Enforcement Actions Roundup: December 2025

Welcome to the January Enforcement Actions Roundup. Each month, we take a closer look at recent enforcement actions, what went wrong, and what financial institutions (FIs) can take away to improve their compliance and risk management programs. 

This roundup features two key resources:  

• Enforcement Actions Tracker: A running tally of actions by agency, category, and topic — making it easy to spot enforcement trends and emerging hot spots.  
• Enforcement Deep Dive: A closer look at each action, including what happened, key takeaways, and the controls your FI should revisit to avoid similar missteps.  

Let's get started.

Related: Bookmark the Ncontracts Enforcement Action Tracker to search the latest enforcement actions by date, category, and regulator.   

2025 Enforcement Action Tracker 

Enforcement Actions Deep Dive: December 2025

CFPB Enforcement Actions

The CFPB issued no institutional enforcement actions in December 2025.

OCC Enforcement Actions

The OCC issued no institutional enforcement actions in December 2025.

FRB Enforcement Actions

The FRB issued no institutional enforcement actions in December 2025.

FDIC Enforcement Actions

FDIC and Alabama Banking Department Issue Consent Order Addressing Capital, Asset Quality, and Liquidity Deficiencies 

• Category: Safety and Soundness
• Topic: Credit Risk Management and Capital Adequacy
• Date: November 3, 2025; Announced November 4, 2025 
• Regulation: 12 CFR 324, 12 CFR 215, AL Admin Code Banking Reg. No. 14
• Enforcement Actions: FDIC-25-0134b
• Related Guidance: FDIC Risk Management Examination Manual - Liquidity and Funds Management, FDIC Risk Management Examination Manual - Asset Quality, Interagency Policy Statement on Allowances for Credit Losses, Interagency Guidance on Concentrations in Commercial Real Estate Lending; Sound Risk-Management Practices 

The FDIC and Alabama State Banking Department jointly issued a Consent Order against a state non-member bank addressing weaknesses in management, asset quality, capital, earnings, and liquidity/funding. The FI must establish a directors' committee to oversee compliance, retain a consultant to assess management capabilities, and provide annual ethics training on conflicts of interest and Regulation O.  

Credit risk management improvements include annual reviews of credit relationships exceeding $1 million, enhanced stress testing, and reducing adversely classified assets to 45% of tier 1 capital plus allowance for credit losses (with an ultimate target of 25%). Capital requirements mandate maintaining a tier 1 leverage ratio of 8% (increasing to 9%) and a total capital ratio of 12%. The bank must also maintain liquidity above 10%, reduce wholesale funding to 10% of total assets, cap asset growth at 10% annually, and obtain regulatory approval before paying dividends or executive bonuses. 

Takeaways

FIs must ensure boards actively oversee risk management and compliance through regular meetings, documentation, and independent committee oversight. Regulators focus on credit risk management, requiring FIs to conduct timely loan reviews, analyze borrower financials, implement strong stress testing, and monitor policy exceptions. ACL methods should reflect actual loss experiences, and loans must be properly graded to identify potential losses quickly. 

FIs must maintain capital augmentation plans with contingency measures for potential sales or mergers if capital levels decline. Heightened supervisory attention on wholesale funding requires adequate liquidity ratios and robust contingency funding plans with early-warning indicators, while minimizing reliance on brokered deposits and unstable funding sources. FIs must also implement rigorous controls over insider transactions and related party dealings, supported by regular ethics training on Regulation O compliance.  

Controls to Evaluate

1. Comprehensive Risk Management: The risk management program is comprehensive, with established risk assessments and internal controls that are in alignment with the institution's risk profile and regular board reporting.  
2. Loan Review Program: The loan review program, internal and/or external, is comprehensive, with annual plans reviewed and approved by the board. The program includes appropriate staffing to attain adequate coverage, scope, analysis, and written reports. The Loan Review program provides for timely and accurate credit classification and risk grading, as well as compliance with SBA lending requirements and some compliance requirements. The reports are presented periodically to the board.  
3. ACL Policies and Procedures: Allowance for Credit Losses policy and procedures are comprehensive, periodically reviewed, and updated as needed.   
4. Reg O Policies and Procedures: Reg O policies and procedures are documented, regularly reviewed, and approved. These include: 
   1. Definitions of insiders: executive officers (anyone who participates or has authority to participate in policymaking)
   2. Directors and principal shareholders (anyone who directly or indirectly owns, controls, or has the power to vote more than 10% of the bank or holding company)
   3. Loan limits and restrictions
   4. Record keeping
   5. Overdraft rules and monitoring
   6. Reporting requirements
   7. Risk management
   8. Responses to public requests regarding insider credit
   9. Sales to and purchases from insiders
   10. Audit requirements
   11. Reporting requirements
   12. Risk management
   13. Responses to requests from the public regarding insider credit
   14. Sales to/purchases from insiders
   15. Audit requirements 
5. Robust Training: Ongoing, regular, and targeted training is provided to all relevant employees. Documentation is maintained regarding all training. All employees, officers, and board members are required to complete basic training courses.

Related Ncontracts Content in Your Platform

• Ncomply Sample Policies: Contingency Funding Plan (CFP) Policy, Liquidity Risk Management Policy, Regulation O- Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks 
• Nrisk Risk Assessments: CECL- Allowance for Credit Losses, Asset Liability Management, Regulation O- Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks, Corporate Governance

NCUA Enforcement Actions

The NCUA issued no institutional enforcement actions in December 2025.

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