On November 7, 2025, the Federal Deposit Insurance Corporation (FDIC) published Financial Institution Letter (FIL) 52-2025, which announced modifications to the Consumer Compliance Examination Manual that significantly updates the consumer compliance examination cadence, adjusting the frequency of consumer compliance examinations and Community Reinvestment Act (CRA) evaluations for FDIC-supervised institutions under the $3 billion assets threshold. In addition, the FDIC has introduced a new compliance mid-point risk analysis for certain institutions. This revision aims to better align supervisory resources with the evolving risk profiles of institutions and reduce unnecessary burden on lower-risk institutions.
What Changed and Why
The FDIC has modified §II-12.1, Examination and Visitation Frequency, of its Consumer Compliance Examination Manual to set new examination and CRA evaluation intervals for newly chartered insured institutions and charter conversions (Table 1), and institutions with total assets of less than $350 million (Table 2) or more than $350 million (Table 3). The tables below, taken from the revised manual, reflect the updated examination cycles:
Table 1 - Initial Examination Frequency Schedule for Newly Chartered and Insured Institutions and Charter Conversions
Note: After 24 months, the institution will follow the applicable Examination Frequency Schedule based on asset size
| Institution Category | Consumer Compliance & CRA Visitation | Consumer Compliance Examination/ CRA Evaluation |
|---|---|---|
| Denovo Institution | Within 12 months of operation | Within 24 months of operation |
| Charter Conversion Institution | Within 2 months of charter conversion | Within 24 months of charter conversion |
Activity Legend (Tables 2 & 3):
- Mid-Point RA = Mid-Point Risk Analysis conducted between examinations
- Compliance = Consumer Compliance-only examination
- CRA = CRA-only evaluation
- C&C = Consumer Compliance examination and CRA evaluation
Table 2 - Consumer Compliance/CRA Examination Frequency Schedule (in months) for Institutions with Total Assets less than $350 Million for either of the two previous year-end Call Reports
| Consumer Compliance Rating | CRA Rating | ||||
|---|---|---|---|---|---|
| Outstanding | Satisfactory | Needs to Improve | Substantial Non-compliance | Not Applicable/ Special Purpose Designation | |
1 |
|
|
|
| |
2 | |||||
3 |
| 12-24 months (C&C) |
| 12-24 months (Compliance) | |
4 |
| 1-12 months (C&C) | 1-12 months (Compliance) | ||
5 | |||||
Table 3 - Consumer Compliance/CRA Examination Frequency Schedule (in months) for Institutions with Total Assets more than $350 Million for either of the two previous year-end Call Reports
| Consumer Compliance Rating | CRA Rating | ||||
|---|---|---|---|---|---|
| Outstanding | Satisfactory | Needs to Improve | Substantial Non-compliance | Not Applicable/ Special Purpose Designation | |
1 |
|
|
|
| |
2 | |||||
3 |
| 12-24 months (C&C) |
| 12-24 months (Compliance) | |
4 |
| 1-12 months (C&C) | 1-12 months (Compliance) | ||
5 | |||||
For many lower-risk institutions, there will be longer intervals between full consumer compliance examinations, while adversely rated institutions will remain subject to more frequent full reviews and targeted compliance examinations.
A key innovation introduced in the revised manual is the introduction of the mid-point risk analysis, a streamlined assessment conducted between full consumer compliance examinations. The assessment is limited to institutions on either the 66-78 month or the 54-66 month examination cycle, with no targeted Consumer Compliance examination or CRA evaluation, to identify trends that may warrant an expedited supervisory response. This mechanism is designed to identify and intervene on issues before they escalate into larger consumer harm or systemic problems. Therefore, the importance of a strong Compliance Management System (CMS) will be vital to identify potential risk areas between exams. If an area arises between cycles, the lookbacks would be since the last examination potentially.
The manual revisions reflect the FDIC’s effort to adopt a more risk-focused supervisory approach while maintaining protections for consumers and the safety and soundness of the industry. For institutions, the updated intervals between examinations place a greater onus on the board and senior management to maintain a monitoring framework that is proactive and risk-focused, emphasize continuous refinement of the CMS, and ensure compliance data and risk metrics are comprehensive and readily available.
Next Steps
The FDIC’s manual update was designed to reduce compliance burdens for lower-risk FDIC-supervised institutions. While this update may lead to fewer supervisory examinations and extended review cycles, institutions must remain vigilant in their compliance oversight efforts, especially given the amount of time that will elapse between examinations. Key considerations include:
- Review and Adjust Compliance Monitoring Frameworks: Institutions should evaluate their CMS to ensure processes are proactive and risk-focused. With longer intervals between full examinations for lower-risk institutions, it is essential to maintain governance, internal monitoring, and continuous refinement of compliance processes.
- Prepare for Mid-Point Risk Analysis: For institutions on extended examination cycles, anticipate the new mid-point risk analysis. Develop processes to collect and analyze compliance data and risk metrics so that emerging risks can be identified and addressed before they escalate.
- Strengthen Board and Senior Management Oversight: The updated schedule places greater emphasis on the ability of the Board and senior management to maintain and demonstrate informed oversight. As such, leadership must remain engaged in overseeing compliance activities and have access to comprehensive data and risk information.
- Stay Informed on Regulatory Changes: Monitor FDIC communications and updates to remain aware of evolving expectations and requirements, and adapt policies and procedures accordingly.
In the heavily regulated banking industry, leaders face more challenges than ever, from striving to meet shareholder and regulatory expectations to pursuing digital innovation. Forvis Mazars can help your financial institution tackle issues inherent to the industry, including market growth, internal control threats, industry consolidation, and compliance. Our team can assist the financial institution with assessing the CMS process in place, performing monitoring in the second or third line, and well as training for compliance personnel. We have the skills and experience in financial services that you can trust, combining a focus on Unmatched Client Experience® with the resources of a global firm. Serving you is our passion and privilege.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.