For more than 90 years, the FDIC has been the gold standard in protecting Americans’ savings, the banking system, and the economy from banking crashes and disasters. That’s because it has consistently prioritized its mission of protecting consumers’ money and safeguarding the more than 4,500 banks that are vital to every city and town across America.
Trump’s Acting FDIC Chairman, Travis Hill, has, however, wasted no time in implementing a deregulatory agenda that clearly stacks the deck in favor of Wall Street banks, while endangering the savings accounts of Americans and risking financial stability. Since he became Acting Chair in January 2025, Hill has ignored public comments that disagree with the Trump Administration’s agenda, held secret Board meetings with no public notice or discussions open to the public, and even undermined his own FDIC staff and supervisors, calling into question their judgment and instead siding with the banking industry. At the same time, he has worked to erode the bank capital cushion that protects against bank failures and taxpayer bailouts and rescinded rules that protect consumers. Any one of these actions would be cause for concern from the Senate Banking Committee, but taken together, they are an unmistakable red alert. The American people rely on their Senators to represent them and Main Street’s interests, so we urge them to ask the following questions to Acting Chair Hill.
Questions for Travis Hill
1. Agency Leadership
There is no question that there has been very serious workplace misconduct at the FDIC for a long time and an inexplicable and inexcusable failure of leadership to stop it. Those failures have spanned Republican and Democratic leadership at the FDIC, including Acting Chair Hill, who served on Chairman Jelena McWilliams’ senior leadership team under the first Trump administration in a direct advisory role to McWilliams.
More recently, Acting Chair Hill has led efforts to fire hundreds of FDIC staff, including many of the most senior leaders at the Agency. A report from the FDIC Office of the Inspector General (“OIG”) identifies the brain drain at the agency as one of the top management challenges. Not only has there been a significant loss of leadership capacity at the agency under Acting Chair Hill, but job offers for new bank examiners were rescinded, which will lead to generations of understaffing in the agency’s supervisory ranks.
Question: What role did you play in addressing and preventing sexual harassment at the FDIC after receiving the July 2020 OIG report?
Question: Affinity groups that offer support and belonging to employees and support their professional growth have long been a strength of the FDIC. When you became Acting Chair, what affinity groups existed at the FDIC? How many/what share of staff belonged to one of these groups? We understand that all groups except the Veterans Affinity Group have been disbanded under your leadership since January 2025. How does this support your staff, improve morale, and work to heal a deeply scarred staff?
Question: Being FDIC Chairman requires much more than technical expertise. What experience do you have leading an agency with the size, scope, and geographic spread of the FDIC?
2. Consumer Protection
The FDIC was created primarily to protect consumers and their money. However, many of the actions that Acting Chair Hill has championed since January 2025 have done just the opposite, including:
- Withdrew the Community Reinvestment Act (“CRA”) rule, with no justification except the pending legislation by the banking industry.
- Undermined its gold standard, reputation, and integrity with weaker rules that will make it harder to stop fraudsters and others from misleadingly, if not falsely claiming or suggesting, that money is protected by FDIC insurance. As digital platforms, such as websites and mobile devices, and automated teller machines (“ATMs”) proliferate, so do such false and misleading claims designed to trick people into believing their money is protected by the FDIC when it is not.
- Stopped a rulemaking that would have reduced destabilizing “hot money” movements in and out of banks (called brokered deposit protections). Prioritizing crypto and fintech firms’ profits over depositor and bank protections, the FDIC said the rule “would have significantly disrupted many aspects of the banking landscape.” The rule that Hill stopped would have closed dangerous loopholes that allowed banks to accept hot money deposits, which increases risks and vulnerabilities to bank stability.
Question: How does withdrawing the CRA rule, and rolling back to the 1995 version of the rule, help low- and moderate-income consumers compared to the updated rule?
Question: Why is the FDIC prioritizing banks’ marketing goals and costs over clear signage for consumers?
3. Bank Capital
Bank capital funding is essential because it can be used to make loans while also protecting American families, small businesses, the financial system, and the economy from bank failures, losses, and taxpayer bailouts. Banks with higher capital can continue providing credit through the economic cycle, in both good times and bad, which helps the economy grow, creates jobs, and reduces the depth, length, and cost of recessions. Banks that don’t have enough capital fail in bad times because they are unable to cover their losses. This is exactly what happened with the largest Wall Street banks when loans and risky investments caused huge losses in 2008. The result was bank failures, costly bailouts, and the worst global financial and economic crisis since the Great Depression. The 2008 Crash cost the American people more than $20 trillion, as well as inflicted other serious damage, including high unemployment, lost savings, homelessness, and foreclosures.
