May 04, 2020
The ripple effects of the COVID-19 pandemic are radiating through our lives, coming with wave after wave of impact. We are gradually awakening to a sense of how profound some of these changes may become, especially as secondary and tertiary effects cascade through the system.
The financial industry is at the heart of much of the needed rescue effort. It is also likely to face escalating, novel risks as the economy hits a convulsive contraction.
This realization has inspired us to run a special series of podcasts on how the pandemic may change financial regulation. We’ll be talking with some of the most thoughtful people in the space, including veterans of past crises and, especially, former heads of regulatory agencies.
Today’s show is the first in that series. My guest is Thomas J. Curry, who served as the US Comptroller of the Currency from 2012 to 2017. For listeners outside the United States, the Office of Comptroller of the Currency, or OCC, is the US regulator of nationally-chartered banks.
Tom has served for decades as a leading regulator at both the state and federal levels. He was the Commissioner of Banks for the Commonwealth of Massachusetts under five different governors, and later was a presidentially-appointed member of the board of the Federal Deposit Insurance Corporation. He is now a partner at the Nutter law firm in Boston and, among other things, chairs the Milken Institute’s Fintech Advisory Committee, on which I am privileged to serve as well. Go to the show notes for more information on his very distinguished career
I’m delighted to say that Tom also serves on the board of directors of my nonprofit, the Alliance for Innovative Regulation. My colleagues and I at AIR watched the pandemic morphing from a health crisis into an economic crisis and realized we could help governments and financial companies that were scrambling to scale up the mechanisms needed to rescue small businesses and people unemployed in the crisis. We are running several initiatives, including a series of hackathons and issuance of a Request for Comment on a while paper we call a Regtech Manifesto. I’ll share more on our efforts in another episode in hopes of sparking further ideas and engagement.
The Future of Regulation episodes are shorter than our normal shows. We’ll be posting them quickly to try to match the breathtaking pace of this dynamic environment, in which nothing stays stable from week to week, or even day to day. Our next guest will be another thoughtful former Comptroller of the Currency, Eugene Ludwig.
More on Tom Curry
Thomas J. Curry is a partner in Nutter’s Corporate and Transactions Department and a co-leader of the firm’s Banking and Financial Services group. He is a regulatory attorney who advises clients on a wide range of policy, financial services regulation, governance, and other issues. He chairs the Milken Institute’s Fintech Advisory Committee and is a foundation board member of the newly launched initiative Alliance for Innovative Regulation (AIR), which will help regulators integrate technology into every stratum. Prior to joining Nutter, Tom served as the U.S. Comptroller of the Currency until May 2017. He most recently served as an expert consultant for the International Monetary Fund.
In 2012, Tom was nominated by President Obama and confirmed by the U.S. Senate to serve as Comptroller of the Currency – the head of the Office of the Comptroller of the Currency, the federal agency that charters, regulates, and supervises national banks and federal savings banks. As Comptroller, Tom served as an ex-officio member of the Board of Directors of the Federal Deposit Insurance Corporation and the Financial Stability Oversight Council. He was also a member of the Group of Governors and Heads of Supervision (GHOS), the oversight body of the Basel Committee on Banking Supervision.
Tom also served as Chairman of the Federal Financial Institutions Examination Council (FFIEC) for a two-year term from April 2013 until April 2015.
Before becoming Comptroller in 2012, Tom served as a member of the Board of Directors of the FDIC. He was nominated by President George W. Bush and confirmed by the U.S. Senate in 2003. He continued to serve on the FDIC Board until May 2017.
Prior to joining the FDIC’s Board of Directors, Tom served five Massachusetts Governors as the Commonwealth’s Commissioner of Banks from 1995 to 2003 and from 1990 to 1991. He was appointed by Governor William F. Weld, a Republican, in 1995 and by Governor Michael S. Dukakis, a Democrat, in 1990.
Tom served as the Chairman of the Conference of State Bank Supervisors from 2000 to 2001, and served two terms on the State Liaison Committee of the FFIEC, including a term as Committee chairman.
Previously, Tom served as Acting Commissioner of Banks from February 1994 to June 1995. He previously served as First Deputy Commissioner and Assistant General Counsel within the Massachusetts Division of Banks. Tom entered state government in 1982 as an attorney with the Massachusetts’ Secretary of State’s Office.
Tom was a longtime member of the NeighborWorks America Board of Directors (NWA). He twice served as Chairman of the Board of Directors, most recently from March 2014 through June 2016. NWA is a Congressionally chartered non-profit whose mission is to support affordable housing and community development.
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