A federal agency recently investigated instances of unauthorized accounts and other unauthorized services applied to banking consumers, which might have implications for owners of an HSBC bank account. While the regulatory investigation has not yet revealed the specific banks known to have used unauthorized accounts, consumer advocates suspect owners of an HSBC bank account might be affected.

An investigation was launched by the Office of the Comptroller of the Currency (OCC) into the practices of many major banks after it was revealed that employees of Wells Fargo, under pressure from the company to drive sales, were opening bank accounts for customers without getting customer consent. That scheme was widely reported in the news and gave rise to many consumers, including customers at other places like those who held an HSBC bank account, to wonder whether or not any unauthorized actions had been carried out in their name.

The OCC claims to have identified more than 20,000 bad accounts across major banks, although the complete results of that investigation have not yet been revealed, according to a report by the Los Angeles Times. These approximately 20,000 accounts had many different issues, including many that were opened without customers’ authorization.

The Wells Fargo scandal prompted the regulatory review of the nation’s biggest financial institutions after many complaints from consumers alleging that banks were opening unauthorized accounts or providing unauthorized services without the consent or knowledge of the consumer. Opening an account without the customer’s knowledge or consent is a potentially fraudulent act and one that would be shocking for a consumer to discover if that person never gave permission.

Owners of an HSBC bank account could be affected if they did not give their authorization to open an account or to add additional services but discovered it after the fact. The investigatory study carried out by the OCC, which regulates federally chartered banks, looked at practices of more than 40 institutions. The OCC has not announced the names of banks where it found potentially fake accounts.

The agency discovered numerous instances in which banks were not able to show that consumers had authorized individual accounts. A period of three years was included in the investigatory study, and it is expected that a total of more than 500 million accounts were opened at banks during that period. Some of the indications that a bank might not have obtained appropriate consent included no proof of customer authorization or lack of proper disclosure provisions.

The sales practices and review of accounts investigation started in 2016 after a $185 million fine hit Wells Fargo for opening accounts without customers’ authorizations. Employees trying to meet aggressive sales goals might have led to the opening of 3.5 million similar accounts at Wells Fargo.

Bank customers who had another account opened in their name or unauthorized services applied to their account could have grounds to participate in a class action lawsuit investigation. Owners of an HSBC bank account could be included if the agency later releases this data or if more consumers come forward reporting concerns over lack of authorization.