Despite clear evidence of the need for higher capital, in 2025 the banking regulators have focused on delivering lower capital requirements for Wall Street banks. In fact, based on Better Markets analysis, recent proposals and upcoming proposals around the capital framework would have a combined effect of slashing more than $200 billion in bank capital and bringing large bank capital to the grossly insufficient levels those banks had before the 2008 Crash.
However, these changes are all being pushed through with record speed and without disclosure to the public of their combined effect. This is despite Acting Chair Hill publicly advocating for “[a]ddressing the issue holistically and transparently.” Now these regulatory heads are using a piecemeal approach to hide their true goal, giving the industry what it wants – the same profit-maximizing capital levels they had before the 2008 Crash.
Question: The wish list of the largest banks on capital requirements has included lowering the enhanced supplementary leverage ratio and watering down the Basel III capital standards. You are pursuing all these efforts. Please explain why you agree with and are seeking to implement every single change on the Wall Street banks’ wish list?
Question: Why do you think it is a good idea for the largest, most complex banks in the country—and the world—to have the same capital levels they had when they caused the 2008 Crash?
4. Bank Merger Policy
Without question, our country benefits from a diversified banking system that includes community banks, regional banks, and large banks. Done right, bank mergers are a healthy part of that system, but done wrong, they can be harmful, costly, and counterproductive for consumers, community banks, and society.
Consolidation in both the number of banks and in products and services has dramatically changed the landscape of the U.S. banking industry, reducing competition, concentrating risks, and increasing financial stability concerns. Currently, megabanks control the U.S. banking system:
- The four largest banks control about 40% of all assets in the banking system.
- The top ten banks hold about half of all deposits and all loans.
- JPMorgan Chase, Goldman Sachs, Bank of America, and Citigroup hold about 90% of the total notional amount of all derivatives contracts held by U.S. banks.
By many measures, consolidation is harmful to consumers and small businesses. For example, large banks offer worse credit card terms and interest rates than small banks and credit unions. A Consumer Financial Protection Bureau (“CFPB”) study showed that the 25 largest credit card issuers charged customers interest rates of 8 to 10 points higher than small- and medium-sized banks and credit unions. This difference equals $400 to $500 in additional annual interest for the average cardholder.
Question: Earlier this year, the FDIC rescinded its merger policy that had been put in place only months before, in September 2024. While the 2024 policy was not perfect, it implemented necessary regulatory procedures to assess whether mergers were in the best interest of consumers, competition, and financial stability. Why did you support rolling back to a policy that does not support the best interests of consumers?
Question: In March 2025, you eliminated the 2024 merger policy with only a 30-day public comment period. This followed years of prudent, judicious, and appropriate analysis that supported strengthening the merger policy in September 2024. Why did you ignore requests from public interest groups and academia (here, here, and here) to extend the comment period to allow appropriate deliberation? Had you already made up your mind to rescind the bank merger policy statement on March 3, 2025, before the public comment period even began?
5. Bank Supervision
One of the most important jobs of the FDIC is bank supervision—regularly evaluating the condition of banks around the country.
All Americans should be alarmed, however, by Acting Chair Hill’s actions that have and will impair the Agency’s supervisors from doing their jobs, including:
- FDIC bank supervisors will no longer identify reputation risk at banks, bending to the demands of the Trump Administrationjust like the Federal Reserve and Office of the Comptroller of the Currency did earlier this year. However, this is pure deception based on fake, trumped-up claims of “debanking.” The Trump Administration and the regulatory agencies claim that the change in supervisory focus will enable fair access for all to the banking industry. But their real goal is to blindfold and handcuff banking supervisors, which will inevitably result in unethical and dangerous actors gaining access to banks for funding.
- FDIC bank supervisors will now be constrained and limited in using Matters Requiring Attention (“MRAs”) to identify, document, and stop dangerous activity at banks. MRAs are used by supervisors as an early-warning system to stop banks’ behavior that could lead to more serious problems later. This system was developed to encourage banks and their supervisors to look for, find, analyze, and mitigate risk, rather than waiting until it grows into a bigger, more serious, more costly, and more dangerous problem.
