Some banking-industry experts are concerned that federal regulation of the industry has not kept up with the sweeping changes in the past twenty years, during which time community banks' share of deposits has fallen from a majority to just 21 percent. Former Federal Deposit Insurance Corp. (FDIC) Chairman William Isaac is concerned that regulators may not have created "procedures and the expertise to deal with" concentration, while L. William Seidman, who also once chaired the FDIC, says "regulators are always behind the curve." Isaac and Seidman both say that federal agencies might get sidetracked by battles over regulatory jurisdiction while big banking companies run into problems. However, both the Office of the Comptroller of the Currency (OCC) and the FDIC say they are prepared; the OCC says it looks at each of the 25 biggest U.S. banks every day and has updated its exams, while the FDIC says it has prepared contingencies for many situations, including failure of large banks. Nonetheless, some in the industry say there could be a problem with the FDIC Improvement Act of 1991's "systemic risk" exception, which allows the federal government to bail out large banks whose failure could hurt the economy; there is concern that there are too many such banks. Independent Community Bankers of America executive vice president Kenneth A. Guenther is among those hoping the FDIC's soon-to-be-proposed deposit insurance reforms take this into account.