Fed Governance – Accountable Independence, or a Spider’s Web?

On the heels of the worst financial crisis since the Great Depression, financial reform legislation passed last year directed the Congress’ General Accountability Office (GAO) to examine Fed emergency lending in the crisis, and also to review the Fed’s governance. Last month, the GAO issued its first report. This report documented how the Fed extended over $1 trillion of various forms of emergency lending, and politely identified room for improvement in management procedures administering this kind of aid in the future. The second report, with broader implications for the future of our central bank, will likely be issued in October.
To help set the stage for that second report, here’s a review of the basic framework for Federal Reserve governance, and a brief introduction to some of the topics relevant for that second report:
The Federal Reserve System, “the Fed,” has a lot of moving, interconnected parts. The two basic components are the Federal Reserve Board of Governors, and the collection of 12 Federal Reserve Banks. In turn, the Federal Open Market Committee (FOMC) melds those two parts to make the Fed’s main monetary policymaking body.
The Board of Governors is a government agency, an independent regulatory commission like the SEC. The Board has 7 seats which are (normally) filled by Presidential appointment, subject to Senate confirmation. (Two of those seats have been vacant for some time.) The Board appointments are for 14 year terms, and they are ‘staggered’ (the individual terms do not coincide with one another). The long, staggered terms are asserted to promote a valuable independence from nearsighted political influence. By law, one of those seven members is appointed by the President to serve as Chairman. Ben Bernanke was first appointed to that post in 2006 by George Bush, and he was reappointed to that role by President Obama in 2010.
The Board of Governors is primarily a policymaking and oversight body, while the day-to-day operations, supervisory and examination roles, and economic reconnaissance are the main province of the 12 Reserve Banks around the country. The banks are separately chartered government corporations. The Federal Reserve Act stipulates that they are to be “conducted under the supervision and control of a board of directors.” But Reserve Bank operations are also subject to supervision and regulation from the Board of Governors and Congressional oversight lies behind the scenes as well, at least in theory. In another melding of authority, Federal Reserve supervisory authority for private financial institutions is rooted in the Board of Governors, but much of that authority is delegated by the Board of Governors to the Reserve banks, with the Board retaining oversight authority after that delegation.
Each of the 12 Reserve Banks is led by a president, whose appointment by the Reserve Banks’ board of directors is subject to the approval of the Board of Governors in Washington. Each of the 12 Reserve Banks is governed by their own board of directors, with the boards holding 9 members grouped in three classes. The 3 Class A directors in each Reserve Bank board are elected by member banks in the district, and ‘represent’ those member banks. The three Class B directors are also elected by member banks, but ‘represent’ the public, at least in theory. The three Class C directors are appointed by the Federal Reserve Board of Governors, and they ‘represent’ the public as well. Read more