The FDIC last week released the 2025 edition of its “Consumer Compliance Supervisory Highlights.” The report includes a summary of the overall consumer compliance performance for FDIC-supervised institutions in 2024, a description of the most frequently cited violations, and an overview of consumer complaint trends. The last report was issued in spring 2024.
In 2024, the FDIC conducted approximately 800 consumer compliance examinations, the agency said in the report. The FDIC uses the Federal Financial Institutions Examination Council’s Uniform Interagency Consumer Compliance Rating System to evaluate supervised institutions’ adherence to consumer protection laws and regulations. As of Dec. 31, 2024, 97% of all FDIC-supervised institutions were rated satisfactory or better for consumer compliance (i.e., ratings of 1 or 2), and 97% were rated “outstanding” or “satisfactory” for the Community Reinvestment Act.
The FDIC cited 1,275 violations of consumer protection statutes and regulations in 2024. Together, the top five most frequently cited violations represented 929 violations or approximately 73% of the total violations cited in 2024. The Truth in Lending Act (Regulation Z) represented 470 violations; the Flood Disaster Protection Act (12 CFR Part 339) represented 143 violations; the Truth in Savings Act (Regulation DD) represented 129 violations; the Electronic Fund Transfer Act (Regulation E) represented 122 violations; and the Home Mortgage Disclosure Act (Regulation C) represented 65 violations. This list contains four of the same laws and regulations from the 2024 report; HMDA replaced Section 5 of the Federal Trade Commission Act as the fifth most cited violation.
The FDIC’s National Center for Consumer and Depositor Assistance, Consumer Response Unit, closed 26,451 written complaints (including webform submissions) and telephone call inquiries in 2024, compared to 23,290 written complaints and telephone call records closed in 2023. This represents a 14% increase. In 2024, the CRU acknowledged 100% of written complaints within 14 days and investigated and responded to 98.6% of complaints “within established performance goal timeframes,” FDIC said.
Of the 23,444 written complaints closed in 2024, the CRU retained and investigated 10,860 and referred 12,478 to other federal banking regulators. As a result of the investigations, the CRU identified 305 apparent errors made by institutions, 132 apparent federal consumer protection regulation violations, and 59 cases requiring escalation to the appropriate FDIC regional office for further review. Fair lending complaints decreased from 68 in 2023 to 62 in 2024, representing a 9% decrease. One or more third-party providers (non-bank financial firms that performs single or multiple services on behalf of banks, such as credit card servicing and processing, payment processing, and transaction error disputes) were identified among 4,282 consumer complaint cases in 2024, representing nearly a 1increase from 2023. An apparent violation of a federal consumer protection regulation was identified in 116 consumer complaint cases involving a TPP in 2024.
