In remarks delivered at the recent Joint European Banking Authority and European Central Bank International Conference, US Acting Comptroller of the Currency Michael Hsu discussed how supervision has evolved in recent decades, and what supervisors can do to remain effective in today's rapidly changing environment.
He highlighted the distinction between supervision and regulation, emphasizing supervision's role in promoting safe practices through ongoing interactions with banks. Hsu likened supervision to a "ground game," where consistent engagement helps banks maintain discipline and improve risk management. He pointed out that recent cyber resilience in the banking sector, as demonstrated during the CrowdStrike incident, was a result of these long-term supervisory efforts.
Hsu described supervision as a "craft," requiring a blend of technical skills, critical thinking, and emotional intelligence. He stressed that supervisors must balance multiple roles, gathering high-quality information from stakeholders and using judgment and discretion to influence banks' behavior. He also acknowledged that supervision often goes unnoticed by the public until a crisis occurs, such as bank failures or compliance breakdowns. This creates an "asymmetry" in perception, where effective supervision prevents crises but receives little recognition.
"This asymmetry can have real impacts on how supervisors do their work," he explained. "When there is a headline-grabbing negative incident—such as a bank failure, compliance or operational breakdown, or violation of law—supervisors understand they may be subject to intense criticism. This can cause them to become unnecessarily cautious, defensive, or to second-guess themselves."
Hsu noted that as banks have grown in size and complexity, supervision must also evolve. He advocated for a more nimble "team-of-teams" approach, particularly for large institutions, to address both traditional financial risks and emerging risks more effectively. "Supervision must be as adept at covering nonfinancial risks as financial risks," Hsu argued. "Trust and confidence in banks and banking are not just about ensuring financial resilience." Changes in the banking system, and the turmoil of spring 2023, may also necessitate a greater focus on "domestic significant banks."
Hsu called for supervisors to operationalize a "risk-based" framework, moving away from what many see as a heavy "check the box" focus in supervision. "The problem with check-the-box supervision is that there are a lot of boxes to check, and each box is given equal weight," he lamented. Under a risk-based framework, supervision is prioritized to focus on the risks that are most critical. Doing so will require that supervisory agencies prioritize agility, learning, and credibility.
"Supervisors are the guardians of trust in banking," Hsu concluded. "This makes bank supervision one of the most important, rewarding, and under-appreciated jobs in finance ... Prioritizing agility and credibility will help ensure that we can continue that well into the future."
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