FDIC's Consumer Compliance Supervisory Highlights for July 2025

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Show Notes: FDIC Consumer Compliance Supervisory Highlights - July 2025Episode SummaryIn this episode, we break down the FDIC's latest Consumer Compliance Supervisory Highlights report, covering 2024 examination results and compliance trends. While focused on FDIC-supervised institutions, this principle-based guidance serves as an excellent roadmap for credit unions and all financial institutions.Key TakeawaysOverall Performance97% of FDIC-supervised institutions rated satisfactory or better for consumer compliance800 consumer compliance examinations conducted in 2024Risk-focused examination approach targets areas with greatest potential for consumer harmTop 5 Most Cited Violations (73% of all violations)Truth in Lending Act (TILA) - 470 violations (37%)Periodic statement disclosure failuresGood faith estimate timing issuesLoan cost breakdown requirementsFlood Disaster Protection Act (FDPA) - 143 violations (11%)Failure to provide required flood insurance45% of FDPA violations related to this single issueTruth in Savings Act (TISA) - 129 violations (10%)Inadequate deposit account disclosuresPre-opening disclosure failuresElectronic Fund Transfer Act (EFTA) - 122 violations (10%)Error investigation procedure failuresTiming and reporting requirement violationsHome Mortgage Disclosure Act (HMDA) - 65 violations (5%)Incomplete data collection and reportingMissing required borrower and loan informationEnforcement Actions & Restitution31 formal and 23 informal enforcement actions$5.6 million in civil money penalties$33.3 million in voluntary restitution to ~400,000 consumers3 referrals to Department of Justice for discrimination violationsConsumer Complaint Trends26,451 complaints closed (14% increase from 2023)100% acknowledgment within 14 days98.6% response rate within performance goalsTop Complaint Categories:Credit cards: 4,733 complaints (29%)Checking accounts: 3,152 complaints (19%)Installment loans/CLOC: 2,708 complaints (12%)Residential real estate: 844 complaints (5%)Most Common Issues:Credit reporting disputes (18%)Transaction errors (9%)Accounts opened without knowledge (6%)Disclosure problems (6%)Service availability issues (5%)Emerging Trends13% increase in third-party provider-related complaints (4,282 cases)Growing vendor oversight challengesPersistent credit reporting and account opening issuesFair lending complaints decreased 9% (68 to 62 cases)Key Compliance Areas for FocusHigh-Risk AreasDisclosure Management: TILA, TISA, and HMDA reporting accuracyOperational Procedures: Flood insurance, error resolution processesVendor Oversight: Third-party provider compliance monitoringData Collection: HMDA and other regulatory reporting requirementsProactive StrategiesImplement robust disclosure review processesEnhance staff training on operational complianceStrengthen vendor management programsMonitor complaint trends as early warning indicatorsWhy This Matters for Credit UnionsWhile this report focuses on FDIC-supervised banks, the consumer protection laws and compliance principles apply broadly across financial services. Credit unions can use these insights to:Benchmark their compliance performanceIdentify potential risk areas before they become problemsEnhance training and procedures in high-violation areasImprove vendor management practicesResources MentionedFDIC Consumer Compliance Examination ManualFederal Financial Institutions Examination Council (FFIEC) Rating SystemFDIC National Center for Consumer and Depositor AssistanceHost NotesThis episode provides actionable insights for compliance professionals, with extensive use of direct quotes from the FDIC report to ensure accuracy. The data shows that while most institutions are performing well, concentrated issues in specific areas offer clear opportunities for improvement across the industry. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.