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    Subject Term: "Federal reserve banks"

    10 publications with a total of 53 open recommendations including 1 priority recommendation
    Director: Lawrance L. Evans, Jr.
    Phone: (202) 512-8678

    17 open recommendations
    Recommendation: To help improve the consistency of federal banking regulators' stress test requirements and help ensure that institutions overseen by different regulators receive consistent regulatory treatment, the heads of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency should harmonize their agencies' approach to granting extensions and exemptions from stress test requirements.

    Agency: Department of the Treasury: Office of the Comptroller of the Currency
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To help improve the consistency of federal banking regulators' stress test requirements and help ensure that institutions overseen by different regulators receive consistent regulatory treatment, the heads of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency should harmonize their agencies' approach to granting extensions and exemptions from stress test requirements.

    Agency: Federal Deposit Insurance Corporation
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To help improve the consistency of federal banking regulators' stress test requirements and help ensure that institutions overseen by different regulators receive consistent regulatory treatment, the heads of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency should harmonize their agencies' approach to granting extensions and exemptions from stress test requirements.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To help provide stronger incentives for companies to perform company-run stress tests in a manner consistent with Federal Reserve goals, the Federal Reserve should remove company-run stress tests from the CCAR quantitative assessment.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To increase transparency and improve CCAR effectiveness, the Federal Reserve should publicly disclose additional information that would allow for a better understanding of the methodology for completing qualitative assessments, such as the role of ratings and rankings and the extent to which they affect final determination decisions.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To increase transparency and improve CCAR effectiveness, the Federal Reserve should, for future determinations to object or conditionally not object to a company's capital plan on qualitative grounds, disclose additional information about the reasons for the determinations.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To increase transparency and improve CCAR effectiveness, the Federal Reserve should publicly disclose, on a periodic basis, information on capital planning practices observed during CCAR qualitative assessments, including practices the Federal Reserve considers stronger or leading practices.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To increase transparency and improve CCAR effectiveness, the Federal Reserve should improve policies for official responses to CCAR companies by establishing procedures for notifying companies about time frames relating to Federal Reserve responses to company inquiries.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To strengthen the scenario design process, the Federal Reserve should assess--and adjust as necessary--the overall level of severity of its severely adverse scenario by establishing a process to facilitate proactive consideration of levels of severity that may fall outside U.S. postwar historical experience.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To strengthen the scenario design process, the Federal Reserve should assess--and adjust as necessary--the overall level of severity of its severely adverse scenario by expanding consideration of the trade-offs associated with different degrees of severity.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve understanding of the range of potential crises against which the banking system would be resilient and the outcomes that might result from different scenarios, the Federal Reserve should assess whether a single severe supervisory scenario is sufficient to inform CCAR decisions and promote the resilience of the banking system. Such an assessment could include conducting sensitivity analysis involving multiple severe supervisory scenarios--potentially using CCAR data for a cycle that is already complete, to avoid concerns about tailoring the scenario to achieve a particular outcome.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To help ensure that Federal Reserve stress tests do not amplify future economic cycles, the Federal Reserve should develop a process to test its proposed severely adverse scenario for procyclicality annually before finalizing and publicly releasing the supervisory scenarios.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should apply its model development principles to the combined system of models used in the supervisory stress tests.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should create an appropriate set of system-level model documentation, including an overview of how component models interact and key assumptions made in the design of model interactions.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process to test and document the sensitivity and uncertainty of the model system's output--the post-stress capital ratios used to make CCAR quantitative assessment determinations--including, at a minimum, the cumulative uncertainty surrounding the capital ratios and their sensitivity to key model parameters, specifications, and assumptions from across the system of models.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process to communicate information about the range and sources of uncertainty surrounding the post-stress capital ratio estimates to the Board during CCAR deliberations.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process for the Board and senior staff to articulate tolerance levels for key risks identified through sensitivity testing and for the degree of uncertainty in the projected capital ratios.

