I have been part of the banking industry since 1982, seeing it
from the vantage point of regulator, attorney, and director. Over
that period of time, the industry has experienced the S&L
debacle and agricultural crisis of the '80s, the privacy
concerns of the '90s, 9/11, and the recent recession and
subsequent recovery. Congress reacted to each of these with major
legislation—FIRREA, FDICIA, GLBA, the Patriot Act, and
Dodd-Frank.
Bankers ask me how I would describe the current environment, and
the words that most often come to mind are "sea change."
Unlike the past, this change has not been driven by a major new
piece of legislation or the repeal of Dodd-Frank (although as I
write, legislation is pending and will likely come next). Rather,
it has come from leadership changes at bank regulatory agencies.
Change is occurring based on how those in leadership positions in
the agencies are choosing to interpret, apply, and enforce the
law.
