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Home > News & Events > Press Releases

Press Release
September 15, 2009

Federal Reserve to implement consumer
compliance supervision program of nonbank
subsidiaries of bank holding companies and
foreign banking organizations
For immediate release
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The Federal Reserve, under a policy announced Tuesday, will
implement a consumer compliance supervision program in nonbank
subsidiaries of bank holding companies (BHCs) and foreign banking
organizations (FBOs) with activities covered by the consumer protection
laws and regulations the Federal Reserve has the authority to enforce.
The policy, which will take effect immediately, also provides for the
investigation of consumer complaints against these nonbank entities.
In 2007, the Federal Reserve, along with the Federal Trade Commission
(FTC), Office of Thrift Supervision (OTS), and two associations of state
regulators, launched a joint pilot project that conducted targeted
consumer protection compliance reviews of selected non-depository
lenders with significant subprime mortgage operations. The policy
announced today builds upon the groundwork of the pilot program and
responds to a need for more effective supervision and consumer
protection. It is designed to improve the Federal Reserve's
understanding of the consumer compliance risk that certain products
and services may pose to the holding companies and consumers and to
guide supervisory activity for these entities.
The Federal Reserve has authority to examine nonbank subsidiaries for

compliance with the Truth in Lending Act (TILA); Equal Credit
Opportunity Act (ECOA); Home Ownership and Equity Protection Act
(HOEPA); Fair Credit Billing Act (FCBA); Consumer Leasing Act (CLA);
Fair Credit Reporting Act (FCRA); Fair Debt Collection Practices Act
(FDCPA); Home Mortgage Disclosure Act (HMDA); Truth in Savings Act
(TISA); any rules promulgated pursuant to the Federal Trade
Commission Act (FTC Act); and the Real Estate Settlement Procedures
Act (RESPA).
The Board's Consumer Affairs Letter is attached.
CA Letter 09-08

Last Update: September 15, 2009

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