In the midst of the flurry of nominations and appointments to federal agencies, President Trump has appointed an acting chair of the Office of the Comptroller of the Currency (OCC), and nominated permanent heads of the OCC and the Consumer Financial Protection Bureau (CFPB). 

Just a few days after appointing former National Credit Union Administration Chair Rodney Hood as acting comptroller of the currency, President Trump nominated Jonathan Gould to lead the OCC and Jonathan McKernan to lead the CFPB. Gould served as chief counsel of the OCC from 2018 to 2021. McKernan was most recently a member of the board of the Federal Deposit Insurance Corporation.

These nominations are interesting for a number of reasons:

• They occurred with little fanfare (i.e., no White House press releases or social media announcements), which is uncharacteristic for the Trump Administration
• Rodney Hood, the very newly appointed acting head of the OCC, is not being tapped to lead the agency on a permanent basis and will not undergo Senate confirmation
• Hood, Gould and McKernan are Washington, D.C. “insiders,” each having previously held senior leadership roles at bank regulatory agencies
• The nomination of McKernan to lead the CFPB is a notable contrast to the openly hostile leadership of the current acting head of the CFPB, Russell Vought (e.g., ordered most work to stop, closed the headquarters for at least a week, cut off funding from the Federal Reserve)

There is currently no indication of the timeline of these nominations or whether they will have public hearings. McKernan's nomination to lead the CFPB will likely receive the most interest and scrutiny from the Senate, especially regarding plans for the agency and whether he intends to adopt the dismantling approach of the current acting head. 

While the nominations are pending, Hood will begin his leadership of the OCC and Vought will continue to lead the CFPB. 

We’ll continue to monitor and assess the impact of these appointments and the direction that the agencies will take.