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BOARD OF GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

WASHINGTON, D.C. 20551

DIVISION OF SUPERVISION

AND REGULATION

SR 17-13

December 7, 2017

Revised October 1, 2020

Note: On April 1, 2019 the Board approved amendments to Part II of the Payment System Risk 

Policy to remove references to the SOSA ranking for determining a foreign banking 

organization’s (FBO) eligibility for a positive net debit cap, the size of its net debit cap, and its 

eligibility to request a streamlined procedure to obtain maximum daylight overdraft capacity (84 

FR 12049 (April 1, 2019)). The implementation date for these amendments, and the elimination 

of the SOSA from the FBO supervision program, is October 1, 2020. See also the Board’s March 

24, 2020 press release. 

TO THE OFFICER IN CHARGE OF SUPERVISION

 AT EACH FEDERAL RESERVE BANK

SUBJECT: Elimination of the Strength of Support Assessment (SOSA) for all Foreign 

Banking Organizations subject to the Interagency Program for Supervising 

the U.S. Operations of Foreign Banking Organizations

Applicability: This guidance applies to each foreign banking organization (FBO) with a 

banking presence in the United States regardless of size or complexity.

The purpose of this letter is to announce that the Federal Reserve will be eliminating the

Strength of Support Assessment (SOSA), including the assignment of a SOSA ranking, from the 

FBO supervision program.

1

 The decision to eliminate the use of the SOSA recognizes that 

Federal Reserve supervisory staff now have more timely access to a variety of resources for 

information on FBO parent banks, home country accounting practices and financial systems, and 

international supervisory and regulatory developments. Although the SOSA will be eliminated, 

Reserve Bank staff will continue to monitor and assess an FBO parent company and home 

country factors previously summarized in the SOSA documents through other components of the 

FBO supervision program.

 1 FBO supervision program requirements, including the SOSA and the SOSA ranking, are described in the 

Guidelines for Implementing the Interagency Program for Supervising the U.S. Operations of Foreign Banking 

Organizations attached to SR letter 00-14, “Enhancements to the Interagency Program for Supervising the U.S. 

Operations of FBOs.”
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With the elimination of the SOSA, the Federal Reserve is also addressing the use of the 

SOSA ranking by other Federal Reserve functions. Under the current Federal Reserve Policy on 

Payment System Risk (PSR Policy), an FBO’s SOSA ranking can affect its eligibility for a 

positive net debit cap, the size of its net debit cap, and its eligibility to request a streamlined 

procedure to obtain maximum daylight overdraft capacity. The Federal Reserve Board proposed 

changes to the PSR Policy which would eliminate reliance upon the SOSA ranking in these 

matters.

2

 Given the absence of a supervisory need for the SOSA, Federal Reserve supervisory 

staff will cease assigning SOSA rankings on the effective date of a final PSR Policy that does not 

include reliance upon an FBO’s SOSA ranking. When the Federal Reserve Board acts to finalize 

the PSR, supervisory staff will notify affected institutions that the SOSA has been eliminated. 

Reserve Banks are requested to distribute this letter to appropriate supervisory staff and 

to each U.S. banking office and the head office of each FBO for which they have supervisory 

responsibility, as well as to the state bank supervisory authorities in their district. In addition, a 

Reserve Bank that is responsible for an FBO’s U.S. supervisory strategy should distribute this 

letter to the FBO’s home country supervisor. In cases where the responsibilities of SOSA and 

the U.S. supervisory strategy for a particular FBO are divided between the Federal Reserve and 

the Office of the Comptroller and the Currency (OCC), Board staff will coordinate with the 

Reserve Bank staff and OCC staff on communicating this program change to the head office of a 

FBO and its home country supervisor.

Questions about this guidance may be directed to Vaishali Sack, Manager, Supervisory 

Program Development and Analysis section, at (202) 452-5221. In addition, questions may be 

sent via the Board’s public website.3

Michael S. Gibson

Director

Cross reference to:

• SR letter 00-14, “Enhancements to the Interagency Program for Supervising the U.S. 

Operations of FBOs”

 2

Refer to the Board’s press release at: release at:

https://www.federalreserve.gov/newsevents/pressreleases/other20171211a.htm.

3 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.