform certain services previously sponsored by the third party bank.
−Removed: SoFi Securities’ agreement with the third party bank provides for receipt by the third party bank of program revenue and transaction fees, and is subject to a minimum monthly card activity fee.
−Removed: The agreement with the third party bank is terminable by SoFi Securities with 120 days prior notice.
+Added: In the fourth quarter of 2022, SoFi Bank gained direct access to debit networks and began to perform certain services previously sponsored by the third party bank, including debit card issuance, and processing and settlement of ACH, check, and wire transactions.
Our legacy cash management product utilizes a sweep administrator to sweep funds to and from program banks, as necessary, under a program broker agreement between SoFi Securities and the sweep administrator, as well as program account and program bank agreements with a variety of sweep program banks.
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Historically, the program account agreements and program bank agreements provided for the rate of interest payable on the balances in a member’s cash management account.
+Added: Following the Bank Merger, we began to allow members to convert their cash management accounts into checking and savings accounts held at SoFi Bank.
Effective June 5, 2022, most of our SoFi Money cash management accounts no longer earn interest, as we implemented our plan to build new features only for SoFi Checking and Savings and reduce support of our SoFi Money cash management accounts.
−Removed: SoFi Invest is a mobile-first investment platform offering members access to trading and advisory solutions, such as active investing, robo-advisory and digital assets accounts.
+Added: SoFi Invest is a mobile-first investment platform offering members access to trading and advisory solutions, such as active investing and robo-advisory.
Our interactive investing experience fosters engagement by allowing members to view and monitor other investors’ activity on the platform.
We view SoFi Invest as an attractive first product for members who may later become deposit account holders or borrow with SoFi.
−Removed: Our active investing service enables members to buy and sell stocks and exchange-traded funds (“ETFs”), to engage in options trading, to purchase shares in IPOs before they trade on an exchange, to buy and sell fractional shares and to access a retirement savings account.
+Added: Our active investing service enables members to buy and sell stocks and ETFs, as well as alternative investment funds, mutual funds and money market funds beginning in January 2024, to engage in options trading, to purchase shares in IPOs before they trade on an exchange, to buy and sell fractional shares, to engage in margin investing and to access a retirement savings account.
Our robo-advisory service offers managed portfolios of stocks, bonds and ETFs.
−Removed: Our digital assets service allows members to buy and sell select digital assets through third-party custodians.
Additionally, we provide introductory brokerage services to our members and have invested heavily to create an appealing mobile investing experience.
−Removed: With respect to our digital assets trading activities, we do not hold or store members’ digital assets, but instead rely on third-party custodians, and we hold an immaterial amount of digital assets in order to facilitate paying new member bonuses when members initiate their first digital assets trade.
−Removed: We do this for member convenience to facilitate a seamless payment of digital assets.
−Removed: SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
−Removed: In connection with our approval as a bank holding company, the Board of Governors of the Federal Reserve (the “Federal Reserve”) determined that the activities of SoFi Digital Assets, LLC in providing members with the ability to buy or sell various digital currencies through SoFi Digital Assets, LLC's omnibus account with a third-party custodian is not a permissible activity under the Bank Holding Company Act and Regulation Y.
+Added: In connection with our approval as a bank holding company in February 2022, the Federal Reserve determined that the activities of SoFi Digital Assets, LLC in providing members with the ability to buy or sell various digital currencies through SoFi Digital Assets, LLC's omnibus account with a third-party custodian is not a permissible activity under the Bank Holding Company Act and Regulation Y.
However, under Section 4 of the Bank Holding Company Act, the Federal Reserve has permitted us to continue our current digital assets related offering for a two-year conformance period from the date we became a bank holding company, with the possibility for three one-year extensions, provided that we do not expand our impermissible activities, except as authorized by the Bank Holding Company Act and Regulation Y, or increase our established risk limits for total customer digital assets maintained in wallets that are accessible online, referred to as “hot wallets”, or held on balance sheet.
+Added: Based on this, in the fourth quarter of 2023, we made the decision to transfer the crypto services provided within SoFi Digital Assets, LLC, and began closing existing digital assets accounts.
+Added: Organization, Summary of Significant Accounting Policies and New Accounting Standards for additional information on the transfer of the crypto services.
+Added: Additional financial services solutions offered within our platform include:
• SoFi Credit Card :
−Removed: The SoFi Credit Card product is designed to help our members save, invest and pay down debt through a variable rewards program, with higher rewards offerings when redeeming into other SoFi products.
−Removed: Our credit card product features no annual fee and up to 3% cash back rewards with direct deposit setup through SoFi.
−Removed: Some of the additional financial services solutions offered within our platform include:
−Removed: • Loan referrals:
−Removed: A service through which we present loan referral leads to our enterprise customers.
+Added: Designed to help eligible members spend better with cash back rewards on every purchase and without limits.
+Added: Our unlimited cash back credit card features no annual fee, no foreign transaction fees and flexible redemption options through statement credit or other SoFi products.
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: • Lantern Credit:
+Added: A financial services marketplace platform developed to help applicants that do not qualify for SoFi products to seek alternative products from other providers, as well as to provide a product comparison experience.
+Added: • Other lending as a service:
+Added: Includes referred loans which are originated by a third-party partner to which we provide pre-qualified borrower referrals, and certain loans which we originate and subsequently sell to a third-party partner.
• SoFi Relay:
−Removed: A personal finance management product that allows members to track all of their financial accounts in one place and utilize credit score monitoring services.
−Removed: SoFi Relay also provides us with unified intelligence about our members and offers us meaningful insights about what SoFi products may help our members best achieve their financial goals.
+Added: A personal finance management product that allows members to track all of their financial accounts in one place and gain meaningful insights into their financial health and habits, such as credit score monitoring and spending behaviors.
+Added: SoFi Relay also provides us with unified intelligence about our members that offers information about what SoFi products and features may help our members best achieve their financial goals, allowing us to further personalize the SoFi experience for our members.
+Added: • SoFi Protect :
+Added: A service through which we partner with providers who offer insurance products to help our members protect their assets, including providers across auto, life, homeowners, renters, and cyber insurance products and estate planning.
+Added: • SoFi Travel :
+Added: A service through which we partner with a provider to offer an easy travel search and booking experience that can be managed directly through the SoFi app or website, alongside expanded member benefits including member prices on certain bookings and additional cash back rewards on purchases made with SoFi Credit Card.
• SoFi At Work :
A service through which we partner with other enterprises looking for a seamless way to provide financial benefits to their employees, such as student loan payments made on their employees’ behalf.
−Removed: • Lantern Credit:
−Removed: A financial services marketplace platform developed to help applicants that do not qualify for SoFi products seek alternative products from other providers, as well as to provide a product comparison experience.
−Removed: • SoFi Protect:
−Removed: A service through which we partner with providers who offer insurance products to help our members protect their assets, including providers across auto, life, cyber, homeowners, property and casualty, and renters insurance products and estate planning.
We believe that the content and features we provide within our mobile application can spur more financial education, which leads to more ways for our members to actively engage in getting their money right and can ultimately demonstrate the effectiveness of our Financial Services Productivity Loop.
We compete at multiple levels, including:
−Removed: (i) competition among other personal loan, student loan, credit card and residential mortgage lenders, (ii) competition for deposits among other banks, some challenger banks and a variety of technology and retail companies, (iii) competition for investment accounts among other introductory brokerage firms and a variety of technology and other companies, (iv) competition for subscribers to financial services content, and (v) competition among other technology platforms for the enterprise services we provide, such as platform-as-a-service through Galileo and cloud-native digital and core banking services through Technisys.
+Added: (i) competition among other personal loan, student loan, credit card and residential mortgage lenders, (ii) competition for deposits among other banks, some challenger banks and a variety of technology and retail companies, (iii) competition for investment accounts among other introductory brokerage firms and a variety of technology and other companies, (iv) competition for subscribers to financial services content, and (v) competition among other technology platforms for the enterprise services we provide, such as platform as a service and cloud-native digital and core banking services.
Competition to fund prime loans.
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Competition to acquire investment brokerage accounts.
−Removed: The leading incumbent brokerage firms are larger, have been in business longer and generally have greater brand awareness than us.
−Removed: We also face competition from neo-brokerage platforms
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−Removed: that provide some of the same features as us, such as a mobile brokerage experience, robo-investing, access to digital assets investing, fractional share investing and options trading.
−Removed: In addition, technology and other companies have begun to offer some basic investing features and the ability to buy and sell digital and other assets.
