A libertarian would require competition and free entry into banking which we do not have. If people want ESG funds, there are plenty of them that directly steer investments to whatever socially conscious ends people want. The real point of the OCC rule is to try to stop the Fed from requiring de-banking of unpopular industries by inventing fictitious risks.
Fictitious risk is OCC code word for stable coins, flash loans and the rest. OCC does not want Swift banks locked out of the new sandbox markets.
John's one other comment about free entry and exit has a corollary, all the banking theories will fail unless the condition is at least assumed in the alternatives. If you do not have free entry and exit, somewhere, then your theory has no algebra, you cannot even talk about outcome possibilities.
The alternative, monefiscals, Next New Green Deal stuff; all that cannot predict outcomes until they have a free entry and exit predictor in their model.
A philosophical note. My free exit and entry base predictor requirement is often called the libertarian premise as John noted. Libetarians get blames for a lot of mathematical requirements. If we should blame anyone, blamed the anarchists, they are the one making new chaos.
The bounded model is a fuzzy but constant market size. At the fundamental, the model is embedded in a boundary containing market of unknown size. And the fundamental answer will be the stable entry and exit congestion at the model boundary. This is known as the error coefficient in liner least squares. In sub atomic, known as the vacuum expectation. In the general case, that is what stabilizes the Markov relative prime sets, seen as round off errors.
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