FDIC Releases Consumer Compliance Supervisory Highlights

The FDIC has published its March 2026 Edition of its Consumer Compliance Supervisory Highlights, detailing examination results and enforcement trends from 2025. While the vast majority of supervised institutions maintained satisfactory compliance ratings, the report indicates that total consumer complaints rose by 21% year over year, with a significant 48% increase in complaints involving third-party service providers.

The report identifies TILA/Regulation Z as the most frequently cited area of non-compliance, representing 40% of all violations. Specifically, examiners noted systemic failures in providing accurate Closing Disclosures and Good Faith Estimates for real property transactions. EFTA/Regulation E was the second most cited violation, with 74% of these cases centered on mishandled error resolution investigations. Finally, the report highlighted that FDIC initiated 16 formal enforcement actions and 11 informal enforcement actions during the year to address consumer compliance examination findings.  The FDIC ordered civil money penalties totaling approximately $150 million to address violations of the FDPA and Section 5 of the Federal Trade Commission Act for Unfair or Deceptive Acts or Practices. In addition, a total of approximately $1.2 billion in restitution was ordered by the FDIC in 2025.  The report also highlights that supervised institutions provided voluntary restitution payments totaling $4.7 million to 47,902 consumers for violations of various consumer protection laws and regulations.

These findings highlight that supervised institutions may want to audit their Compliance Management Systems. With 75% of all citations relating to just five regulations (TILA, EFTA, FDPA, TISA, and HMDA) supervised institutions might consider prioritizing these “top five” in their 2026 internal audit plans to mitigate the risk of enforcement actions.