From the Glass-Steagall Act of 1933 to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the U.S. banking regulatory environment has been a legal and compliance cacophony.
Since the United States has a dual banking system—banks are federally or state chartered—banking supervision is widespread and extensive. The Office of the Comptroller of Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System are just some of the parties involved with bank administration at the federal level. Furthermore, as promoted by Dodd-Frank, the Financial Stability Oversight Council (FSOC) was fashioned as an additional monitoring agency to oversee the aforementioned primary federal banking regulators.
In addition to these primary federal regulators, there are many state banking boards and commissions that oversee the nation’s banks. Here is an additional short list of agencies and monitoring bodies that supervise depository institutions and financial services firms:
• Consumer Financial Protection Bureau
• The Office of Foreign Assets Control
• The Financial Crimes Enforcement Network
• The Department of Justice
• The Securities and Exchange Commission
• The Commodity Futures Trading Commission
• The Financial Industry Regulatory Authority
Before you start thinking there is no need for the Commodity Futures Trading Commission to regulate the bank where you make your deposits, think again. Banks cannot pick and choose how they’re regulated. To stay profitable and viable in the marketplace, banks are trying to maintain the most profitable client relationships. So they are moving out of relationships that are less profitable and holding on to relationships they wouldn’t want to see go to a competitor.
Why does all this matter to you?
It matters because your relationship with your bank doesn’t exist in a vacuum. Your depository institution must comply with most, if not all, of these regulatory agencies. My message to you is simple: Talk with your banker.
Explore new banking services that can help maintain the bank’s appetite for your business. Perform a proper liquidity analysis to identify the difference between the low- and non-performing dollars that are dormant in deposit at your bank and the transactional dollars that you need for operational purposes. Look at the banking services your entity is currently using (or not using) and perform a cost-benefit analysis on your treasury services to see how beneficial they are to your bottom line. How has your entity changed the way it does its banking to stay ahead of the ever-changing banking dynamic? In short, what impacts your bank will impact your banking relationship.
three+one is here to help you in performing the liquidity and cost-benefit analyses you need to improve your banking relationships.
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See Us At These Upcoming Events and Conferences:
Ohio GFOA – September
GFOA SC – October
PA GFOA – October