I am not clear on this either, found the following out on the web, but if that is true why does the FR say specifically say it will have not unique impact on $10 billion or less??? Would someone who is smarter please set us straight?
Several federal agencies have authority over entities in the financial services marketplace. The FTC has broad jurisdiction over nonbank financial companies, including nonbank mortgage companies, mortgage brokers, finance companies, and units of bank holding companies. The FTC Act and the other statutes that the FTC enforces specifically exempt banks, savings and loan institutions, and federal credit unions from the agency’s jurisdiction.