Financial Institution Letter: FDIC Consumer Compliance Supervisory Highlights

Consumer compliance violations are not policy failures; they are decision-record failures. When a bank charges an overdraft fee without documenting the authorization logic, or reports inaccurate FCRA data without a named reviewer and timestamp, the institution has failed to produce the artifact that proves the decision was lawful at the moment it was made. The FDIC's annual highlights confirm that examiners continue to find gaps in the same statutory regimes year after year, which signals that training and policy updates are insufficient remediation. Decision Governance closes the loop: every fee assessed, every disclosure omitted, every data field reported must carry a machine-readable record of who decided, why, what evidence supported it, and when it was reviewed — produced as a system of record, not reconstructed in hindsight for the examiner.