Board of Governors of the Federal Reserve System

In 2023, the Board issued a unanimous policy statement on Section 9(13) of the Federal Reserve Act, affirming its policy position that the same bank activity, presenting the same risks, should be subject to the same regulatory framework. As noted in the statement, this principle of equal treatment helps to level the competitive playing field among banks with different charters and different federal supervisors, mitigating the risks of regulatory arbitrage. This principle continues to hold true today. Therefore, I cannot agree to rescind the current policy statement and adopt a new one that would, in effect, encourage regulatory arbitrage, undermine a level playing field, and promote incentives misaligned with maintaining financial stability. I dissent.