Insights

From charters and customer data to “debanking” and M&A, the rules of competition in banking are shifting fast — and the institutions that adapt early will have the edge.

From charters and customer data to “debanking” and M&A, the rules of competition in banking are shifting fast — and the institutions that adapt early will have the edge.

Who owns bank customers' data? It's a murky legal question, and answering it will determine the relationship between banks and fintechs in a future of open banking, writes Gene Ludwig.

Who owns bank customers' data? It's a murky legal question, and answering it will determine the relationship between banks and fintechs in a future of open banking, writes Gene Ludwig.

From chartering strategies to evolving risk, today’s environment demands more than ambition. Sound regulatory practices and strategic prudence are fast becoming key drivers of long-term success.

From chartering strategies to evolving risk, today’s environment demands more than ambition. Sound regulatory practices and strategic prudence are fast becoming key drivers of long-term success.

For fintechs and crypto firms looking to charter through M&A, acquiring a U.S. bank is more than a growth play—it’s a test of readiness. The real challenge starts well before the charter is granted: demonstrating the capacity to manage risk, meet supervisory expectations, and build lasting credibility in a regulated system.

We could be on the cusp of serious economic instability. Smart bankers should take the time to do a deep dive into the risk profile of their customers, and identify potential trouble spots, writes Gene Ludwig.

We could be on the cusp of serious economic instability. Smart bankers should take the time to do a deep dive into the risk profile of their customers, and identify potential trouble spots, writes Gene Ludwig.

A carefully evaluated growth risk management strategy can help banks seize current expansion opportunities without sacrificing soundness or profitability.

A carefully evaluated growth risk management strategy can help banks seize current expansion opportunities without sacrificing soundness or profitability.

We can’t build sound policy on outdated metrics or regulate the future with rules from the past. As Gene Ludwig explains in Starling's 2025 Compendium, legacy frameworks in economic measurement and financial regulation are falling short. Stability and progress demand modern tools: sound data, smart oversight, and policy built for today’s economy.

We can’t build sound policy on outdated metrics or regulate the future with rules from the past. As Gene Ludwig explains in Starling's 2025 Compendium, legacy frameworks in economic measurement and financial regulation are falling short. Stability and progress demand modern tools: sound data, smart oversight, and policy built for today’s economy.

The United States has benefited from foreign financial institutions investing, lending, and employing at scale within its borders. But a provision in the “Big Beautiful Bill” threatens to reverse that trend.

The United States has benefited from foreign financial institutions investing, lending, and employing at scale within its borders. But a provision in the “Big Beautiful Bill” threatens to reverse that trend.

It is time we work to support institutions in trouble, rather than simply punishing the institutions and the public, writes Gene Ludwig.

It is time we work to support institutions in trouble, rather than simply punishing the institutions and the public, writes Gene Ludwig.

As the public well runs shallower, it is the regulated banking system — with its scale, infrastructure, and community roots — that must dig deeper.

As the public well runs shallower, it is the regulated banking system — with its scale, infrastructure, and community roots — that must dig deeper.

The size definitions used to classify banks are like a suit tailored in a different era. Over time, the financial body has changed but we've failed to alter the suit.

The size definitions used to classify banks are like a suit tailored in a different era. Over time, the financial body has changed but we've failed to alter the suit.

With a new regulatory team emerging under a new administration, the financial industry faces one of those rare windows where meaningful reform is actually possible. We should not let this opportunity slip through the cracks.

With a new regulatory team emerging under a new administration, the financial industry faces one of those rare windows where meaningful reform is actually possible. We should not let this opportunity slip through the cracks.

An administration willing to rethink longstanding regulatory norms could implement targeted reforms that unlock the potential for increased investment, innovation, and job creation across the country.

An administration willing to rethink longstanding regulatory norms could implement targeted reforms that unlock the potential for increased investment, innovation, and job creation across the country.

Regulatory reform in banking has often been compared to moving a giant boulder uphill—slow, cumbersome, and requiring immense coordination. But every so often, the incline flattens just enough to make meaningful progress possible.

Regulatory reform in banking has often been compared to moving a giant boulder uphill—slow, cumbersome, and requiring immense coordination. But every so often, the incline flattens just enough to make meaningful progress possible.

