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- So Much for That Plan
-
- "More than 70% of commercial bank assets are held by organizations that are supervised
- by at least two federal agencies; almost half attract the attention of three or four.
- Banks devote on average about 14% of their non-interest expense to complying with
- rules" (Anonymous 88). A fool can see that government waste has struck again. This
- tangled mess of regulation, among other things, increases costs and diffuses
- accountability for policy actions gone awry. The most effective remedy to correct
- this problem would be to consolidate most of the supervisory responsibilities of the
- regulatory agencies into one agency. This would reduce costs to both the government and
- the banks, and would allow the parts of the agencies not consolidated to concentrate on
- their primary tasks. One such plan was introduced by Treasury Secretary Lloyd Bentsen
- in March of 1994. The plan called for folding, into a new independent federal agency
- (called the Banking Commission), the regulatory portions of the Office of the
- Comptroller of the Currency (OCC), the Federal Reserve Board, the Federal Deposit
- Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS). This plan
- would save the government $150 to $200 million a year. This would also allow the FDIC
- to concentrate on deposit insurance and the Fed to concentrate on monetary policy
- (Anonymous 88). Of course this is Washington, not The Land of Oz, so everyone can't be
- satisfied with this plan. Fed Chairman Alan Greenspan and FDIC Chairman Ricki R.
- Tigert have been vocal opponents of the plan. Greenspan has four major complaints
- about the plan. First, divorced from the banks, the Fed would find it harder to
- forestall and deal with financial crises. Second, monetary policy would suffer because
- the Fed would have less access to review the banks. Thirdly, a supervisor with no
- macroeconomic concerns might be too inclined to discourage banks from taking risks,
- slowing the economy down. Lastly, creating a single regulator would do away with
- important checks and balances, in the process damaging state bank regulation (Anonymous
- 88). To answer these criticisms it is necessary to make clear what the Fed's job is.
- The Fed has three main responsibilities: to ensure financial stability, to implement
- monetary policy, and to oversee a smoothly functioning payments system (delivering
- checks and transferring funds) (Syron 3). The responsibilities of the Fed are linked to
- the banking system. For the Fed to carry out its job it must have detailed knowledge
- of the working of banks and financial markets. Central banks know from the experience
- of financial crises that regulatory and monetary policy directly influence each other.
- For example, a banking crises can disturb monetary policy, discouraging lending and
- destroying consumer confidence, they can also disrupt the ability to make or receive
- payments by check or to transfer funds. It is for these reasons that it is argued that
- the Fed must maintain a regulatory role with banks. The Treasury plan would leave the
- Fed some access to the review of banks. The Fed, which lends through its discount
- window and operates an interbank money transfer system, would have full access to bank
- examination data. Because regulatory policy affects monetary policy and systemic risk,
- it is necessary that the Fed have at least some jurisdiction. The Fed must be able to
- effectively deal with current policy concerns. The Banking Commission would be mainly
- concerned with the safety and stability of the banks. This would encourage
- conservative regulations, and could inhibit economic growth. The Fed clearly has a
- hands on knowledge of the banking system. "The common indicators of monetary policy -
- the monetary aggregates, the federal funds rate, and the growth of loans - are all
- influenced by bank behavior and bank regulation. Understanding changes and taking
- action in a timely fashion can be achieved only by maintaining contact with examiners
- who are directly monitoring banks" (Syron 7). The banking system is what ultimately
- determines monetary policy. It is only common sense to have personnel in the Fed that
- have a better understanding of the system other than just through financial statements
- and examination reports. The Fed also needs the authority to change bank behavior that
- is inconsistent with its established monetary policy and with financial stability.
- This requires both the responsibility for writing the regulations and the
- responsibility for enforcing those regulations through bank supervision. State banking
- charters have already started to be affected. Under the proposed plan, state chartered
- banks would be subject to two regulators. While the federal bank would have only one.
- Thus, making the state bank charter less attractive. However, an increasing number of
- banks are opting for state supervision. It turns out that many banks are afraid of
- losing existing freedoms, or of failing to gain new ones, if supervision is
- centralized. "State regulators have given their banks more freedom than federal ones:
- 17 now permit banks to sell insurance (and five to underwrite it, 23 allow them to
- operate discount stockbrokers and a handful even let them run estate agencies"
- (Anonymous 91). The FDIC has two main criticisms of the Treasury's plan. First, FDIC
- Chairman Tigert believes "that it is very important that there be checks and balances
- in the system going forward" (Cocheo 43). Second, Tigert believes that, since the FDIC
- is the one who writes the checks for bank failures, the FDIC should be allowed to keep
- its independence. It is necessary to maintain the checks and balances of different
- agencies. This separation is necessary because of the differences in examinations of
- the different regulatory agencies with respect to the same institutions. It is
- important "that the independent [deposit] insurer have access to information that's
- available not only through reporting requirements, but also through on-site
- examinations" (Cocheo 43). Tigert explains that the FDIC must keep backup examination
- authority. As well as maintain the ability to conduct on-site examinations of all
- institutions it insures, not just the state-chartered nonmember banks it supervises
- directly. "She agrees with those who say there is no need for duplicative
- examinations, but insists FDIC must be able to look at institutions whose condition or
- activities have changed drastically enough to be of concern to the insurer.
- While consolidation of the bank supervisory process is overdue, issues of bank
- supervision and regulation affect the entire economy. There is no way to tell what is
- in store for banking regulation in the future. It is known, however, that we must
- beware that all the regulatory agencies in place now, are in place for a reason.
- Careful thought and debate must be undertaken before any reform is made. In the end,
- Americans seem no more inclined to tolerate concentration among regulators than they are
- among banks.
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- Works Cited
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- Anonymous. "American Bank Regulation: Four Into One Can Go." The
- Economist 330 (March 5, 1994): 88-91.
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- Cocheo, Steve. "Declaration of Independence." ABA Banking Journal 87
- (February 1995): 43-48.
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- Syron, Richard F. "The Fed Must Continue to Supervise Banks." New England Economic Review
- (January/February 1994): 3-8.
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- Works Consulted
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- Anonymous. "Banking Bill Spells Regulatory Relief." Savings & Community
- Banker 3 (September 1994): 8-9.
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- Broaddus, J. Alfred Jr. "Choices in Banking Policy." Economic Quarterly
- (Federal Reserve Bank of Richmond) 80 (Spring 1994): 1-9.
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- Reinicke, Wolfgang H. "Consolidation of Federal Bank Regulation?" Challenge
- 37 (May/June 1994): 23-29.
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