John C. Dugan

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John C. Dugan is the 29th Comptroller of the Currency. He took office in August 2005.

The Comptroller of the Currency is the administrator of national banks and chief officer of the Office of the Comptroller of the Currency (OCC). The OCC supervises nearly 1,600 federally chartered commercial banks and about 50 federal branches and agencies of foreign banks in the United States, comprising nearly two-thirds of the assets of the commercial banking system. The Comptroller also is a director of the Federal Deposit Insurance Corporation and NeighborWorks® America.[1]

Record and controversies

Dugan has worked hard to protect banks every step of the way. "WHEN Darrell McGraw, the attorney general of West Virginia, decided to sue Capital One Bank in 2005, alleging credit card abuses, his office expected to face a phalanx of high-priced defense lawyers. What it didn’t expect was that Capital One would get a hand from the federal government. As Mr. McGraw tells it, his legal team was thwarted every step of the way by Capital One and the O.C.C." [2] The New York Times article goes on to say: "For more than a decade, the O.C.C. has beaten back state attorneys general who have tried to enforce state consumer laws against national banks, arguing that federal laws pre-empt those of the states: the O.C.C. has stopped Georgia from enforcing predatory lending laws, intervened in New York’s effort to investigate discriminatory lending and opposed a campaign by New England states to curb gift card fees." [3]

Furthermore, Dugan does not deny the active opposition to states seeking to punish banks. He claims the state actions against banks could "cripple national banking" and have a bad impact on consumers. [4] "Consumer advocates say they remain underwhelmed by Mr. Dugan’s efforts. “It’s hard to get help from an agency that thinks the banks are always right,” said Travis B. Plunkett, legislative director of the Consumer Federation of America." [5]

Financial Reform Involvement

Recently, Dugan has opposed a proposal that limits banks' ability to raise interest rates on existing credit card balances. [6] With respect to reforms at the state level, "he has opposed efforts by state officials who try to crack down on abusive consumer-lending practices, arguing that national banks aren’t in their jurisdiction. At the same time, he rarely imposes serious penalties related to consumer protection, particularly against the big banks." [7]

With regard to Senator Dodd's financial regulation bill, Dugan said the Consumer Financial Protection Agency is too strong. [8] "In every case consumer protection has the edge and will trump safety and soundness and I think that is backwards," said John Dugan, the comptroller of the currency, at an American Bankers Association conference. The comments were unusually forthright from an influential regulator and came amid a surge of lobbying from regulators and banks before next week's mark-up of the bill in the banking committee." [9] Dugan pointed to pre-emption in the bill as a problem, a process by which federal regulators overrule their state counterparts. However, state attorneys-general and some community banks do not agree with Dugan. "At issue is whether consumer protection laws will for the first time be enforced in an effective way," said Tom Miller, the attorney-general of Iowa, who was one of 40 attorneys-general who sent a letter to lawmakers in November urging stronger state oversight. "The question is will senators be on the side of the big banks and give them special protection or on the side of the public?" [10]

Dugan is advocating for the weaker version of the financial bill, the House version. "We had hoped in the Senate the bill would correct and address some of those concerns and in fact lead more toward a place where we have strong uniform standards," Comptroller John Dugan said Wednesday. "Unfortunately, it seems to be a step backward from what the House bill had done." [11]

The Green Book

Dugan directed development of Modernizing the Financial System: Recommendations for Safer, More Competitive Banks, known as The Green Book, a Reagan-era "manifesto for sweeping economic change." According to an article in The Nation[12], " it established him as one of the earliest architects of the "too big to fail" economy."

From The Nation article:

"It was unquestionably the blueprint for the major Clinton-era deregulation," says George Washington University Law School professor Arthur Wilmarth Jr., a longtime banking scholar. "It was the first real recipe for too big to fail."


From The Nation article[13]: " 1993, Dugan took a job as a partner at the Covington & Burling law firm, where he began advising big banks on skirting the very regulations he had been writing for years. A top client was the American Bankers Association, the chief lobby group for the banking industry. One of Dugan's most important assignments was to help the ABA push through Gramm-Leach-Bliley. "ABA helped craft nearly every significant part of the Act that affects the banking industry," Dugan boasted in a 1999 letter to ABA bankers."


“To have a regulator this partial and this helpful to the people he is supposed to regulate is, to say the least, very troubling,” says the Iowa attorney general, Tom Miller, who has tangled with the O.C.C. “It’s a pretty warped view of public responsibility.” [14]

"The time has come for change," Dugan wrote in the Green Book. "Laws must be adapted to permit banks to reclaim the profit opportunities they have lost to changing markets. Where banking organizations have natural expertise in other lines of business, they should be allowed to provide it.... Adapting to market innovation is critical."

“I call them as I see them,” says Mr. Dugan, who plans to step down when his term expires this summer. “I’ve done some unpopular things with the industry on things that they didn’t like. And I have done some unpopular things where people thought I was doing things that were too pro-bank.” [15]

Background info

efore his appointment as Comptroller, Mr. Dugan was a partner at the law firm of Covington & Burling, where he chaired the firm's Financial Institutions Group and specialized in banking and financial institution regulation.

He served at the U.S. Department of the Treasury from 1989 to 1993 and was appointed Assistant Secretary for Domestic Finance in 1992. While at Treasury, Mr. Dugan had extensive responsibility for policy initiatives involving banks and financial institutions, including the savings and loan cleanup, Glass-Steagall and banking reform, and regulation of government-sponsored enterprises. In 1991, he oversaw a comprehensive study of the banking industry that formed the basis for the financial modernization legislation proposed by the administration of the first President Bush.

From 1985 to 1989, Mr. Dugan was Counsel and Minority General Counsel for the U.S. Senate Committee on Banking, Housing, and Urban Affairs. There he advised the committee as it considered the Competitive Equality Banking Act of 1987, the Proxmire Financial Modernization Act of 1988; and the Financial Institutions Reform, Recovery, and Enforcement Act of 1989.

A 1977 University of Michigan graduate with an A.B. in English literature, Mr. Dugan earned his J.D. from Harvard Law School in 1981. Born in Washington, D.C., in 1955, Mr. Dugan lives in Chevy Chase, Maryland, with his wife, Beth, and his two children, Claire and Jack.[16]

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Articles and resources

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See also


  1. From Dugan's OCC biography, accessed February 24, 2010.
  2. Andrew Martin,"Comptroller of Currency Often Sides with Banks, Critics Say,", New York Times, March 26, 2010.
  3. Id.
  4. Id.
  5. Id.
  6. Andrew Martin,"Comptroller of Currency Often Sides with Banks, Critics Say,", New York Times, March 26, 2010.
  7. Andrew Martin,"Comptroller of Currency Often Sides with Banks, Critics Say,", New York Times, March 26, 2010.
  8. Suzanne Kapner,"US Consumer Protection Proposals Attacked,","Financial Times,"March 18, 2010.
  9. Id.
  10. Id.
  11. Cheyenne Hopkins,"Bad to Worse: OCC Sees Flaws in Dodd Reform Bill,","American Banker,"March 18, 2010.
  12. Zach Carter, A Master of Disaster, The Nation, December 16, 2009
  13. Zach Carter, A Master of Disaster, The Nation, December 16, 2009
  14. Andrew Martin"Comptroller of Currency Often Sides with Banks,", New York Times, March 26, 2010.
  15. Andrew Martin"Comptroller of Currency Often Sides with Banks,", New York Times, March 26, 2010.
  16. From Dugan's OCC biography, accessed February 24, 2010.

External resources

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