Past efforts to restructure bank supervision have been derailed by politics and agency turf wars. It remains to be seen whether the Trump administration is willing to spend the political capital necessary to see it through, writes Gene Ludwig

Past efforts to restructure bank supervision have been derailed by politics and agency turf wars. It remains to be seen whether the Trump administration is willing to spend the political capital necessary to see it through, writes Gene Ludwig

Washington is awash with talk about how the new Trump administration could upend the United States' bloated and unevenly harsh banking regulation. Banks may now find it easier to merge and to chase new businesses. But large and lasting changes to the landscape and methods of banking supervision in the US won’t be quick or easy.

Washington is awash with talk about how the new Trump administration could upend the United States' bloated and unevenly harsh banking regulation. Banks may now find it easier to merge and to chase new businesses. But large and lasting changes to the landscape and methods of banking supervision in the US won’t be quick or easy.

As bankers know all too well, regulations alone are often too burdensome. But those rules are only the tip of the iceberg. Bank supervision is often the real cause of excess burden.

As bankers know all too well, regulations alone are often too burdensome. But those rules are only the tip of the iceberg. Bank supervision is often the real cause of excess burden.

Modernization of the bank regulatory system is essential, but it is a task that requires precision and the thoughtful application of some basic principles.

Modernization of the bank regulatory system is essential, but it is a task that requires precision and the thoughtful application of some basic principles.

As the regulatory landscape shifts, bank boards can no longer afford to be passive recipients of examiner guidance.

As the regulatory landscape shifts, bank boards can no longer afford to be passive recipients of examiner guidance.

Recent and anticipated departures from key financial regulatory agencies have understandably raised questions about potential major shifts in regulatory priorities. While a deregulatory mood will indeed prevail within both the new administration and the agencies, we predict that, in the end, the change will be less “revolutionary” than “evolutionary.”

Recent and anticipated departures from key financial regulatory agencies have understandably raised questions about potential major shifts in regulatory priorities. While a deregulatory mood will indeed prevail within both the new administration and the agencies, we predict that, in the end, the change will be less “revolutionary” than “evolutionary.”

From formal regulations to non-public enforcement actions, banking supervisors use a variety of tools to communicate their expectations. Drawing from over thirty years of practical experience, James Hilton offers seven tips for navigating the often-complex enforcement process.

Some reforms to the Federal Home Loan Bank System might be necessary, but it would be unwise to eliminate a critical source of funding for banks across the country, write Ludwig Advisors' Eugene Ludwig and James Hilton.

Some reforms to the Federal Home Loan Bank System might be necessary, but it would be unwise to eliminate a critical source of funding for banks across the country, write Ludwig Advisors' Eugene Ludwig and James Hilton.

Like barnacles on a ship, regulations tend to accumulate without being changed or withdrawn until a deliberate effort to upgrade them occurs. Absent such a modernization effort, the sheer volume of regulation doesn’t make the system safer—it weighs it down.

Like barnacles on a ship, regulations tend to accumulate without being changed or withdrawn until a deliberate effort to upgrade them occurs. Absent such a modernization effort, the sheer volume of regulation doesn’t make the system safer—it weighs it down.

If the Trump administration is really planning to trim back regulations on banking and financial services firms, the industry needs to get out in front of the process by identifying necessary reforms, writes Gene Ludwig.

If the Trump administration is really planning to trim back regulations on banking and financial services firms, the industry needs to get out in front of the process by identifying necessary reforms, writes Gene Ludwig.

As the private credit market expands, it raises critical questions about its impact on the broader economy. Can we trust that the lower leverage ratios of private credit funds compared to banks will insulate us from a crisis? Or is this a ticking time bomb waiting to explode?

As the private credit market expands, it raises critical questions about its impact on the broader economy. Can we trust that the lower leverage ratios of private credit funds compared to banks will insulate us from a crisis? Or is this a ticking time bomb waiting to explode?

One wonders if the nonbank financial system, with its limited regulation, could be considered a modern-day "wildcat" system ripe for instability, writes former Comptroller of the Currency Eugene Ludwig.

One wonders if the nonbank financial system, with its limited regulation, could be considered a modern-day "wildcat" system ripe for instability, writes former Comptroller of the Currency Eugene Ludwig.

Despite the anticipation of a new era in banking and regulation post-election, the reality is that the existing systems and bureaucratic machinery are likely to remain largely unchanged.

Despite the anticipation of a new era in banking and regulation post-election, the reality is that the existing systems and bureaucratic machinery are likely to remain largely unchanged.

Two former comptrollers of the currency argue that state-level efforts to regulate nationally chartered banks fly in the face of both the law and good sense.

