Request for Information on Annual Consumer Trust in Banking Survey, 37917-37920 [2023-12301]
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Federal Register / Vol. 88, No. 111 / Friday, June 9, 2023 / Notices
2023, from 9:00 a.m. to 4:30 p.m.
Eastern Daylight Time (EDT).
Requests to attend the meeting must
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FOR FURTHER INFORMATION CONTACT:
Capt. Jeffrey Flumignan, Designated
Federal Officer, by email at MTSNAC@
dot.gov or by phone at (347) 491–2349.
Maritime Transportation System
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SUPPLEMENTARY INFORMATION:
I. Background
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II. Agenda
III. Public Participation
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section.
(Authority: 5 U.S.C. 552b; 5 U.S.C. app.
Sections 1–16; 41 CFR parts 102 and 103; 49
CFR part 1.93(a).)
By Order of the Maritime Administrator.
T. Mitchell Hudson, Jr.,
Secretary, Maritime Administration.
[FR Doc. 2023–12307 Filed 6–8–23; 8:45 am]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
[Docket ID OCC–2023–0003]
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37917
Request for Information on Annual
Consumer Trust in Banking Survey
Office of the Comptroller of the
Currency (OCC), Treasury.
ACTION: Request for information and
comment.
AGENCY:
The OCC is gathering
information and comments to inform
the development of an annual survey to
understand consumer trust in banking
and bank supervision that the agency
plans to develop and implement, as
discussed in the OCC’s Strategic Plan
for 2023–2027. The purpose of this
request for information (RFI) is to solicit
input to maximize the value and use of
any survey. Specifically, the RFI seeks
comments on the scope of the survey,
components and drivers of trust, and
ways to track and analyze trust over
time.
SUMMARY:
Comments must be received on
or before October 10, 2023.
ADDRESSES: Commenters are encouraged
to submit comments through the Federal
eRulemaking Portal. Please use the title
‘‘Consumer Trust in Banking Survey
Request for Information’’ to facilitate the
organization and distribution of the
comments. You may submit comments
by any of the following methods:
• Federal eRulemaking Portal—
Regulations.gov: Go to https://
www.regulations.gov. Enter ‘‘Docket ID
OCC–2023–0003’’ in the Search Box and
click ‘‘Search.’’ Public comments can be
submitted via the ‘‘Comment’’ box
below the displayed document
information or by clicking on the
document title and then clicking the
‘‘Comment’’ box on the top-left side of
the screen. For help with submitting
effective comments, please click on
‘‘Commenter’s Checklist.’’ For
assistance with the Regulations.gov site,
please call 1–866–498–2945 (toll free)
Monday–Friday, 9 a.m.–5 p.m. ET, or
email regulationshelpdesk@gsa.gov.
• Mail: Chief Counsel’s Office,
Attention: Comment Processing, Office
of the Comptroller of the Currency, 400
7th Street SW, Suite 3E–218,
Washington, DC 20219.
• Hand Delivery/Courier: 400 7th
Street SW, Suite 3E–218, Washington,
DC 20219.
Instructions: You must include
‘‘OCC’’ as the agency name and ‘‘Docket
ID OCC–2023–0003’’ in your comment.
In general, the OCC will enter all
DATES:
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Federal Register / Vol. 88, No. 111 / Friday, June 9, 2023 / Notices
Background Information
regulators, the OCC recognizes that an
effective supervisory framework across
federal and state regulators can support
a strong and fair banking system, which
enables individuals, communities, and
the U.S. economy to thrive. The public’s
trust in banks is an important aspect of
a thriving and stable banking system.
Without trust, banks cannot attract or
retain customers, including depositors,
or meet the credit needs of the
communities they serve.
The safety and soundness of banks
can clearly impact consumer’s trust in
them. Recent events and the 2008
financial crisis have underscored the
importance of trust in banking and the
role banks play in economic growth. For
instance, following the collapse of
Lehman Brothers in 2008, people who
lost trust in their bank were more than
four times more likely to withdraw
deposits from their bank than those who
retained full trust.1 Furthermore, the
effects of lost trust in banks can be long
lasting. Research suggests that in
circumstances where there were bank
runs, the aggregate level of deposits may
not return to pre-crisis levels.2 Such
effects have implications for banks’
asset portfolios and loans and
availability of credit to borrowers.
The fairness of banks’ products and
services and banks’ compliance with
laws and regulations can also impact
consumers’ trust in banks.
Discrimination on a prohibited basis,
deceptive or unfair practices, and fraud
are examples of practices that erode
trust in banking. They may reflect weak
controls and can suggest a
disproportionate prioritization of profits
over consumers or an indifference to
certain groups and communities.
