14 - Administrative Politics with Clear Stakes and Venues: Strategic Commenting upon Federal Reserve Debit Card Regulations

Summary

Daniel Carpenter and Brian Libgober conclude Part IV by examining policymaking that originates in the bureaucracy, focusing on debit card regulation under the Dodd-Frank Act. Here, key interest groups precisely understood the stakes and process of bureaucratic policymaking, rendering it highly traceable. In addition, the stakes were quite zero-sum. The authors argue that these conditions encourage more intense and effective interest group activity than is the case in typical administrative policymaking. To assess this argument, the chapter provides a detailed narrative of the rule’s development, integrating quantitative evidence about the impact of the rule’s evolution on stakeholder firms. Consistent with expectations, the analysis suggests that debit card regulation attracted more lobbying and of a more diverse kind than other Dodd-Frank regulations, including ones such as the Volcker Rule where the aggregate impact was far higher but with less readily traceable policy effects. These findings highlight that even in administrative policymaking, the traceability of policy outcomes to government officials’ decisions will affect how private interests act to shape these decisions.