Two former comptrollers of the currency argue that state-level efforts to regulate nationally chartered banks fly in the face of both the law and good sense.

Effective supervision is a “ground game” that necessitates ongoing interactions between supervisors and banks.

Effective supervision is a “ground game” that necessitates ongoing interactions between supervisors and banks.

Artificial intelligence is poised to become an integral part of the financial system. But, banks must remain vigilant in assessing the potential risks, including the growing threat of cyberattacks. By understanding these risks and taking proactive measures, banks can safeguard their operations and protect their customers' sensitive information.

Artificial intelligence is poised to become an integral part of the financial system. But, banks must remain vigilant in assessing the potential risks, including the growing threat of cyberattacks. By understanding these risks and taking proactive measures, banks can safeguard their operations and protect their customers' sensitive information.

The financial services industry is undergoing rapid transformation. Technological advancements, regulatory shifts, and evolving customer expectations are reshaping the competitive landscape. Data is emerging as a critical differentiator.

The financial services industry is undergoing rapid transformation. Technological advancements, regulatory shifts, and evolving customer expectations are reshaping the competitive landscape. Data is emerging as a critical differentiator.

It has never been more important for banks, particularly those over $10 billion in assets, to establish ironclad data quality, governance, and control standards. Failure to do so will have cascading negative consequences, writes Eugene Ludwig.

It has never been more important for banks, particularly those over $10 billion in assets, to establish ironclad data quality, governance, and control standards. Failure to do so will have cascading negative consequences, writes Eugene Ludwig.

A convergence of factors, including third-party reliance and increasing cloud adoption, has created a complex operational risk landscape. How can banks prioritize third-party management and technology to build a resilient risk management framework that supports long-term success?

The Supreme Court's recent decisions in Loper Bright and Jarkesy have ignited a fierce debate about the balance of power between federal agencies, the judiciary, and banks. By curtailing agency discretion and expanding the scope of jury trials, these rulings mark a significant shift in administrative law.

The Supreme Court's recent decisions in Loper Bright and Jarkesy have ignited a fierce debate about the balance of power between federal agencies, the judiciary, and banks. By curtailing agency discretion and expanding the scope of jury trials, these rulings mark a significant shift in administrative law.

The basics of good banking — a strong balance sheet, customer service and solid risk analysis — will always be important. But in the future, technological competence will be the difference between the sector's winners and losers.

The basics of good banking — a strong balance sheet, customer service and solid risk analysis — will always be important. But in the future, technological competence will be the difference between the sector's winners and losers.

With the line between banks and fintechs growing ever blurrier, financial services supervisors ought to consider adjusting regulation to fit the kinds of activity an institution is engaged in.

With the line between banks and fintechs growing ever blurrier, financial services supervisors ought to consider adjusting regulation to fit the kinds of activity an institution is engaged in.

Can banks and regulators collaborate to create a win-win situation? Can simplifying and focusing regulations create a safer, more-flexible banking system that serves American businesses and consumers more effectively?

Can banks and regulators collaborate to create a win-win situation? Can simplifying and focusing regulations create a safer, more-flexible banking system that serves American businesses and consumers more effectively?

The question is not whether there will be an economic downturn or whether banks will have to manage problem loans and regulatory scrutiny. It's how regulators and banks can do better during the next downturn than they have done in the past.

The question is not whether there will be an economic downturn or whether banks will have to manage problem loans and regulatory scrutiny. It's how regulators and banks can do better during the next downturn than they have done in the past.

Emerging regulatory frameworks, institutional interest, and technological advancements set the stage for a transformative future in the crypto industry

Proposed bank regulations are a key topic in Washington, but recent turmoil at the FDIC and strong industry opposition have slowed their progress. The question remains: will the Fed finalize its "Endgame" proposal before the upcoming elections?

Proposed bank regulations are a key topic in Washington, but recent turmoil at the FDIC and strong industry opposition have slowed their progress. The question remains: will the Fed finalize its "Endgame" proposal before the upcoming elections?

Globalization has made the world smaller. At the same time, it has made consumer lending bigger and far more complex. Gaps in traditional credit reports and increased unpredictability from the diversification of borrowers have complicated many credit decisions and changed the way we think about underwriting models.

Globalization has made the world smaller. At the same time, it has made consumer lending bigger and far more complex. Gaps in traditional credit reports and increased unpredictability from the diversification of borrowers have complicated many credit decisions and changed the way we think about underwriting models.

