May 29, 2020

This morning, Brian Brooks is starting his new job as acting Comptroller of the Currency. I’m fortunate to know Brian well, and over the years he and I have spent many hours talking about all the themes that we explore here on Barefoot Innovation. As he takes on his new role, I’m delighted that we were able to sit down together (virtually) and share some of that conversation with you.

Brian came to the OCC from Coinbase. That makes him, in effect, the first fintech Comptroller of the Currency. Before Coinbase he was general counsel of Fannie Mae. Those are two very different kinds of companies, and in today’s show, he tells a story I didn’t know about how he got interested in fintech while he was at Fannie Mae. As you will hear, he has a clear and compelling vision for how technology will, and should, change both financial regulation and banking.

When Brian decided to go to the OCC, he had no way to know that he would be taking its helm amidst an all-out, historically-unprecedented economic crisis. I asked him how he thinks this pandemic will impact bank regulation, short and long term, and I also asked what he hopes to achieve in his role, above and beyond the crisis work.

The common denominator that I hear running through all his plans is technology innovation, both in the national banking system and at the OCC. Our talk ranges from new charters to clarifying powers of national banks, to third party risk management, to the digital dollar, to a project for reviewing every line of OCC rules and guidance to weed out references to old technology like fax machines.

We also cover financial inclusion. He has plans for a further round of rulemaking on the Community Reinvestment Act. He also has ideas for enabling more inclusive loan underwriting by using new data and AI, and he talks about how doing so would require clear regulatory rules of the road on how to prevent illegal disparate impact. My own view is that solving that issue, all by itself, could become the biggest regulatory driver of financial inclusion in memory.

For the OCC internally, Brian also has ambitious plans for innovation in the financial regulatory process itself. They include a bigger role for the Office of Innovation, a shift onto a single supervisory platform, and a clear vision for how technology should, and shouldn’t, change the lives of the OCC’s incredibly talented people.

Our listeners know I’m a former Deputy Comptroller of the Currency. It was exciting to see Brian’s commitment to the traditional strengths of the OCC and the national banking system, and to see the possibilities of building on them with new technology. As I listened to him talk, I could imagine a future in which banking and fintech flow together more, to the benefit of each other, and to the great benefit of their customers in the Digital Age.

At the end of our discussion, I asked Brian to talk about something that I know about him, but that most listeners don’t. I’ll just say, it has to do with music.

More on Brian Brooks

Brian P. Brooks is the Acting Comptroller of the Currency.

He came into this role upon the resignation of the 31st Comptroller of the Currency Joseph M. Otting, due to Mr. Brooks’ designation as First Deputy Comptroller by Treasury Secretary Steven T. Mnuchin pursuant to his authority under 12 USC § 4.

As Acting Comptroller of the Currency, Mr. Brooks is the administrator of the federal banking system and chief officer of the Office of the Comptroller of the Currency (OCC). The OCC supervises nearly 1,200 national banks, federal savings associations, and federal branches and agencies of foreign banks that conduct approximately 70% of all banking business in the United States. The mission of the OCC is to ensure that national banks and federal savings associations operate in a safe and sound manner, provide fair access to financial services, treat customers fairly, and comply with applicable laws and regulations.

The Comptroller also serves as a director of the Federal Deposit Insurance Corporation and a member of the Financial Stability Oversight Council and the Federal Financial Institutions Examination Council.

Prior to becoming Acting Comptroller, Mr. Brooks served as Senior Deputy Comptroller and Chief Operating Officer. In this role, he oversaw OCC bank supervision, bank supervision policy, economics, supervisory system and analytical support, systemic risk identification support and specialty supervision, and innovation. He also served as a member of the OCC’s Executive Committee and was the Chair of the Technology and Systems Subcommittee, since joining the agency in April 2020.

Prior to joining the OCC, Mr. Brooks served as Chief Legal Officer of Coinbase Global, Inc. He headed the legal, compliance, audit, investigations, and government relations functions for the company, which served 20 million customers. He held this position since September 2018.

From 2014-2018, Mr. Brooks served as Executive Vice President, General Counsel, and Corporate Secretary of the $3.2 trillion Fannie Mae. He was previously a Vice Chairman of OneWest Bank, N.A., from 2011 to 2014. Before OneWest, he was managing partner of the Washington, D.C. office of the global law firm O’Melveny & Myers LLP, where he also served as chair of the firm’s financial services practice group.

Prior to joining the OCC, Mr. Brooks also served on the Boards of Directors of Avant, Inc. and Fannie Mae, and also served as an advisor to a number of technology startups.

Mr. Brooks holds a bachelor’s degree in government from Harvard University and a law degree from the University of Chicago.

More for our Listeners.

Don’t forget to follow me on Twitter and LinkedIn.

If you haven’t already done so, listen to my talks with two former Comptrollers of the Currency, Thomas Curry and Eugene Ludwig, in our special series on how the pandemic may impact the Future of Financial Regulation. We also have conversations coming up in the series with Christopher Woolard, interim CEO of the UK Financial Conduct Authority and Jelena McWilliams, Chairman of the FDIC.

The conference schedule is coming back to life through a combination of virtual events and live ones scheduled for fall. I will be speaking at Emerge Live on June 22nd in a panel to discuss the aftermath of COVID-19 and how we can move toward finhealth solutions to help small businesses. Also coming up on July 10th is Finovate Asia, where I will moderate a panel on priorities and concerns in regulating fintech. It is so great to see that technology has allowed these conferences to continue, even if it is virtual. I’m also looking forward to speaking soon to an internal event of the Bermuda Monetary Authority.

LendIt Fintech in New York has been rescheduled for the end of September and I am looking forward to speaking there as well. Later in the year I’ll be at Money 2020 and the Singapore Fintech Festival, one way or the other. And in July, I’ll be participating in the base touch program on the finalists for the G-20 Global Techsprint, for which I will be a judge.

One more note: I had virtual conference events this week in the US, Africa and Asia. At all of them, there was a palpable sense that this pandemic, for all its terrible impacts, is having the positive effect of accelerating digitization in both finance and financial regulation. I have no doubt about it. This world is going to change.

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