Saturday, May 28, 2022

Comptroller

Comptroller (pronounced kuhn-troh-ler)

A variant spelling of controller, used especially as a title of some financial executives.

Circa 1500: From the late Middle English compteroller, a spelling mistake which became a variant of countreroller (from which Modern English ultimately gained controller) due to medieval folk etymology, the notion being there was a link to the Middle French compte (account); the Middle French compteroleur is attested circa 1375.  Originally the two spellings were equivalent and pronounced identically; the sometimes-used modern pronunciation (komp-troll-ah) is based on the spelling.  Controller is thus sometimes a homophone, sometimes not and there seem to be pedants on both sides of fence upon which most sit.  Comptroller and comptrollership are nouns; the noun plural is comptrollers.

Controller came from the From Middle English countreroller, from the Anglo-Norman contreroulour and the Middle French contreroleur (the Modern French contrôleur), from the Medieval Latin contrārotulātor, from contrārotulāre (from which is descended the modern control).  The original meaning in English was “an official in charge of accounts in a king's household" from the late thirteenth century Anglo-French contrerolleour, from the Old French contrerelleor, from the Medieval Latin contrarotulator.  The broader sense of one who manages the finances of a corporation or institution" emerged from circa 1450-1500; the first syllable was confused with count from the Latin comptus (an account) from computare, hence the creation of comptroller.

Comptroller & Controller

Comptroller is an example of the haphazard way mistakes sometimes made their way into English, became entrenched and then, often with some enthusiasm, were adopted throughout the British Empire and beyond.  Although adherence is not universal, the convention of use is that if employed in government service, the job is styled as comptroller (eg Comptroller-General, Household Comptroller etc) and if in the private sector, controller (eg Financial Controller) is used.  Because of its origin, the very existence of “comptroller” attracted disapproval until well into the twentieth century but the distinction between the two words must have proved useful because it has endured; that’s how English works.  The evolution of the convention was organic but unfortunately less helpful than it might have been.  More useful would have been for comptroller to apply to people and controller to electric or mechanical devices for controlling circuits or systems but the convention was a product of its time.

A legacy of empire is that the civil services of many members of the Commonwealth and the United States contain many comptrollers.  In India, for example, the civil service appointments are essentially the same as under the Raj.  The Comptroller and Auditor General of India audits all receipts and expenditure of the Government of India and the state governments, including QUANGOs and other authorities where funding substantially is provided by government.  The Comptroller of the President's Household is a position analogous with a similar appointment at Buckingham Palace and, by statute, is always a Navy Captain.  Similar positions of comptrollers exist in the governor's household in each state and union territory.

Set in stone: The Office of the Comptroller of the Currency.

Although it has existed since emerging in 1863 from the slew of legislation passed during the US Civil War (1861-1865), the regulator of the nation’s largest financial institutions remains one of the more obscure federal bodies, something perhaps related to its name being misleading in that it plays little direct role in currency matters, both the US Federal Reserve (the “Fed”) and the Treasury (of which the independent OCC is technically a part) being far more influential.  The Office of the Comptroller of the Currency (OCC) is an interesting case study illustration a number of the phenomena noted in organizational behavior exclusive to governmental institutions which, unlike institutions which have to justify their ongoing existence on some easily understood metric (like running at a profit).

The OCC’s notional supervisory bailiwick is the “national” banks, so-called because they are chartered under the National Bank Act which also dates from 1863.  The wartime function of all this actually had little to do with the banks; the legislation and the OCC were designed to be a way the Union armies could be financed and with the outcome of the conflict still in the balance, the advantages to be gained by creating a financing mechanism which could strengthen the Northern economy, military and industry by then obvious.  At the time, the banks operated under charters issued by the states and their core business was not attracting deposits and lending but the issuing of banknotes and because the economy ran on banknotes (gold and silver coins had a function but couldn’t support modern commerce as once they had).

Neither the administration nor the Congress really had any alternative as a mechanism to finance the war which had drained the federal coffers induced borrowing to the point where the capital markets were depleted to the extent of being a threat to both the economy and military operations.  While a fiat currency would seem a textbook solution, an acceptance of the concept was still years away so the compromise was for (1) the federal government to charter the banks, (2) to taxed the state banknotes into existence and (3), require the new “national” banks to invest their reserves in US government bonds.  Instantly it created a source of finance the South couldn’t match.  In wartime, the system worked well, perhaps even more effectively than the government had envisaged but what it meant was that when the war ended, the new, powerful, National banks remained but without the demand that they act as a conduit of money to support the needs of the state.

So the big banks proceeded to do what big banks do, the result being over the decades one bank scandal panic and crisis after another until in 1913, the Federal Reserve was created which obviated any the need private banknotes, the national currency (in the form of Federal Reserve notes), then still backed by physical gold the medium of exchange for all purposes.  The big banks adapted well to the new environment and so did the OCC which evolved into what can be understood only as the big bank’s lobbyist, an administrative layer between them and regulation, a tendency furthered by the emergence of what’s known as “regulatory arbitrage”.  Because the US system for chartering banks is a patchwork (states authorize some banks, along with the OCC, and the Federal Deposit Insurance Corporation (FDIC) has an authority physically to examine the records of all banks) the banks can actually choose their regulator and some have left the state-based systems and “joined” the OCC orbit where the regulatory environment is much more benign.  This regulatory arbitrage is self-reinforcing because as institutions shift their status, they also move their fees, thereby further strengthening the OCC, the implication being the banks are valued clients rather than institutions to regulate.

Currencies need to be regulated which was a relatively simple (if technically complex) business when the objects were physical paper (or plastic) and metal but the emergence of cryptocurrencies without a national identity has required a different approach. 

The OCC last had a full-time, permanent comptroller in mid-2020.  President Biden (b 1942; US president since 2021) has made several attempts to have the Senate confirm an appointment but without success.  The Republicans appear to believe only white mane are qualified for such a role and even some Democrat senators have found the political positions of some of the White House’s offering just too radical an given that white men seem now to be anathema to the factions which control the Democratic Party, there seem little prospect the OCC will soon gain a new comptroller.  One suggestion has been to solve many problems by abolishing the OCC and transferring its functions to the FDIC and while that might result in a better regulated environment, as the troubles with the First Republic bank illustrate, its supervisory regime is hardly perfect and despite all that’s been revealed since 2008, the big banks still enjoy an implicit guarantee from the federal government that they’ll be bailed out in the event of another financial crisis. They are still too big to fail, regardless of which authority acts as their nominal supervisor.

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