Why Governor Barr Is Right

In a speech delivered on June 6, 2026, at American University, Federal Reserve Governor Michael S. Barr issued one of the most urgent warnings in recent memory about the trajectory of U.S. bank regulation. His address, titled “Deregulating in a Financial Boom: What Could Go Wrong?”, laid out a meticulous, evidence-based case against the current wave of bank deregulation unfolding across federal regulatory agencies. Governor Barr is right — and the constellation of risks now accumulating in the banking sector makes his warnings not merely prudent but essential.

Barr’s central argument is straightforward: deregulation may deliver a short-term sugar high, but it leaves the financial system dangerously underinsured against the kind of catastrophic shocks that devastate ordinary Americans. He draws on a rich body of academic research and the bitter lessons of history — the Great Depression, the savings and loan crisis of the 1980s, and the Global Financial Crisis of 2007–2009 — to show that weakening regulatory safeguards during periods of apparent financial strength is precisely when policymakers are most tempted, and most likely, to make irreversible mistakes. I agree with this assessment entirely.

The specific regulatory rollbacks Barr catalogs are alarming in their breadth. Over the past year and a half, the Federal Reserve and other banking agencies have reduced the stressfulness of bank stress tests, eroded leverage ratios for large banks, weakened the U.S. implementation of the Basel III international capital accord, and reduced the GSIB surcharge — the capital add-on specifically designed to offset the systemic danger posed by the eight largest banks, which together hold approximately 60 percent of banking sector assets. In aggregate, these steps have reduced capital requirements for the largest banks by 6 percent, translating to $60 billion less capital available to absorb losses and prevent failure from spreading through the financial system. Barr rightly notes that current capital standards were already near the low end of what academic research identifies as optimal; cutting further tips the balance toward fragility, not strength.

I have sounded the alarm repeatedly in recent months, documenting in sharp detail the specific vulnerabilities now lurking beneath the surface of the banking sector. “Risks in the Banking Sector: What’s Lurking Behind the Headlines,” I wrote about dangers that headlines do not capture — risks building quietly even as bank profits appear robust. In “Rising Private Credit Defaults Are Testing Banks and Insurers“ I highlighted how the rapid growth of private credit markets is now generating real stress, with defaults rising and banks deeply entwined with this sector through credit lines and shared asset exposures. Barr makes the same point in his speech: bank credit commitments to other financial entities exceeded $2.6 trillion in the second half of 2025, and banks and nonbanks are now so closely interconnected that stress in one sector will rapidly transmit to the other.

I have also written about my significant concerns about changing the CAMELS supervisory rating system. Barr also raises this when he describes the Federal Reserve’s weakening of the large-bank rating framework as essentially “grade inflation.” In “Rewriting Banking’s Report Card: The Risks of Changing CAMELS,” my main point is that shifting to backward-looking financial measures, and reducing the weight placed on forward-looking risk management indicators, means regulators will be slower to spot the problems that matter most. Barr notes that the share of large banks rated as well-managed under the new, more permissive framework doubled from the end of 2024 to recent observations — not because banks got better, but because the grading curve was relaxed.

The macroeconomic stakes could not be higher. “Banks Face a Two-Front War: Inflation and Rising Defaults” and this is the environment in which these regulatory changes are being made: banks are simultaneously grappling with sustained inflationary pressures and a growing wave of credit defaults across consumer and commercial portfolios. The Federal Reserve itself is warning that “…. America’s Financial System Is Strong But Risks Are Rising.” The Fed’s financial stability reports have acknowledged elevated asset valuations, stretched credit markets, and emerging vulnerabilities — even as deregulatory pressure mounts. These are not abstract concerns. They are the precise conditions under which weaker capital buffers and lighter supervisory oversight could prove catastrophic.

The historical record Barr invokes is sobering. Resolving the savings and loan crisis cost $160 billion — 5 percent of one year’s GDP — the equivalent of $1.6 trillion in today’s economy. The Global Financial Crisis required direct government outlays of approximately $650 billion, or 4.5 percent of annual GDP, to stabilize the system, and even that intervention left unemployment at 10 percent and scarred the balance sheets of millions of households for years. Research by Christina and David Romer, covering twenty-four advanced economies, found that GDP declines following financial crises peak at 6 percent after three and a half years. Estimates supporting the design of Basel III put cumulative output losses far higher — between 20 and 60 percent of GDP. These tail risks during a stock market boom should not be ignored. They are the predictable consequences of allowing regulatory safeguards to erode.

I still believe that “Weakening Bank Regulations Is a Risk Americans Can’t Afford” and “Deregulate Banks Now, Downgrade Later.” Short-term competitive pressure, profit-seeking, and political convenience are driving regulatory decisions whose costs will be borne by everyone — not just the banks and their shareholders. When the next crisis comes, as history shows it eventually will, it will be workers, small businesses, and communities who absorb the blow.

Governor Barr’s speech is an act of institutional conscience from within the Federal Reserve itself. He has dissented from each of the major deregulatory decisions affecting large banks, and he continues to speak out because he understands what is at stake. The cumulative relaxation of capital requirements, liquidity rules, supervisory rigor, and consumer protections does not represent a careful recalibration of the regulatory balance — it represents a systematic dismantling of the safeguards built from the wreckage of past crises.

The evidence is clear, the history is unambiguous, and the current risk makes this the worst possible moment to reduce the resilience of the banking system. Governor Barr is right: when the bill comes due, we will all pay the price.