Abstract:
This case examines the efforts of the Federal Deposit Insurance Corporation (FDIC) to establish a special "consumer affairs" office in response to the mandate of the 1975 Federal Trade Commission Improvement Act. The creation of the office stirred internal debate in the FDIC over a number of questions: chiefly, whether the new office should be autonomous, reporting directly to the FDIC board, or simply incorporated into an existing division; whether it should have its own investigative staff or should rely on the existing bank examination staff; how the new office should interact with FDIC regional offices; and how broadly the office should interpret the consumer protection mandate. The case recounts the positions taken in this debate, the decision arrived at by the FDIC chairman, the early operations of the Office of Bank Affairs, and later attempts to redefine its organizational role.
