WASHINGTON — Enforcement actions by the nation’s three primary federal banking regulators declined over the past decade despite changes in presidential administrations, with the sharpest reduction occurring at the Federal Reserve, according to a new analysis by the Brookings Institution.
The study reviewed public enforcement actions issued by the Federal Reserve, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corp. between 2015 and 2025, spanning both Democratic and Republican administrations.
According to the Brookings analysis, the three agencies collectively averaged 341 enforcement actions annually between 2017 and 2019, compared with 263 per year between 2023 and 2025.
The changes varied by regulator:
- The FDIC’s average annual enforcement actions fell from 168 to 126.
- The OCC’s average increased slightly from 91 to 95.
- The Federal Reserve’s average dropped from 81 to 42.
Brookings researchers Aaron Klein and Michael Connell said the decline at the Fed exceeded 58% since former Federal Reserve Gov. Daniel Tarullo, who served as the central bank’s de facto vice chair for supervision, left the Board of Governors in 2017.
Additional Findings
The researchers examined the enforcement data in the context of a banking industry that has become significantly smaller through consolidation. The number of U.S. banks fell approximately 30% between 2015 and 2025, declining from 6,182 institutions to 4,336, according to the analysis.
During that period, the number of institutions supervised by each regulator also declined:
- The OCC’s supervised institutions fell 36%.
- The FDIC’s declined 31%.
- The Federal Reserve’s dropped 16%.
The researchers said it remains unclear whether the number of supervised banks or the total assets within the banking system is the more appropriate benchmark for evaluating enforcement activity. However, they concluded that adjusting for the number of supervised institutions makes the Fed’s decline appear even more pronounced, while enforcement at the FDIC remains relatively stable and the OCC shows an increase.
Collapse of SVB Examined
The analysis also points to the 2023 collapse of Silicon Valley Bank, which was supervised by the Federal Reserve, as an example of the potential consequences of weak supervision.
Following the bank’s failure, Federal Reserve officials acknowledged that supervisors were slow to identify problems and act. In its own review, the Fed concluded its supervisory approach had been “too deliberative” and overly focused on building consensus before taking action.
Klein and Connell questioned whether that assessment extends beyond the Silicon Valley Bank case.
According to the researchers, either Federal Reserve-supervised institutions have become more compliant than banks overseen by the OCC and FDIC, or the central bank has reduced supervisory enforcement by either declining to elevate problems into formal enforcement actions or failing to identify issues requiring action.
Fed Move is Questioned
The researchers also questioned the Federal Reserve’s recent move toward new supervisory principles that they said appear to raise the threshold for enforcement actions while encouraging examiners to give greater weight to banks’ own assessments of whether deficiencies have been corrected.
Brookings noted that relatively little data are yet available from regulators appointed during President Donald Trump’s second term. However, the researchers said the trends identified in the study appear to be continuing.
The findings also challenge the view that financial regulation fluctuates significantly depending on which political party controls the White House, according to the analysis.
“This data cuts against the common narrative that financial regulation is like a pendulum, swinging up in times of Democratic administrations and down in times of Republican ones,” Klein and Connell wrote. “While there is a change in pattern, it is more akin to a ratchet-level phenomenon whereby the decline in regulation under the first Trump term levels off under Biden.”
