Having worked at CK, specifically on personal loans, I'm going to with Hanlon's razor here. (Never attribute to malice that which is adequately explained by stupidity.) Not saying the fine isn't warranted, it is.

CK was a place where things were so complex (perhaps needlessly) you couldn't find anyone to explain what was going on. On this topic, you could ask people on the data team how their models worked (to determine what card or loan offers show to what users) and they seemed to have no idea, they just wanted to put the models in an AB test and see if conversion numbers went up or down.

Aside from this, there was plenty of politicking and ambitious people. Not surprised no one was really paying attention to whether or not they were running afoul of any laws. Also, I'm going to guess they made more than $3M on these mistakes that likely impacted their users' credit scores negatively.