In an opinion article published in the American Banker yesterday, Eugene Ludwig, CEO of Ludwig Advisors, argues that regulatory modernization requires precision and thoughtfulness, rather than a broad slashing of regulatory requirements and agencies.
"It is tempting, especially for newcomers, to think modernizing bank oversight is as simple as ripping pages from the Code of Federal Regulation," Ludwig, who served as the US Comptroller of the Currency from 1993 to 1998, writes. “The fleeting sense of euphoria such a simplification might provide to those who have operated under our supervisory system will soon fade, particularly if a financial crisis ensues. And if the missing pages are replaced only by the judgment of agency supervisors, the regulated may even long for the certainty that published regulations once provided.”
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