Question: The FDIC’s decisions put blindfolds on bank supervisors, forcing them to ignore risks and wrongdoing unless the activities affect a bank’s financial condition. Won’t this only increase lawbreaking, victimize investors and depositors, and result in more bank failures and bailouts, opening banks’ doors to sex-traffickers like Jeffrey Epstein, crypto criminals like Changpeng Zhao and Sam Bankman-Fried, and egregiously poor management at Silicon Valley Bank?
Question: You also supported allowing bankers, with no bank supervision experience, to overturn FDIC supervisory decisions. Not only is it a grave mistake to create a structure that will allow banks to undermine your own agency’s supervisory decisions, but it is also a waste of resources to create an entirely new office to do this work. Isn’t it true that there are only between 2 and 4 supervisory appeals each year? Amid the largest job cuts at the FDIC in years, how do you justify creating this new office and hiring more staff?
6. Community Reinvestment
Working Americans are no better off financially today, and in some cases, they are worse off than they were decades ago, despite decades of banks’ claimed focus on community reinvestment.
In 2023, the Agencies finalized a new CRA rule. While not perfect, the 2023 rule took important steps in the right direction to improve community reinvestment activities by banks, and recognized the significant changes in banking since 1995, when the last CRA rule was last updated.
Now, the Agencies have decided to rescind the 2023 final rule, primarily based on the uncertainty that the industry’s litigation has caused. The Agencies also explain that there has been a “change in agency priorities” since the 2023 rule was finalized.
Not only is the decision to rescind the 2023 rule a mistake, but it is also arbitrary and capricious. The Agencies are sweeping aside, without adequate justification, an extensive body of research, data, analysis, and public input that resulted in a strong, affirmative, interagency statement that the 2023 rule would achieve the Agencies’ objectives related to the CRA. In advance of the 2022 proposal and for more than a year between the 2022 proposal and the 2023 final rule, all three Agencies engaged in a thoughtful and thorough review of data, research, and public comments. Based on this data and analysis, they concluded that the 2023 rule rightly encourages “banks to expand access to credit, investment, and banking services in LMI communities;” “adapts to changes in the banking industry, including internet and mobile banking;” and tailors “CRA evaluations and data collection to bank size and type.” Yet now, the Agencies suddenly declare that rescission of the entire 2023 rule is the best course of action, citing merely litigation and regulatory uncertainty facing the banks. The Agencies offer no new data or evidence to rebut their prior empirical analysis or to justify their sharp retreat from their 2023 improvements to the old rule.
Question: How will low- and moderate-income communities be better served by rescinding the CRA compared to the updated rule?
Question: Debanking has also been an area of debate, but you focus on bank accounts that have been closed for “political, social, religious, or other views,” while low-income and underserved communities are not a part of that conversation. Why are you not focused on those communities that have been discriminated against and underserved by banks for generations?
7. Community Banks
Community banks are the bread and butter of the FDIC, and the agency has claimed for decades to be supportive of community banks. However, Acting Chair Hill’s actions show that he has not only been supportive of the largest banks but also, in fact, implemented every piece of the large bank industry agenda. Giving the largest banks more advantages ultimately hurts the ability of community banks to compete and survive.
In the last few months, Acting Chair Hill has worked with the Fed and the OCC to implement the wish list of the largest banks at an incredible pace (the wish list has been publicly stated by the industry’s lobbyists and is linked below). For example, he has advocated for cutting the enhanced supplementary leverage ratio requirements for the largest banks by 15 to 30 percent, which will severely endanger the Deposit Insurance Fund. He has also supported watering down the original Basel Endgame capital requirements.
All these changes will make the already huge advantage large banks have over community banks even bigger. It won’t be an unlevel playing field anymore – community banks won’t even be playing the same ballgame. To prove the point that the regulatory agencies don’t care about true community banks, the OCC changed its definition of community banks to be banks with up to $30 billion in assets. Banks of that size – or anywhere near that size – are not community banks, and it is a clear move by the OCC to move the goalpost and promote more consolidation in the banking sector.
Question: Given all the actions you are taking to favor large banks, how can you say that you are in favor of and working for community banks?
Question: Is your real goal to promote further consolidation in the banking sector and effectively eliminate community banks?
Question: In 2012, the FDIC established a solid definition of what it means to be a community bank, rightly considering many qualitative aspects, beyond just asset size. Each quarter, the FDIC uses this definition to report on the health of community banks in the Quarterly Banking Profile. Do you believe in this definition? Or, do you plan to follow the OCC’s lead and consider all banks with $30 billion in assets or less a community bank?
