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Press Release
October 16, 2008

Federal Reserve issues guidance for
consolidated supervision of bank holding
companies and combined U.S. operations of
foreign banking organizations
For immediate release
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The Federal Reserve on Thursday issued enhanced guidance that
refines and clarifies its programs for the consolidated supervision of
bank holding companies and the combined U.S. operations of foreign
banking organizations (FBOs). The Federal Reserve also released
guidance clarifying supervisory expectations with respect to firmwide
compliance risk management.
While initiation of these efforts predated the recent period of
considerable strain in the financial markets, these enhanced approaches
to consolidated supervision and firmwide compliance risk management
emphasize several elements that should support a more resilient
financial system.
The Federal Reserve continues to work, both independently and in
conjunction with other supervisors and functional regulators, on a
number of initiatives to strengthen supervisory approaches and reinforce
expectations for sound practices in response to market events.
"This supervisory guidance on consolidated supervision and compliance
risk management will better equip our supervisory staff, working closely
with other U.S. and foreign supervisors and regulators, to understand
and assess the full range and scope of a banking organization's

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operations and risks," said Federal Reserve Board Governor Randall S.
Kroszner.
"This guidance should not only provide greater clarity regarding our
longstanding responsibilities as a consolidated supervisor, but is also
responsive to ongoing developments in the financial sector. The
objectives of fostering financial stability and deterring or managing
financial crises will be furthered by the Federal Reserve having a more
complete view of firmwide risks and controls," Governor Kroszner
said.     
The continuing growth in the size and complexity of many banking
organizations exposes these firms to a wide array of potential risks,
while at the same time making it more challenging for a single
supervisor to have a comprehensive perspective on the firm as a
whole. In this regard, the consolidated supervision guidance is designed
to foster consistent Federal Reserve supervisory practices and
assessments across institutions with similar activities and risks.
The guidance describes how Federal Reserve staff develops an
understanding and assessment of the consolidated operations of a bank
holding company and the U.S. operations of an FBO through continuous
monitoring activities, discovery reviews, and testing activities, as well as
through interaction with, and reliance to the fullest extent possible on,
other relevant supervisors and functional regulators.   
The separate compliance risk management guidance endorses the
principles set forth in the April 2005 paper issued by the Basel
Committee on Banking Supervision entitled Compliance and the
compliance function in banks. This guidance clarifies certain Federal
Reserve supervisory policies regarding compliance risk management
programs and oversight at large banking organizations with complex
compliance profiles.
The supervisory guidance on both consolidated supervision and
compliance risk management is attached.
SR Letter 08-8/CA Letter 08-11
SR Letter 08-9/CA Letter 08-12

Last Update: October 16, 2008

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