Many banking organizations need to merge to meet the new tougher regulatory expectations and compete with non-banks. But mergers are now becoming tougher, not easier. Are regulators tilting the playing field so much that healthy market forces will be frustrated to the detriment of sound bank operation?

Many banking organizations need to merge to meet the new tougher regulatory expectations and compete with non-banks. But mergers are now becoming tougher, not easier. Are regulators tilting the playing field so much that healthy market forces will be frustrated to the detriment of sound bank operation?

The removal of preemption would lead to regulatory uncertainty, stifle innovation, and ultimately harm the competitiveness of the U.S. financial system.

The removal of preemption would lead to regulatory uncertainty, stifle innovation, and ultimately harm the competitiveness of the U.S. financial system.

Restrictive regulations may be stifling US FinTech companies, hindering economic growth, and putting American consumers and businesses at a disadvantage. Is it time to rethink the approach?

The ability of the Office of the Comptroller of the Currency to preempt state banking laws on behalf of nationally chartered banks must be preserved, writes former U.S. Comptroller of the Currency Eugene Ludwig.

The ability of the Office of the Comptroller of the Currency to preempt state banking laws on behalf of nationally chartered banks must be preserved, writes former U.S. Comptroller of the Currency Eugene Ludwig.

As January fades and the one-year anniversary of the most-recent banking crisis casts a long shadow, American financial institutions find themselves staring down a turbulent 2024.

As January fades and the one-year anniversary of the most-recent banking crisis casts a long shadow, American financial institutions find themselves staring down a turbulent 2024.

In Part 1, Gene Ludwig unravels the intricate web of factors behind last spring's disastrous bank failures — technological manipulation exploited regulatory gaps, sparking panic and triggering collapse. In Part 2, Gene moves beyond the post-mortem and into proactive defense, taking up the tools to build a financial future more resilient against tomorrow's tremors.

In Part 1, Gene Ludwig unravels the intricate web of factors behind last spring's disastrous bank failures — technological manipulation exploited regulatory gaps, sparking panic and triggering collapse. In Part 2, Gene moves beyond the post-mortem and into proactive defense, taking up the tools to build a financial future more resilient against tomorrow's tremors.

The Spring 2023 bank runs sent shockwaves through the financial system and gave us a terrifying glimpse into a new era of systemic risk. In a new two-part op-ed, Gene Ludwig dissects these novel vulnerabilities, suggesting limitations in our current regulatory framework and outlining steps for a more dynamic and adaptable system.

The Spring 2023 bank runs sent shockwaves through the financial system and gave us a terrifying glimpse into a new era of systemic risk. In a new two-part op-ed, Gene Ludwig dissects these novel vulnerabilities, suggesting limitations in our current regulatory framework and outlining steps for a more dynamic and adaptable system.

The drift from fundamental safety-and-soundness analysis to rigid views of how a bank must be managed, if left unchecked, will contribute to a diminution in the importance of the banking industry in the American financial landscape and a failure to appreciate the vital role banks of different types play in meeting the economic needs of consumers and businesses alike.

The drift from fundamental safety-and-soundness analysis to rigid views of how a bank must be managed, if left unchecked, will contribute to a diminution in the importance of the banking industry in the American financial landscape and a failure to appreciate the vital role banks of different types play in meeting the economic needs of consumers and businesses alike.

We need nuanced regulation and supervisory practices that recognize the distinct qualities of each enterprise being supervised. By doing so, we can preserve one of the special strengths of the U.S. economy.

We need nuanced regulation and supervisory practices that recognize the distinct qualities of each enterprise being supervised. By doing so, we can preserve one of the special strengths of the U.S. economy.

The United States is blessed with banks of all sizes, each tailored to fit the needs of our diverse economy. However, policymakers have come to underappreciate the importance of mid-sized banks to the economy — banks with asset sizes ranging from $10 billion to $700 billion.

The United States is blessed with banks of all sizes, each tailored to fit the needs of our diverse economy. However, policymakers have come to underappreciate the importance of mid-sized banks to the economy — banks with asset sizes ranging from $10 billion to $700 billion.

One of America’s great economic strengths is allowing, if not encouraging, the diversity of American banking. The spring's banking crisis and how it ultimately is dealt with by Congress and regulators could well undermine this structure and with it, large parts of the American economy.

One of America’s great economic strengths is allowing, if not encouraging, the diversity of American banking. The spring's banking crisis and how it ultimately is dealt with by Congress and regulators could well undermine this structure and with it, large parts of the American economy.