Changes in trust in banks can also
affect banks’ earnings, funding costs,
business models, and safety and
soundness. The reciprocal nature of the
relationship between trust and safety
and soundness should make consumer
trust a key variable of interest to bank
regulators. Moreover, trust in banks can
The OCC, as the federal regulator for
national banks, federal savings
associations, and federal branches and
agencies of foreign banking
organizations (collectively, ‘‘national
banks’’), is committed to its mission of
ensuring that the institutions it
supervises operate in a safe and sound
manner, provide fair access to financial
services, treat customers fairly, and
comply with applicable laws and
regulations. While other types of banks
have other federal and/or state
1 Guiso, L. (2010) ‘‘A trust-driven financial crisis.
Implications for the future of financial markets.’’
Einaudi Institute for Economic and Finance
Working Paper Series 1006, available at: https://
ideas.repec.org/p/eie/wpaper/1006.html.
2 Iyer, R., & Puri, M. (2012). ‘‘Understanding Bank
Runs: The Importance of Depositor-Bank
Relationships and Networks,’’ The American
Economic Review, 102(4): 1414–1445, available at:
https://www.jstor.org/stable/23245460.
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comments received into the docket and
publish the comments on the
Regulations.gov website without
change, including any business or
personal information provided such as
name and address information, email
addresses, or phone numbers.
Comments received, including
attachments and other supporting
materials, are part of the public record
and subject to public disclosure. Do not
include any information in your
comment or supporting materials that
you consider confidential or
inappropriate for public disclosure.
You may review comments and other
related materials that pertain to this
action by the following method:
• Viewing Comments Electronically—
Regulations.gov: Go to https://
regulations.gov/. Enter ‘‘Docket ID OCC–
2023–0003’’ in the Search Box and click
‘‘Search.’’ Click on the ‘‘Documents’’ tab
and then the document’s title. After
clicking the document’s title, click the
‘‘Browse Comments’’ tab. Comments can
be viewed and filtered by clicking on
the ‘‘Sort By’’ drop-down on the right
side of the screen or the ‘‘Refine
Results’’ options on the left side of the
screen. Supporting materials can be
viewed by clicking on the ‘‘Documents’’
tab and filtered by clicking on the ‘‘Sort
By’’ drop-down on the right side of the
screen or the ‘‘Refine Documents
Results’’ options on the left side of the
screen. For assistance with the
Regulations.gov site, please call 1–866–
498–2945 (toll free) Monday–Friday, 9
a.m.–5 p.m. ET, or email
regulationshelpdesk@gsa.gov.
The docket may be viewed after the
close of the comment period in the same
manner as during the comment period.
FOR FURTHER INFORMATION CONTACT:
Chau Do (Deputy Comptroller for
Economics and Risk Analysis in
Supervision Risk and Analysis), (202)
649–5550. If you are deaf, hard of
hearing, or have a speech disability,
please dial 7–1–1 to access
telecommunications relay services.
SUPPLEMENTARY INFORMATION:
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also impact financial inclusion 3 and
financial stability.4
For these reasons, as part of the OCC’s
efforts to safeguard the public’s trust in
the federal banking system and
contribute to a federal banking system
that is safe, sound, and fair, the OCC is
developing an annual consumer trust in
banking survey with the goals of
understanding, measuring, and tracking
the consumer trust in banking and bank
supervision over time. By surveying the
public, the OCC could identify area(s)
where trust can be further enhanced.
The results of the proposed survey may
complement existing sources of public
and supervisory information and
provide additional insight into the many
aspects that are important to consider in
working to maintain and enhance
consumer trust in banking and bank
supervision. The OCC could publish the
main results of the annual survey in an
OCC report to inform policymakers,
bankers, and researchers about the
trends and drivers of consumer trust in
banking and bank supervision. Other
more detailed reports on specific trust
topics may also be produced.
Request for Comment
In this RFI, the OCC is inviting
interested members of the public,
including financial industry
participants, other government agencies,
academic and research organizations,
consumer advocacy and financial
education organizations, trade
associations, and financial services
customers to comment on the possible
scope of the survey, components and
drivers of trust, and ways to track and
analyze trust over time.
Scope of Survey
Trust survey questions have generally
been limited to assessing customers’
sentiment toward financial institutions
or their level of trust in the financial
institution with which they have an
account. However, trust in financial
3 See for example, Xu, X. (2020) ‘‘Trust and
financial inclusion: A cross-country study.’’
Finance Research Letters, 35, available at: https://
www.sciencedirect.com/science/article/pii/
S1544612319303915, and Allen, F., Demirguc-Kunt,
A., Klapper, L., and Peria, M.S.M., (2016) ‘‘The
foundations of financial inclusion: Understanding
ownership and use of formal accounts.’’ Journal of
Financial Intermediation, 27: 1–30, available at:
https://www.sciencedirect.com/science/article/pii/
S1042957315000534.
4 See for example, Chernykh L., Davydov D., and
Sihvonen J., (2019). ‘‘Financial Stability and Public
Confidence in Banks.’’ BOFIT Discussion Paper No.
2/2019, available at: https://ssrn.com/
abstract=3339743 or https://dx.doi.org/10.2139/ssrn.