Question: Community banks account for 70% of all agriculture loans, 36% of all small business loans, and 30% of all commercial real estate loans, all well above their 15% share of total loans. They also approve loans to a broader set of borrowers than large banks through their unique “relationship lending” model. And, importantly, they lend 75 percent of their deposits to the real economy versus only 40 percent of deposits for the largest banks. Shouldn’t the FDIC be doing everything it can to support and grow community banks instead of supporting the largest banks?
8. Crypto
The dangers of cryptocurrency are in the news every day, detailing new risks, new scams, and new illegal activities related to it. Despite most banks—including 90% of community banks—saying they do not currently use crypto and have no plans to start, Acting Chair Hill has been clearing the way to open the banking industry to crypto’s dangers. For example,
- The FDIC, along with the Fed and OCC, rescinded policy statements on crypto, saying that banks should be monitoring and controlling their own risk and essentially saying regulators will clean up the mess after banks, consumers, and the economy are harmed.
- FDIC Acting Chair Hill is working to expand crypto assets into the banking system. For example, he said, “deposits are deposits, regardless of the technology or recordkeeping deployed,” failing to mention the inherent volatility and danger of crypto assets.
- Under Acting Chair Hill’s leadership, the FDIC released formerly confidential documents related to bank crypto-activities and supervisory actions.
Question: The vast majority of banks recognize the risks and dangers of crypto and have made the business decision to steer clear of it. Moreover, most consumers do not hold or use crypto. Why then are you allowing crypto into the banking industry?
9. Resolution Planning
The spring 2023 bank failures demonstrated that banks’ living wills were woefully inadequate, and planning for how to handle large bank failures was a disaster. For example, SVB and First Republic Bank had each filed resolution plans several months ahead of their failures, but the FDIC had not yet reviewed them, even months later, before the banks failed. Important progress was made during 2024, with final rules that require resolution plans and living wills for the largest and systemically important banks. However, as the FDIC admitted in discussions in 2024, the plans made under these new rules have not been tested in a real-life failure of a large bank.
Question: Do you agree that resolution plans for large banks cannot be trusted because they have not been tested in a real-life situation where a large bank has been resolved successfully without significant government support?
Question: Recently, you mentioned wanting to allow more shadow banks to bid on failing banks. However, with shadow banks being unregulated and uncommitted to supporting Main Street America, won’t this just lead to more problems and more consolidation in the banking sector?
10. Corporate Banks (Industrial Loan Companies)
There is a long history in the U.S. of ensuring the separation between banking and commerce, and for good reason. The Bank Holding Company Act, passed in 1956, prohibits bank holding companies from engaging in commercial activities and from controlling (or being controlled by) commercial enterprises. This longstanding policy was specifically designed to prevent the dangers associated with banking and commercial conglomerates, including:
- Excessive concentrations of financial and economic power and political influence;
- Conflicts of interest that would compromise the ability of banks to act as objective providers of credit and other financial services; and
- Heightened risk of contagion between the financial and commercial sectors of our economy, greatly increasing the likelihood of systemic crises that would require huge bailouts to avoid devastating financial, economic, and social consequences.
Simply put, Congress has consistently recognized that commercial enterprises should not benefit from the backstop provided to the tightly-regulated banking system. However, the existence of industrial loan companies (“ILCs” or “corporate banks”) directly contradicts this separation, allowing regular commercial companies to own and operate banks. These corporate banks are allowed to exist because of a little-known loophole that allows corporations not only to own banks but also to do so without the same regulations as “traditional” banks. In other words, this special carveout provides corporate banks with an unfair advantage and increases the type of risks that the separation of commerce and banking seeks to avoid.
Unfortunately, FDIC Acting Chairman Hill is ignoring decades of research and FDIC experience that demonstrate the risks of corporate banks. In July 2025, Hill rescinded a proposed rule that would have taken much-needed action to strengthen regulatory control of corporate banks and protect the financial system. But Hill has gone even further, inviting more corporate banks to open. This invitation led to five applications to open new corporate banks in the first half of 2025 alone, outnumbering the applications for new traditional banks during the same period. This trend contrasts with the 23 applications for new traditional banks received by the FDIC in 2023 and 2024 combined, none of which were corporate banks. This shift should concern all Americans because the FDIC should be supporting community banks and Main Street. Instead, it is disproportionately supporting corporate giants and endangering financial stability.
Question: Why are you working to give large corporations more of a competitive advantage in the financial market?
Question: Why does it make sense to ignore decades of research and experience about the risks of corporate banks and start with a blank sheet of paper?
