Long before George Bailey wrestled with Mr. Potter in "It's a Wonderful Life," the public decried the pay of top executives in large financial institutions. Overpaid bank executives are the villains in regulatory morality tales and feed distorted public perceptions about bankers' pay.
It is true that the very top bank executives make more in a year than most of us make in a lifetime, but compensation of this magnitude is rare. Most banks in this country are small businesses and pay employees modest salaries. The Bureau of Labor Statistics reports that the average annual salary of a bank employee was $49,540 in 2012, not much higher than the average annual across all occupations, $45,790.
Yet one group in banking stands out as highly paid—federal bank regulators. Before the Dodd-Frank Act, the average employee of a federal bank regulatory agency received 2.3 times the average compensation of a private banker. By 2013 this ratio increased to more than 2.7—and in some cases considerably more.
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The average compensation at the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corp. (FDIC) and the Consumer Financial Protection Bureau (CFPB) exceeded $190,000 in 2012. The staff at the Federal Reserve is likely even better compensated, but the Fed refuses to release employee salaries.
You might think high-paying jobs at these agencies require special skills. Not so. At the OCC, secretaries make on average $79,182 per annum. Motor vehicle operators (the agency's limo drivers) at the FDIC earn $82,130. Human resources management trainees at the CFPB make $110,759 a year.
Averages tell only part of the story. In 2012, 68% of FDIC and CFPB staff—and 66% at the OCC—earned above $100,000 a year. Nearly 19% of the CFPB and OCC staff earn more than $180,000 a year. At the OCC, 10.5% of workers earn above $200,000 a year, at the FDIC 9.3%.
Fewer than 7% of employees in any of these regulatory agencies earned less than $50,000. In other words, 93% of the employees in these federal bank regulatory agencies earned more than the average banker's salary in 2012.
These bloated salaries trace back to the savings-and-loan crisis of the 1980s, which was attributed in part to regulators' inability to attract and retain experienced bank supervisors. The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 permitted federal bank regulatory agencies to establish their own compensation and benefits without the approval of the Office of Personnel Management.
This reform has not worked as Congress intended. Instead of raising salaries to attract and retain employees for specialized, hard-to-fill jobs, federal bank regulatory agencies have increased the salaries of all employees. Ironically, the hard-to-fill jobs that require substantial education or professional experience—such as attorneys and economists with banking experience—have the smallest premiums over comparable private positions.
Salary premiums are especially large for easy-to-fill jobs that require no specialized, hard-to-hire skills. This problem promises to become even more acute under Dodd-Frank, as all federal bank regulatory agencies (except the Fed) are now allowing employee unions to negotiate compensation. Only a few other, small, government agencies can set employee pay independent of the government's general scale.
Who pays for these generous salaries? Bank shareholders pay directly through insurance premiums on deposits and examination fees levied by the bank regulatory agencies. These costs are passed on in higher customer fees and loan rates. The high compensation of CFPB employees is funded by taxpayers through the Federal Reserve.
The runaway labor costs of these regulator agencies are not subject to congressional control, and they add up. Employee compensation accounts for about 80% of the operating costs of bank regulatory agencies. If the average regulatory employee's compensation were equalized between bankers and regulators, the direct cost of bank regulation would fall by more than 50%.
Targeted compensation exceptions to the government's general salary schedule offer a potential solution. These exceptions have been used successfully by NASA, the National Institutes of Health and other agencies to recruit and retain specialized staff without inflating the salaries of all employees.
It is up to Congress to re-establish control of bank regulators' compensation. There is no reason these agencies should be allowed to impose unnecessarily large fees on banks and their customers to fund largess for their employees.