零售银行业的同步监管建议

© Oliver WymanEXECUTIVE SUMMARY1Werefertotheinstitutionsaffectedbyproposalsas“in-scopebanks”throughoutthedocumentforsimplicityandconsistencypurposes.However,werecognizethereisregulationbeingproposedthatalsoaffectsnon-banks,andtheframeworkcanbeappliedtoanyinstitution.US retail banking is governed by financial regulations designed to improve customeroutcomes, enhance safety and soundness of financial institutions, preserve financialstability, and improve competitiveness across the industry.Regulatory proposals from various agencies, at times, impose requirements that impactbanks in overlapping ways. This is especially true when the regulations try to tackle commonobjectives, sometimes producing complex interactions. While in some cases the impactscan be additive, in other cases one proposal can offset certain costs or benefits of another.In still other cases, the combination of two or more proposals can produce outcomesnot expected from any of them individually. Such interactions can result in unintendedconsequences, which are easier to identify when the full set of relevant proposals areassessed holistically. However, there is no broadly accepted framework that considersthe impact of multiple regulatoryproposals.We aim to address this gap by offering a framework to guide the analysis of aggregatedimpacts from multiple proposals. We focus primarily on the ultimate impact on consumerssince most regulation is intended for their benefit. We approach this topic from threeangles: the direct impact of regulatory requirements, knock-on impact from in-scope banks’adaptation to new requirements,1and further impact from industry evolution.•Direct impact from regulatory requirements.Regulatory proposals will often directlyaffectconsumers’ financial lives by imposing requirements on certain financial productsor services they use, such as by establishing new requirements for customer onboardingor setting price caps for certain fees. Such requirements may directly affect the productsor prices available to consumers, or the process to open accounts and access them,including the information consumers must provide. These changes may also impactcustomer behavior. For example, lower prices on certain product features, like late fees,may incentivize consumers to pay late even more often, since the deterrence factoris smaller.•Impact from banks’ adaptation to new requirements.New regulations can significantlychange the operational requirements, costs, risks, or potential sources of revenue forbanks. As banks adapt their business models accordingly, these adjustments can alsoresult in significant customer impacts. For example, a rule that restricts pricing from aproduct may lead some banks to rethink their pricing strategies to sustain the product’soverall profitability. This may result in higher prices that certain, or all, customers needto pay. Whereas, if a combination of multiple regulations restricts several of the mostpractical sources of revenue for a product, banks might reduce provision of the product,which can have an impact on product availability for consumers. © Oliver Wyman•Impact from industry evolution.While in-scope banks make individual strategic choices,some common themes can emerge — for example, an increase or decrease in productsor services provided to customers by this group. These themes are expected to promptreactions from other providers in retail banking, potentially creating new industry trends.For example, if many in-scope banks decide to stop the provision of a product becauseregulation rendered it uneconomical or too risky, out-of-scope firms may find a sizableexpansion opportunity, changing the mix of providers in the market and affecting thechoices and protections available to consumers.Consumers experience the combined impact from all three of these angles. For example,they may experience differences in pricing, access to products, and the range and natureof product features at their disposal because of the dynamics discussed in the bulletedlist, above. Different customer segments (for example, high-net-worth individuals, smallbusinesses, and low-to moderate income individuals) may experience these shifts tovarious degrees.While it is logical to assess customer impact by stepping through these three angles oneafter another as unique phases, in practice, they sometimes overlap. For example, in-scopebanks will likely consider potential impacts on industry evolution before making their owndecisions. For the sake of simplicity and clarity, we discuss these angles sequentially, but theframework is flexible and can be adapted to more complex analyticalapproaches.As an illustration, this paper offers a stylized application of the framework to thecombination of three major regulatory proposals at the time of writing (early 2024) giventheir common impact on card businesses (credit or debit/checking accounts): The FederalReserve Board’s proposed revisions to Regulation II’s interchange fee cap, the CFPB’sc