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Thomas Curry
Title: Partner, Financial Services, Nutter
Age: 60
Experience: 31 years
After more than a decade of working in Washington D.C., Thomas Curry is coming back to Boston for good. The former U.S. comptroller of the currency has been hired as a partner at the law firm Nutter to co-lead the financial services practice with his good friend Ken Ehrlich. Prior to his new role, Curry spent his entire illustrious career in the public sector. He was twice the Massachusetts commissioner of banks, first from 1990 to 1991, and then again from 1995 to 2003. George W. Bush nominated Curry to become a member of the board of directors of the FDIC in 2003. He was on the board for eight years before becoming comptroller in 2012 to earlier this year, when President Donald Trump replaced him with Acting Comptroller Keith Noreika
Nutter will be Curry’s first foray into the private sector, but it also presents an opportunity for him to walk to work every day from his home in the North End, as opposed to flying back and forth from Washington D.C. every weekend, which he did for the 13 years he worked there. “I have worked with members of the banking team here as a regulator, and I have the deepest respect for them,” Curry told Banker & Tradesman. “I had been a lawyer earlier in my career. In government, you really need to understand the law to be an effective regulator, so I thought this would be a good fit to join the vibrant banking practice they have here at Nutter, and come back home.”
Q: What were some of the banking issues you worked on at the OCC that you hope to continue to focus on at Nutter?
A: The value of coming to Nutter is really to be able to utilize the experience I have and the counsel – I use the word counsel deliberately – to be able to advise banks of what the underlying policy issues are behind some of the rules and regulations; how to approach some of the strategic issues that banks are facing today.
From a risk management standpoint, one thing I was a strong advocate for was the need for banks to recognize and deal with strategic risks. In today’s environment that means technology and the changing demographics within their customer base. That was the reason I put out a white paper on responsible innovation, did a rethink of how the OCC should approach new ways of doing traditional banking activities and established an Office of Innovation that really ended up being a safe place for both banks and fintech firms. People with ideas could come in and talk about what products they were either interested in as a bank, whether that was by acquiring from a vendor, developing in house or possibly doing a joint venture with a fintech firm.
Q: Why is it important for banks, fintech firms and regulators to collaborate?
A: From a fintech firm’s standpoint, you need to know the environment that your client, vendor or partner operate under, the rules of the road. The Office of Innovation was a way for people who are developing a product to come in during the development phase to get some insight or direction so they avoid ending up with a product that has a flaw built into it. The example I give – this has come up in the past – is a lot of work has been done in trying to assess an individual’s credit worthiness by working on algorithms.
The problem from the regulatory standpoint is that if you use prohibited factors as part of that, you can run into fair lending issues. That has enormous reputational risks from a fintech’s standpoint and regulatory risk from a bank’s standpoint. From a public policy standpoint, there is real value for fintech because it can provide more access to banking services, particularly for people who have been underserved or unbanked.
There could also be issues with the Community Reinvestment Act, in terms of how you transition to a fully electronic world for banking. What happens to brick and mortar branches, particularly if you are in a low- to moderate-income community that relies on a bank for economic or community stability? There are some people who will be left out of the electronic world, whether it’s cost, lack of familiarity or training. If banks offer nearly exclusive electronic banking in the future, how do you make sure people are not left behind? This development has CRA and public policy implications.
Q: Given the timing of your term as comptroller, you had the opportunity to work under both the Obama and Trump administrations. What was the main difference between the two regulatory approaches?
A: I think we have the best financial system in the world, and that includes our bank regulatory structure. The key is that we have independent bank regulatory agencies at both the federal and state level, so the culture at all agencies is to do what is best for the safety and soundness of the system. From a public policy standpoint, who is in elected office really doesn’t affect basic bank supervision. It will have influence in terms of policy changes going forward, but it doesn’t drive the day-to-day core principles of effective supervision from a bank stability standpoint.
It’s interesting – a lot of what I dealt with at the beginning of my career in Massachusetts served me well later on in my career. When I was bank commissioner, way back when the banking crisis occurred in the late 1980s and early 1990s, the Bank of New England had collapsed; in Rhode Island, there had been the collapse of a private deposit insurer which sparked cross border deposit runs here in Massachusetts. We had a local economic depression.
That was useful training and gave me perspective on how to deal with the global financial crisis when I served on the FDIC board during 2007 and 2008. That experience helped me identify the problems and how to deal with some of them. This background also served me well with the implementation of the Dodd-Frank Act and the numerous regulations that accompanied it.
Q: What do you think of the Senate’s recently proposed Dodd-Frank relief bill?
A: One of the big issues with the proposed Dodd-Frank relief bill is the terms of the asset threshold to determine if a bank is a systemically important institution. As I said in Senate testimony I gave earlier in my career, the threshold is not an end-all; it’s really the first screen in determining whether an institution poses a systemic threat or systemic implications. What regulators need is the flexibility to tailor their supervision to risks that an institution faces so an increase, per se, in the asset threshold does not necessarily weaken the system, but bank supervisors need to have the tools to address what those risks are. The bill gives some flexibility to the federal government to enhance prudential supervisory requirements and at the end of the day, that is really the key.
Curry’s Five Things Boston Does Better Than D.C.:
- Pizza
- Football – Patriots over Redskins
- Baseball – Red Sox over Nationals
- Basketball – Celtics over Wizards
- Hockey – Bruins over Capitals
