Have there been regulatory failures involved in the subprime meltdown?
The really abusive, aggressive practices have grown up in the non-federally regulated area. I do think the states are now making a concerted effort to raise the standard so it's similar to the federal standard. Whether that will be adequate by itself, I think, is yet to be seen. I think in the subprime area, right now, frankly, the problem is not about consumers trying to get mortgages now. It's more about consumers who have the loans, and they end up facing a foreclosure situation. We have put standards into place affecting future loans, and I think if the market does come back, there will be an effective way that it will be dealt with at the federal level, and the states are trying hard. Whether that will be enough across the board is what Congress is looking at.
The OCC is not the place most bank customers think of when they need help. Sounds like you're trying to increase the agency's consumer protection profile.
Over time, the consumer protection responsibilities have definitely increased for the OCC because so many retail consumer activities have gravitated to the national banks. If you look at helpwithmybank.gov and our customer assistance group in Houston, we have beefed that up very substantially. I don't think many people know we do as much as we do. People are using [the website]; we've put out public-service announcements. And that's all part of an effort to get more visibility—recognizing, however—and this is an important point—that the first place consumers have to go to try to get their matters resolved is to the bank itself. We can't be the first line of defense to try to resolve disputes. It would just overwhelm the agency. But our role and responsibility will frankly increase over time. And we are committed to providing the resources.