3339743, and Miao J., Wang, P. (2015) ‘‘Banking
bubbles and financial crises.’’ Journal of Economic
Theory, 157: 763–792, available at: https://
www.sciencedirect.com/science/article/pii/
S002205311500037X.
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institutions may differ based on
customers’ experiences with the
financial product sought or used (e.g.,
credit card, mortgage, demand deposit
account) or with the type of financial
service providers (e.g., federally
chartered depository institutions, statechartered depository institutions, credit
unions, non-banks).
Question 1: Are there certain
segments of the U.S. population (e.g.,
geographic, unbanked, underbanked,
demographic groups) that should be
targeted for inclusion to ensure survey
participation is sufficiently high to
make generalized statements about
those groups? Are there specific types of
questions that should be included for
any such targeted group?
Question 2: What are some of the key
considerations in determining whether
the survey should focus solely on
groups of potential bank customers that
have not been the subject of previous
surveys, such as (1) those who use
wealth or asset management services or
private banking services; (2) those who
regularly use overdraft products, small
dollar unsecured loans, remittances
services, or low-cost deposit accounts;
or (3) small business owners? For
example, what are the benefits or
drawbacks of focusing on segments of
customers, and are there certain types of
questions that should be included in
order to maximize those benefits?
Question 3: Alternatively, what are
some key considerations in determining
whether the survey respondents should
be expansive to reflect the general
population? For example, what are the
benefits or drawbacks of surveying
individuals, not limited to bank
customers or potential bank customers,
and are there certain types of questions
that should be included in order to
maximize those benefits?
Question 4: What are some of the key
considerations in determining whether
the survey should include questions
related to customers’ use of specific
types of financial products or services
such as mortgage loans, credit cards, or
overdrafts?
Question 5: What are the key
considerations in asking respondents to
distinguish between different financial
institutions (i.e., federally chartered
depository institutions, state-chartered
depository institutions, credit unions,
non-banks) providing financial services
in terms of their experience,
perceptions, or trust?
Question 6: To what extent should the
OCC consider conducting a survey
focused solely on federally chartered
depository institutions?
Question 7: To what extent should the
OCC consider conducting a survey
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focused more broadly on banks (i.e.,
bank holding companies and federally
chartered and state- chartered
depository institutions)?
Question 8: To what extent should the
OCC consider conducting a survey
focused more broadly on banks and
non-banks (e.g., fintech firms) that
provide financial services or products?
Components of Trust
Admittedly, consumer trust in the
banking system is hard to explicitly
define since the public may have
various issues in mind when asked
about their level of trust in financial
institutions. Although there is no clear
consensus on all of the components of
trust, research 5 has generally found that
the following components influence a
customer’s level of trust in a financial
institution: competency, goodwill,
integrity, and transparency.
• Competency can refer to the ability
of the financial institution to: (1)
consistently provide financial services
and relevant information to assist
customers with their decisions, (2)
promptly address problems and
complaints, and (3) safeguard customer
information appropriately.6
• Goodwill can refer to the financial
institution’s responsiveness and
empathy for the customer’s needs and
welfare.7
• Integrity can refer to whether the
financial institution treats customers in
a fair and equal way and the financial
institution does not defraud consumers
or misuse their private information.8
• Transparency can refer to whether
the financial institution provides clear
communication and the disclosure of
5 See for example, Kidron, A. and Kreis, Y. (2020),
‘‘Listening to bank customers: the meaning of
trust.’’ International Journal of Quality and Service
Sciences, 12(3): 355–370, available at https://
doi.org/10.1108/IJQSS-10-2019-0120; Ennew, C.T.
and Sekhon, H. (2007), ‘‘Measuring trust in
financial services: the Trust Index.’’ Consumer
Policy Review, 17(2): 62–68, available at https://
www.researchgate.net/publication/285769675_
Measuring_trust_in_financial_services_the_Trust_
Index; and Roy, S.K. and Shekhar, V. (2010),
‘‘Dimensional hierarchy of trustworthiness of
financial service providers.’’ International Journal
of Bank Marketing, 28(1): 47–64, available at:
https://doi.org/10.1108/02652321011013580.
6 Kidron, A. and Kreis, Y. (2020), ‘‘Listening to
bank customers: the meaning of trust.’’
International Journal of Quality and Service
Sciences, 12(3): 355–370, available at: https://
doi.org/10.1108/IJQSS-10-2019-0120.
7 Yu, P.L., Balaji, M.S. and Khong, K.W. (2015),
‘‘Building trust in internet banking: a
trustworthiness perspective.’’ Industrial
Management and Data Systems, 115(2): 235–252,
available at: https://doi.org/10.1108/IMDS-09-20140262.
8 van Esterik-Plasmeijer, P.W.J. and van Raaij,
W.F. (2017), ‘‘Banking system trust, bank trust, and
bank loyalty.’’ International Journal of Bank
Marketing, 35(1): 97–111, available at: https://
doi.org/10.1108/IJBM-12-2015-0195.
