The parallels were more than coincidence. The company was being run by former Santander executives who had left that bank amid the investigation. By 2020, most of Exeter’s corporate leadership — including its CEO and its operations chief — was composed of people who had overseen Santander during the period that the state attorneys general said it was “misleading, failing to disclose material information, or otherwise confusing consumers.”

Those elected officials, however, have taken a decidedly different approach with Exeter. In fact, in 12 states that participated in the Santander agreement, officials have taken little or no action in dozens of cases alleging nearly identical behavior, according to a ProPublica investigation.