On July 3, the FDIC released its 2025 edition of its Consumer Compliance Supervisory Highlights report. The report described the FDIC’s aggregated findings from approximately 800 consumer compliance examinations conducted in 2024 of state non-member banks and thrifts. In total, 97 percent of examined institutions received a satisfactory or better rating for consumer compliance and CRA performance, but the FDIC did cite a total of 1,275 Level 3 and Level 2 (the highest and second-highest level of severity, respectively) violations of consumer protection statutes and regulations. The top five most-cited violations included violations of TILA/Regulation Z (470 violations), the Flood Disaster Protection Act (FDPA)/12 C.F.R. § 339 (143 violations), Truth in Savings Act (TISA)/Regulation DD (129 violations), EFTA/Regulation E (122 violations), and the Home Mortgage Disclosure Act (HMDA)/Regulation C (65 violations). As previously covered by InfoBytes, the FDIC last released their report in March 2024.
The report identified the three most cited TILA violations as (1) failure to provide required periodic statements for open-end credit plans, (2) failure to provide good faith estimates of disclosures for closed-end transactions secured by real property, and (3) failure to provide detailed breakdowns of loan costs for such transactions. The most commonly cited FDPA violation was the failure to provide adequate flood insurance when required. TISA violations typically involved the failure to provide accurate and clear deposit account disclosures. EFTA violations centered on improper investigations of alleged electronic fund transfer errors. HMDA violations most frequently involved insufficient data collection or reporting for required mortgage lending data fields. The report also summarized consumer complaint data, noting that the most common product complaints in 2024 related to credit cards (19 percent) and checking accounts (19 percent).
In 2024, the FDIC initiated 31 formal enforcement actions and 23 informal enforcement actions to address these examination findings and obtained civil monetary penalties totaling approximately $5.6 million for violations of the FDPA, Section 5 of the FTC Act, HMDA, and unsafe or unsound banking practices related to noncompliance with consumer protection laws. In addition, supervised institutions provided voluntary restitution payments totaling $33.3 million to about 400,000 consumers for violations of consumer protection laws and regulations. The FDIC also referred three matters to the DOJ for ECOA violations.
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