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the relevant information to enable
customers’ understanding of the benefits
and costs associated with a financial
product or service.9
Question 9: Are the definitions above
of the components of trust useful and
appropriate? If not, what modifications
should be considered?
Question 10: Are the components of
trust comprehensive? If not, what
additional components should be
considered?
Question 11: Are some components of
trust superfluous? Which ones are not
necessary?
Question 12: How important is it to
differentiate among the components of
trust?
Question 13: Does the relative
importance differ depending on the type
or size of the financial institution or the
financial services or products customers
use, or the specific segment of the
population?
Measuring and Tracking Trust
Surveys may be designed to either
directly measure trust (e.g., rank level of
trust from 1–5) or indirectly, by inferring
trust from reported behaviors (e.g.,
closing a bank account, switching
financial institutions). Additionally, in
measuring trust in financial institutions,
it may be important to distinguish
between broad scope trust (system-level
trust in financial institutions) and
narrow scope trust (trust in one’s own
financial institution) and identify the
various drivers that influence the
public’s level of trust. Research 10
suggests there are four important drivers
that may affect customers’ trust in
financial institutions: (1) economic
factors (e.g., unemployment rate,
financial crisis), (2) direct personal
experience, (e.g., quality of financial
services delivered), (3) customers’
personal characteristics (e.g., financial
literacy, demographic characteristics,
economic and political views), and (4)
government oversight and policy
measures (e.g., financial regulators,
laws, government).
Question 14: What are some of the key
considerations in determining whether
the survey should include questions
aimed to measure and monitor trust in
financial institutions (i.e., system-level),
and/or questions focused on customers’
9 Roy, S.K. and Shekhar, V. (2010), ‘‘Dimensional
hierarchy of trustworthiness of financial service
providers.’’ International Journal of Bank
Marketing, 28(1): 47–64, available at: https://
doi.org/10.1108/02652321011013580.
10 See, for example: van der Cruijsen, C., de Haan,
J., and Roerink, R. (2020), ‘‘Trust in Financial
Institutions: A Survey.’’ De Nederlandsche Bank
Working Paper No. 693, available at: https://
dx.doi.org/10.2139/ssrn.3677835.
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level of trust in the financial institution
with which they have an account?
Question 15: To what extent should
trust survey measurements be based on
direct and/or indirect measures (as
described above)?
Question 16: Do the drivers of trust
listed above comprehensively identify
key factors in measuring and tracking
trust in financial institutions over time?
If not, what other drivers could be used?
Question 17: How important is
understanding the drivers of trust in
developing a trust measurement for
financial institutions?
Question 18: What are some of the key
factors to consider in developing survey
questions that capture how personal
characteristics influence trust in
financial institutions?
Question 19: What are some of the key
factors to consider in creating survey
questions to capture how trust in bank
regulators influence customers’ trust in
banks?
Question 20: What are some of the key
factors to consider in creating survey
questions to capture how trust in the
government influence customers’ trust
in financial institutions?
Question 21: What are the key
advantages and disadvantages of having
a single banking regulator conducting
the survey? To what extent should the
OCC consider alternative approaches,
such as conducting a joint survey with
one or more other federal bank
regulators?
(Authority: 12 U.S.C. 1)
Michael J. Hsu,
Acting Comptroller of the Currency.
[FR Doc. 2023–12301 Filed 6–8–23; 8:45 am]
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CORPORATION
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
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[Docket ID OCC–2021–0011]
Interagency Guidance on Third-Party
Relationships: Risk Management
The Board of Governors of the
Federal Reserve System (Board), the
Federal Deposit Insurance Corporation
(FDIC), and the Office of the
Comptroller of the Currency (OCC),
Treasury.
AGENCY:
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ACTION:
Final interagency guidance.
The Board, FDIC, and OCC
(collectively, the agencies) are issuing
final guidance on managing risks
associated with third-party
relationships. The final guidance offers
the agencies’ views on sound risk
management principles for banking
organizations when developing and
implementing risk management
practices for all stages in the life cycle
of third-party relationships. The final
guidance states that sound third-party
risk management takes into account the
level of risk, complexity, and size of the
banking organization and the nature of
the third-party relationship. The
agencies are issuing this joint guidance
to promote consistency in supervisory
approaches; it replaces each agency’s
existing general guidance on this topic
and is directed to all banking
organizations supervised by the
agencies.
SUMMARY:
The guidance is final as of June
6, 2023.
FOR FURTHER INFORMATION CONTACT:
Board: Kavita Jain, Deputy Associate
Director, (202) 452–2062, Chandni
Saxena, Manager, (202) 452–2357,
Timothy Geishecker, Lead Financial
Institution and Policy Analyst, (202)
475–6353, or David Palmer, Lead
Financial Institution and Policy
Analyst, (202) 452–2904, Division of
Supervision and Regulation; Matthew
Dukes, Counsel, (202) 973–5096,
Division of Consumer and Community
Affairs; or Claudia Von Pervieux, Senior
Counsel, (202) 452–2552, Evans Muzere,
Senior Counsel, (202) 452–2621, or
Alyssa O’Connor, Senior Attorney, (202)
452–3886, Legal Division, Board of
Governors of the Federal Reserve
System, 20th and C Streets NW,
Washington, DC 20551. For users of
telephone systems via text telephone
(TTY) or any TTY-based
Telecommunications Relay Services
(TRS), please call 711 from any
telephone, anywhere in the United
States.
