Keep Calm and Carry On

There’s a lot of change going on right now, in every aspect of our lives. Uncertainty abounds – from the broader geopolitical landscape to our government’s internal upheaval, and there is a pervasive uneasiness about how all of these changes will impact our day-to-day lives. How do we make sense of it all?

Let’s consider what we have heard about the prospect of a consolidation of the Consumer Financial Protection Bureau (CFPB) and Federal Deposit Insurance Corporation (FDIC) within the Office of Comptroller Currency (OCC). This comes from a Wall Street Journal article about discussions at the White House to merge the FDIC and OCC, and a Bloomberg Law article revealing that there are email address lists being developed at the OCC for transferees from the CFPB and FDIC. This is starting to feel very similar to a corporate merger or acquisition.

When it comes to mergers and acquisitions (M&A’s), employees and customers can experience a range of emotions, including anxiety, fear, excitement, anger, and sometimes even relief, depending on their role, the stage of the process, and the perceived impact on their job security and corporate culture. Layoffs, including mass layoffs, are often an unavoidable and painful element of M&As. Without open communication, employee engagement and empathetic leadership, it’s understandable that there is a lot of apprehension about potential changes.

In most M&A’s, there is also a special consideration, or at least a good-faith attempt, to integrate culture. Unfortunately, in this instance, there seems to be a purposeful intent to replace culture, especially in consideration of the recent Executive Order curtailing the independence of regulators for the stated goal of improving the administration of the executive branch and increasing the regulators’ accountability to the American people.

What can we do in light of this massive change and uncertainty, where the “how” in execution is less than graceful? In the words of the British Ministry of Information during World War II, often attributable to Winston Churchill, “keep calm and carry on” seems like sound advice.

What could this slogan mean for us in our current circumstance? Initially, in your own personal day-to-day, take care of yourself and those around you, and that includes acknowledging all of the different emotions that you are feeling. At work, continue attending to all of your compliance obligations and functions as normal. For example, as of this date, the CFPB portal is still working, so be sure to resolve any errors and file your Home Mortgage Disclosure Act (HMDA) data on time, by March 3, 2025. (March 1, the typical due date, falls on a Saturday this year.)

Did you see the OCC Enforcement Actions issued for February 2025 in News Release 2025 - 12? Clearly, we can expect that supervision, exams and enforcement actions will be continuing, now and into the future.

The short-term challenges we are currently experiencing should hopefully result in long-term benefits, such as cost savings, reduced redundancies and increased efficiencies across banking regulators. Consider, for example, how long we have been trying to get all of the regulatory agencies to agree on a uniform approach to the Community Reinvestment Act (CRA). Ultimately, it may be good for the financial services industry to enjoy consistency, such as one uniform exam manual to standardize the interpretation and application of laws and regulations. It’s unfortunate that the path there is clunky and inelegant. In the interim, keep calm and carry on!