Revolving Door Governance : Bank Supervisors in the United States, 1863-1933

Federal bank supervision began in the United States with the enactment of the National Bank Act in 1863. From that point until the banking crises of the 1930s, the leaders of the US supervisory agencies—the Comptroller of the Currency (1863) and the Federal Reserve (1913)—recognized that bank supervisory work was often a stepping-stone to future careers in banking. As Comptroller D. R. Crissinger wrote in 1922, “The best testimony to the high quality and character of the examining force is found in the fact that the bureau has constant difficulty in retaining the services of its skilled examiners because their special qualifications constantly appeal to the best banks, which are continually drafting them away from the bureau at greatly advanced compensation.” Certainly, as Crissinger recognized, this constituted a loss for supervisory agencies, and Comptrollers and Fed officials used the constant drain of experienced examiners to lobby for better supervisory compensation. Yet, as this paper demonstrates, supervisory leaders also understood this process as a net gain for the banking system, which in the nineteenth and early-twentieth century United States had a proliferation of small, unit banks but few well-trained bankers. Indeed, Comptrollers of the Currency often followed the same path, moving from government service into the management of banks they supervised. Ultimately, the paper argues that US financial supervisors practiced “revolving door governance,” where bank supervisors were able to recruit competent staff at low pay on the promise of future banking careers. Examiners, in turn, brought their knowledge and expertise into the banking system. In this way, the paper suggest that the revolving door in early US financial governance is more akin to regulatory schooling than regulatory capture, thought the lines between legitimate transit and unseemly corruption always remained thin and porous