Bank safety-and-soundness examinations barely slow down during a federal shutdown — because their regulators aren't funded by Congress

FDIC, Federal Reserve, and OCC examiner operations across the 2013, 2018-19, and 2025 shutdowns

Summary

It essentially doesn't. Bank safety-and-soundness examinations — the on-site and off-site supervisory work done by the FDIC, the Federal Reserve, and the OCC — do not stop or meaningfully slow during a federal government shutdown, and there is no examination backlog to clear afterward. That is because none of the three federal banking regulators is funded through the annual congressional appropriations process: the FDIC and OCC run on assessments/fees paid by the banks they supervise, and the Federal Reserve funds itself from its own monetary-policy operations. Since a shutdown is a lapse in appropriated funding, agencies that never draw on appropriations have nothing to lapse. Examiners keep reporting to work and exam schedules proceed largely as planned. This has held across the three longest recent shutdowns: 16 days in October 2013, 35 days in December 2018-January 2019, and a record 43 days in October-November 2025.

This stands in sharp contrast to the SEC and CFTC, which are appropriations-funded and furlough most staff during a shutdown, producing a real backlog of registration reviews, exam requests, and enforcement matters that takes weeks to work through once funding resumes.

Why bank regulators are structurally insulated

The three prudential bank regulators finance themselves outside the appropriations process:

FDIC — funded by deposit-insurance assessments paid by insured banks, plus investment income; receives no annual appropriation.
Federal Reserve (including bank supervision staff at the Board and the 12 Reserve Banks) — funded from its own income on securities holdings and other monetary-policy operations.
OCC — funded almost entirely (about 96%, per the Treasury Department's own congressional budget justification for the OCC) from semiannual assessments on national banks and federal savings associations, with the remainder from investment income. The OCC sits inside the Treasury Department administratively, but its examiner workforce and operating budget do not depend on Treasury's appropriated funds.

Because a shutdown is legally a lapse in appropriated budget authority, an agency with no appropriated budget authority to begin with has nothing that lapses. All three agencies' contingency guidance and public shutdown FAQs state examiners should report to work as usual.

What the record shows across three shutdowns

Shutdown	Duration	Effect on safety-and-soundness exams
October 2013	16 days	FDIC, Fed, OCC continued normal supervisory operations; no reported exam suspension.
Dec 2018 - Jan 2019	35 days (longest at the time)	Banking agencies remained open and operational. Some secondary, non-exam friction appeared: an FDIC rule's public-comment period could not commence, and some Bank Holding Company Act application comment periods were disrupted because they rely on Federal Register publication (which itself can be delayed). Regulators jointly encouraged banks to work with shutdown-affected borrowers.
Oct - Nov 2025	43 days (new record)	FDIC, Fed, OCC again confirmed continued normal operations. The OCC (housed in Treasury) saw only "minor" administrative friction since most Treasury staff are deemed essential. The Fed, FDIC and OCC jointly issued shutdown-related lending guidance (e.g., on the lapsed National Flood Insurance Program) — evidence the agencies were actively working, not furloughed.

No source found in this research — agency shutdown FAQs, law-firm shutdown advisories, or trade press covering all three episodes — reports a suspension of bank examinations or a subsequent examination backlog for FDIC/Fed/OCC. The disruptions that do surface around shutdowns and banks are adjacent, not supervisory: the National Flood Insurance Program lapses (blocking mortgage closings requiring flood insurance), SBA loan guarantee processing pauses, CDFI Fund application processing pauses, and a blackout of BLS/Census economic data banks use for planning and stress testing.

Contrast: agencies that stop, and build a real backlog

The SEC and CFTC are funded through normal appropriations (the SEC's fee collections are appropriated, not directly retained) and furlough the large majority of staff in a shutdown. Corporation Finance, Investment Management, Trading and Markets, and OCIE (exams) at the SEC stop processing registration statements, exemptive applications, and routine examinations, producing a genuine backlog of registration reviews and exam work that agency staff must then work through once funding resumes — the opposite of the banking-agency picture. Brookings drew exactly this comparison in arguing that bank and market regulators should be funded the same way, because the contrast between the two groups is so stark.

What This Report Does Not Answer

Quantitative examiner-hours-lost or backlog-days-to-clear figure: No public dataset was found quantifying examiner-hours lost or a specific backlog-clearance duration for FDIC/Fed/OCC, because agencies and trade press uniformly report no material disruption occurred to quantify. AskAmerica's own catalog was checked (search_catalog) and confirmed to carry no examination-schedule or furlough-tracking table, so this gap is a genuine absence in both this corpus and public reporting, not an unchecked assumption.