BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551
DIVISION OF CONSUMER
AND COMMUNITY AFFAIRS
CA 04-10
October 29, 2004
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS:
SUBJECT: Updated Regulation Risk Table
Attached is an updated Regulation Risk Table (22 KB PDF) , which reflects recent changes in the risk rating associated with two of our consumer protection regulations, Regulation CC and Regulation P. Reserve Bank staff should begin using this revised Regulation Risk Table with examinations commencing on or after November 1, 2004 .
Because subpart D of Regulation CC implements new compliance requirements for state member banks that can result in financial liability if performed incorrectly, the revised Regulation Risk Table reflects the risk to the bank of noncompliance with this new subpart. While the portions of Regulation CC that pertain to the Expedited Funds Availability Act (subpart B) remain at a risk level 2, the newer provisions of subpart D, which address the provisions of the Check 21 Act, are assigned a risk level 4.
The attached Regulation Risk Table also reflects a change to the regulation risk assigned to Regulation P. Due to the Federal Reserve System's experience examining for the provisions of Regulation P, which has revealed that few member banks are sharing customers' nonpublic personal information and has identified limited numbers of violations, Regulation P has been assigned a risk level 2.
Questions on the updated Regulation Risk Table should be referred to the Oversight Review Examiner assigned to your district.
Sincerely,
(signed)
Shawn McNulty
Associate Director