FDIC: Thomas F. Lyons, Associate
Director, Risk Management Policy,
TLyons@fdic.gov, (202) 898–6850), or
Judy E. Gross, Senior Policy Analyst,
JuGross@fdic.gov, (202) 898–7047,
Policy & Program Development,
Division of Risk Management
Supervision; Paul Robin, Chief, probin@
fdic.gov, (202) 898–6818, Supervisory
Policy Section, Division of Depositor
and Consumer Protection; or Marguerite
Sagatelian, Senior Special Counsel,
msagatelian@fdic.gov, (202) 898–6690
or Jennifer M. Jones, Counsel,
jennjones@fdic.gov, (202) 898–6768,
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Supervision, Legislation & Enforcement
Branch, Legal Division, Federal Deposit
Insurance Corporation; 550 17th Street
NW, Washington, DC 20429.
OCC: Kevin Greenfield, Deputy
Comptroller for Operational Risk Policy,
Tamara Culler, Governance and
Operational Risk Policy Director, Emily
Doran, Governance and Operational
Risk Policy Analyst, or Stuart Hoffman,
Governance and Operational Risk Policy
Analyst, Operational Risk Policy
Division, (202) 649–6550; or Eden Gray,
Assistant Director, Tad Thompson,
Counsel, or Graham Bannon, Attorney,
Chief Counsel’s Office, (202) 649–5490,
Office of the Comptroller of the
Currency, 400 7th Street SW,
Washington, DC 20219. If you are deaf,
hard of hearing, or have a speech
disability, please dial 7–1–1 to access
telecommunications relay services.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. Discussion of Comments on the Proposed
Guidance
A. General Support for the Proposed
Guidance
B. Terminology and Scope
C. Tailored Approach to Third-Party Risk
Management
D. Specific Types of Third-Party
Relationships
E. Risk Management Life Cycle
F. Subcontractors
G. Oversight and Accountability
H. Other Matters Raised
III. Paperwork Reduction Act
IV. Text of Final Interagency Guidance on
Third-Party Relationships
I. Introduction
Banking organizations 1 routinely rely
on third parties for a range of products,
services, and other activities
(collectively, activities). The use of third
parties can offer banking organizations
significant benefits, such as quicker and
more efficient access to technologies,
human capital, delivery channels,
products, services, and markets.
Banking organizations’ use of third
parties does not remove the need for
sound risk management. On the
contrary, the use of third parties,
especially those using new technologies,
may present elevated risks to banking
organizations and their customers,
including operational, compliance, and
strategic risks. Importantly, the use of
third parties does not diminish or
remove banking organizations’
1 For a description of the banking organizations
supervised by each agency, refer to the definition
of ‘‘appropriate Federal banking agency’’ in section
3(q) of the Federal Deposit Insurance Act (12 U.S.C.
1813(q)). This guidance is relevant to all banking
organizations supervised by the agencies.
E:\FR\FM\09JNN1.SGM
09JNN1
Agencies
[Federal Register Volume 88, Number 111 (Friday, June 9, 2023)]
[Notices]
[Pages 37917-37920]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-12301]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
[Docket ID OCC-2023-0003]
Request for Information on Annual Consumer Trust in Banking
Survey
AGENCY: Office of the Comptroller of the Currency (OCC), Treasury.
ACTION: Request for information and comment.
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SUMMARY: The OCC is gathering information and comments to inform the
development of an annual survey to understand consumer trust in banking
and bank supervision that the agency plans to develop and implement, as
discussed in the OCC's Strategic Plan for 2023-2027. The purpose of
this request for information (RFI) is to solicit input to maximize the
value and use of any survey. Specifically, the RFI seeks comments on
the scope of the survey, components and drivers of trust, and ways to
track and analyze trust over time.
DATES: Comments must be received on or before October 10, 2023.
ADDRESSES: Commenters are encouraged to submit comments through the
Federal eRulemaking Portal. Please use the title ``Consumer Trust in
Banking Survey Request for Information'' to facilitate the organization
and distribution of the comments. You may submit comments by any of the
following methods:
Federal eRulemaking Portal--Regulations.gov: Go to https://www.regulations.gov. Enter ``Docket ID OCC-2023-0003'' in the Search
Box and click ``Search.'' Public comments can be submitted via the
``Comment'' box below the displayed document information or by clicking
on the document title and then clicking the ``Comment'' box on the top-
left side of the screen. For help with submitting effective comments,
please click on ``Commenter's Checklist.'' For assistance with the
Regulations.gov site, please call 1-866-498-2945 (toll free) Monday-
Friday, 9 a.m.-5 p.m. ET, or email [email protected].
