But I think it would be a mistake to conclude from these remarks that banking will be easier. I think this is an important dynamic to articulate: Direct regulatory burdens might be lessened for banks, but competitive pressures and consumer expectations are sure to increase. Regulators no longer want to be overly cautious of technology and innovation; they won’t act as the moat. There is no longer ideological opposition and skepticism to nonbank, technology-first entrants into the bank space; there now seems to be ideological openness. What does that mean for the future of banking? The future of banks? The future of community banks within that?
Take, for example, the “skinny master account” that was floated by Fed Gov. Christopher Waller in an October speech. McKernan said he “love[d]” the proposal, but that it would need to be carefully studied and, if formally proposed, implemented in “cautious, calibrated” steps that foster innovation in the banking and payment system.
“This is one of these questions that will have compounding implications as we move forward. How we decide or don't decide — that implicitly is a decision of its own,” he said. “Fair to say, we're going to see a lot more developments on this topic in the coming months.”
One potential challenge or concern is how a skinny master account could impact liquidity in the financial institutions space. Institutions may have payment-related liabilities on their balance sheets — a natural advantage tied to their master accounts. A skinny master account could be one more pound of competitive pressure on these liabilities, on top of pressures posed from other institutions, money market funds and newer entrants like reward-paying stablecoins and crypto national trust banks.
“Like it or not, technology is going to pressure that dynamic. … That is a profound change in market structure that we need to think about: the implications for consumers, for growth, for credit, maturity, liquidity, intermediation. It's not our job to stand in the way of change,” McKernan said. “But we need to make sure that these things are driven by fundamentals and not by the regulatory framework, and that we are thinking ahead as to what that means for the financial system.”
(Also: “Like it or not” is kind of a wild phrase to say, but it might be one of the more plainly stated truisms on that stage.)
But even outside of the challenges that come from navigating a more competitive and permissive regulatory environment, financial institutions are burdened by their own legacy technology and business models that are adapting slowly to digital channels and newer capabilities.
Speaking of the future of finance, I was fortunate enough to share the stage at AFC as a moderator for a panel with four bankers involved in embedded finance: Jason Hardgrave, CEO of Darien, Connecticut-based DR Bank; Austin Strong, CEO of Ogden, Utah-based TAB Bank; Dub Sutherland, CEO of Pecos, Texas-based TransPecos Banks; and Matt Michaelis, chairman and CEO of Emprise Bank.
On my panel, they discussed how they changed their banks to meet the tech and compliance demands of the embedded finance space. Of the work needed to run virtual ledgers and build out artificial intelligence-driven capabilities that can better monitor and identify risks, while also managing the identity and talent shift needed to move from physical distribution channels and communities to digital ones.
I have always believed that the embedded finance and banking as a service banks will be the first to need to do this, but they’re the harbingers. Increasingly, I believe all banks will need to follow in their footsteps. And as the CEOs on my panel will tell you: none of that is easy.
So, back to McKernan’s statement and this newsletter’s opening question: What does the future of banking look like? Are there more banks in the future or less? Are there more de novos banks in 2035 than there are de novos in 2025? Will the United States have 500 fewer banks, 1,000 or more? Will more traditional commercial banks join the ranks of my esteemed panelists and grow through embedded finance and fintech partnerships, or will they grow through branches? Will I be using stablecoins instead of travel credit cards, and will my assets be tokenized instead of tangible?
I don’t know, and I couldn’t begin to make specific predictions (I would uhhh not write a newsletter if I could). I may not even know if I’ll know what the future looks like until it becomes my present. McKernan is thinking about these questions as well, even as he and the agency heads and lawmakers march us forward to that unknown destination.
“Top of mind for me is trying to think more creatively about the financial system of the future. [That’s v]ery challenging because, of course, whatever we can imagine is not actually going to be where we end up,” he said. “Then working backwards from there, to think about what needs to change in the financial regulatory framework.”