+Added: We face competition from brokerage platforms that provide some of the same features as us, such as a mobile brokerage experience, robo-investing, fractional share investing and options trading.
+Added: In addition, the leading incumbent brokerage firms are larger, have been in business longer and generally have greater brand awareness than us.
+Added: Technology and other companies have begun to offer some basic investing features and the ability to buy and sell digital and other assets.
Competition to attract financial services content viewership.
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We face competition from larger institutions that could make investments into an integrated platform as a service solution or to a cloud-native digital and core banking solution, and also undercut our pricing, preventing our current clients from renewing, while also impeding our attempts to acquire new clients.
+Added: SoFi Technologies, Inc.
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Our sales and marketing efforts are designed to drive brand awareness, improve member acquisition efficiency and accelerate our Financial Services Productivity Loop.
−Removed: We attract and retain members through multiple marketing channels, including social media, traditional media such as the press, online affiliations, search engine optimization, search engine marketing, offline partnerships, preapproved direct mailings and television advertising.
+Added: We attract and retain members through multiple marketing channels, including social media, traditional media such as the press, online affiliations, search engine optimization, search engine marketing, offline partnerships and sponsorship arrangements, preapproved direct mailings and television advertising.
We continue to optimize our marketing strategy through a focus on our full suite of financial products and iterate on opportunities to accelerate the Financial Services Productivity Loop.
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This summary is not a comprehensive analysis of all applicable laws, and is qualified by reference to the full text of statutes and regulations referenced below, which may be modified or amended from time to time.
−Removed: As a bank holding company, we are subject to regulation, supervision and examination by the Federal Reserve under the Bank Holding Company Act of 1956, as amended (“BHCA”), and SoFi Bank is subject to regulation, supervision and examination by the Office of the Comptroller of the Currency (the “OCC”).
+Added: As a bank holding company, we are subject to regulation, supervision and examination by the Federal Reserve under the BHCA, and SoFi Bank is subject to regulation, supervision and examination by the OCC, and beginning January 1, 2024, SoFi Bank and its affiliates became subject to supervision and examination by the CFPB.
+Added: SoFi Securities is subject to regulation by FINRA and the SEC and the Company and its affiliates are subject to supervision and examination by various state regulators.
Bank Holding Company Regulation.
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Source of Strength.
−Removed: Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), we are required to serve as a source of financial strength for SoFi Bank.
+Added: Under the Dodd-Frank Act, we are required to serve as a source of financial strength for SoFi Bank.
This means that we may be required to provide capital or liquidity support to SoFi Bank, even at times when we may not have the resources to provide such support to SoFi Bank.
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Treasury to be financial in nature or incidental to such financial activity.
−Removed: Financial holding companies may also engage in activities that are determined by the
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−Removed: Federal Reserve to be complementary to financial activities.
+Added: Financial holding companies may also engage in activities that are determined by the Federal Reserve to be complementary to financial activities.
“Financial activities” is broadly defined to include not only banking, insurance and securities activities, but also merchant banking and additional activities that the Federal Reserve, in consultation with the Secretary of the Treasury, determines to be financial in nature, incidental to such financial activities, or complementary activities that do not pose a substantial risk to the safety and soundness of depository institutions or the financial system generally.
−Removed: If a financial holding company or any depository institution subsidiary of a financial holding company fails to remain well capitalized and well managed, the Federal Reserve may impose such limitations on the conduct or activities of the financial holding company as the Federal Reserve determines to be appropriate, and the company and its affiliates may not commence any new activity or acquire control of shares of any company engaged in any activity that is authorized particularly for financial holding companies without first obtaining the approval of the Federal Reserve.
+Added: If a financial holding company or any depository institution subsidiary of a financial holding company fails to remain well capitalized and well managed, the Federal Reserve may impose such limitations on the conduct or activities of the financial holding company as the Federal Reserve determines to be appropriate, and the company and its affiliates may not commence any new activity or acquire control of shares of any company engaged in any activity that is authorized particularly
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+Added: for financial holding companies without first obtaining the approval of the Federal Reserve.
The Company must also comply with all applicable Federal Reserve requirements for financial holding companies.
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Additionally, the FDIC has secondary supervisory authority as the insurer of SoFi Bank’s deposits.
−Removed: SoFi Bank is also subject to regulations issued by the CFPB, as enforced by the OCC.
Pursuant to the Dodd-Frank Act, the Federal Reserve may directly examine the subsidiaries of the Company, including SoFi Bank.
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to terminate insurance of deposits, to assess civil money penalties, to issue directives to increase capital, to place SoFi Bank into receivership, and to initiate injunctive actions against banking organizations and institution-affiliated parties.
+Added: CFPB Regulation.
+Added: Beginning January 1, 2024, SoFi Bank and its affiliates became subject to supervision and regulation by the CFPB with respect to federal consumer protection laws, including laws relating to fair lending and the prohibition of unfair, deceptive or abusive acts or practices in connection with the offer, sale or provision of consumer financial products and services.
+Added: As part of its regulatory oversight, the CFPB has authority to take enforcement actions against firms that offer certain products and services to consumers using practices that are deemed to be unfair, deceptive or abusive.
Deposit Insurance.
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The FDIC has the authority to adjust deposit insurance assessment rates at any time.
−Removed: Under the Federal Deposit Insurance Act (“FDIA”), insurance of deposits may be terminated by the FDIC if the FDIC finds that the insured depository institution has engaged in unsafe and unsound practices, is in an unsafe or unsound condition to continue operations or has violated any applicable law, regulation, rule, order or condition imposed by the FDIC.
+Added: Further through SoFi Money, members have access to expanded FDIC insurance coverage of up to $2 million through a reciprocal deposit network of participating banks in our Insured Deposit Program.
+Added: Under the FDIA, insurance of deposits may be terminated by the FDIC if the FDIC finds that the insured depository institution has engaged in unsafe and unsound practices, is in an unsafe or unsound condition to continue operations or has violated any applicable law, regulation, rule, order or condition imposed by the FDIC.
For 2023, the FDIC insurance expense for SoFi Bank was $21.7 million.
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Prior approval from the OCC is required in order for SoFi Bank to acquire another bank or establish a new branch office.
−Removed: Well capitalized and well managed banks may acquire other banks in any state, subject to
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−Removed: certain deposit concentration limits and other conditions, pursuant to the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994, as amended by the Dodd-Frank Act.
+Added: Well capitalized and well managed banks may acquire other banks in any state, subject to certain deposit concentration limits and other conditions, pursuant to the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994, as amended by the Dodd-Frank Act.
Brokered Deposits.
−Removed: The FDIA and FDIC regulations generally limit the ability of an insured depository institution to accept, renew or roll over any brokered deposit unless the institution’s capital category is “well capitalized” or, with the FDIC’s approval, “adequately capitalized.” Depository institutions that have brokered deposits in excess of 10% of total assets are subject to increased FDIC deposit insurance premium assessments;
+Added: The FDIA and FDIC regulations generally limit the ability of an insured depository institution to accept, renew or roll over any brokered deposit unless the institution’s capital category is “well capitalized” or, with the FDIC’s
+Added: SoFi Technologies, Inc.
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+Added: approval, “adequately capitalized.” Certain depository institutions that have brokered deposits in excess of 10% of total assets are subject to increased FDIC deposit insurance premium assessments;
however, for institutions that are “well capitalized” and have a CAMELS composite rating of 1 or 2, reciprocal deposits are deducted from brokered deposits.
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Community Reinvestment Act.
−Removed: The Community Reinvestment Act (“CRA”) requires the OCC to evaluate SoFi Bank’s performance in helping to meet the credit needs of the entire communities it serves, including low and moderate-income neighborhoods, consistent with its safe and sound banking operation.
+Added: The CRA requires the OCC to evaluate SoFi Bank’s performance in helping to meet the credit needs of the entire communities it serves, including low and moderate-income neighborhoods, consistent with its safe and sound banking operation.
A bank’s performance under the CRA is taken into consideration when evaluating and approving applications for charters, bank mergers, acquisitions, and branch openings.
On January 1, 2023, SoFi Bank began operating under a five-year CRA strategic plan which includes measurable goals relating to:
−Removed: (i) Community Development (“CD”) Lending and CD Investments, (ii) CD Contributions, (iii) CD Services, (iv) Small Business Lending, and (v) Retail Services and Products.
+Added: (i) CD Lending and CD Investments, (ii) CD Contributions, (iii) CD Services, (iv) Small Business Lending, and (v) Retail Services and Products.
