The government should have an independent systemic regulator but not combine the existing bank regulators into one agency and shouldn't create a separate regulator for financial products, ABA President Edward L. Yingling wrote Treasury Secretary Timothy Geithner.
The systemic risk regulator should be a council of regulators chaired by the Federal Reserve Chairman that would research problems and recommend solutions with the Fed as the lead regulator, Yingling wrote.
Having one bank regulator-combining the Office of the Comptroller of the Currency, the Office of Thrift Supervision and the regulatory functions of the Fed and FDIC–would be "the end of a true dual banking system" that would disadvantage state-chartered banks.
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