Susan Krause Bell

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+1 202 869 9512 direct
Washington, DC

Previous Experience

  • Senior Deputy Comptroller for International Affairs, Office of the Comptroller of the Currency
  • Senior Deputy Comptroller for Bank Supervision Policy, OCC 
  • Deputy Comptroller for Economic Analysis and Strategic Planning, OCC 
  • Member, Basel Committee on Banking Supervision, OCC 

Thought Leadership

  • "Spotlight Turns to Risk Culture," Promontory Sightlines InFocus, March 20, 2014
  • "The New U.S. Framework for Supervision of Foreign Banks," Promontory Sightlines InFocus, March 3, 2014
  • "Financial Regulators Flag Systemic Concerns," Promontory Sightlines InFocus, May 30, 2013
  • "Deconstructing the Coming U.S. Capital Regime," Promontory Sightlines InFocus, November 19, 2012
  • “Banking in the Era of Financial Reform,” RMA Journal, October 2010
  • Numerous speeches before financial industry groups on Basel III, the Dodd-Frank Act, risk management, and other topics

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Susan Krause Bell

Managing Director

Susan advises clients on new and ongoing regulatory issues, such as the Dodd-Frank Act and Basel capital rules, and ongoing supervisory priorities, including enterprise risk management and corporate governance. She also assists banks in managing and implementing regulatory directives. Before joining Promontory, Susan worked for 20 years at the Office of the Comptroller of the Currency.


Susan worked for 20 years at the Office of the Comptroller of the Currency, where she served as senior deputy comptroller for international affairs, senior deputy comptroller for bank supervision policy, and deputy comptroller for economic analysis and strategic planning. She was a member of the OCC executive committee, where she managed the OCC’s international relationships, and of the Basel supervisors’ committee, where she served as chair of the first Basel transparency group. She also was chair of the Federal Financial Institutions Examination Council’s supervision task force, which coordinated supervisory policies among the U.S. banking agencies. During her time at the OCC, Susan oversaw the development of the Supervision by Risk program, which was subsequently emulated by other U.S. bank supervisors and several foreign regulatory agencies. She also led a major initiative to reduce regulatory burden and improve credit availability.


  • Ph.D., economics, University of Southern California
  • M.A., economics, University of Southern California
  • B.A., mathematics, University of California at Los Angeles

Affiliations, Awards, and Civic Engagements

Representative Engagements

  • Assisted a large bank that was in danger of losing its financial holding company status due to a regulatory downgrade; the client implemented corrective actions and restored its rating.
  • Led a team that advised a large trade association and its members on monitoring and implementing rule-making stemming from the Dodd-Frank Act.
  • Conducted an assessment of a bank’s enterprise risk management architecture and made recommendations for improvement, as directed by a regulatory order.

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