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- Banking
- 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.
- <br><br><b>Bibliography</b><br><br>
- Anonymous. American Bank Regulation: Four Into One Can Go. The
- Economist 330 (March 5, 1994): 88-91.
- Cocheo, Steve. Declaration of Independence. ABA Banking Journal 87
- (February 1995): 43-48.
- Syron, Richard F. The Fed Must Continue to Supervise Banks. New
- England Economic Review (January/February 1994): 3-8.
- Works Consulted
- Anonymous. Banking Bill Spells Regulatory Relief. Savings & Community
- Banker 3 (September 1994): 8-9.
- Broaddus, J. Alfred Jr. Choices in Banking Policy. Economic Quarterly
- (Federal Reserve Bank of Richmond) 80 (Spring 1994): 1-9.
- Reinicke, Wolfgang H. Consolidation of Federal Bank Regulation?
- Challenge 37 (May/June 1994): 23-29.
- <br><br>
- Words: 1210
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