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FDIC’s Consumer Compliance Supervisory Highlights Summer of 2025 – Consumer Lending
In July 2025, the FDIC released its Consumer Compliance Supervisory Highlights publication (“Highlights”), which provides an overview of its consumer compliance activities and the issues identified by its examiners in 2024. During 2024, the FDIC’s consumer compliance examiners found that the most frequently cited regulatory violations (representing approximately 73 percent of the total violations cited in 2024) involve the Truth in Lending Act (TILA) and Regulation Z; the Flood Disaster Protection Act (FDPA); the Truth in Savings Act (TISA) and Regulation DD; the Electronic Fund Transfers Act (EFTA) and Regulation E; and the Home Mortgage Disclosure Act (HMDA) and Regulation C.
FDIC’s Consumer Compliance Supervisory Highlights Summer of 2025 - TISA & EFTA
Recently, the FDIC issued the agency’s Consumer Compliance Supervisory Highlights (“Supervisory Highlights”) for the Summer of 2025. The purpose of the Supervisory Highlights is, in part, to improve transparency regarding supervisory activities and to provide a high-level survey of consumer compliance issues identified in 2024.
CFPB Sued for Delaying the Section 1071 Rule
As previously reported by BCG, the CFPB’s Section 1071 Small Business Lending Data Collection (SBLDC) Rule (codified in 12 FR Part 1002, Subpart B) has recently come under serious scrutiny. Not only has the rule survived various legal challenges, the compliance dates for the SBLDC Rule were recently delayed by the CFPB in June 2025, and it’s expected that the CFPB will substantially revise the rule. Now, consumer advocacy groups have sued the CFPB to implement the SBLDC Rule.
Application of AB 130’s New Servicing and Foreclosure Requirements for Subordinate Mortgages to Commercial Loans
QUESTION: Do the new California subordinate mortgage servicing and foreclosure requirements under Assembly Bill (AB) 130 apply to commercial loans?
FRB, OCC, and FDIC Issue Joint Statement on Crypto-asset Safekeeping Activities
On July 14, 2025, the OCC, FRB, and FDIC (the “Agencies”) issued a joint statement regarding financial institutions that are (or are considering) providing safekeeping services for crypto-assets (the “Joint Statement”). The Joint Statement discusses existing laws, regulations, and important risk management principles that apply when providing safekeeping services for crypto-assets.
Agencies Propose Rescinding 2023 CRA Final Rule
As previously reported in April 2025, the federal bank regulatory agencies made clear their plans to rescind the Community Reinvestment Act (CRA) rule finalized in October 2023 (the “2023 CRA Final Rule”). On July 16, 2025, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (the “Agencies”) followed through on that plan by issuing a joint proposal to rescind the 2023 CRA Final Rule and replace it with prior CRA regulations. 90 FR 34086.
Table of Contents
CONSUMER FINANCE
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FDIC’s Consumer Compliance Supervisory Highlights Summer of 2025 – Consumer Lending
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OCC Removes Disparate Impact Liability From Fair Lending Examination Manual
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District Court Vacates CFPB Medical Debt Rule
BANKING OPERATIONS & FINTECH
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FDIC’s Consumer Compliance Supervisory Highlights Summer of 2025 - TISA & EFTA
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Court Pauses Section 1033 Lawsuit
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FinCEN Extends Fentanyl Orders Against Mexican Financial Institutions
COMMERCIAL LENDING
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CFPB Sued for Delaying the Section 1071 Rule
COMMERCIAL LENDING Q&A
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Application of AB 130’s New Servicing and Foreclosure Requirements for Subordinate Mortgages to Commercial Loans
CORPORATE GOVERNANCE
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FRB, OCC, and FDIC Issue Joint Statement on Crypto-asset Safekeeping Activities
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Congress Passes GENIUS Act
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FDIC Rescinds 2024 Merger Policy Statement
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FDIC Publishes Notice of Proposed Guidelines for Appeals of Material Supervisory Determinations
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FDIC Withdraws Proposed Rule on Oversight of Parent Companies of Industrial Banks and Loan Companies
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FDIC Proposes Adjusting and Indexing Certain Regulatory Thresholds to Reflect Inflation
CRA/HMDA Corner
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Agencies Propose Rescinding 2023 CRA Final Rule
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