The FDIC recently published its annual Consumer Compliance Supervisory Highlights, covering examination results and consumer complaint trends for FDIC-supervised state-chartered banks and thrifts that are not members of the Federal Reserve System (supervised institutions). The report, summarized below, describes the FDIC’s findings from approximately 825 consumer compliance examinations of supervised institutions and from a review of approximately 32,000 consumer complaints.
Most frequently cited violations identified in examinations
In 2025, the FDIC identified 1,155 violations of consumer protection statutes and regulations through exams of supervised institutions. The top five most frequently cited violations accounted for almost 75% of total violations cited and related to the following areas, all of which were also the top cited categories of violations in 2024[1]:
- Truth in Lending Act (TILA)/Regulation Z (462 violations): The most common TILA violations involved institutions failing to provide required information in disclosures about the cost of credit to borrowers, as set forth in Regulation Z.
- Electronic Fund Transfer Act (EFTA)/Regulation E (136 violations): The bulk of EFTA violations, which climbed to the second-most frequently cited issue from the year prior, stemmed from how institutions handled investigations of EFT errors.
- Flood Disaster Protection Act (FDPA) (131 violations): The most frequently cited FDPA violation involved institutions’ extension of loans secured by properties in designated flood hazard zones without ensuring that adequate flood insurance was in place at closing.
- Truth in Savings Act (TISA)/Regulation DD (74 violations): Examiners found that some institutions failed to provide accurate disclosures regarding the terms and costs of consumer deposit accounts.
- Home Mortgage Disclosure Act (HMDA)/Regulation C (72 violations): The most common HMDA violations involved institutions failing to provide sufficient data for one or more required data fields, including borrower information and loan information.
Enforcement actions
In 2025, the FDIC brought 16 formal enforcement actions and 11 informal enforcement actions to address examination findings. The FDIC issued orders totaling approximately $150 million against institutions to address flood insurance violations under the FDPA and unfair acts or practices under Section 5 of the Federal Trade Commission Act. The FDIC also required approximately $1.2 billion in restitution through formal orders while supervised institutions also provided voluntary restitution payments totaling $4.7 million to 47,902 consumers.
Consumer complaint trends
The FDIC’s Consumer Response Unit (CRU) closed more than 32,000 complaints in 2025, an increase of 21% from 2024. Of the complaints investigated by the FDIC, the CRU identified 280 errors made by financial institutions, 108 federal consumer protection violations and 76 cases requiring further review by an FDIC regional office. Fair lending complaints decreased by 37%, from 62 in 2024 to 39 in 2025.
Complaints received centered around a handful of financial products, with credit cards, checking accounts, installment loans and consumer lines of credit drawing the highest complaint volume. Across all complaints, the top issue raised related to credit reporting, which accounted for 35% of all issues identified. Of note, third-party service providers were cited in more than 6,300 consumer complaints, representing a nearly 48% increase compared to 2024.
The FDIC’s review and resolution of consumer complaints led to $1.67 million in voluntary restitution and compensation to consumers, which was less than provided to consumers in 2024. More than 600 cases were resolved through corrected credit reports, debt forgiveness, suspension of collection activity, loan modifications and other non-monetary actions.
Looking ahead
The examination findings and consumer complaint trends highlighted in the report shed light on where the FDIC may focus its supervisory and examination efforts moving forward.
However, the report comes as federal financial regulators, including the FDIC, have generally scaled back certain enforcement and supervisory efforts amidst staff reductions. In particular, the FDIC’s workforce has dropped by about 20%. Just last week, the Office of the Inspector General cited concerns as to whether the reduction in personnel could impact the “FDIC’s capacity to maintain sufficient skilled personnel for statutorily required examinations and to execute the resolution and receivership activities.”
Nonetheless, in light of the report findings and complaint trends, supervised institutions should continue to monitor disclosures, electronic fund transfer error resolution procedures and flood insurance requirements, in addition to assessing their third-party provider oversight programs.
[1] The FDIC report focuses on the five most frequently cited Level 3 or Level 2 violations and does not include Level 1 violations, which are the “lowest level of concern.”