Our Position

Preserving the Independence of the Federal Banking Agencies and the Dual Banking System

Position

  • ICBA opposes any action that erodes the independence of the federal banking agencies.

  • ICBA supports bipartisan board oversight at the federal banking agencies.

  • ICBA strongly supports the independence of each federal bank supervisor but encourages enhanced and improved cooperation and consultation among the agencies.

  • ICBA supports preservation of the dual banking system which promotes consumer confidence in the banking system and allows for a diversity of financial institutions.

Background

Independence

Bank regulators must be objective, nonpartisan and protected from political influence. Independence prevents the politicization of bank supervision and regulation and avoids politically motivated direction of policies. The independence of the federal banking agencies must be preserved to promote consumer confidence in the banking system, the smooth functioning and safe and sound operation of the banking system, and in turn, the health of the national economy.

Bipartisan Oversight

Bipartisan oversight of the federal financial agencies is an important check-and-balance mechanism that promotes the independence of bank regulators, provides stability between changing political administrations, and prevents frequent, polarizing shifts in regulatory policies. Bipartisan boards encourage robust dialogue, diverse viewpoints, and thoughtful deliberation in policy development, and have been a core tenet of community bank oversight since 1933 when Congress created the FDIC.

Agency Cooperation and Coordination

While regulatory choice is important, interagency cooperation and coordination of efforts among the federal banking agencies is equally necessary. Congress has increasingly directed the agencies to adopt concurrent rules and policies which ensure institutions of similar size and complexity are subject to consistent regulation, regardless of charter.

The Dual Banking System

The dual-banking system is a critical and unique feature of the United States’ banking system that promotes a vibrant and competitive financial services industry and balances national and local interests. The dual-banking system allows banks the freedom to choose a charter, and in turn, select a primary regulator. The dual-banking system must be preserved because it allows for a diversity of financial institutions, accounts for the differences in large and small bank supervision, and promotes a resilient and competitive marketplace.

Staff Contact

Jenna Burke

EVP, General Counsel, Government Relations & Public Policy

ICBA

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