For more than a decade the Office of the Comptroller of the Currency has floated in its own parallel universe, ignoring -- or worse, failing to expose -- evidence of lawbreaking by major banks. It seems to me that the best way to encourage them do a better job is to put some of their skin in the game. So perhaps the next organization the OCC should fine is itself -- for the offense of failing to accomplish its core mission and in so doing, exposing the American consumer to great harm. Then, perhaps, we should take that money, and hand it over to the CFPB, which has a better shot at accomplishing what the OCC is either unable or unwilling to get done.
Adam Levin is chairman and cofounder of Credit.com and Identity Theft 911. His experience as former director of the New Jersey Division of Consumer Affairs gives him unique insight into consumer privacy, legislation and financial advocacy. He is a nationally recognized expert on identity theft and credit.