Chairman Donald E. Powell
Federal Deposit Insurance Corporation
American Bankers Association Annual Meeting
October 8, 2002
I am glad to be with you here in Phoenix. This is a great setting for your
conference, and a wonderful time of year to be here.
I want to talk to you this morning about changes. About changes in the world
and in the financial services industry, and the need to keep changing ourselves
in order to keep ahead.
A cursory glance of the Fortune 500 in 1982 versus 2002 is revealing. In
1982, seven of the top ten performers were oil companies. Two were automobile
manufacturers and one was a technology company. A simple list that reflected a
In 2002, the list is a lot different. We were down to three "energy"
companies. Two of these, ExxonMobil and ChevronTexaco, are the product of
mega-mergers and are much different firms than their ancestors 20 years ago. The
third energy firm on the list, Enron, is in bankruptcy. Two automobile
manufacturers, Ford and General Motors, remain, as does the technology firm,
IBM. But this years list also includes a financial services giant (Citigroup),
and two highly diversified manufacturer/retailers (General Electric and Phillip
Morris). The top performer? Wal-Mart.
This trend away from established, traditional industries and toward highly
diversified giants with a customer focus was mirrored in the banking industry
over the last 20 years.
Heres what has happened to banking since 1982. Deposit interest rates have
been deregulated. Geographic restrictions have been eliminated. Restrictions on
permissible activities and products have been loosened, as well as restrictions
on bank structure. There were profound advances in telecommunications and
data-processing capabilities that have empowered both banks and their nonbank
competitors. This all resulted in a profound transformation for both the broader
economy and the banking industry.
The numbers tell the story.
Twenty years ago, there were 14,396 insured commercial banks. Today, there
are 7,966 a net reduction of 45 percent. In the past 20 years, there have been
close to 1,500 bank failures and more than 9,100 mergers.
These mergers led to an unprecedented consolidation in the industry, and
resulted in the concentration of industry resources in a few very large and very
complex banking firms. In 1982, the largest commercial bank had total assets of
$118 billion; today, we have eight banks larger than that. In 1982, the ten
largest banking companies controlled about 25 percent of total industry assets.
Today, the ten largest control almost half of the industrys assets. Put another
way, the combined assets of all community banks with less than $1 billion
are exceeded by the combined assets of the three largest institutions in the
Over the past 20 years, weve also seen increased competition from nonbank
competitors for banks business.
First, there has been a dramatic rise in the use of money-market accounts and
mutual funds as a viable destination for the nations savings. In 1980, 93
percent of Americans money was held in insured depository accounts, while
money-market funds and mutual-fund shares accounted for the remaining 7 percent.
By 2001, however, the share held by insured depository institutions had fallen
to approximately 45 percent of the overall total.
And while this was happening, a similar trend was occurring in the credit
markets. In 1980, about 45 percent of all credit-market liabilities were held by
depository institutions. By 2001, this figure had declined to about 25 percent.
During the same timeframe, asset pools, mutual funds, closed-end funds and
money-market funds have seen their share of the credit pie increase from less
than 10 percent to approximately 35 percent.
These figures are impressive and I must confess they sometimes keep me up
at night. Originally conceived as a way around the interest rate restrictions 20
years ago, money market accounts have clearly established themselves in the
marketplace. There are several reasons for this: the technology developed which
made this market possible, the transaction costs were lower than traditional
banking relationships, and the broader marketplace was experiencing substantial
growth. This all led to greater consumer demand and the greater ability, on the
part of some nonbank financial services firms, to meet that demand.
It is important to remember, however, that banks were not entirely left
behind by this shift. A good portion of this transfer of money from demand
deposits to money-market accounts and mutual funds actually occurred
within the banking system. The June 2002 Call Reports, for example,
indicate about one-in-four banks offer these non-traditional products. About
that many also indicated they were using their businesses to sell third-party
investment products. At mid-year, just under 2,000 banks reported income from
investment-banking activities including underwriting, investment advisory, and
merger and acquisition services. The total income from these activities in
commercial banks was $4.697 billion, or 2.3 percent of their net operating
revenue on average. Further, banks first-half 2002 net operating revenue that
came from sales and servicing of mutual funds was about 1.5 percent of their
And many banking companies also sell mutual funds, stocks, bonds, and
annuities outside their commercial bank subsidiaries yet within the holding
company shell. So it appears a good portion of the shift to stocks, mutual funds
and money-market accounts has occurred within (and with the help of) a bank.
