John Dugan led the OCC as U.S. comptroller of the currency from 2005 to 2010. He is currently chair of Citigroup Inc. He is a former chair of the bank regulatory practice at the law firm Covington & Burling.
Two former comptrollers of the currency argue that state-level efforts to regulate nationally chartered banks fly in the face of both the law and good sense, threatening to take the country back to the era of "wildcat" banking.
Banking officials can reasonably disagree on new standards for current expected credit losses, but the accounting body developed the rules over many years and based them on extensive feedback.