SoFi Bank’s 2023-2027 CRA performance will be examined based upon the CRA strategic plan’s five measurable goals as defined in the strategic plan and, as a result, the OCC’s standard performance evaluation criteria will not be utilized to evaluate SoFi Bank’s CRA performance throughout the duration of the strategic plan period.
The OCC rates a national bank’s compliance with the CRA as “Outstanding”, “Satisfactory”, “Needs to Improve” or “Substantial Noncompliance”.
+Added: On October 23, 2023, the Federal Reserve, OCC and FDIC approved changes to their CRA regulations, maintaining the existing CRA ratings (Outstanding, Satisfactory, Needs to Improve, and Substantial Noncompliance) but modifying the evaluation framework to replace the existing tests generally applicable to banks with at least $2 billion in assets (the lending, investment, and services tests) with four new tests and associated performance metrics.
+Added: The new CRA regulations will become effective on January 1, 2026.
Failure of SoFi Bank to receive at least a “Satisfactory” rating could inhibit SoFi Bank or the Company from undertaking certain activities, including acquisitions of other financial institutions.
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Enhanced Prudential Supervision.
−Removed: SoFi Bank did not have $10 billion or more of consolidated assets as of December 31, 2022, but it is likely that it will in the near future.
−Removed: In addition, the Company had in excess of $10 billion in total consolidated assets as of December 31, 2022.
−Removed: The Dodd-Frank Act and other federal banking laws subject companies with $10 billion or more of consolidated assets to additional regulatory requirements.
+Added: Both SoFi Bank and the Company, which controls SoFi Bank, had total consolidated assets in excess of $10 billion as of December 31, 2023 which subjects them to additional regulatory requirements under the Dodd-Frank Act and other federal banking laws.
+Added: Section 1025 of the Dodd-Frank Act and the CFPB’s interpretations thereof provide that the CFPB has authority to examine any insured depository institution and with total assets of more than $10 billion for four consecutive quarters and any affiliate thereof.
+Added: Beginning January 1, 2024, SoFi Bank and its affiliates became subject to CFPB supervision and regulation with respect to federal consumer protection laws, including laws relating to fair lending and the prohibition of unfair, deceptive or abusive acts or practices in connection with the offer, sale or provision of consumer financial products and services.
+Added: As part of its regulatory oversight, the CFPB has authority to take enforcement actions against firms that offer certain products and services to consumers using practices that are deemed to be unfair, deceptive or abusive.
Section 1075 of the Dodd-Frank Act, which is commonly known as the “Durbin Amendment”, amended the Electronic Fund Transfer Act to restrict the amount of interchange fees that may be charged and prohibit network exclusivity for debit card transactions.
−Removed: SoFi Bank will be required to comply with the restrictions on interchange fees by July 1, 2023, which may negatively impact future interchange fees.
−Removed: In addition, Section 619 of the Dodd-Frank Act, commonly known as the “Volcker Rule”, which generally prohibits banking entities from engaging in proprietary trading and from acquiring or retaining an ownership interest in or sponsoring certain types of investment funds, does not apply to an insured depository institution if it, and every company that controls it, has total consolidated assets of $10 billion or less and consolidated trading assets and liabilities that are 5% or less of consolidated assets.
−Removed: While SoFi Bank had total consolidated assets of less than $10 billion as of December 31, 2022, the Company, which controls SoFi Bank, had total consolidated assets in excess of $10 billion as of December 31, 2022.
−Removed: As a result, the Company and SoFi Bank are subject to the Volcker Rule.
−Removed: The Volcker Rule does not significantly impact the operations of the Company and SoFi Bank, as we do not have any significant engagement in the businesses prohibited by the Volcker Rule.
−Removed: Finally, Section 1025 of the Dodd-Frank Act and the CFPB’s interpretations thereof provide that the CFPB has authority to examine any insured depository institution with total assets of more than $10 billion for four consecutive quarters and any affiliate thereof.
+Added: The restrictions on interchange fees became applicable to SoFi Bank on July 1, 2023, which may negatively impact future interchange fees.
+Added: In addition, Section 619 of the Dodd-Frank Act, commonly known as the “Volcker Rule”, which generally prohibits banking entities from engaging in proprietary trading and from acquiring or retaining an ownership interest in or sponsoring certain types of investment funds, applies to insured depository institutions if it, and every company that controls it, has total consolidated assets of $10 billion or more and consolidated trading assets and liabilities that are 5% or more of consolidated assets.
+Added: The Volcker Rule, while applicable, does not significantly impact the operations of the Company and SoFi Bank, as we do not engage in a significant amount of activity that is subject to the Volcker Rule.
+Added: Finally, Section 165 of the Dodd-Frank Act, as amended by the Economic Growth, Regulatory Relief and Consumer Protection Act, and 12 C.F.R.
+Added: Part 30 require the Federal Reserve and the OCC, respectively, to implement enhanced prudential
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+Added: regulation applicable to bank holding companies with consolidated assets of $100 billion or more and national banks with total assets of $50 billion or more.
+Added: The enhanced prudential standards include risk-based and leverage capital requirements, liquidity standards, requirements for overall risk management, and stress-test requirements.
+Added: Once the Company’s or SoFi Bank’s assets are equal to or greater than the applicable asset thresholds, we will be subject to these enhanced prudential regulations.
Capital Adequacy and Safety and Soundness
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However, for purposes of processing regulatory applications and notices, the Federal Reserve’s Regulation Y provides that a bank holding company is considered “well capitalized” if:
−Removed: (i) on a consolidated basis, the bank holding company maintains a total risk-based capital ratio of 10.0% or greater, (ii) on a consolidated basis, the bank holding company maintains a Tier 1 risk-based capital ratio of 6.0% or greater, and (iii) the bank holding company is not subject to any written agreement, order, capital directive, or prompt corrective action directive issued by the Federal Reserve to meet and maintain a specific capital level for any capital measure.
+Added: (i) on a consolidated basis, the bank holding company maintains a total risk-based capital ratio of 10.0% or greater, (ii) on a consolidated basis, the bank holding company maintains a Tier 1 risk-based capital ratio of 6.0% or greater, and (iii) the bank holding company is not subject to any written agreement, order, capital
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+Added: directive, or prompt corrective action directive issued by the Federal Reserve to meet and maintain a specific capital level for any capital measure.
Safety and Soundness Standard.
Guidelines adopted by the federal bank regulatory agencies pursuant to the FDIA establish general standards relating to internal controls and information systems, internal audit systems, loan documentation, credit underwriting, interest rate exposure, asset growth, asset quality, earnings, and compensation and benefits.
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−Removed: these guidelines require, among other things, appropriate systems and practices to identify and manage the risk and exposures specified in the guidelines.
+Added: In general, these guidelines require, among other things, appropriate systems and practices to identify and manage the risk and exposures specified in the guidelines.
The guidelines prohibit excessive compensation as an unsafe and unsound practice and describe compensation as excessive when the amounts paid are unreasonable or disproportionate to the services performed by an executive officer, employee, director or principal shareholder.
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securities borrowing or lending transactions with an affiliate that creates a credit exposure to such affiliate;
−Removed: or a derivatives transaction with an affiliate that creates a credit exposure to such affiliate.
+Added: or a derivatives transaction with an affiliate that
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: creates a credit exposure to such affiliate.
Covered transactions are also subject to certain collateral security requirements.
Covered transactions as well as other types of transactions between a bank and a bank holding company must be conducted under terms and conditions, including credit standards, which are at least as favorable to the bank as prevailing market terms.
−Removed: Moreover, Section 106 of the Bank Holding Company Act Amendments of 1970 provides that, to further competition, a bank
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−Removed: holding company and its subsidiaries are prohibited from engaging in certain tying arrangements in connection with any extension of credit, lease or sale of property of any kind, or the furnishing of any service.
+Added: Moreover, Section 106 of the Bank Holding Company Act Amendments of 1970 provides that, to further competition, a bank holding company and its subsidiaries are prohibited from engaging in certain tying arrangements in connection with any extension of credit, lease or sale of property of any kind, or the furnishing of any service.
Consumer Financial Services Laws and Regulations
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Failure to comply with consumer protection laws and regulations can subject financial institutions to enforcement actions, fines and other penalties.
−Removed: The OCC examines SoFi Bank for compliance with CFPB rules and enforces CFPB rules with respect to SoFi Bank.
−Removed: As noted above, the CFPB has authority to examine any insured depository institution with total assets of more than $10 billion and any affiliate thereof.
+Added: Prior to January 1, 2024, the OCC examined SoFi Bank for compliance with CFPB rules and enforced CFPB rules with respect to SoFi Bank.
