FDIC Releases Spring 2022 Consumer Compliance Supervisory Highlights

The FDIC released the Spring 2022 edition of the Consumer Compliance Supervisory Highlights (Highlights), which provided transparency into the FDIC’s consumer compliance supervisory activities.  The Highlights provided a high-level overview of the consumer compliance violation trends that the FDIC observed in the examination of insured institutions in 2021.  The most common violations were of Regulation Z (TILA), the flood insurance requirements of the Flood Disaster Protection Act (FDPA), electronic fund transfer errors under Regulation E, force-place hazard insurance requirements under RESPA, and the timing and content of disclosures made for deposit accounts. 

The Highlights also provided an overview of FDIC regulatory matters and consumer complaints submitted to the FDIC, most notably referring two matters to the Department of Justice for purported fair lending concerns:  one regarding the use of Department of Education data in a manner that the FDIC asserts excluded student loan borrowers at Historically Black Colleges and Universities; and the other a redlining matter based on HMDA data and branching locations.