Brian P. Brooks Statement on Becoming Acting Comptroller

WASHINGTON—Brian P. Brooks today released the following statement on becoming Acting Comptroller of the Currency.

I am deeply honored to serve my country as Acting Comptroller of the Currency and lead this important and prestigious agency during this challenging time.

Over the past several months, the federal banking system has been integral to the nation’s response to COVID-19. It has been a central means to deliver relief to businesses and consumers and has continued to function admirably under significant stress. Banks and savings associations entered this crisis well positioned to play this important role. They remain a source of strength for the economy and an engine of opportunity.

The nation can rely on the federal banking system due in large part to the 3,600 men and women of the Office of the Comptroller of the Currency who have maintained a flexible regulatory framework in which banks can evolve to meet the needs of their communities; rigorously examined banks to ensure their safe, sound, and fair operation; and when necessary exercised our authority to enforce corrective action.

An agency with a 157-year history understands COVID-19’s seemingly long shadow is temporary. While managing through its effects will take significant focus and effort, we must not lose sight that we aim toward a longer, brighter purpose. We should approach our work not just with an eye to the next year, but to ensure the federal banking system adapts to the changing needs of consumers, markets, and the nation for the next 50 or 100 years.

The agency can take both the long view and meet the challenges facing banks today by focusing on four priorities: 1) build upon responsible innovation to help the banking system keep up with changes in the way American consumers and businesses manage their finances; 2) enhance the strength of the federal banking system by enhancing the scope and relevance of the national charter; 3) ensure banks serve their entire community through fair access to credit, capital, and financial services; and 4) provide OCC employees engaging, rewarding, and challenging career opportunities.

Build upon responsible innovation to help the banking system keep up with changes in the way American consumers and businesses manage their finances

Innovation is a personal passion of mine, and the OCC can build on its foundation of innovation to provide banks and thrifts the regulatory certainty, the flexible framework, and oversight that allows them to evolve and capitalize on technology and innovation to deliver better products and services, to operate more efficiently, and to reduce risk in the system. Some of that work includes defending our authority to issue bank charters that support companies’ ability to engage in the business of banking on a national scale, including taking deposits, lending money, or paying checks. We should support banks’ use of new technology, products, and models that safely and fairly accelerate the velocity of money, create greater financial inclusion, and empower consumers and businesses with more control over their financial affairs.

Enhance the strength of the federal banking system by enhancing the scope and relevance of the national charter

COVID-19 reminded us that challenges facing a nation often rely on a national strategy, response, and capability for our collective good. Lincoln understood this when he created a system of national banks in 1863 to unify our republic, provide for interstate commerce, and solidify a national currency with the country’s full faith and credit behind it. Hamilton understood this, too, although Lin-Manuel Miranda gave it a better melody and educated a generation about the centrality of national banks to the collective prosperity of a nation. Maintaining that system requires vigilance and care, but we also have to remember that we are not curating a history museum—we’re overseeing a system that has to be responsive to the needs of Americans in this generation and the next. As the administrator of the federal banking system we have a responsibility to defend the authority and the powers Congress granted that enable the federal banking system to evolve, to harness the power of rapidly changing technologies and financial markets, to support a nationwide economy, and to serve local needs. We will work to clarify what true lender means, to underscore that the terms of a lawfully made contract remain valid for the duration of that contract even if it is sold by a bank to another investor, and to specify what the parameters of the “fintech charter” and other special purpose charters should be.

Ensure banks serve their entire community through fair access to credit, capital, and financial services

If the first two priorities provide the bedrock on which a federal banking system can thrive, the third priority focuses on why they exist at all—to serve their entire community. Last week, the OCC acted to strengthen Community Reinvestment Act rules which will encourage banks to lend and invest more and to make assessing how well banks serve their entire community more disciplined and consistent.

But there is more to it than that. Section 324 of the Dodd-Frank Act clarifies that the OCC mission includes ensuring “fair access to financial services, and fair treatment of customers by, the institutions and other persons subject to its jurisdiction.” Fair access has come under attack. Whether under the disreputable practice of “Choke Point” or under the guise of reputation risk, we should not tolerate lawful entities being denied access to our federal banking system based on their popularity among a powerful few. That is a dangerous and untenable practice that we will work to correct.

Provide OCC employees engaging, rewarding, and challenging career opportunities

Our success in ensuring banks operate in a safe, sound, and fair manner relies entirely on the men and women who serve the nation examining banks every day to assess their health, promote their compliance with laws and regulations, and provide sage counsel and insight that only the nation’s preeminent prudential supervisor can. It is service at its finest, and I am proud to work alongside such dedicated and professional people. The OCC Executive Committee and I will do everything in our power to provide a world-class place for OCC employees to work that delivers the resources and support necessary to successfully oversee the world’s most respected banking system.

These priorities will guide our effort over the months ahead and will ensure a safe, sound, and fair federal banking system; will help banks better serve the consumers, businesses, and communities that rely upon them, and will promote growth and economic opportunity, particularly for Main Street America.

I congratulate Joseph Otting, the 31st Comptroller of the Currency and my friend, on a successful tour and on the many accomplishments the agency achieved under his stewardship. I am also grateful to Secretary of the Treasury Steven Mnuchin for his leadership and his confidence in giving me this rare and august responsibility.