+Added: As noted above, beginning January 1, 2024, SoFi Bank and its affiliates became subject to supervision and regulation by the CFPB as an insured depository institution with total assets of more than $10 billion.
Truth in Lending Act.
−Removed: The Truth in Lending Act (“TILA”) and Regulation Z, which implements it, require lenders to provide consumers with uniform, understandable information concerning certain terms and conditions of their loan and credit transactions prior to the consummation of a credit transaction and, in the case of certain education, mortgage, and open-end loans, at the time of a loan solicitation, application, approval and origination of a credit transaction.
−Removed: TILA also regulates the advertising of credit and gives borrowers, among other things, certain rights regarding updated disclosures and periodic statements, security interests taken to secure the credit, the right to rescind certain loan transactions, a right to an investigation and resolution of billing errors, and the treatment of credit balances.
+Added: The TILA and Regulation Z, which implements it, require lenders to provide consumers with uniform, understandable information concerning certain terms and conditions of their loan and credit transactions prior to the consummation of a credit transaction and, in the case of certain education, mortgage, and open-end loans, at the time of a loan solicitation, application, approval and origination of a credit transaction.
+Added: TILA also regulates the advertising of credit, including limitations on co-branding private education lender’s products with educational institutions in the marketing of private education loans, and gives borrowers, among other things, certain rights regarding updated disclosures and periodic statements, security interests taken to secure the credit, the right to rescind certain loan transactions, a right to an investigation and resolution of billing errors, and the treatment of credit balances.
For certain types of credit transactions, lenders are not permitted to originate loans with certain high-risk features, such as negative amortization and balloon payments, and must provide certain consumer protections during the underwriting and origination process, such as providing a right to an appraisal of mortgaged property, and verifying the consumer’s ability to repay the loan prior to making a decision to approve an application for the loan.
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Real Estate Settlement Procedures Act.
−Removed: The federal Real Estate Settlement Procedures Act (“RESPA”) and Regulation X, which implements it, require certain disclosures to be made to the borrower at application, as to the lender’s initial disclosures (or good faith estimate) of loan origination costs, and at closing with respect to the real estate settlement statement;
+Added: The federal RESPA and Regulation X, which implements it, require certain disclosures to be made to the borrower at application, as to the lender’s initial disclosures (or good faith estimate) of loan origination costs, and at closing with respect to the real estate settlement statement;
apply to certain loan servicing practices including escrow accounts, member complaints, servicing transfers, lender-placed insurance, error resolution and loss mitigation.
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Equal Credit Opportunity Act.
−Removed: The federal Equal Credit Opportunity Act (“ECOA”) prohibits creditors from discriminating against credit applicants on the basis of race, color, sex, age, religion, national origin, marital status, the fact that all or part of the applicant’s income derives from any public assistance program or the fact that the applicant has in good faith exercised any right under the federal Consumer Credit Protection Act or any applicable state law.
+Added: The federal ECOA prohibits creditors from discriminating against credit applicants on the basis of race, color, sex, age, religion, national origin, marital status, the fact that all or part of the applicant’s income derives from any public assistance program or the fact that the applicant has in good faith exercised any right under the federal Consumer Credit Protection Act or any applicable state law.
Regulation B, which implements ECOA, restricts creditors from requesting certain types of information from loan applicants and from using advertising or making statements that would discourage on a prohibited basis a reasonable person from making or pursuing an application.
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Fair Housing Act.
−Removed: The federal Fair Housing Act (“FHA”) applies to credit related to housing and prohibits discrimination on the basis of race or color, national origin, religion, sex, familial status and handicap.
+Added: The federal FHA applies to credit related to housing and prohibits discrimination on the basis of race or color, national origin, religion, sex, familial status and handicap.
The FHA prohibits discrimination in advertising regarding the sale or rental of a dwelling, which includes mortgage credit discrimination.
The FHA may place restrictions on a creditor’s targeted marketing strategies, due to the risk that such strategies may increase a creditor’s fair lending risk.
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Home Mortgage Disclosure Act.
−Removed: The federal Home Mortgage Disclosure Act (“HMDA”) requires lenders to collect, report and disclose certain information about their mortgage lending activity to the CFPB.
+Added: The federal HMDA requires lenders to collect, report and disclose certain information about their mortgage lending activity to the CFPB.
Much of the data reported pursuant to HMDA is made public and can be used by regulators and third parties to ascertain information about our mortgage lending activity.
−Removed: Regulators and litigants may use the data to make inferences about our compliance with ECOA, FHA and similar anti-
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−Removed: discrimination laws.
+Added: Regulators and litigants may use the data to make inferences about our compliance with ECOA, FHA and similar anti-discrimination laws.
Effective in 2018, the CFPB issued a final rule which greatly expanded the amount of data that mortgage lenders are required to collect and report under HMDA.
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Fair Credit Reporting Act.
−Removed: The federal Fair Credit Reporting Act (“FCRA”), as amended by the Fair and Accurate Credit Transactions Act, promotes the accuracy, fairness and privacy of information in the files of consumer reporting agencies.
+Added: The federal FCRA, as amended by the Fair and Accurate Credit Transactions Act, promotes the accuracy, fairness and privacy of information in the files of consumer reporting agencies.
FCRA requires a permissible purpose to obtain a consumer credit report and requires persons that furnish loan payment information to credit bureaus to report such information accurately.
3 unchanged sentences
Fair Debt Collection Practices Act.
−Removed: The federal Fair Debt Collection Practices Act (“FDCPA”) provides guidelines and limitations on the conduct of third-party debt collectors in connection with the collection of consumer debts.
+Added: The federal FDCPA provides guidelines and limitations on the conduct of third-party debt collectors in connection with the collection of consumer debts.
The FDCPA limits certain communications with third parties, imposes notice and debt validation requirements, and prohibits threatening, harassing or abusive conduct in the course of debt collection.
−Removed: While the FDCPA applies to third-party debt collectors, debt collection and loan servicing laws of certain states impose similar requirements on creditors who collect their own debts or contract with third parties to collect their debts.
+Added: While the FDCPA applies to third-party debt collectors, and not original creditors, debt collection and loan servicing laws of certain states impose similar requirements on creditors who collect their own debts or contract with third parties to collect their debts.
In addition, the CFPB prohibits UDAAP in debt collection, including first-party debt collection.
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Servicemembers Civil Relief Act.
−Removed: The federal Servicemembers Civil Relief Act (“SCRA”) allows military members to suspend or postpone certain civil obligations so that the military member can devote his or her full attention to military duties.
+Added: The federal SCRA allows military members to suspend or postpone certain civil obligations so that the military member can devote his or her full attention to military duties.
The SCRA requires us to adjust the interest rate of borrowers who qualify for and request relief.
1 unchanged sentence
Military Lending Act.
−Removed: The Military Lending Act (“MLA”) restricts, among other things, the interest rate and other terms that can be offered to active military personnel and their dependents.
+Added: The MLA restricts, among other things, the interest rate and other terms that can be offered to active military personnel and their dependents.
The MLA caps the interest rate that may be offered to a covered borrower for most types of consumer credit to a 36% military annual percentage rate, or “MAPR”, which includes certain fees such as application fees, participation fees and fees for add-on products.
1 unchanged sentence
Electronic Fund Transfer Act and NACHA Rules.
−Removed: The federal Electronic Fund Transfer Act (“EFTA”), and Regulation E that implements it, provide guidelines and restrictions on the provision of electronic fund transfer services to consumers, and on making an electronic transfer of funds from consumers’ bank accounts.
−Removed: In addition, transfers performed by electronic transfers using the Automated Clearinghouse network (“ACH”) are subject to detailed timing and notification rules and guidelines administered by the National Automated Clearinghouse Association (“NACHA”).
+Added: The federal EFTA, and Regulation E that implements it, provide guidelines and restrictions on the provision of electronic fund transfer services to consumers, and on making an electronic transfer of funds from consumers’ bank accounts.
+Added: In addition, transfers performed by electronic transfers using the ACH network are subject to detailed timing and notification rules and guidelines administered by the NACHA.
Most transfers of funds in connection with the origination and repayment of loans are performed by electronic fund transfers, such as ACH transfers.
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Recently, the NACHA Board of Directors approved a change in the NACHA Operating Rules that requires ACH Originators to perform account validation as part of their commercially reasonable fraudulent transaction detection systems.
−Removed: Electronic Signatures in Global and National Commerce Act/Uniform Electronic Transactions Act.