Mail: Chief Counsel's Office, Attention: Comment
Processing, Office of the Comptroller of the Currency, 400 7th Street
SW, Suite 3E-218, Washington, DC 20219.
Hand Delivery/Courier: 400 7th Street SW, Suite 3E-218,
Washington, DC 20219.
Instructions: You must include ``OCC'' as the agency name and
``Docket ID OCC-2023-0003'' in your comment. In general, the OCC will
enter all
[[Page 37918]]
comments received into the docket and publish the comments on the
Regulations.gov website without change, including any business or
personal information provided such as name and address information,
email addresses, or phone numbers. Comments received, including
attachments and other supporting materials, are part of the public
record and subject to public disclosure. Do not include any information
in your comment or supporting materials that you consider confidential
or inappropriate for public disclosure.
You may review comments and other related materials that pertain to
this action by the following method:
Viewing Comments Electronically--Regulations.gov: Go to
https://regulations.gov/. Enter ``Docket ID OCC-2023-0003'' in the
Search Box and click ``Search.'' Click on the ``Documents'' tab and
then the document's title. After clicking the document's title, click
the ``Browse Comments'' tab. Comments can be viewed and filtered by
clicking on the ``Sort By'' drop-down on the right side of the screen
or the ``Refine Results'' options on the left side of the screen.
Supporting materials can be viewed by clicking on the ``Documents'' tab
and filtered by clicking on the ``Sort By'' drop-down on the right side
of the screen or the ``Refine Documents Results'' options on the left
side of the screen. For assistance with the Regulations.gov site,
please call 1-866-498-2945 (toll free) Monday-Friday, 9 a.m.-5 p.m. ET,
or email [email protected].
The docket may be viewed after the close of the comment period in
the same manner as during the comment period.
FOR FURTHER INFORMATION CONTACT: Chau Do (Deputy Comptroller for
Economics and Risk Analysis in Supervision Risk and Analysis), (202)
649-5550. If you are deaf, hard of hearing, or have a speech
disability, please dial 7-1-1 to access telecommunications relay
services.
SUPPLEMENTARY INFORMATION:
Background Information
The OCC, as the federal regulator for national banks, federal
savings associations, and federal branches and agencies of foreign
banking organizations (collectively, ``national banks''), is committed
to its mission of ensuring that the institutions it supervises operate
in a safe and sound manner, provide fair access to financial services,
treat customers fairly, and comply with applicable laws and
regulations. While other types of banks have other federal and/or state
regulators, the OCC recognizes that an effective supervisory framework
across federal and state regulators can support a strong and fair
banking system, which enables individuals, communities, and the U.S.
economy to thrive. The public's trust in banks is an important aspect
of a thriving and stable banking system. Without trust, banks cannot
attract or retain customers, including depositors, or meet the credit
needs of the communities they serve.
The safety and soundness of banks can clearly impact consumer's
trust in them. Recent events and the 2008 financial crisis have
underscored the importance of trust in banking and the role banks play
in economic growth. For instance, following the collapse of Lehman
Brothers in 2008, people who lost trust in their bank were more than
four times more likely to withdraw deposits from their bank than those
who retained full trust.\1\ Furthermore, the effects of lost trust in
banks can be long lasting. Research suggests that in circumstances
where there were bank runs, the aggregate level of deposits may not
return to pre-crisis levels.\2\ Such effects have implications for
banks' asset portfolios and loans and availability of credit to
borrowers.
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\1\ Guiso, L. (2010) ``A trust-driven financial crisis.
Implications for the future of financial markets.'' Einaudi
Institute for Economic and Finance Working Paper Series 1006,
available at: https://ideas.repec.org/p/eie/wpaper/1006.html.
\2\ Iyer, R., & Puri, M. (2012). ``Understanding Bank Runs: The
Importance of Depositor-Bank Relationships and Networks,'' The
American Economic Review, 102(4): 1414-1445, available at: https://www.jstor.org/stable/23245460.
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The fairness of banks' products and services and banks' compliance
with laws and regulations can also impact consumers' trust in banks.
Discrimination on a prohibited basis, deceptive or unfair practices,
and fraud are examples of practices that erode trust in banking. They
may reflect weak controls and can suggest a disproportionate
prioritization of profits over consumers or an indifference to certain
groups and communities.
Changes in trust in banks can also affect banks' earnings, funding
costs, business models, and safety and soundness. The reciprocal nature
of the relationship between trust and safety and soundness should make
consumer trust a key variable of interest to bank regulators. Moreover,
trust in banks can also impact financial inclusion \3\ and financial
stability.\4\
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\3\ See for example, Xu, X. (2020) ``Trust and financial
inclusion: A cross-country study.'' Finance Research Letters, 35,
available at: https://www.sciencedirect.com/science/article/pii/S1544612319303915, and Allen, F., Demirguc-Kunt, A., Klapper, L.,
and Peria, M.S.M., (2016) ``The foundations of financial inclusion:
Understanding ownership and use of formal accounts.'' Journal of
Financial Intermediation, 27: 1-30, available at: https://www.sciencedirect.com/science/article/pii/S1042957315000534.
