Enforcement Actions Roundup: July 2025

Welcome to the August edition of our Enforcement Actions Roundup, a monthly summary where our regulatory experts break down recent enforcement actions from the previous month, highlight what went wrong, and offer insights to help your institution stay ahead of similar risks. 

The Enforcement Actions Roundup includes two key elements:   

• The Enforcement Actions Tracker is a running total of enforcement actions by agency – keeping a tally of enforcement actions broken down by overall category and individual topics addressed by each action. This makes it easy to pick out enforcement trends and hot topics. 
• The Enforcement Deep Dive reviews each enforcement action to understand what happened, key takeaways, and controls you should review at your institution to avoid making the same mistake.  

Let's dive in.

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

2025 Enforcement Action Tracker

Please note that a single enforcement action may be included under multiple topics.

Enforcement Actions Deep Dive: June 2025 

CFPB Enforcement Actions

There were no institutional enforcement actions by the CFPB in July.

OCC Enforcement Actions

There were no institutional enforcement actions by the OCC in July.

FRB Enforcement Actions

There were no institutional enforcement actions by the FRB in July. 

NCUA Enforcement Actions

There were no institutional enforcement actions by the NCUA in July.

FDIC Enforcement Actions

FDIC Issues Enforcement Actions for Flood Disaster Protection Act Violations

• Category: Lending Compliance
• Topic: Flood Insurance
• Product and Services: Real Estate Lending
• Date: June 3, 2025; June 16, 2025
• Regulation: 12 CFR 339
• Enforcement Action: 1; 2
• Related Guidance: Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance
  

The FDIC issued enforcement actions against two institutions for violations of the Flood Disaster Protection Act (FDPA). Both institutions failed to follow force-placed flood insurance requirements. The second institution also neglected to obtain flood insurance on a building securing a loan, get adequate flood insurance at the time of originating a loan, and provide borrowers with a Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance when required.

Takeaways

Flood insurance violations remain the highest enforcement area of 2025. If institutions determine at any time during the term of a designated loan that the property is not covered by flood insurance or covered by an adequate amount of flood insurance, they must notify the borrower that they need to obtain flood insurance at their own expense. If the borrower fails to get their insurance within 45 days after notification, the institution must obtain coverage on the borrower's behalf. 

However, if the borrower notifies the institution that they have obtained their coverage, the institution must end the separate coverage and refund all premiums paid by the borrower for any insurance purchased by the institution.

Related: Navigating Flood Compliance in 2025 

Controls to Evaluate

1. Comprehensive Flood Insurance Policies and Procedures: Flood insurance policies and procedures are in place and are reviewed periodically. Roles and responsibilities are clearly defined, and policies and procedures are communicated to all staff. Procedures include
   1. Pulling flood determinations for loans that will be secured by real estate
   2. Requiring flood insurance for real estate secured loans in a designated flood zone before loan closing
   3. Notification to customers of flood insurance requirements
   4. Review process to ensure proper flood insurance is in place before loan closing and for the duration of the loan
   5. Monitoring loans to ensure that flood insurance coverage is maintained for the entire duration of the loan
   6. Flood insurance renewal monitoring and tracking
   7. Force placement insurance requirements and customer notification processes
   8. Maintaining documentation of flood insurance policies in the loan file, including proof of coverage and policy details
2. Updated Loan Operations Procedures: Loan Operations procedures include continuous monitoring of all insurance policies and related escrow (if applicable), including flood insurance, and handling all forced-place policies as necessary, plus providing all notices and disclosures as required. 
3. Trained Employees: All staff involved in flood insurance processes receive ongoing training to stay abreast of changes in requirements. 
4. Periodic Reviews: The Compliance department periodically reviews to ensure compliance with Flood Insurance requirements. 

Related Ncontracts Content in Your Platform

•    Ncomply Sample Policies: Flood Disaster Protection Act (FDPA) Policy 
•    Nrisk Risk Assessments: Flood Disaster Protection Act 
•    Nverify Audits: Flood Disaster Protection Act (FDPA) 

Want the scoop on key regulatory updates from the first half of 2025?

Join Ncontracts’ experts as they unpack what’s still evolving and explain what it means for your compliance priorities, risk posture, and exam readiness.