The Fed will start examining nonbank subsidiaries of bank holding companies for compliance with certain consumer-related laws and regulations including, TILA, RESPA, ECOA, FCRA,FDCPA, the consumer leasing act and TISA, among others. For community banking organizations the examinations are slated to be scheduled in the second quarter of 2010. Large banking organizations will be getting an earlier start on examinations.
The Fed anticipates conducting on-site as well as off-site examinations. The exams will be risk-focused and will include on-going monitoring, discovery reviews and, potentially, full-scope examinations with transaction testing and investigation of consumer complaints. No new guidance is currently planned; the Fed will use the existing supervision policies and procedures as a framework for conducting examinations.
You can click this link to view the Fed's notice:
http://www.federalreserve.gov/boarddocs/caletters/2009/0908/caltr0908.htm.
"John Knight is the complete package when it comes to solid advice on all of the challenges and opportunities that our bank faces in today's volatile economy. John's background and experience are renowned. I have always found him to be steady in his demeanor and approach to problem solving and that is a big plus given the current regulatory environment for banking."
-- E. David Locke, Chairman and CEO of McFarland State Bank
"John Knight and the banking group at Boardman are thoroughly knowledgeable on federal and state banking laws and have demonstrated decades of commitment to the sound representation of Wisconsin banks and WBA."
-- Rose Oswald Poels, President & CEO of the Wisconsin Bankers Association