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What Falling Enforcement Numbers Don’t Tell You
Enforcement Lyndon Nelson Enforcement Lyndon Nelson

What Falling Enforcement Numbers Don’t Tell You

Bank enforcement is falling across every US regulator. The natural reading is that supervision has gone soft.

A new Brookings dataset (2015–2025) shows enforcement actions down sharply at the Fed, moderately at the FDIC, roughly flat at the OCC — regardless of which party held the White House. But a single falling number can't tell you why.

Run a simple exercise: fifty enforcement cases, five banks, ten types of misconduct, every case worth pursuing, resources for fifteen. Which fifteen?

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