\4\ See for example, Chernykh L., Davydov D., and Sihvonen J.,
(2019). ``Financial Stability and Public Confidence in Banks.''
BOFIT Discussion Paper No. 2/2019, available at: https://ssrn.com/abstract=3339743 or https://dx.doi.org/10.2139/ssrn.3339743, and Miao
J., Wang, P. (2015) ``Banking bubbles and financial crises.''
Journal of Economic Theory, 157: 763-792, available at: https://www.sciencedirect.com/science/article/pii/S002205311500037X.
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For these reasons, as part of the OCC's efforts to safeguard the
public's trust in the federal banking system and contribute to a
federal banking system that is safe, sound, and fair, the OCC is
developing an annual consumer trust in banking survey with the goals of
understanding, measuring, and tracking the consumer trust in banking
and bank supervision over time. By surveying the public, the OCC could
identify area(s) where trust can be further enhanced. The results of
the proposed survey may complement existing sources of public and
supervisory information and provide additional insight into the many
aspects that are important to consider in working to maintain and
enhance consumer trust in banking and bank supervision. The OCC could
publish the main results of the annual survey in an OCC report to
inform policymakers, bankers, and researchers about the trends and
drivers of consumer trust in banking and bank supervision. Other more
detailed reports on specific trust topics may also be produced.
Request for Comment
In this RFI, the OCC is inviting interested members of the public,
including financial industry participants, other government agencies,
academic and research organizations, consumer advocacy and financial
education organizations, trade associations, and financial services
customers to comment on the possible scope of the survey, components
and drivers of trust, and ways to track and analyze trust over time.
Scope of Survey
Trust survey questions have generally been limited to assessing
customers' sentiment toward financial institutions or their level of
trust in the financial institution with which they have an account.
However, trust in financial
[[Page 37919]]
institutions may differ based on customers' experiences with the
financial product sought or used (e.g., credit card, mortgage, demand
deposit account) or with the type of financial service providers (e.g.,
federally chartered depository institutions, state-chartered depository
institutions, credit unions, non-banks).
Question 1: Are there certain segments of the U.S. population
(e.g., geographic, unbanked, underbanked, demographic groups) that
should be targeted for inclusion to ensure survey participation is
sufficiently high to make generalized statements about those groups?
Are there specific types of questions that should be included for any
such targeted group?
Question 2: What are some of the key considerations in determining
whether the survey should focus solely on groups of potential bank
customers that have not been the subject of previous surveys, such as
(1) those who use wealth or asset management services or private
banking services; (2) those who regularly use overdraft products, small
dollar unsecured loans, remittances services, or low-cost deposit
accounts; or (3) small business owners? For example, what are the
benefits or drawbacks of focusing on segments of customers, and are
there certain types of questions that should be included in order to
maximize those benefits?
Question 3: Alternatively, what are some key considerations in
determining whether the survey respondents should be expansive to
reflect the general population? For example, what are the benefits or
drawbacks of surveying individuals, not limited to bank customers or
potential bank customers, and are there certain types of questions that
should be included in order to maximize those benefits?
Question 4: What are some of the key considerations in determining
whether the survey should include questions related to customers' use
of specific types of financial products or services such as mortgage
loans, credit cards, or overdrafts?
Question 5: What are the key considerations in asking respondents
to distinguish between different financial institutions (i.e.,
federally chartered depository institutions, state-chartered depository
institutions, credit unions, non-banks) providing financial services in
terms of their experience, perceptions, or trust?
Question 6: To what extent should the OCC consider conducting a
survey focused solely on federally chartered depository institutions?
Question 7: To what extent should the OCC consider conducting a
survey focused more broadly on banks (i.e., bank holding companies and
federally chartered and state- chartered depository institutions)?
Question 8: To what extent should the OCC consider conducting a
survey focused more broadly on banks and non-banks (e.g., fintech
firms) that provide financial services or products?
Components of Trust
Admittedly, consumer trust in the banking system is hard to
explicitly define since the public may have various issues in mind when
asked about their level of trust in financial institutions. Although
there is no clear consensus on all of the components of trust, research
\5\ has generally found that the following components influence a
customer's level of trust in a financial institution: competency,
goodwill, integrity, and transparency.
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\5\ See for example, Kidron, A. and Kreis, Y. (2020),
``Listening to bank customers: the meaning of trust.'' International
Journal of Quality and Service Sciences, 12(3): 355-370, available
at https://doi.org/10.1108/IJQSS-10-2019-0120; Ennew, C.T. and
Sekhon, H. (2007), ``Measuring trust in financial services: the
Trust Index.'' Consumer Policy Review, 17(2): 62-68, available at
https://www.researchgate.net/publication/285769675_Measuring_trust_in_financial_services_the_Trust_Index; and
Roy, S.K. and Shekhar, V. (2010), ``Dimensional hierarchy of
trustworthiness of financial service providers.'' International
Journal of Bank Marketing, 28(1): 47-64, available at: https://doi.org/10.1108/02652321011013580.
