cross - function process that is devoted to the identification and analysis of these trends to provide early warnings on emerging consumer problems for our examination team, and enhance our messaging to consumers and nonprofit support organizations. additionally, we are leading a robust and informed dialogue among community and financial industry stakeholders on ways to modernize the 1977 community reinvestment act ( cra ) to reflect changes to the financial landscape and new delivery mechanisms for financial products. how we function the board's division of consumer and community affairs ( dcca ) has primary staff responsibility for carrying out our consumer protection program. but the division draws substantially on resources and expertise from other functions of the board and the federal reserve system. the board's experience is that the most effective programs require a multidisciplinary approach that draws on a deep understanding of consumer behaviors and interests, as well as financial markets and industry operations. recognizing that, key elements of the division's program include : • rulemaking as a pillar of our consumer protection program that utilizes a team of attorneys to write regulations that implement legislation, update regulations, respond to a changing marketplace, put useful and effective disclosures in place, and prohibit unfair and deceptive acts and practices ; • consumer testing to develop effective disclosures that are meaningful to consumers ; • supervision and enforcement of state member banks and bank holding companies and their nonbank affiliates to ensure that consumer protection rules are being followed ; • consumer complaint and inquiry processes to assist consumers in resolving grievances with their financial institutions and to answer their questions ; • consumer education to inform consumers about what they need to know when making decisions about their financial services options ; • research to understand the implications of policy on consumer financial markets ; • outreach to national and local government agencies, consumer and community groups, academia, and industry to gain a broad range of perspectives, and to inform policy decisions and effective practices ; • support for national and local agencies and organizations that work to protect and promote community development and economic empowerment to historically underserved communities. interconnections between consumer protection and prudential supervision as early as the 1970s, the board recognized the need for dedicated experts to conduct consumer compliance examinations. since that time, the board has had a separate examination force, specially trained in the intricacies of consumer compliance laws and regulations. at the same time, there is recognition that consumer protection supervision is connected in important ways to prudential supervision. as a result, the board's separate divisions for consumer protection and prude

of the federal reserve and other federal bank regulators, and consequently, these entities were not subject to examinations to assess see design and testing of effective truth in lending disclosures : findings from qualitative consumer testing research, submitted to the federal reserve board of governors by macro international, inc. ( december 15, 2008 ), and design and testing of effective truth in lending disclosures : findings from experimental study, submitted to the federal reserve board by macro international, inc. ( december 15, 2008 ). compliance with federal consumer protection laws. we believe, therefore, that it is appropriate for congress to consider, as part of regulatory reform, a strengthened supervisory and enforcement scheme, in partnership with state regulators and enforcement officials, for closing the regulatory gap with respect to independent nonbank lenders. recognizing the critical need to conduct on - site reviews of credit practices of nonbank lenders, the board, in july 2007, initiated a multiagency partnership to conduct targeted consumer compliance reviews of selected nonbank lenders that had significant subprime mortgage operations. the joint effort is the first time multiple agencies have collaborated to plan and conduct consumer compliance reviews of independent mortgage lenders and nonbank subsidiaries of bank and thrift holding companies, as well as mortgage brokers doing business with, or working for, these entities. the agencies involved – the federal reserve, the office of thrift supervision ( ots ), the federal trade commission ( ftc ), and state agencies represented by the conference of state bank supervisors and the american association of residential mortgage regulators – developed detailed work plans for the targeted consumer compliance reviews. the pilot program has been completed and the federal reserve is fully committed to implementing its own program of supervision of nonbank subsidiaries of holding companies on an ongoing basis. as with the pilot, we will continue to work cooperatively and share information with other agencies with overlapping jurisdictions. promoting consumer awareness the federal reserve has a long history of providing useful consumer information and promoting awareness of emerging financial market trends and how those trends will affect consumers. our consumer information website ( http : / / www. federalreserve. gov / consumerinfo ) includes 23 consumer topics, providing useful information on bank accounts, consumer credit, and home mortgages. we have also developed calculators to help consumers explore mortgage choices and mortgage financing. we recently launched english and spanish versions of our credit card repayment calculator, which allows consumers to estimate how long it will take to pay off their credit card bills if