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State Representation on the FDIC Board
Position Summary
Sometimes legislative history tells a fuller story of a bill’s provisions. In 1996, Congress amended the Federal Deposit Insurance Act (FDI Act) to require that at least one of the FDIC’s three independent directors have state bank supervisory experience. I want to make clear why this requirement can only be met with an individual who has served as a state official responsible for supervising state banks.

Section 2 of the FDI Act requires that the FDIC Board be made up of the following:

  • The Comptroller of the Currency
  • The director of the Consumer Financial Protection Bureau
  • Three other directors (including the chairman and vice chairman), one of whom “shall have state bank supervisory experience.”

The plain language of the law and its legislative history clearly contemplate that one of the directors (not including the Comptroller or the CFPB director) have experience as a state official responsible for supervising state-chartered banks. 

State Representation on the FDIC Board News