−Removed: The federal Electronic Signatures in Global and National Commerce Act (“ESIGN”), and similar state laws, particularly the Uniform Electronic Transactions Act (“UETA”), authorize the creation of legally binding and enforceable agreements utilizing electronic records and signatures.
−Removed: ESIGN and UETA require businesses that want to use electronic records or signatures in consumer
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−Removed: transactions and to provide electronic disclosures and other electronic communications to consumers, to obtain the consumer’s consent to receive information electronically.
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+Added: Electronic Signatures in Global and National Commerce Act/Uniform Electronic Transactions Act.
+Added: The federal ESIGN, and similar state laws, particularly the UETA, authorize the creation of legally binding and enforceable agreements utilizing electronic records and signatures.
+Added: ESIGN and UETA require businesses that want to use electronic records or signatures in consumer transactions and to provide electronic disclosures and other electronic communications to consumers, to obtain the consumer’s consent to receive information electronically.
Bank Secrecy Act .
−Removed: We have implemented various anti-money laundering policies and procedures to comply with applicable federal anti-money laundering laws, regulations and requirements, such as designating a Bank Secrecy Act (“BSA”) officer, conducting an annual risk assessment, developing internal controls, independent testing, training, and suspicious activity monitoring and reporting.
−Removed: We apply the customer identification and verification program rules pursuant to the USA PATRIOT Act amendments to the BSA and its implementing regulations and screen certain customer information against the list of specially designated nationals and other lists of sanctioned countries, persons, and entities maintained by the Treasury Department’s Office of Foreign Assets Control (“OFAC”).
−Removed: Additionally, SoFi Digital Assets, LLC is registered with and regulated by the Financial Crimes Enforcement Network (“FinCEN”) as a money services business (“MSB”) with respect to its digital assets business activities.
+Added: We have implemented various anti-money laundering policies and procedures to comply with applicable federal anti-money laundering laws, regulations and requirements, such as designating a BSA officer, conducting an annual risk assessment, developing internal controls, independent testing, training, and suspicious activity monitoring and reporting.
+Added: We apply the customer identification and verification program rules pursuant to the USA PATRIOT Act amendments to the BSA and its implementing regulations and screen certain customer information against the list of specially designated nationals and other lists of sanctioned countries, persons, and entities maintained by the Treasury Department’s OFAC.
+Added: Additionally, SoFi Digital Assets, LLC is registered with and regulated by the FinCEN as a MSB with respect to its digital assets business activities, which were transferred in the first quarter of 2024.
As an MSB, we are subject to FinCEN regulations implementing the BSA, which requires MSBs to develop and implement risk-based anti-money laundering programs, report large cash transactions and suspicious activity, and maintain transaction records, among other requirements.
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Loan Servicing.
−Removed: With respect to our private education loan business, we are subject to the CFPB’s rule that enables it to supervise certain non-bank student loan servicers that service more than one million borrower accounts.
−Removed: The rule covers servicers of both federal and private education loans and is designed to ensure that bank and non-bank servicers follow the same rules in the student loan servicing market.
−Removed: We are impacted by the rule because we have engaged the Missouri Higher Education Loan Authority (“MOHELA”) to service our private education loans.
−Removed: MOHELA currently services more than one million student loan borrower accounts.
+Added: We are subject to CFPB supervision and regulation of our loan servicing activities conducted by SoFi Bank and SoFi Lending Corp.
+Added: even in scenarios where we have engaged third-party servicers such as MOHELA to service our private education loans and Cenlar FSB to service our home loans.
In addition, for so long as SoFi Lending Corp.
−Removed: acts as servicer of any of our private education loans, we are subject to certain state licensing requirements applicable to loan servicers even though we have engaged MOHELA to service our private education loans, as we retain master servicing rights.
+Added: acts as servicer of any of our private education loans, we are subject to certain state licensing requirements applicable to student loan servicers even though we have engaged MOHELA to service our private education loans, as we retain master servicing rights.
With respect to our broader consumer loan business, we are subject to federal and state laws regulating loan servicers.
−Removed: We are impacted by these rules even though we service loans we originate, and engage third parties like MOHELA to service certain types of loans, because some state laws, such as the California Rosenthal Act, apply to creditors and first party servicers.
+Added: We are impacted by these rules even though we service loans we originate, and engage third parties like MOHELA and Cenlar FSB to service certain types of loans, because some state laws, such as the California Rosenthal Act, apply to creditors and first party servicers.
Some state laws also apply to parties that indirectly service loans through the use of third-party servicer contracts.
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We are currently licensed as a loan servicer in several states and may be required to seek additional licenses.
−Removed: If we seek additional licenses, a state may impose fines, restrict our activity in that state, or seek other relief for activity conducted prior to the issuance of a license.
−Removed: For example, in 2019, we entered into a consent order with the Commonwealth of Pennsylvania Department of Banking and Securities, requiring us to pay a civil fine for conducting mortgage servicing activity as a master servicer before we obtained a mortgage servicing license in Pennsylvania.
−Removed: Other State Lending and Money Transmission Laws.
+Added: If we seek additional licenses, a state has in the past and may in the future impose fines, restrict our activity in that state, or seek other relief for activity conducted prior to the issuance of a license.
+Added: Other State Lending Laws.
SoFi Lending Corp.
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Many states have adopted lending regulations that prohibit various forms of high-risk or sub-prime lending and place obligations on lenders to substantiate that a member will derive a tangible benefit from the proposed credit transaction and/or have the ability to repay the loan.
−Removed: These laws have required most lenders to devote considerable resources to building and maintaining automated systems to perform loan-by-loan analysis of
+Added: These laws have required most lenders to devote considerable resources to building and maintaining automated systems to perform loan-by-loan analysis of points, fees and other factors set forth in the laws, which often vary depending on the location of the mortgaged property.
+Added: Many of these state lending laws are vague and subject to differing interpretation, which exposes us to some risks.
+Added: The number and complexity of these laws, and vagaries in their interpretations, present compliance and litigation risks from inadvertent error and omissions which we may not
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−Removed: points, fees and other factors set forth in the laws, which often vary depending on the location of the mortgaged property.
−Removed: Many of these state lending and money transmitter laws are vague and subject to differing interpretation, which exposes us to some risks.
−Removed: The number and complexity of these laws, and vagaries in their interpretations, present compliance and litigation risks from inadvertent error and omissions which we may not be able to eliminate from our operations or activities.
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+Added: be able to eliminate from our operations or activities.
The laws, regulations and rules described above are subject to legislative, administrative and judicial interpretation, and some of these laws and regulations have been infrequently interpreted or only recently enacted.
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Marketing Regulations.
−Removed: Our marketing and other business practices are subject to federal and state regulation and our expansion into new product offerings, including digital assets and exchange-traded funds under the SoFi Invest product, subject us to additional regulatory scrutiny.
−Removed: For example, we and the FTC entered the FTC Consent Order regarding savings calculations in our student loan refinancing advertisements.
−Removed: In addition, we are subject to the Federal Telephone Consumer Protection Act (“TCPA”), which regulates, among other things:
+Added: Our marketing and other business practices are subject to federal and state regulation and our expansion into new product offerings, including ETFs and, beginning in January 2024, alternative investment funds, mutual funds and money market funds, under the SoFi Invest product, subject us to additional regulatory scrutiny.
+Added: For example, we and the FTC entered into the FTC Consent Order regarding savings calculations in our student loan refinancing advertisements.
+Added: In addition, we are subject to the TCPA, which regulates, among other things:
(i) the use of automated telephone dialing systems to make certain calls or text messages to cellphones without prior consent, and (ii) certain calls and text messages to numbers properly registered on the federal do not call list without permission or an established business relationship, and the Federal CAN-SPAM Act and the Telemarketing Sales Rule, and analogous state laws, to the extent that we market credit or other products and services by use of email or telephone marketing.
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SoFi Securities is an affiliated registered broker-dealer and FINRA member, and SoFi Digital Assets, LLC is a FinCEN registered MSB that also holds money transmitter or money service licenses in a majority of states and the District of Columbia.
+Added: In the fourth quarter of 2023, we transferred the crypto services provided by SoFi Digital Assets, LLC, and began closing existing digital assets accounts.
+Added: This process was completed in the first quarter of 2024.
We offer cash management accounts, which are brokerage products, through SoFi Securities.
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These additional requirements relate to matters including maintaining effective and comprehensive compliance programs, record-keeping and reporting and disclosure requirements.
