Welcome to the December Enforcement Actions Roundup — our monthly look at the enforcement activity from the past month, what went wrong, and what financial institutions (FIs) can learn from it.
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
| Fair Lending | Advertising | AML/CFT | Underwriting | UDAAP | Electronic Funds Transfers | Insider Activities | Flood Insurance | Financial Risk | Concentration | Military Lending | |
| CFPB | 1 | 2 | 4 | 1 | 1 | ||||||
| OCC | 3 | 1 | 8 | 3 | |||||||
| FRB | 1 | 3 | 1 | ||||||||
| FDIC | 5 | 3 | 1 | 1 | 1 | 10 | 5 | ||||
| NCUA |
Enforcement Actions Deep Dive: November 2025
CFPB Enforcement Actions
There were no institutional enforcement actions issued by the CFPB in November 2025.
OCC Enforcement Actions
There were no institutional enforcement actions issued by the OCC in November 2025.
FRB Enforcement Actions
FRB Issues Two Enforcement Actions for Flood Insurance Violations
- Category: Lending Compliance
- Topic: Flood Insurance
- Date: September 12, 2025; Announced November 6, 2025
- Regulation: 42 U.S.C. 50; 12 CFR 208
- Enforcement Actions: 42 U.S.C. 50; 12 CFR 208
- Related Guidance: Flood Disaster Protection Act: 2022 Interagency Questions and Answers Regarding Flood Insurance (2022-16)
The FRB issued two enforcement actions for flood insurance violations related to loan requirements in special flood hazard areas (SFHAs). Each institution had three separate violations, each carrying a $2,000 civil monetary penalty.
Takeaways
Flood insurance violations have taken center stage over the last two years, with no signs of slowing down. One of the most common causes of these violations is failing to ensure that properties located in Special Flood Hazard Areas (SFHAs) are covered by adequate flood insurance. Financial institutions cannot make, increase, extend, or renew designated loans secured by buildings or mobile homes in SFHAs unless the property is covered by adequate flood insurance for the loan term.
Banks must use FEMA's standard flood hazard determination form to assess whether collateral is in an SFHA where flood insurance is available under the National Flood Insurance Program (NFIP). Institutions also need to retain copies of completed determination forms for the life of the loan and maintain proper internal controls to monitor compliance throughout their loan portfolios.
Controls to Evaluate
- 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:
- Pulling flood determinations for loans that will be secured by real estate
- Requiring flood insurance for real estate secured loans in a designated flood zone before loan closing
- Notification to customers of flood insurance requirements
- Review process to ensure proper flood insurance is in place before loan closing and for the duration of the loan
- Monitoring loans to ensure that flood insurance coverage is maintained for the entire duration of the loan
- Flood insurance renewal monitoring and tracking
- Force placement insurance requirements and customer notification processes
- Maintaining documentation of flood insurance policies in the loan file, including proof of coverage and policy details
- Loan Operations Procedures: Loan Operations procedures include continuous monitoring of all insurance policies and related escrow (if applicable), including flood insurance; handling all forced-place policies as necessary; and providing all notices and disclosures as required.
- Trained Staff: All staff involved in flood insurance processes receive ongoing training to stay abreast of changes in requirements.
- Periodic Reviews: The compliance department periodically performs 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)
FDIC Enforcement Actions
There were no institutional enforcement actions issued by the FDIC in November 2025.
NCUA Enforcement Actions
There were no institutional enforcement actions issued by the NCUA in November 2025.
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