In 2009, the Fed granted Section 23A exemptions to the
banking arms of Ally Financial Inc., HSBC Holdings Plc, Fifth
Third Bancorp, ING Groep NV, General Electric Co., Northern
Trust Corp., CIT Group Inc., Morgan Stanley and Goldman Sachs
Group Inc., among others, according to letters posted on the
Fed’s website. The central bank terminated exemptions last year for
retail-banking units of JPMorgan, Citigroup, Barclays Plc, Royal
Bank of Scotland Plc and Deutsche Bank AG. The Fed also ended an
exemption for Bank of America in March 2010 and in September of
that year approved a new one. Section 23A “is among the most important tools that U.S.
bank regulators have to protect the safety and soundness of U.S.
banks,” Scott Alvarez, the Fed’s general counsel, told Congress
in March 2008.