The Obama Administration’s current financial services regulatory restructuring (RR) proposal includes the streamlining of our regulatory system by the earth-shaking recommendation of combining the Office of Thrift Supervision (OTS) with the Office of the Comptroller of the Currency (OCC), with the OCC as the surviving regulator charged with the regulation of all national banks and federally chartered thrift institutions, leaving the Federal Reserve Board (FED) as the federal regulator of all state “member banks” (i.e., those state-chartered banks that are members of the Federal Reserve System) and the Federal Deposit Insurance Corporation (FDIC) as the federal regulator of all state banks that are FDIC insured but not “member banks”.
While this is certainly a step in the right direction, it misses the opportunity to combine all federal bank regulators into a single federal bank regulator (FBR) which in effect would move the Fed and the FDIC (as well as the OTS) out of the bank regulatory business and reduce the number of our federal bank regulators from four to one.
