Conceived as a counterweight to public administration of monetary policy, the quasi-private Federal Reserve Banks now seem an institutional anomaly. The role that private interests play in Reserve Bank governance has prompted criticism that their anomalous structure renders the Reserve Banks unduly insulated and prone to financial industry influence. Yet a survey of the practical effect of the Reserve Banks’ unusual governance structure demonstrates not a privileging of private industry interests, but instead a pattern of elevating Federal Reserve System insiders, with potential involvement from publicly appointed Board of Governors of the Federal Reserve System. As a result, this Note argues that conventional fears of the consequences of Reserve Bank governance are largely unrealized. This pattern of elevating Federal Reserve System insiders, however, raises alternate concerns of institutional homogeneity. This Note thus advocates for transparency reforms aimed at mitigating these concerns—reforms that address not a problem of industry influence in Reserve Bank governance, but one of Federal Reserve System insularity.
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