Alert September 22, 2009

FRB to Issue Compliance Ratings to Nonbank Subsidiaries of Bank Holding Companies and Foreign Banking Organizations

The FRB established a new Consumer Compliance Supervision Program for nonbank subsidiaries of bank holding companies and foreign banking organizations. The Program will monitor compliance of activities covered by consumer protection laws and regulations, establish a new rating system, and investigate consumer complaints.

The Program formally implements a pilot program that was launched by the FRB in conjunction with the FTC and the OTS in 2007. The pilot program, however, was not as extensive as the Program currently being implemented. Under the Program, the FRB, through targeted and full scope examinations, will compile risk profiles of, and issue compliance ratings to, nonbank subsidiaries. Click here for the FRB’s letter announcing the Program.