As I mentioned, some forms of tying by banks are expressly permitted, and the statute does not apply to tying arrangements imposed by a bank’s nonbank affiliates. Moreover, divining whether a bank imposed a prohibited tie often requires a close review of the facts and circumstances associated with a particular transaction.
Our Financial Literacy program will support this process. We also believe that literacy will encourage more transparency and accountability on policies and fundamentals over which we have control. It will better equip the private sector to ask pointed, relevant questions of policy makers.