Federal Reserve Issues Policy on Consumer Compliance Supervision for Nonbank Subsidiaries of Bank Holding Companies and Foreign Banking Organizations


On September 14, 2009, the Federal Reserve Board (FRB) issued an important policy relating to the FRB’s supervision of nonbank subsidiaries of bank holding companies (BHCs) and foreign banking organizations (FBOs). The policy requires the FRB staff to conduct risk-focused consumer compliance supervision of, and to investigate consumer complaints against, these entities with respect to activities covered by those consumer protection laws and regulations within the FRB’s enforcement jurisdiction. In its press release accompanying the policy, the FRB indicated that the policy “is designed to improve the [FRB’s] understanding of the consumer compliance risk that certain products and services may pose to the holding companies and consumers and to guide supervisory activities for these entities.” The FRB policy will likely open a new chapter in the supervision of BHCs and FBOs, and many of those entities will be required to devote an increased level of resources to their consumer compliance programs.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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