−Removed: The Advisers Act and the Exchange Act generally grant the SEC broad administrative powers, including the power to limit or restrict an investment adviser or our broker-dealer from conducting advisory or brokerage activities, respectively, in the event they fail to
+Added: The Advisers Act and the Exchange Act generally grant the SEC broad administrative powers, including the power to limit or restrict an investment adviser or our broker-dealer from conducting advisory or brokerage activities, respectively, in the event they fail to comply with federal securities laws.
+Added: Additional sanctions that may be imposed for failure to comply with applicable
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−Removed: comply with federal securities laws.
−Removed: Additional sanctions that may be imposed for failure to comply with applicable requirements include the prohibition of individuals from associating with an investment adviser or broker-dealer, the revocation of registrations and other censures and fines.
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+Added: requirements include the prohibition of individuals from associating with an investment adviser or broker-dealer, the revocation of registrations and other censures and fines.
Even if an investigation or proceeding did not result in a sanction or the sanction imposed against us or our personnel by a regulator was small in monetary amount, the adverse publicity relating to the investigation, proceeding or imposition of these sanctions could harm our reputation and cause us to lose existing members or fail to gain new members.
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FINRA and the SEC also have the authority to conduct periodic examinations of SoFi Securities, and may also conduct administrative proceedings, and have the authority to levy fines and other penalties on SoFi Securities.
−Removed: SoFi Securities is registered with the Municipal Securities Rulemaking Board (“MSRB”) and subject to the MSRB’s regulatory regime, including applicable MSRB rules.
+Added: SoFi Securities is registered with the MSRB and subject to the MSRB’s regulatory regime, including applicable MSRB rules.
SoFi Securities is a Participant of DTC and is, therefore, subject to DTC’s regulatory regime, including applicable DTC rules and bylaws.
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State Licensing Requirements
−Removed: One or more of our subsidiaries may need, and have obtained, one or more state licenses to broker, acquire, service and/or enforce loans, and to engage in money transmitter activities.
+Added: One or more of our subsidiaries may need, and have obtained, one or more state licenses to broker, acquire, service and/or enforce loans.
Where we have obtained licenses, state licensing statutes may impose a variety of requirements and restrictions on us, including:
2 unchanged sentences
• restrictions on collections;
−Removed: • usury rate caps;
+Added: • usury rate caps to the extent the non-bank subsidiary originates loans;
• restrictions on permissible terms in consumer agreements;
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+Added: TABLE OF CONTENT S
• anti-money laundering and compliance program requirements;
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Some laws may also impose physical and electronic security requirements regarding the safeguarding of personal information.
−Removed: On January 1, 2020, the California Consumer Privacy Act (“CCPA”) took effect, directly impacting our California business operations and indirectly impacting our operations nationwide.
+Added: On January 1, 2020, the CCPA took effect, directly impacting our California business operations and indirectly impacting our operations nationwide.
The CCPA provides for civil penalties for violations, as well as a private right of action for certain data breaches that result in the loss of personal information.
While personal information that we process that is subject to the GLBA is exempt from the CCPA, the CCPA regulates other personal information that we collect and process in connection with the business.
−Removed: Effective January 1, 2023, the California Privacy Rights Act (“CPRA”), which amends the CCPA, imposed additional obligations on companies covered by the legislation, including by expanding consumers’ rights with respect to certain sensitive personal information.
−Removed: The CPRA also creates a new state agency that will be vested with authority to implement and enforce the CCPA and the CPRA.
−Removed: Some observers have noted that the CCPA and CPRA could mark the beginning of a trend toward more stringent privacy legislation in the U.S., which could increase our potential liability and adversely affect our business.
−Removed: For example, on March 2, 2021, Virginia enacted the Consumer Data Protection Act (the “CDPA”) and, on July 8, 2021, Colorado’s governor signed the Colorado Privacy Act (“CPA”) into law.
−Removed: The CDPA and the CPA were both effective January 1, 2023.
−Removed: While the CDPA and CPA incorporate many similar concepts of the CCPA and CPRA, there are also several key differences in the scope, application, and enforcement of the laws that will change the operational practices of regulated businesses.
−Removed: The new laws will, among other things, impact how regulated businesses collect and process personal sensitive data, conduct data protection assessments, transfer personal data to affiliates, and respond to consumer rights requests.
−Removed: Certain other state laws impose similar privacy obligations and, in many others, lawmakers have proposed laws that would be similar to the CCPA or CPRA.
−Removed: We anticipate that more states may enact comprehensive privacy legislation, which
+Added: Effective January 1, 2023, the CPRA, which amended the CCPA, imposed additional obligations on companies covered by the legislation, including by expanding consumers’ rights with respect to certain sensitive personal information.
+Added: The CPRA also created a new state agency that is vested with authority to implement and enforce the CCPA and the CPRA.
+Added: In addition to California, several other states have passed comprehensive privacy laws similar to the CCPA.
+Added: Certain of these laws are in force and others will enter in effect in the coming years.
+Added: Like the CCPA, these laws create obligations related to the processing of personal information, as well as special obligations for the processing of “sensitive” data.
+Added: Some of the provisions of these laws may apply to our business activities.
+Added: There are also states that are strongly considering comprehensive privacy laws and it is anticipated that other states will be considering these laws in the future.
+Added: Further, Congress has also been debating passing a federal privacy law.
+Added: In addition, other states have proposed and/or passed legislation that regulates the privacy and/or security of certain specific types of information.
+Added: For example, a small number of states have passed laws that regulate biometric data specifically and Washington has passed a law that governs health data, with “health data” defined broadly.
+Added: These various privacy and security laws may impact our business activities, including our identification of research subjects, relationships with business partners and ultimately the marketing and distribution of our products.
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−Removed: provides consumers with new privacy rights and increases the privacy and security obligations of entities handling certain personal information of such consumers.
−Removed: These proposals, if enacted, may add complexity, variation in requirements, restrictions and potential legal risk, require additional investment of resources in compliance programs, impact strategies and the availability of previously useful data and could result in increased compliance costs and/or changes in business practices and policies.
−Removed: The existence of comprehensive privacy laws in different states in the country would make our compliance obligations more complex and costly and may increase the likelihood that we may be subject to enforcement actions or otherwise incur liability for noncompliance.
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+Added: The existence of comprehensive privacy laws in different U.S.
+Added: states would make our compliance obligations more complex and costly and may increase the likelihood that we may be subject to enforcement actions, civil litigation or otherwise incur liability for noncompliance.
Our broker-dealer and investment advisers are subject to SEC Regulation S-P, which requires that these businesses maintain policies and procedures addressing the protection of customer information and records.
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In addition, Galileo has been granted several patents.
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We believe building a durable culture will be a key determinant in our ability to help our members get their money right and ultimately to achieve our mission.
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Our number one Company priority is building a durable culture of diversity, where people love where they work in alignment with our core values.
−Removed: Our resulting initiatives are designed to support, develop and inspire our employees, which in turn we believe will ultimately unlock the potential of the organization, drive excellence across the business and solidify SoFi as a top career destination where people love to work.
+Added: Our resulting initiatives are designed to support, develop and inspire our employees, which in
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: turn we believe will ultimately unlock the potential of the organization, drive excellence across the business and solidify SoFi as a top career destination where people love to work.
We have established the following guiding principles to help us achieve our goals:
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Diversity, Equity and Inclusion
−Removed: Part of what makes SoFi a dynamic place to work is our commitment to living our core values, one of which is to “embrace diversity.” A diverse workforce enables us to collaborate, create and, ultimately, accomplish our mission of helping people achieve financial independence.
−Removed: Our Diversity, Equity and Inclusion (“DE&I”) objective is to create a company culture where every employee feels like they genuinely belong, are respected and valued, and can do their best work.
−Removed: In addition to this
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−Removed: being ingrained within our culture, we also see it as a competitive advantage.
−Removed: Our DE&I site features our ambitious goals to improve representation and the programs we have in place to meet and exceed these goals to both hold ourselves accountable and make this information easily accessible to the public.
−Removed: Based on voluntary employee self-identification data by our U.S.-based workforce, as of January 1, 2023:
−Removed: • 43% of our workforce was comprised of employees who identify as female;
−Removed: • 57% of our workforce was comprised of individuals who identify as part of an underrepresented group (“URG”).
−Removed: We are committed to increasing our total population of URGs to 60% by the end of 2023;
+Added: Part of what makes SoFi a dynamic place to work is our commitment to living our 11 core values, one of which is to “embrace diversity.” A diverse workforce unlocks collaboration, accelerates creativity, and ultimately enables us to accomplish our mission of helping millions of people achieve financial independence.
