Tara Sugiyama Potashnik, an associate with Venable LLP, provided
assistance with this Paper.
Observations from a Former Financial Regulator on the Need for
Diversity and Innovation in the Provision of Third-Party Credit
Scores
Introduction
During the years leading to the Financial Crisis of 2008 and its
fallout, I was uniquely positioned to observe (and in some cases,
respond to) the unfolding of the many challenges that the crisis
presented. At the height of this tumultuous period, I was serving
as the Chief Counsel, and later as the Acting Director, of the
Office of Thrift Supervision (OTS). Additionally, I served as a
board member of the Federal Deposit Insurance Corporation (FDIC)
and NeighborWorks America, as well as a member of the Federal
Financial Institutions Examination Council (FFIEC). Prior to that
time, I had also dedicated much of my career to government finance
and the financial services sector, serving as a senior career
employee focusing on
