On July 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) issued the Summer 2025 edition of its Consumer Compliance Supervisory Highlights (“Supervisory Highlights”). The latest edition focuses on information about the overall results of the approximately 800 FDIC consumer compliance examinations conducted in 2024 providing some insight into areas of consumer compliance performance, the most frequently cited violations, and growing trends in consumer complaints.
The FDIC reports that 1,275 violations of consumer protection statutes and regulations were cited in 2024. Of those, five types of violations make up 73% of the total number of violations cited during the year.
The most common violations under each statute includes:
- Truth in Lending Act (“TILA”) and Regulation Z, including 12 CFR §1026.7(b), 12 CFR § 1026.19(e), and 12 CFR §§ 1026.38(f) – (k), covering failure of creditors to provide borrower with clear information about the terms and costs of credit (21% of cases). Specifically, the most common violations related to the creditor requirements to provide: a periodic statement for certain open-end credit plans; a good faith estimate for closed-end transactions, following timing requirements; and a detailed breakdown of all loan costs associated with closed-end transactions.
- Flood Disaster Protection Act (“FDPA”) and its implementation regulation, 12 CFR Part 339, covering failure of an institution to require flood insurance (45% of cases). The most common violation was adequate flood insurance not being in place at the time a loan secured by a building or mobile home located in a special flood hazard area was consummated.
- Truth in Savings Act (“TISA”) and Regulation DD, 12 CFR §§ 1030.4(a) and (b), covering failure of banks to provide clear disclosures about the terms and costs of consumer deposit accounts (65% of cases). The most common violations were for institutions not providing consumers clear and concise disclosures in writing. Also, violations for not providing consumers specific disclosure information before opening a deposit account.
- Electronic Fund Transfer Act (“EFTA”) and Regulation E, 12 CFR § 1005.11(c), covering failure to properly investigate electronic fund transfer errors (47% of cases). Institutions are required to investigate certain types of alleged electronic fund transfer errors and make any needed corrective steps within certain timeframes.
- Home Mortgage Disclosure Act (“HMDA”) and Regulation C, 12 CFR § 1003.4(a), covering failure to publicly disclose sufficient data about mortgage lending data (77% of cases). The most common violation involved institutions not providing required information for one or more data fields.
The Supervisory Highlights also discuss consumer complaint trends. In 2024, the FDIC received a total of 23,444 written complaints. This total reflects an increase of 14% from the prior year. Fair lending complaints decreased by 9% in that same time period.
Out of the total number of consumer complaints, 10,860 were investigated by the FDIC, and 12,478 were referred to other federal regulators. The agency initiated 31 formal enforcement actions, and 23 information enforcement actions. Three matters were referred to the U.S. Department of Justice for possible Equal Credit Opportunity Act violations.
In addition to monetary compensation, the FDIC also reports that consumers received non-monetary compensation such as updates to credit reports, updates to bank records, reinstatement of accounts, cessation of collection calls or actions, forgiven debt, and loan modifications.