The Federal Reserve issued a consent prohibition order against a former Primelending loan officer for infractions, including conflict of interest and submission of falsified loan documents.

As a loan officer for the Dallas-based lender, Aquana Raffington is alleged to have originated and earned commissions on at least $1.7 million worth of fraudulent mortgages during her six months of employment in mid 2022. 

"Raffington's conduct constituted violations of law or regulation, unsafe or unsound banking practices, and breaches of fiduciary duty, and involved her personal dishonesty and her willful and continuing disregard for the safety and soundness of Primelending," the consent order said. 

Raffington's actions led Primelending to originate mortgages to borrowers who worked at businesses owned by her and a family member, in violation of the company's conflict of interest policy. Raffington also knowingly submitted falsified income and asset statements and other accompanying documents, according to the Fed's filing.  

In agreeing to the order, Raffington is barred from employment at any depository banking institution or its subsidiaries and similar foreign entities, or involvement in any possible future business affairs, including voting as a shareholder. Primelending is the mortgage subsidiary of Plainscapital Bank and its parent, Hilltop Holdings. 

Resolution of the case involves no admission or denial of the allegations by Raffington and is considered permanent unless later revoked. Since her termination from Primelending in late 2022, she has worked as a self-employed business consultant, according to her Linkedin profile.

The Fed's enforcement activities in 2025

Consent prohibitions issued by the central bank can be imposed upon either individuals or companies. While the Federal Reserve continued to enforce violations allegedly committed by banking employees throughout 2025, typically for misuse or theft of company or customer funds, the year was largely characterized by the release of institutions from orders they previously agreed to enter. 

The Fed rescinded over 20 enforcement orders against financial institutions, including high-profile cases involving Wells Fargo, but terminated only one of a former banking employee during the first several months of the second Trump administration. Other federal regulators made similar moves, with many directly impacting mortgage lenders. 

Of the three new consent orders banks entered in 2025, all involved flood insurance violations. The Fed executed more than a dozen actions against bank employees over the same time period. 

Raffington's consent prohibition marks the second enforcement action against an individual employee so far in 2026 following an agreement signed by the regulator and a Regions Bank branch manager in early January.