A Road Map for Coordinating Federal and State Regulation

May 27, 2014, 5:33 p.m. EDT 1 Min Read

Law and regulation

OCC's Curry Offers 'Blunt' Advice to State Regulators

Comptroller of the Currency Thomas Curry told a room full of state commissioners Wednesday that regulators need to "step up their game" rather than get caught up in competition between state and federal agencies.

By Rachel Witkowski

May 14
Law and regulation

How the OCC Will Change its 'Heightened Expectations' Proposal

The Office of the Comptroller of the Currency is likely to make changes to its proposal outlining the "heightened expectations" the largest banks must face after the industry raised concerns that certain provisions could backfire.

By Rachel Witkowski

April 15
Law and regulation

Examiners-in-Residence Should Be Pulled Out of Megabanks: OCC Report

A team of international regulators delivered a sweeping report on Thursday calling for significant changes to the Office of the Comptroller of the Currency's supervision process, including pulling examiners-in-residence out of the biggest banks and making changes to the bank rating system.

By Rachel Witkowski

December 5

Re: "OCC Curry Offers 'Blunt' Advice to State Regulators" (May 14, 2014)

In his recent speech before the Conference of State Bank Supervisors, Comptroller of the Currency Thomas Curry expressed concerns about the potential lack of adequate funding for state bank regulators and the risk of state regulators becoming too dependent on shared examinations with federal supervisors. His fear is that such a development could result in states ceding responsibility to the federal agencies and thus undermine the very real benefits of our dual banking system. His concern is well founded.

As a former state bank regulator, I strongly agree with Curry's worry that state budgetary constraints or charter conversions can reduce resources available to state agencies. Curry states that if sufficient resources were not available to perform quality oversight when he was a state banking commissioner, he would have "closed up the shop" or sought a regional supervisory compact before ceding authority to federal regulators.

However, state fiscal and budgetary issues are a reality. So is the risk of loss of state assessments due to charter conversions or mergers.

Fortunately, this very concern was addressed in a recent Bipartisan Policy Center report entitled "Dodd-Frank's Missed Opportunity: A Road Map for a More Effective Regulatory Architecture." In the report, co-chaired by myself and Mark Olson, we propose an innovative pilot program that would allow states to participate in a consolidated exam force, giving them more access to federal resources without relinquishing authority to federal regulators. The proposal would preserve the dual banking system while bringing about greater coordination and more efficient use of both state and federal resources.

Richard H. Neiman is co-chair of the regulatory architecture task force within the Bipartisan Policy Center's financial regulatory reform initiative and a former New York State Superintendent of Banks.