Circular
Federal Reserve to Implement Consumer Compliance Supervision Program of Nonbank Subsidiaries of BHCs and FBOs
September 16, 2009
Circular No. 12136

The Federal Reserve is implementing 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 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.

See press release for full details.

Press release offsite
CA Letter 09-08 offsite pdf