Consumer Compliance Outlook: First Issue 2025

2024 Aggregate Supervisory Data for Institutions the Federal Reserve Supervises

The Federal Reserve System is the primary federal regulator for state member banks. Since 2023, Consumer Compliance Outlook (CCO) has been regularly publishing three types of aggregate supervisory data for these banks:

The top consumer law violations identified by our examiners
The top categories of consumer complaints
The top Matters Requiring Immediate Attention (MRIAs) and Matters Requiring Attention (MRAs)

The Federal Reserve uses these data to enhance outreach and examiner training, to risk-focus future compliance examinations, and to inform its understanding of areas where supervised institutions face compliance challenges and where consumers are encountering issues with the institutions’ financial services and products.

CCO has also been publishing articles that leverage these data points to enhance the transparency of the Federal Reserve’s consumer compliance supervisory activities and to provide practical steps that institutions may consider when addressing certain consumer compliance risks. This issue lists the top-cited violations and consumer complaints and includes two articles on the top-cited violations. CCO will publish articles and data for the top-issued MRIAs and MRAs in a future 2025 issue.

During 2024, Federal Reserve System examiners conducted 223 examinations.¹ Table 1 lists the most frequently cited violations in 2024.²

TABLE 1: Top Consumer Violations in 2024 for State Member Banks

Provision		Number of Violations	Percentage of All Violations
1.	Regulation C (Home Mortgage Disclosure Act), 12 C.F.R. §1003.4(a): Requires a financial institution to collect specified data points on applications, originations, and purchases of covered loans.	253	38.2
2.	Regulation BB (Community Reinvestment Act), 12 C.F.R. §228.42(a): Requires a bank to collect and maintain specific data for each small business or small farm loan originated or purchased by the bank during the evaluation period.	53	8.0
3.	Regulation E (Electronic Fund Transfers Act), 12 C.F.R. §1005.11(c): Requires a financial institution to perform an investigation and determine whether an error occurred within 10 business days of receiving a notice of error.	35	5.3
4. (Tie)	Federal Trade Commission Act, Section 5(a), 15 U.S.C. §45: Prohibits unfair or deceptive acts or practices in or affecting commerce.	12	1.8
(Tie)	Regulation DD (Truth in Savings Act), 12 C.F.R. §1030.4(b): Requires a depository institution to provide certain information in account disclosures that must be provided to a consumer before an account is opened.	12	1.8
6. (Tie)	Regulation Z (Truth in Lending Act), 12 C.F.R. §1026.38(o): Requires a creditor to disclose certain loan calculations associated with a closed-end mortgage transaction on the Closing Disclosure.	10	1.5
(Tie)	Regulation Z (Truth in Lending Act), 12 C.F.R. §1026.19(e): Requires a creditor in a closed-end mortgage transaction to provide good faith estimates of the disclosures required in the Loan Estimate.	10	1.5
(Tie)	Regulation H (Flood Disaster Protection Act), 12 C.F.R. §208.25(i): Requires a bank that makes a loan secured by a property in a special flood hazard area to deliver a written notice to the borrower indicating whether flood insurance is available under the Flood Disaster Protection Act.	10	1.5
9.	Regulation Z (Truth in Lending Act), 12 C.F.R. §1026.38(f): Requires a creditor to disclose all loan costs associated with a closed-end mortgage transaction on the Closing Disclosure under the heading “Closing Cost Details.”	9	1.4
10. (Tie)	Regulation E (Electronic Fund Transfers Act), 12 C.F.R. §1005.11(d): Requires a financial institution to respond to a consumer’s notice of error in writing if it determines that no error occurred or that an error occurred in a manner or amount different from that described by the consumer.	8	1.2
(Tie)	Regulation Z (Truth in Lending Act), 12 C.F.R. §1026.38(i): Requires a creditor to calculate cash to close in a closed-end mortgage transaction on the Closing Disclosure.	8	1.2
(Tie)	Regulation H (Flood Disaster Protection Act), 12 C.F.R. §208.25(c): Prohibits a bank from making a loan secured by a property in a special flood hazard area unless the property is covered by flood insurance for the term of the loan.	8	1.2
Subtotal of Top Violations		428	64.7
Total		662	100

During 2024, the Federal Reserve monitored consumer complaints by topic. Table 2 describes the most frequent topics of consumer complaints in 2024.³

TABLE 2: Top Consumer Complaints in 2024 for State Member Banks

Complaint Topic		Number of Complaints	Percentage of All Complaints
1.	Restricted/Blocked Account	3,102	38.2
2.	Fraud/Forgery	1,255	15.4
3.	Error Resolution	902	11.1
4.	Funds Availability/Withdrawals/Unable to Access Funds	850	10.5
5.	Credit Reporting	624	7.7
6.	Fees/Terms/Rates	226	2.8
7.	Account Closure	211	2.6
8.	Application/Account Opening	114	1.4
9.	Debt Validation	106	1.3
10.	Inability to Pay	88	1.1
Subtotal of Complaints in Top 10 Categories		7,478	92.1
Total of All 2024 Complaints		8,127	100

ENDNOTES

¹ The Federal Reserve System examines state member banks using an examination calendar that factors in institution size and risk profile. Therefore, not all state member banks were examined in 2024.

² For the purposes of this table, a violation is a citation of a bank in an examination report by the Federal Reserve for violating the listed provision; the listed numbers do not refer to the number of consumers the violation affected.

³ The Federal Reserve investigates complaints against state member banks and selected nonbank subsidiaries of bank holding companies (Federal Reserve–regulated entities). For more information on the Federal Reserve’s complaint handling process, see the 110th Annual Report of the Board of Governors of the Federal Reserve System and The Fed Explained: What the Central Bank Does.