FDIC Issues Consumer Compliance Supervisory Highlights

The FDIC recently released its Consumer Compliance Supervisory Highlights (July 2025) which provides an overview of its supervisory activities in 2024. It includes:

• A summary of consumer compliance exam results;
• A description of the most frequently cited violations; and,
• An overview of consumer complaints

Five regulations accounted for about 73% of the total violations cited. These included Truth in Lending Act (Regulation Z), Flood Disaster Protection Act, Truth in Savings Act (Regulation DD), Electronic Funds Transfers Act (Regulation E) and the Home Mortgage Disclosure Act (Regulation C).

While none of these were terribly surprising, Regulation DD is an area that we haven’t seen a lot of regulatory focus recently. Even so, there are ample opportunities to go astray. Often times, problems with Regulation DD arise from system updates and conversions. Not only do the required disclosures need to be clear and conspicuous and meet specific content requirements, but institutions also need to ensure the disclosures accurately reflect their actual practices. In this Highlights, Regulation DD had more violations cited than either Regulation E or HMDA. The most common included:

• 1030.3 - This requires disclosures to be clear and conspicuous, and in writing.
• 1030.4(a) and §1030.4(b) - These sections cover the timing and content requirements for the disclosures.

Published
2025/07/31