特朗普2.0——对金融服务的影响

© Oliver WymanHow will financial regulation change under Trump 2.0, and what are some potentialimplications for the financial services industry? This note lays out some initial thoughts andis organized into the followingsections:•The BigPicture•EarlyMoves•Basel IIIEndgame•What’s HighlyProbable?•What’sLikely?•What’sUnlikely?•The Key ConceptualChoices•The Key TechnicalDimensionsTHE BIG PICTUREDeregulation is an important overall theme for President-elect Donald Trump, and this willcertainly extend to financial regulation. While the winds will blow strongly in this directionin Trump’s second term, it’s important to keep in mind that, given all the other importantissues at hand, virtually no president focuses on financial regulation. The exceptions havecome after major financial crises, as former Presidents Barack Obama and Franklin D.Roosevelt faced. Therefore, high-level policy in this area will largely be set by the TreasurySecretary, the Director of the National Economic Council, and possibly some other senioradvisers to the President, including the Vice President. In turn, the President is unlikelyto give great weight to financial regulation when filling these roles. This means that thereis an element of chance as to where they come down on specific approaches to financialregulation within the broader context of an overall push for deregulation. Nevertheless,we anticipate meaningful changes in the operating environment for US financial servicesentities. These changes — alongside a more permissive environment for bank mergers —may prompt a wave of regional bankconsolidation.The choice of individuals for the key regulatory roles themselves will, of course, focus muchmore on financial regulatory issues. Their appointments will begin to give us a clearer idea ofthe specific direction and intensity of deregulation. This matters because “deregulation” cantake many forms, as discussed later in this note, and can be pushed to variousdegrees.There were clearly elements of financial deregulation at play during Trump’s first term, butmost steps were relatively modest. There is a chance that Trump 2.0 will follow the samepath depending on who is appointed, but it seems likely that a substantially bolder approachwill be taken and that there will be a bigger push from the administration. Trump appearsmore focused on his legacy now, including deregulation, and has a more unified teamaround him that no longer includes the types of establishment Republicans who resisted © Oliver Wymanmany of his moves early in Trump 1.0. The election results will almost certainly emboldenTrump, and he is now relatively unconstrained in his ability to have appointees confirmedby the Senate, although extreme choices might still fail to getthrough.There are constraints on financial deregulation that may limit progress under Trump 2.0. First,legislation in this area remains unlikely. Democrats are usually very happy to fight on theseissues, as they believe the public is with them. As long as the Senate retains the filibuster rule,which allows 41 or more senators to block consideration of a piece of legislation, most financialderegulation legislation would be doomed. This is not an absolute barrier. There may be a lawfor which enough Democrats could be persuaded to defect. There are also procedural optionsunder certain circumstances, including attaching the provisions to a larger bill considered onethat must be passed. In practice, though, the filibuster is a formidable obstacle. There is sometalk of removing the filibuster rule, but it seems unlikely during this comingCongress.Second, it is inherently difficult to change supervisory culture and actions at the financialregulators. The incentive structure for supervisors strongly encourages conservatism, sincethey are harshly blamed when things go wrong and receive little reward when they areflexible. They are also aware that Democrats and Republicans tend to differ sharply in theirphilosophies of financial regulation, making them more resistant when there is a change inparty control, since another four years may change thingsagain.Third, Republicans will not have a majority on the Federal Reserve Board until January 2026unless something unexpected happens. Any actions that, in practice, require agreementfrom the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office ofthe Comptroller of the Currency (OCC) could be delayed as a result. Depending on Fed ChairJerome Powell’s views, some of the more aggressive deregulatory steps might not happenuntil he rolls off as Chair in May 2026, given hisinfluence.EARLY MOVESThe Trump administration will likely move quickly to achieve two key objectives: demonstrateits deregulatory intent and establish greater control over the financial regulatory agencies,consistent with an overall administration push to have greater say over regulation inall sectors.Issuance of one or more Executive Orders. Trump 2.0 is likely to follow in the foot