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Strengthening and Streamlining Prudential Bank Supervision Hearing

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Strengthening and Streamlining Prudential Bank Supervision Hearing S. HRG. 111–407 STRENGTHENING AND STREAMLINING PRUDENTIAL BANK SUPERVISION HEARING BEFORE THE COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS UNITED STATES SENATE ONE HUNDRED ELEVENTH CONGRESS FIRST SESSION ON STRENGTHENING AND STREAMLINING PRUDENTIAL BANK SUPER- VISION TO BETTER PROVIDE THE SAFETY, SOUNDNESS, AND STA- BILITY OF THE FINANCIAL MARKETS AUGUST 4 AND SEPTEMBER 29, 2009 Printed for the use of the Committee on Banking, Housing, and Urban Affairs ( Available at: http://www.access.gpo.gov/congress/senate/senate05sh.html U.S. GOVERNMENT PRINTING OFFICE 56–376 PDF WASHINGTON : 2010 For sale by the Superintendent of Documents, U.S. Government Printing Office Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800 Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001 COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS CHRISTOPHER J. DODD, Connecticut, Chairman TIM JOHNSON, South Dakota RICHARD C. SHELBY, Alabama JACK REED, Rhode Island ROBERT F. BENNETT, Utah CHARLES E. SCHUMER, New York JIM BUNNING, Kentucky EVAN BAYH, Indiana MIKE CRAPO, Idaho ROBERT MENENDEZ, New Jersey MEL MARTINEZ, Florida DANIEL K. AKAKA, Hawaii BOB CORKER, Tennessee SHERROD BROWN, Ohio JIM DEMINT, South Carolina JON TESTER, Montana DAVID VITTER, Louisiana HERB KOHL, Wisconsin MIKE JOHANNS, Nebraska MARK R. WARNER, Virginia KAY BAILEY HUTCHISON, Texas JEFF MERKLEY, Oregon JUDD GREGG, New Hampshire MICHAEL F. BENNET, Colorado EDWARD SILVERMAN, Staff Director WILLIAM D. DUHNKE, Republican Staff Director AMY S. FRIEND, Chief Counsel DEAN V. SHAHINIAN, Senior Counsel CHARLES YI, Senior Policy Adviser BRIAN FILIPOWICH, Legislative Assistant DEBORAH KATZ, OCC Detailee MATTHEW GREEN, FDIC Detailee MARK JICKLING, CRS Detailee MARK OESTERLE, Republican Chief Counsel JIM JOHNSON, Republican Counsel ANDREW J. OLMEM, JR., Republican Counsel JEFFERY L. STOLTZFOOS, Republican Counsel HEATH P. TARBERT, Republican Special Counsel CHAD DAVIS, Republican Professional Staff Member DAWN RATLIFF, Chief Clerk DEVIN HARTLEY, Hearing Clerk SHELVIN SIMMONS, IT Director JIM CROWELL, Editor (II) CONTENTS TUESDAY, AUGUST 4, 2009 Page Opening statement of Chairman Dodd .................................................................. 1 Opening statements, comments, or prepared statements of: Senator Johnson Prepared statement ................................................................................... 43 Senator Reed Prepared statement ................................................................................... 43 WITNESSES Sheila C. Bair, Chairman, Federal Deposit Insurance Corporation .................... 2 Prepared statement .......................................................................................... 44 Responses to written questions of: Senator Bunning ....................................................................................... 79 John C. Dugan, Comptroller of the Currency, Office of the Comptroller of the Currency ......................................................................................................... 4 Prepared statement .......................................................................................... 48 Responses to written questions of: Senator Bunning ....................................................................................... 82 Daniel K. Tarullo, Member, Board of Governors of the Federal Reserve System ................................................................................................................... 5 Prepared statement .......................................................................................... 66 Responses to written questions of: Senator Bunning ....................................................................................... 89 John E. Bowman, Acting Director, Office of Thrift Supervision .......................... 7 Prepared statement .......................................................................................... 72 Responses to written questions of: Senator Bunning ....................................................................................... 90 TUESDAY, SEPTEMBER 29, 2009 Opening statement of Chairman Dodd .................................................................. 99 Prepared statement .......................................................................................... 132 WITNESSES Eugene A. Ludwig, Chief Executive Officer, Promontory Financial Group, LLC ........................................................................................................................ 101 Prepared statement .......................................................................................... 