fresh voices from the front lines of change







The Office of the Comptroller of the Currency (OCC) is the top bank regulatory agency in the United States. It oversees the largest banks in the country, and completely failed to regulate them effectively in the years leading up to the Great Financial Crash of 2008. Its banks ultimately needed hundreds of billions in bailout dollars to stay alive, an economic embarrassment that could have been avoided had the OCC simply done its job. Still worse, over the course of the housing bubble, the OCC actively attacked other bank regulators at the state level to prevent them from enforcing predatory lending laws. On April 8, Comptroller of the Currency John Dugan and his predecessor John Hawke will testify before the Financial Crisis Inquiry Commission. Here are 10 questions the Commission should ask Dugan and Hawke about their roles in the financial crisis:

1. Prior to taking up his job as Comptroller, Dugan worked as a major lobbyist for the banking industry. What clients did Dugan lobby for prior to becoming their chief regulator?

2. How much money did Dugan make as a bank lobbyist?

3. Why is Dugan continuing to receive lobbying talking points from bank executives in secret?

4. As a lobbyist, Dugan helped push through some of the most radical deregulatory legislation in history. Given the severity of the recent financial crisis, does he regret any of those actions?

5. What job will Dugan seek when his term as Comptroller ends in August?

6. How much bailout money did OCC-regulated banks receive? Please include sums received under the Troubled Asset Relief Program and the Temporary Liquidity Guarantee Program.

7. Why did the OCC, under both Hawke and Dugan, sue state regulators to prevent them from enforcing predatory lending laws?

8. The OCC joined the bank lobby in the lawsuit against state regulators. Is it appropriate for a regulator to team up with the lobbying arms of the banks it oversees?

9. The OCC is pushing hard against President Barack Obama’s proposal to create a new Consumer Financial Protection Agency that would have authority to write and enforce consumer protection regulations. Given the OCC’s record of actively weakening consumer protection rules during the housing bubble, why does the OCC believe it should continue to have authority over consumer abuses?

10. What was the single biggest mistake the OCC made in the years leading up to the crash?

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