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Sergio Correia|Stephan Luck|Emil Verner Supervising Failing BanksSergio Correia, Stephan Luck, and Emil VernerFederal Reserve Bank of New York Staff Reports, no.1168October2025https://doi.org/10.59576/sr.1168 Abstract This paper studies the role of banking supervision in anticipating, monitoring,and disciplining failingbanks. We document that supervisors anticipate most bankfailures with a high degree of accuracy.Supervisors play an important role in requiringtroubled banks to recognize losses, taking enforcementactions, and ultimately closingfailing banks. To establish causality, we exploit exogenous variation insupervisorystrictness during the Global Financial Crisis. Stricter supervision leads to more lossrecognition, reduced dividend payouts, and an increase in the likelihood and speedof closure. Increasedstrictness entails a trade-off between a lower resolution cost tothe FDIC and reduced credit. JEL classification:G01, G21, N20, N24Keywords:banking supervision, financial stability, financial regulation Luck: Federal Reserve Bank of New York (email:stephan.luck@ny.frb.org).Correia: Federal ReserveBank of Richmond (email:sergio.correia@rich.frb.org).Verner:MIT Sloan School of Management andNBER(email:everner@mit.edu).The authors thankRosalind Bennett, Mark Carey, Robert Clark, HarryCooperman, Thomas Eisenbach, João Granja,Yadav Gopalan (discussant), Bev Hirtle, Kathryn Judge,Joe Mason, Matt Plosser, Ben Ranish, Farzad Saidi,Amit Seru,andAdi Sunderam, as well as seminarparticipants at the Federal Reserve Bank of New York, Boardof Governors of the Federal Reserve, FosterSchool of Business at University of Washington, SITE FinancialRegulation, Yale Program on FinancialStability, and UMass Amherst for useful comments.TheythankNatalia Fischl-Lanzoni and TiffanyFermin for excellent research assistance. This paper presents preliminary findings and is being distributed to economists and other interestedreaders solely to stimulate discussion and elicit comments. The views expressed in this paper are those ofthe author(s) and do not necessarily reflect theposition of the Federal Reserve Bank of New York or theFederal Reserve System. Any errors or omissions are the responsibility of the author(s). To view the authors’ disclosure statements, visithttps://www.newyorkfed.org/research/staff_reports/sr1168.html. 1Introduction Banking supervision seeks to safeguard the health of the financial system by monitoringfinancial institutions and enforcing regulatory compliance.1In the U.S., government agen-cies and banks spend considerable resources on bank examinations.2The effectiveness ofbanking supervision, however, is hotly debated. Supervision has been subject to a rangeof critiques, from failing to anticipate bank failures and crises, to delaying the closureof troubled banks, to imposing overly restrictive credit conditions.3Understanding thebenefits and shortcomings of banking supervision is especially important in light ofrecent public discussions about possible reform and consolidation of the U.S. supervisoryand regulatory landscape.4 This paper empirically examines how banking supervision contributes to the financialhealth of the banking system. Our analysis exploits confidential supervisory data coveringall commercial bank examinations in the U.S. between 2000 and 2023. We document thatsupervisors anticipate most bank failures with a high degree of accuracy at short horizons.Supervisors play a significant role in ensuring that banks’ financial statements recognizelosses, that troubled banks are subject to enforcement actions, and that banks that aresufficiently undercapitalized and deemed unviable are closed. To establish the causaleffect of stricter supervision, we analyze a natural experiment during the 2008 GlobalFinancial Crisis (GFC). We find that banks exogenously subject to stricter supervisionduring the GFC recognized more losses, increased retained earnings, weremorelikely to fail, and were closed more quickly. Elevated strictness lowered the cost of failure to theFDIC but also led to reduced credit in the short term. Taken together, our findings suggest that a key role of banking supervision is toanticipate, monitor, and discipline failing banks. In the presence of deposit insurance,banks are insulated from market discipline (Diamond and Rajan, 2001; Calomiris andJaremski, 2019; Cucic et al., 2024). This can allow insolvent banks to operate for longerthan may be optimal. Our findings suggest that supervision can safeguard the health ofthe financial system by leading banks to recognize losses faster and, if necessary, closinginsolvent banks. Timely intervention can reduce the scope for gambling for resurrection,minimize credit misallocation, and reduce the cost of failures (Kareken and Wallace, 1978;Kane, 1989b; Caballero et al., 2008; Blattner et al., 2023). At the same time, our findingssuggest that strict supervision can tighten regulatory capital constraints and reduce creditas a consequenc