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February 9, 2024

FDIC’s Proposal to Improve Banks’ Governance and Risk Management Will Help Prevent Failures and Crashes that Devastate Main Street

WASHINGTON, D.C.— Dennis M. Kelleher, Co-Founder, President, and CEO, issued the following statement on the filing of Better Markets’ Comment Letter to the Federal Deposit Insurance Corporation (FDIC), urging them to adopt improved and enforceable guidelines for corporate governance and risk management structures for the largest banks.

“Unlike most other corporations, the consequences of large banks being poorly run can be catastrophic to innocent hardworking Americans. To avoid that, bank boards of directors are charged with ensuring that banks have robust risk management and internal control frameworks, and effectively overseeing senior management. Unfortunately, those bank boards all failed miserably in 2008, as did the bank boards involved in the 2023 banking crisis, and that contributed significantly to the banking crises, which both times lead to contagion and bailouts.  These crises once again demonstrated how inadequate corporate governance is and how much it needs to be strengthened.

“The FDIC’s proposal represents a crucial step towards better protecting the financial system from banking collapses and their fallout by raising the standards and expectations for board and management structures at large banks to align with the dangers they pose to the American people. Mismanagement, recklessness, negligence, and ignorance can no longer be tolerated. The proposal has several strengths, including greater detail on expectations for both the board and management, as well as the enforceability of these requirements. We also applaud the FDIC’s support of the need for board diversity but encourage more focus on the need for greater banking expertise. Board members must have sufficient knowledge and skills to effectively fulfill their fiduciary duties at large and complex banks.

“Importantly, this proposal is tailored and targeted at the greatest risks that can cause the greatest damage, which is why it applies to only 57 of the 3,012 banks that the FDIC supervises. The FDIC should promptly approve and implement these long overdue and much needed requirements.”

You can find the comment letter here.


Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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