132 Martin N. Baily, Senior Fellow, Economic Studies, The Brookings Institution . 104 Prepared statement .......................................................................................... 144 Richard S. Carnell, Associate Professor, Fordham University School of Law .... 107 Prepared statement .......................................................................................... 153 Richard J. Hillman, Managing Director, Financial Markets and Community Investment Team, Government Accountability Office ...................................... 109 Prepared statement .......................................................................................... 159 STRENGTHENING AND STREAMLINING PRUDENTIAL BANK SUPERVISION TUESDAY, AUGUST 4, 2009 U.S. SENATE, COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS, Washington, DC. The Committee met at 9 a.m. in room SD–538, Dirksen Senate Office Building, Senator Christopher J. Dodd (Chairman of the Committee) presiding. OPENING STATEMENT OF CHAIRMAN CHRISTOPHER J. DODD Chairman DODD. The Committee will come to order. Let me wel- come our guests who are in the hearing room this morning, as well as to welcome our very distinguished panel of witnesses, and we thank the four of you and the second panel that is going to come as well. I have informed our colleagues already, those who are here, and others, we are under some time constraints. We have a couple of votes around 10:30 that are coming up on the floor of the Senate. There is a meeting that we are going to have that begins a little after noon that many of us are going to have to attend later. So we are not going to make any opening statements, including the Chairman and the Ranking Member. We have agreed this morning just to get right to our witnesses. I know my colleague from Tennessee would like that precedent, I tell you. He has been dying for that moment for 2 years. [Laughter.] Senator SHELBY. Mr. Chairman, when he was mayor, nobody spoke. Chairman DODD. No, no. Just the mayor spoke. We are not set- ting precedent here, but we are certainly going to, this morning, move in that direction. So let me thank again everyone for being with us this morning. Obviously, strengthening and streamlining prudential bank super- vision is a major subject matter. We have had I do not know how many hearings. What is the number? Twenty-eight hearings since January on this subject matter of financial modernization regula- tions. And, obviously, this is a very critical piece to the extent we are going to have consolidation of our financial regulators. And so I welcome our witnesses here this morning. Many—well, all of you have been before us on numerous occasions to talk about the various aspects of the financial troubles our Nation has been in over the last number of years. And I just want to make one point, and I know all of you at the table pretty well, and I know (1) 2 you understand this because I believe you care about this as well. Our job, obviously, here is not to protect regulators. Our job is, ob- viously, to protect the people who count on us and you and the sys- tem to provide the safety and soundness and the stability of the fi- nancial markets. That is what this is all about. And I know you get that and understand that, but I sometimes think we need to clear the air a little bit to make sure people understand what we are talking about as we describe the structure and the architecture that will provide that sense of stability and safety and soundness that we are looking for. So, with that, let me just turn directly, if I can, to you, Sheila, to start in on this. I will ask you to try and be brief. Again, all the documents and all of my colleagues’ opening statements will be in- cluded in the record at this point here. We will try and be a little more careful on the clock than we might otherwise be because of time constraints. Jim, I am just explaining we have got some votes in an hour and a half or so. We are going to try and move along to the extent pos- sible. Sheila, we thank you again for being with us. STATEMENT OF SHEILA C. BAIR, CHAIRMAN, FEDERAL DEPOSIT INSURANCE CORPORATION Ms. BAIR. Thank you, Senator Dodd, Ranking Member Shelby, and Members of the Committee. Today you have asked us to ad- dress the regulatory consolidation aspects of the Administration’s proposal and whether there should be further consolidation. The yardstick for any reform should be whether it deals with the fundamental causes of the current crisis and helps guard against future crises. Measured by that yardstick, we do not believe the case has been made for regulatory consolidation of State and Fed- eral charters. Among the many causes of the current crisis, the ability to choose between a State and Federal charter was not one of them. As a consequence, we see little benefit to regulatory consolidation and the potential
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