+Added: Our DE&I objective is to create a company culture where every employee feels like they genuinely belong, are respected and valued, and can do their best work.
+Added: This approach will unlock the potential of the organization and is a competitive advantage for SoFi.
+Added: One of the ways we ensure our global, diverse employees feel a sense of connection to our strategy and mission is through our quarterly Objectives and Key Results (“OKR”) process.
+Added: Each year, company priorities are developed in partnership with our executive staff team and the SoFi Leadership Group.
+Added: These priorities are shared with the company at the beginning of each year, as well as quarterly.
+Added: Teams and individuals are then able to map their OKRs to the company objectives, which align all employees on the company vision and strategy.
+Added: For the last three years, our #1 company priority has been culture and DE&I.
+Added: As part of this commitment to improving representation at all levels of the company, we set ambitious three-year goals in 2020:
+Added: to increase our total URG population to 60%, and to increase URG representation in management to 50%.
+Added: Based on voluntary employee self-identification data by our U.S.-based workforce, as of December 31, 2023:
+Added: • 57% of our workforce was comprised of individuals who identify as part of an URG;
individuals who identify with a URG represented 51% of our full-time management positions (defined as people-manager and above);
−Removed: We are committed to increasing our URG representation in management positions to 50% by the end of 2023;
• Individuals who identify with a URG represented 63% of our executive workforce.
−Removed: To help achieve these goals, we continue to focus on attraction, assessment, engagement and development at all levels.
−Removed: This means that we will work to achieve fair and transparent processes in talent assessment and hiring, performance management, career progression and retention across all stages of the employee lifecycle.
+Added: Additionally, 44.1% of our U.S.-based workforce was comprised of employees who identify as female, 3.5% as veterans, 6.2% as LGBTQIA+, and 5.7% as people with disabilities as of December 31, 2023.
+Added: Creating lasting and meaningful change is not a short-term project.
+Added: Improving DE&I requires a multi-faceted approach to ensure that all employees are having an equitable experience.
+Added: This journey requires transparency and accountability at all levels of the organization.
+Added: To help meet and achieve our long-term goals, we have focused on fair and transparent processes in talent assessment and hiring, to performance management, career progression and retention, we have developed programs that support our all employees across all stages of the employee lifecycle.
As a foundation to this work, we have developed competency-based assessments for roles in marketing, operations and engineering to assist in reducing unconscious biases in both our hiring and promotion practices.
−Removed: We have also formalized a university hiring program and returning military program to ensure we are bringing in talent at all levels of the Company.
−Removed: We are also working to create a stronger sense of inclusion and belonging for our employees in general with a lens on representation.
−Removed: We offer a targeted mentorship program for our URG population called SoFi GROW.
−Removed: We also work with our international offices to work to ensure our employees have access to our Employee Resource Groups (called SoFi Circles, some of which are further described below), and that we are taking into consideration local and regional differences as it pertains to DE&I.
−Removed: The four key focus areas and associated programs outlined below enable us to create and sustain a culture where everyone feels valued, heard and has equal opportunity to thrive.
−Removed: Goals Programs
−Removed: Enablement, Awareness and Education:
−Removed: Create awareness around how social identities contribute to our professional environment and our success
−Removed: • Voluntary, confidential Employee Self Identification includes LGBTQ+, Persons with a disability, and Veterans
−Removed: • Mandatory company-wide diversity trainings :
−Removed: Unconscious Bias, Building an Inclusive Culture, Bystander Intervention and Escalation, and Hiring the SoFi Way
−Removed: • Learning and development opportunities:
−Removed: Manager Learning Series with a focus on our behavioral competencies that encompass knowledge, skills, attitudes and actions that distinguish excellent performers;
−Removed: LevelUp Series for all employees with a focus on career development, showing employees how their roles tie into the Company and its mission.
−Removed: Access, Development and Network:
−Removed: Develop a connected workforce with high job satisfaction and engagement, and provide our allies with leadership development opportunities
−Removed: • SoFi Circles (Employee Resource Groups):
−Removed: Internal groups that identify through a common culture or experience that builds community and empowerment for our employees
−Removed: • SoFi GROW (URM Internal Mentorship Program):
−Removed: Seeks to inspire and elevate our most underrepresented communities at SoFi by fostering professional development and accelerating the path for allies to take action
−Removed: • Explorer Program:
−Removed: Six-month development program designed to help our hourly operations employees learn new skills and promote internal mobility
−Removed: • Manager Essential Training:
−Removed: Designed to provide new managers at SoFi with the tools and resources they need to create a supportive, inclusive work environment where their team can do their best work
−Removed: • The Embracing Diversity Podcast:
−Removed: Monthly podcast to inform our broader SoFi community on important diversifying topics that aim to embrace inclusivity, belonging and awareness
+Added: We have also formalized university hiring and returning military programs to ensure we are bringing in talent at all levels of the company.
+Added: We have also worked to create a stronger sense of inclusion and belonging for all employees, with a lens on representation.
+Added: SoFi proudly sponsors nine Employee Resource Groups, known internally as SoFi Circles.
+Added: These employee-led communities help build high-trust relationships, create safe and brave spaces to raise awareness on important, pertinent topics, and help our organization thrive by fostering a sense of community.
+Added: Examples of their programs include:
+Added: listen & learn workshops, cultural events, keynote speaker series, give back donation initiatives, and volunteering opportunities for all.
+Added: We also work with our international offices to ensure employees have access to Circles, and that we are taking into consideration local and regional differences as it pertains to DE&I.
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−Removed: Goals Programs
−Removed: Fairness and Clarity in Processes:
−Removed: Actively attempt to mitigate unconscious and conscious bias in the hiring process and in annual performance calibrations by working to ensure the processes are objective and inclusive
−Removed: • Competency-based interviewing:
−Removed: Anchor our interview process to identify success competencies associated with each role versus informal interviews
−Removed: • Employee trainings:
−Removed: Effective Leadership in a Remote World (for people managers), Unconscious Bias (required for all hiring teams), Managing within the Law (required for people managers) and Bystander Intervention and Escalation (required for all employees)
−Removed: • Partnerships with national military organizations and universities to increase the diversity of our applicant pool
−Removed: Accelerated Increase in Representation:
−Removed: We work to foster attraction, engagement and retention of underrepresented employees by increasing external brand awareness and supporting SoFi employee career development
−Removed: • Increase accessibility and visibility of jobs by partnering with organizations like Diversity Jobs;
−Removed: partner with organizations like Latinas in Tech to attract and engage top talent
−Removed: • Build relationships with diverse university students and military professionals through partnerships and direct recruitment
−Removed: • Cultivate career development for employees through SoFi GROW mentorship and Explorer programs, as well as Meet our SoFi-ety initiative, where we can “meet” our employees who are part of these programs, and see how they are learning, growing and helping to transform the Fintech industry
−Removed: We believe that a combination of these approaches will help increase the representation, engagement and retention of women, Black, Latinx, and all employees who identify as being from a URG across all levels, roles and business groups.
−Removed: In order to stay accountable to our DE&I goals, we have expanded our accountability metrics to include retention, promotion and engagement alongside hiring, and we review these practices with each business leader quarterly to monitor progress.
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+Added: The SoFi Circles and their defined missions:
+Added: Each SoFi Circle is open to all of our employees, regardless of location, tenure, or subsidiary.
+Added: Being a SoFi Circle member gives employees access to unique programming and opportunities to connect with other SoFi Circle members—either as identifying members or as an ally.
+Added: In order to stay accountable to our DE&I goals, we review hiring, engagement, promotion and retention metrics with each executive business leader bi-annually.
We actively track our self-reported URG/URM hiring rates against the total addressable market, the rate of our promotions of this population against their dominant peer group’s rate, as well as the rate of attrition, to monitor and try to help ensure we are not disproportionately losing URG/URM at a faster rate than our peer group.
−Removed: In 2023, we are committed to building on this foundation by focusing on raising the voices of our URG/URM communities through an editorial program, which aims to:
−Removed: (i) get to the truth around the diverse experiences of the URG/URM communities at SoFi to make principles-based decisions to help provide further support and awareness across all levels of the organization, (ii) bridge quantitative and qualitative DE&I data gaps by providing an opportunity to hear directly from sources in different avenues on their experiences, and (iii) put words into action regarding DE&I at SoFi and help further curate an environment where transparency, authenticity and inclusivity are the focal points of the strategies we implement.
−Removed: We also plan to launch a formalized internal mobility program to work to ensure career coaching, advocacy and development.
