Bank regulation in the United States is highly fragmented compared with other G10 countries where most countries have only one bank regulator. In the US banking is regulated at both the federal and state level, depending on the type of charter a banking organization has and on its organizational structure, it may be subject to numerous federal and state banking regulations. Some of the key regulators that a US bank may be regulated by can be categorized by the activity the bank is carrying out for standard banking activities such as lending and borrowing. The regulatory authorities will include the Federal Reserve System, otherwise known as the Fed, which is the central bank in the US, the office of the comptroller of the currency, the OCC, which has responsibility for ensuring banks operate in a safe and sound manner. And the Federal Deposit Insurance Corporation, the FDIC, which provides guarantees for depositors if banks fail. Each state will also have its own regulators and many other regulators may be involved with regards to customer protection and financial crime.

For securities and investing activities, the main regulators are the Securities and Exchange Commission, the SEC, which regulates the market as a whole for the protection of the consumer, and to promote confidence in the market and the financial industry Regulatory authority or FINRA, which is responsible for ensuring banks follow the necessary rules. For the futures and options market, the main regulators are the CFTC, the Commodities Futures Trading Commission, and the NFA, the National Futures Association. In essence, the CFTC sets the regulations and the NFA ensures firms comply with these regulations. Apart from the bank regulatory agencies, the US maintains separate securities, commodities and insurance regulatory agencies at the federal and state level. Unlike Japan and the United Kingdom, where regulatory authority over the banking, securities and insurance industries is combined into one single financial service agency. US Banking regulation addresses privacy disclosure, fraud prevention, anti-money laundering, anti-terrorism, anti-usury lending, which aims to prevent lending at excessive interest rates and the promotion of lending to lower income populations. Some individual cities also enact their own financial regulation laws, for example, defining what constitutes usurious lending. In the United Kingdom, the Bank of England, BOE, is a critical regulator given its role as the central bank. It is responsible for preventing the buildup of systemic risk, which is the risk associated with a collapse or failure of a company, industry, financial institution, or an entire economy. It is the risk of a major failure of a financial system. The BOE also acts as a settlement agent to enable financial institutions to make payments to each other in times of financial stress. The BOE is willing to step in and to be the lender of last resort. Should a financial institution deemed too big to fail, find itself in trouble, or is deemed to otherwise be important to support.

The UK uses what is referred to as a Twin Peak approach to regulation using two specialist peak regulators. The Prudential Regulation Authority PRA is responsible for the maintenance of financial system stability. While the financial conduct authority FCA is responsible for market conduct and consumer protection. To carry out their role, the PRA creates policies for firms to follow and monitors their business activities with the aim of ensuring that the financial services and products are provided in a safe and sound way. Their regulation is designed to be forward looking and take into account the bigger picture, rather than just regulating an individual firm in isolation. To ensure that the UK financial markets are honest, competitive, and fair for consumers, the FCA has three main objectives to protect consumers from bad conduct, to protect the integrity of the UK financial system, and to promote competition in the interest of consumers. Under the EUs single supervisory mechanism regulation SSM, the European Central Bank, the ECB carries out clearly defined supervisory tasks to protect the stability of the European financial system. Together with the National Competent Authorities NCAs of participating member states, the SSM Regulation and the SSM framework regulation provide the legal basis for the operational arrangements related to the prudential tasks of the SSM. The European system set up for the supervision of the financial sector is made up of three supervisory authorities, the European Securities and Markets Authority, the European Banking Authority, and the European Insurance and Occupational Pensions Authority. The system also comprises the European Systemic Risk Board, as well as the Joint Committee of the European Supervisory, A authorities and the National Supervisory Authorities. While the National Supervisory authorities remain in charge of supervising individual financial institutions, the objective of the European supervisory authorities is to improve the functioning of the internal market by ensuring appropriate, efficient, and harmonized European regulation and supervision. We'll have a quick look at how two European Union countries, Germany and France, implement these EU directives in their own countries. In Germany, the BaFin and the Deutsche Bundesbank share banking supervision, but not as a Twin Peak model, like the UK. BaFin is the administrative authority responsible for the supervision of institutions under Germany's Banking Act, the Deutsche Bunesbank's responsibility is to assist the BaFin in the supervision of banks and financial services providers.

France has two regulators responsible for the authorization and supervision of banks, insurers, and other financial institutions. The ACPR regulates the banking and insurance sectors in France. It is charged with preserving the stability of the financial system and protecting the customers, insurance policy holders, members and beneficiaries of the persons that it supervisors. The AMF regulates participants and products in France's financial markets. It approves the rules applicable to financial markets and market infrastructures, approves the corporate finance transactions of listed companies and authorizes financial services professionals and the collective investment products under its supervision.