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Competency can refer to the ability of the financial
institution to: (1) consistently provide financial services and
relevant information to assist customers with their decisions, (2)
promptly address problems and complaints, and (3) safeguard customer
information appropriately.\6\
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\6\ Kidron, A. and Kreis, Y. (2020), ``Listening to bank
customers: the meaning of trust.'' International Journal of Quality
and Service Sciences, 12(3): 355-370, available at: https://doi.org/10.1108/IJQSS-10-2019-0120.
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Goodwill can refer to the financial institution's
responsiveness and empathy for the customer's needs and welfare.\7\
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\7\ Yu, P.L., Balaji, M.S. and Khong, K.W. (2015), ``Building
trust in internet banking: a trustworthiness perspective.''
Industrial Management and Data Systems, 115(2): 235-252, available
at: https://doi.org/10.1108/IMDS-09-2014-0262.
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Integrity can refer to whether the financial institution
treats customers in a fair and equal way and the financial institution
does not defraud consumers or misuse their private information.\8\
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\8\ van Esterik-Plasmeijer, P.W.J. and van Raaij, W.F. (2017),
``Banking system trust, bank trust, and bank loyalty.''
International Journal of Bank Marketing, 35(1): 97-111, available
at: https://doi.org/10.1108/IJBM-12-2015-0195.
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Transparency can refer to whether the financial
institution provides clear communication and the disclosure of the
relevant information to enable customers' understanding of the benefits
and costs associated with a financial product or service.\9\
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\9\ Roy, S.K. and Shekhar, V. (2010), ``Dimensional hierarchy of
trustworthiness of financial service providers.'' International
Journal of Bank Marketing, 28(1): 47-64, available at: https://doi.org/10.1108/02652321011013580.
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Question 9: Are the definitions above of the components of trust
useful and appropriate? If not, what modifications should be
considered?
Question 10: Are the components of trust comprehensive? If not,
what additional components should be considered?
Question 11: Are some components of trust superfluous? Which ones
are not necessary?
Question 12: How important is it to differentiate among the
components of trust?
Question 13: Does the relative importance differ depending on the
type or size of the financial institution or the financial services or
products customers use, or the specific segment of the population?
Measuring and Tracking Trust
Surveys may be designed to either directly measure trust (e.g.,
rank level of trust from 1-5) or indirectly, by inferring trust from
reported behaviors (e.g., closing a bank account, switching financial
institutions). Additionally, in measuring trust in financial
institutions, it may be important to distinguish between broad scope
trust (system-level trust in financial institutions) and narrow scope
trust (trust in one's own financial institution) and identify the
various drivers that influence the public's level of trust. Research
\10\ suggests there are four important drivers that may affect
customers' trust in financial institutions: (1) economic factors (e.g.,
unemployment rate, financial crisis), (2) direct personal experience,
(e.g., quality of financial services delivered), (3) customers'
personal characteristics (e.g., financial literacy, demographic
characteristics, economic and political views), and (4) government
oversight and policy measures (e.g., financial regulators, laws,
government).
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\10\ See, for example: van der Cruijsen, C., de Haan, J., and
Roerink, R. (2020), ``Trust in Financial Institutions: A Survey.''
De Nederlandsche Bank Working Paper No. 693, available at: https://dx.doi.org/10.2139/ssrn.3677835.
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Question 14: What are some of the key considerations in determining
whether the survey should include questions aimed to measure and
monitor trust in financial institutions (i.e., system-level), and/or
questions focused on customers'
[[Page 37920]]
level of trust in the financial institution with which they have an
account?
Question 15: To what extent should trust survey measurements be
based on direct and/or indirect measures (as described above)?
Question 16: Do the drivers of trust listed above comprehensively
identify key factors in measuring and tracking trust in financial
institutions over time? If not, what other drivers could be used?
Question 17: How important is understanding the drivers of trust in
developing a trust measurement for financial institutions?
Question 18: What are some of the key factors to consider in
developing survey questions that capture how personal characteristics
influence trust in financial institutions?
Question 19: What are some of the key factors to consider in
creating survey questions to capture how trust in bank regulators
influence customers' trust in banks?
Question 20: What are some of the key factors to consider in
creating survey questions to capture how trust in the government
influence customers' trust in financial institutions?
Question 21: What are the key advantages and disadvantages of
having a single banking regulator conducting the survey? To what extent
should the OCC consider alternative approaches, such as conducting a
joint survey with one or more other federal bank regulators?
(Authority: 12 U.S.C. 1)
Michael J. Hsu,
Acting Comptroller of the Currency.
[FR Doc. 2023-12301 Filed 6-8-23; 8:45 am]
BILLING CODE 4810-33-P