The FDIC has announced significant updates to its Consumer Compliance Examination Manual, specifically examination schedules. These changes, effective November 7, 2025, reflect a more risk-based approach to scheduling compliance and CRA evaluations.

Institutions will now be placed on potentially longer examination cycles based on their asset size and the rating of their most recent joint Consumer Compliance/CRA examination.

For institutions on the longer cycles (66–78 and 54–66 months), the FDIC will conduct a mid-point risk analysis to determine whether an interim supervisory activity, such as a targeted visitation, is warranted. Institutions with less favorable ratings (Consumer Compliance ratings below “2” or CRA ratings below “Satisfactory”) will continue to receive more frequent supervisory attention.

The FDIC has published a redlined version of the updated manual. You can access it here. Alternatively, you can view the changes on page 66 of the FDIC Consumer Compliance Examination Manual, available here.

CCI recommends sharing this information with senior management at your institution. Once you have determined where your bank falls within the new exam schedule, ensure that you adjust internal timelines for audits and exams accordingly. With the potential for less frequent regulatory examinations, institutions should consider strengthening internal or external audit coverage, particularly in higher-risk areas, to ensure ongoing compliance. Proactive oversight will be essential to maintaining regulatory standards between formal exams. We suggest having open communication with your FDIC examiner to help clarify expectations. For any questions, please reach out to us at inquiries@completecompli.com.

 

Sarah Smith, CRCM, CAFP