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CSBS Sets Record Straight on Foreign Bank Supervision

Statement by John W. Ryan, President & CEO, Conference of State Bank Supervisors


I was disappointed to read Comptroller Otting’s recent remarks concerning foreign banking organizations which operate under a state license or charter. To the Comptroller, state-chartered foreign banks that operate on a multistate basis encounter “different entities and regulators [that] add complexity and operating costs and, in my view as a banker, may not be the most efficient approach to conducting banking in the United States."
Contrary to this perception, for decades state regulators have operated under the State Coordination Agreement -- see it here – where foreign banks with multistate operations have a single point of contact among state regulators. That regulator works with the bank and coordinates supervision and examinations with other states. Thus, our approach ensures nationwide coordination, regulatory efficiency, and local accountability.