This adaptability is heartening. In todays volatile marketplace, you cannot
underestimate the challenge you face from more innovative, less-regulated
competitors who design products strangely similar to what you offer at your
bank. You cannot assume that your proprietary franchise while certainly
valuable and at the center of our countrys financial structure will last
forever in its present form.
The past decade is certainly evidence of that. While this transformation has
changed the industry forever and devastated the best laid plans of many
bankers it brought much needed innovation and vibrancy to many areas of the
Industry assets increased more than three-fold since 1982, to $6.7 trillion.
Capital is up, earnings are at record levels, revenues are more diversified and
less cyclical than at any time in the history of U.S. banking. New
risk-management capabilities allow you to follow your customer to financial
products that better serve their needs. I believe this diversity in the income
stream is one reason financial institutions weathered the recent economic
downturn so well.
Its not just the big, complex banking companies that have benefited from the
changes of the past 20 years. New charters are up: about 15 percent of all
community banks are less than 10 years old one-in-four are less than 20 years
old. And community banks are healthy, too. We at the FDIC see proof of that in
improved CAMELS ratings, better capitalization, less drain on revenue from
loan-loss provisions, and increased noninterest income.
All of these factors indicate an important and continuing role for banks in
But the challenges and the forces of change cannot be ignored. You will
have to continue to adapt and reinvent yourselves to stay ahead of the curve.
Remember: your share of the pie has never been richer but it has never been
Not all the challenges will be long-term. Traditional problems, in the short
term, will still occupy your time. The Comptroller of the Currency, last week,
indicated net interest margins are likely to decline in the third and fourth
quarters of this year. We have been following some deterioration in credit
quality over the past few months. And while the interest margins are favorable
to banks right now, there is some potential for difficulty should the interest
rate environment change.
While the economic situation will likely monopolize your time in the near
term, there are underlying market and technology trends that will continue to
shape the industry and, indeed, test your ability to adapt. Lets look at a few
Gramm-Leach-Bliley is the law of the land, and the affiliations allowed in
that model seem likely to become predominant in the marketplace. While this will
lead to economies of scale that are good, from an economic viewpoint, it will
tend to lead to tremendously complex organizations that could be difficult to
manage in a traditional sense.
Another challenge to the industry comes from nonbank providers of credit,
like credit unions, that have advantages community banks do not have, yet offer
similar products. Pressure also comes from less regulated entities like mortgage
lenders, finance companies and other nonbank providers of credit all of whom
are competing for your traditional customers.
The entrepreneurial bank model is also gaining a larger share of consumer
credit nationwide, without offering anything resembling the traditional customer
relationship. This innovation is not all bad. While these institutions
subprime lenders, credit-card banks are successfully providing access to
credit, and making better use of data to understand customers backgrounds, the
fact is that this model remains largely untested through a full economic cycle.
During the recent downturn, many of these banks did not survive intact. Some
failed. Others had to change their business model or hold more capital and
reserves against the fact that their assets were more risky. In short, the free
market, and our regulatory system, worked. While the problems weve seen have
led to greater regulatory oversight, the fact remains that these institutions
found a new market and found customers willing to buy their product.
There is also a new generation of banking customer coming along that seems to
feel less need to do business with an insured institution. I see this trend
among my friends and associates many of them do not have a traditional banking
relationship. And the demographic data we are looking at seem to suggest that my
friends have plenty of company.
Then there is the issue of risk management. In the past 20 years, we have
moved from transactions with fairly predictable outcomes, to an unpredictable
and often volatile marketplace full of risks that have to be actively managed.
This is true whether you are big or small. But it poses unique problems and
interesting tradeoffs: quantitative versus qualitative decision-making. Credit
scores versus customer relationships. Models versus judgment. Third-party
due-diligence versus a culture of credit inside individual banking
organizations. How you weigh each of these variables and many more we cannot
even anticipate today -- will determine your success in todays marketplace.