−Removed: Training and Manager Excellence
−Removed: We believe strongly in investing in our employees and this is a focus throughout the employee lifecycle.
+Added: We action plan to address opportunities with each business unit group.
+Added: While we are proud of the progress we have made, our DE&I journey has only just begun.
+Added: In order to unlock the potential of our organization, to scale and grow as a company, we have expanded our DE&I approach to focus on a holistic strategy that will impact the entire SoFi ecosystem - from our members and clients, to our stakeholders, and current and prospective employees.
+Added: We call this new approach the 4 P’s:
+Added: People, Practices, Partnerships, and Policy:
+Added: • People focuses on FINDing, GROWing, and KEEPing our talent in order for them to invest in themselves, their futures and in the financial world.
+Added: • Practices focuses on ensuring we have the right systems, structures, and processes in place that drive accountability and equitable outcomes for everyone including for leaders and managers.
+Added: • Partnerships focus is on finding and establishing external strategic partnerships that create a diverse talent pipeline, provide professional development and networking opportunities for our staff, and amplify the SoFi brand (specifically within underserved communities).
+Added: • Policy focuses on building a world-class supplier diversity program so that small businesses have an opportunity to successfully participate and compete to supply goods and services for SoFi.
+Added: In 2024, we continue to focus on our four priorities to ensure we achieve our long term efforts.
+Added: Learning and Manager Excellence
+Added: We believe strongly in investing in our employees throughout the employee lifecycle.
Great care is taken to onboard new hires and set them up for success, both in terms of a broad understanding of SoFi’s mission, values, strategic points of differentiation and products, as well as role-specific learning.
−Removed: To this end, throughout the year we offer ongoing learnings, including:
−Removed: weekly company-level All Hands meetings, monthly programming on a diverse range of topics spanning general business updates to developmental topics, such as financial and personal wellness, and other opportunities for learning from internal and external speakers.
+Added: To this end, throughout the year we offer ongoing learnings,
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+Added: TABLE OF CONTENT S
+Added: regular company-level All Hands meetings, periodic programming on a diverse range of topics spanning general business updates to developmental topics, such as financial and personal wellness, and other opportunities for learning from internal and external speakers.
To enable continuous learning, we have deployed an online training platform, which offers thousands of courses and training sessions, ranging from skill development to manager resources.
The training sessions consist of live training, speakers and targeted learning content.
−Removed: We also offer ongoing learning opportunities for our people managers to ensure they are well equipped to support their employees.
−Removed: In addition to training on our compensation philosophy and tools, manager effectiveness and other basic ongoing processes administered by the People team, we also employ a seven-week manager onboarding program.
+Added: We also offer ongoing learning opportunities for our people managers to ensure they are well equipped to support and lead diverse and distributed teams.
+Added: In addition to training on our compensation philosophy and tools, manager effectiveness and other basic ongoing processes administered by the People team, we also employ an eight-week manager onboarding program.
This program covers a variety of topics, including DE&I, how to give effective feedback, a recruiting overview and best practices and various other components to set new leaders at SoFi up for success.
−Removed: Within our online training platform, we developed a manager excellence series, ranging over six identified competencies.
+Added: We also create opportunities for employees and managers to provide feedback on their learning experiences via surveys and focus group sessions.
+Added: In 2023, we also launched Manager Central, a centralized hub of resources, learning and support for managers.
+Added: We also offer a suite of bespoke, just-in-time self-access learning content that is tailored to meet the needs of a growing organization, and that is tied to key activities on the calendar.
+Added: This approach is being rolled out for the internal Performance and Rewards program, for which we have created a manager toolkit of resources and a learning curriculum on Giving and Receiving Feedback, both for managers and employees at SoFi.
+Added: In 2024, we will continue to focus on manager development by offering an array of solutions for them to be upskilled, build inclusion and create thriving teams.
Our compensation programs are designed to attract, retain and motivate talented, deeply qualified and committed individuals who believe in our mission, while rewarding employees for long-term value creation.
−Removed: We have a pay-for-
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−Removed: performance culture in which employee compensation is aligned to Company performance, as well as individual contributions and impact.
−Removed: Our equity program aligns employee compensation to the long-term interests of our shareholders, while encouraging them to think and act like owners.
+Added: We have a pay-for-performance culture in which employee compensation is aligned to Company performance, as well as individual contributions and impact.
+Added: Our long-term incentive program aligns employee compensation to the long-term interests of our shareholders, while encouraging them to think and act like owners.
As we continue to evolve our programs and practices, we strive for a fair, competitive, transparent and equitable approach in recognizing and rewarding our employees.
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We have a comprehensive benefits program to support the physical, mental and financial well-being of our employees.
−Removed: We have one core medical plan in which SoFi pays 100% of the monthly premium and additional medical plans with premiums that are significantly subsidized.
−Removed: In addition to core medical, we offer fertility and maternity benefits to help employees who are looking to grow their family, including a reimbursement solution for eligible family building expenses, a paid parental leave benefit, as well as a partially subsidized back-up family care benefit.
+Added: based workforce we have one core medical plan in which SoFi pays 100% of the monthly premium and additional medical plans with premiums that are significantly subsidized.
+Added: In addition to core medical, we offer fertility and parental benefits to help employees who are looking to grow their family, including a reimbursement solution for eligible family building expenses, a paid parental leave benefit, as well as a partially subsidized back-up family care benefit.
To support the mental health of our employees, we offer a benefit that allows our employees to meet with coaches and clinical care providers at no cost to them.
−Removed: Our tuition reimbursement and student loan repayment programs provide financial support to our employees that allows them to advance their education and pay off existing student loan debt.
−Removed: Our benefits package also includes, among other things, basic life insurance and supplemental life insurance, short-term and long-term disability insurance, a Section 401(k) retirement savings plan, and competitive paid time off.
+Added: Our tuition reimbursement and student loan repayment programs in the U.S.
+Added: provide financial support to our employees that allows them to advance their education and pay off existing student loan debt.
+Added: Our benefits packages also include, among other things, basic life insurance and supplemental life insurance, short-term and long-term disability insurance, a Section 401(k) retirement savings plan, and competitive paid time off.
Additionally, our program SoFi Gives is a benefit that provides eligible employees with paid time off to engage in volunteer opportunities within their communities.
−Removed: We now offer our employees the choice of working full time in the office, a hybrid approach, or full-time remote.
−Removed: Coming into the office remains 100% voluntary, unless a person’s role requires them to be on site to do their job.
−Removed: Additionally, we introduced additional programs focused on childcare as well as support specific to balancing the demands of work and personal family needs.
−Removed: An additional benefit was the introduction of “SoFridays,” where exempt employees are encouraged to end their work week at 2:00 pm local time each Friday.
As of December 31, 2023, we employed approximately 4,400 employees, of which approximately 73% were located in the United States and 27% were located internationally.
−Removed: None of our employees are currently represented by a labor union or have terms of employment that are subject to a collective bargaining agreement.
+Added: None of our U.S.
+Added: based employees are currently represented by a labor union or have terms of employment that are subject to a collective bargaining agreement.
We consider our relationship with our employees to be very strong and have not historically experienced any work stoppages.
+Added: Environmental, Social, and Corporate Governance
+Added: Sustainable business practices are embedded into our day-to-day operations, as we continue to make critical investments in our team and infrastructure to be further able to scale and support new avenues of growth.
+Added: We believe this not only aligns with our number one company priority of making our culture better every second and ensuring DE&I is at the center of everything we do, but also improves our profitability and supports long-term value creation for our shareholders.
+Added: SoFi Technologies, Inc.
+Added: TABLE OF CONTENT S
+Added: In December 2023, we published our first comprehensive ESG report which shares how our company priorities, core values, mission and commitments to the communities we serve shape how we do business, support our employees, and create a meaningful and lasting impact for our members and customers.
+Added: This report covers a broad set of ESG-related efforts which have been key to informing our approach, including our people programs, product development processes, community investments and social impact, environmental footprint, corporate governance strategies, risk management operations, public policy initiatives and more.
+Added: In addition, we have an ESG Committee comprised of key management stakeholders who are tasked with tracking our progress within our ESG initiatives using real world, data-based metrics, as well as devising and executing strategies to create an even greater impact.
+Added: This and any other ESG-related reports and information included on our investor relations website are not incorporated by reference into, and do not form any part of, this Annual Report on Form 10-K.
Additional Information
5 unchanged sentences
SoFi Technologies, Inc.
−Removed: T ABLE OF CONTENTS
+Added: TABLE OF CONTENT S
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.