The Federal Deposit Insurance Corporation (FDIC) has released its 2025 Consumer Compliance Supervisory Highlights, which cover trends discovered during approximately 800 supervisory examinations conducted by the agency in 2024.

The document reviews consumer compliance performance, the most frequently cited violations, and trends in consumer complaints.

Consumer compliance performance

The report notes that in 2024, 97% of all FDIC-supervised institutions were rated satisfactory or better for consumer compliance, and that 97% were rated “Outstanding” or “Satisfactory” for the Community Reinvestment Act (CRA).

Most frequently cited violations

The FDIC found that there were 1,275 violations of consumer protection statutes and regulations in 2024, with the top five most frequently cited statute violations representing 73% of total violations.

The most common violations under each statute included:

• TILA 15 U.S.C. § 1637 and 12 CFR § 1026.7(b), 15 U.S.C. § 1638 and 12 CFR § 1026.19(e), and, 15 U.S.C. § 1604 and 12 CFR §§ 1026.38(f) – (k), covering failure of creditors to provide borrowers with clear information about the terms and costs of credit. (21% of cases.)
• FDPA (42 U.S.C. § 4012(b) and 12 CFR § 339.3(a), covering failure of an institution to provide flood insurance (45% of cases.)
• TISA/Reg DD 12 U.S.C. § 4303 and 4305 and 12 CFR §§ 1030.3 and 12 U.S.C. §§ 4303-4305 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 of cases.)
• EFTA/Reg E 15 U.S.C. § 1693f and 12 CFR § 1005.11(c), covering failure to properly investigate electronic transfer errors. (47% of cases.)
• HMDA/Reg 12 U.S.C. § 2801 and 12 CFR § 1003.4(a), covering failure to publicly disclose sufficient data about mortgage lending data. (77% of cases.)

Enforcement trends

In 2024, the FDIC initiated 31 formal and 23 informal enforcement actions to address consumer compliance examination findings, yielding $5.6 million in civil monetary penalties. Additionally,

• Supervised institutions provided voluntary restitution payments totaling $33.3m to approximately 400,000 consumers.
• The FDIC referred three violations to the DOJ for violations of the Equal Credit Opportunity Act.

Consumer complaint trends

• The FDIC reported a 14% increase in complaints from 2023.
• Of the 23,444 written complaints, 10,860 were investigated while 12,478 were referred to other regulators.
• Investigations uncovered 305 institutional errors, 132 regulation violations, and 59 cases needing escalation.
• Consumers received over $2m in voluntary restitution and non-monetary relief in 937 cases, with top complaint categories including credit cards, checking accounts, instalment loans/CLOCs, and residential real estate loans.