So what is my opinion about all this? What do I think should happen? Let me
just say that Im a big fan of the free market. Banks play an essential role in
keeping that market operating. Regulatory interventions should only occur when
they are needed to protect the safety and soundness of the system. So Im not
going to stand here and tell you this or that innovation or structure is any
better or worse than any other. Todays banking model will look very different
ten years from now. The marketplace will ultimately decide the outcome. Our
challenge as regulators is to balance this market-driven evolution with good
policies that ensure we meet our own mission to protect the stability of the
This will not always be easy. There will be inevitable regulatory debates
about how to handle the new ideas, the new structures and the new innovations.
Let me give you an example. We all know we are ultimately going to have to
deal with the question of banking and commerce even though the governor of
California has taken the issue off the table for the time-being. We have heard
from very experienced and thoughtful people about the hazards of this model, but
it is worth noting the FDIC has not traditionally been as opposed as some to the
question of bank ownership by commercial firms.
There are valid criticisms of this model. Those criticisms include questions
about conflicts of interest, about expanding the federal safety-net to the
broader marketplace, and about concentrations of economic power. These are all
important and we should be thoughtful about how we proceed. But the very same
questions can, in many respects, be raised about the financial holding company
model currently enshrined in law and moving toward predominance in the
In our view, Congress has given us good tools to manage the relationship
between parents and insured subsidiaries. These are a great help in preventing
the problems that have been identified with this sort of business arrangement
indeed the FDIC manages these relationships every day in the industrial loan
company model with little or no risk to the deposit insurance funds and no
subsidy transferred to the nonbank parent.
I realize this issue worries many community bankers. In response, I would
simply say that bankers must be nimble, they must innovate, and they must
embrace the possibilities of emerging markets and structures. Those who put
these values into practice will be the survivors in the banking marketplace of
the future not necessarily those who "Just Say No."
The banking and commerce issue is just one example presented to us by the
marketplace where we the regulators are going to have to react. There are
others. Newer, more complex, organizations raise questions about the adequacy of
corporate governance. The complexities of the retail market raise questions
about how to maintain good credit cultures inside the largest banks in the
country. The changing demands of the marketplace raise questions about the
adequacy of our disclosure policy. The dynamic nature of risk management brings
us to the brink of new and profound changes in how we measure and manage capital
adequacy in large institutions. The rapid transfer of customer information
through technology raises questions about privacy, the use of proprietary data
and to what extent the customer relationship should be regulated. The policy
questions raised by the "tying" of banking products and services at the consumer
level. The increasing ties between our banking industry and international arena
raise questions about how we understand and manage risks from far outside our
borders and how we as regulators ensure a level playing field for our domestic
industry. This is not a complete list. I could cite dozens more.
You need to understand these issues in order to stay in business and serve
your customers and your communities. We regulators need to understand them in
order to perform our role of safeguarding the banking system, promoting safety
and soundness, and protecting the integrity of the deposit insurance funds.
Often, from the regulatory perspective, we respond piecemeal as issues arise
and present themselves for decision. I believe we need to undertake a more
thorough and comprehensive review, and to share what we learn with the industry
in a context that is useful and informative.
So I am announcing today that the FDIC will kick off a major study on the
future of banking in America. Over the next year, we will study the underlying
trends in the economy and the industry. We will look at what this suggests for
the future, and identify emerging policy questions likely to confront both
regulators and the industry over the next decade. Ive mentioned some of these
today. Others will present themselves as we proceed with our work. Still others,
like whether we should restructure the federal banking regulators, are already
on the table and the subject of ongoing discussion.
As we work on the study, we will work hard gathering industry input and the
views of the other regulators. And I will share our thinking, from time to time,
as we go along. The last time the FDIC undertook a study of this magnitude was
15 years ago when the Corporation called for many of the legislative changes
that have occurred in the intervening years. Now it is time for the next step,
and I expect this project will set the stage for great things to come.
As Ive said already today, I cannot tell you exactly what the banking
marketplace of the future will look like. But I can assure you it will be
populated with institutions that wisely maintain and use their capital, who are
nimble and responsive to the evolution of the markets, and who cultivate a
culture of execution who believe in getting the job done and upholding
the highest standards of the profession.
It will not be easy. There will be many challenges. But I appreciate what you
do every day to keep our economy operating despite all this. I look forward to
working with you, and hearing your views, as we examine these important issues.
Again, I appreciate the opportunity to speak here today. I encourage you to
call on us whenever we can be of help.