    Agency: Federal Reserve System
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Lawrance Evans
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: To provide greater assurance that the Federal Reserve is complying with the Monetary Control Act's requirement to establish fees on the basis of costs actually incurred and an allocation of imputed private-sector costs, the Chair of the Federal Reserve Board of Governors of the Federal Reserve System should consider ways to incorporate the costs related to integrated planning for recovery and wind down and compliance with antimoney-laundering requirements, to the extent practicable, in its imputed private-sector cost methodology.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To provide greater assurance that the Federal Reserve is complying with the Monetary Control Act's requirement to establish fees on the basis of costs actually incurred and an allocation of imputed private-sector costs, the Chair of the Federal Reserve Board of Governors of the Federal Reserve System should periodically obtain independent testing of the methods the Federal Reserve uses to capture its actual costs and simulate those of the private sector.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Alicia Puente Cackley
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: To help ensure that adequate data collection efforts by state insurance regulators produce sufficient, reliable data to oversee the LPI market, NAIC should work with the state insurance regulators to develop and implement more robust policies and procedures for the collection of annual data from LPI insurers to ensure they are complete and reliable.

    Agency: National Association of Insurance Commissioners
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: To help ensure that adequate data collection efforts by state insurance regulators produce sufficient, reliable data to oversee the LPI market, NAIC should work with the state insurance regulators to complete efforts to obtain more detailed national data from LPI insurers.

    Agency: National Association of Insurance Commissioners
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Lawrance Evans
    Phone: (202) 512-8678

    4 open recommendations
    Recommendation: To ensure that NCUA has adequate authority to determine the safety and soundness of credit unions, Congress should consider modifying the Federal Credit Union Act to grant NCUA authority to examine technology service providers of credit unions.

    Agency: Congress
    Status: Open

    Comments: In July 2015, we suggested that Congress modify the Federal Credit Union Act to grant NCUA authority to examine technology service providers of credit unions. As of October 2016, Congress had not granted NCUA such authority.
    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency: Department of the Treasury: Office of the Comptroller of the Currency
    Status: Open

    Comments: In July 2015, we recommended that the Office of the Comptroller of the Currency (OCC) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. In September 2015, OCC stated that it is taking two actions to respond to our recommendation. First, the agency is integrating the Cybersecurity Assessment Tool (Tool), developed by OCC and other federal financial institution regulators, into OCC's ongoing IT examinations of national banks and federal savings associations. Officials believe that the Tool will provide OCC with a repeatable and measurable process for assessing both the level of risk and the maturity of risk management processes within and across OCC-supervised institutions. Also, officials believe that data gathered in this process will allow OCC to monitor industry trends and identify new or emerging weaknesses where additional guidance or supervisory actions may be needed. Furthermore, the Tool will help OCC allocate examiner resources and better target examiner training. OCC began integrating the Tool in selected examinations in December 2015. Second, OCC stated that it enhanced its guidance and procedures for examiners to identify and aggregate supervisory concerns into matters requiring attention (MRAs), which are the mechanism OCC uses to communicate supervisory concerns to bank management and directors. OCC believes that the enhancements will facilitate systemic categorization of supervisory concerns that strengthen recording, monitoring, and analyzing of volumes and trends across bank portfolios. Also, the enhanced guidance discusses the relationship between MRAs, interagency ratings, OCC's risk assessment system, and enforcement actions. OCC believes that these process enhancements combined with the integration of the Tool, will improve its ability to assess information security practices at medium and small institutions. We will continue to monitor OCC's progress in implementing the Tool and the resulting trend analyses that the Tool is intended to facilitate.
    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency: Federal Reserve System
    Status: Open

    Comments: In July 2015, we recommended that the Board of Governors of the Federal Reserve System (Board) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. As of October 2016, the Board had not provided an update on its efforts to address this recommendation.
    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency: National Credit Union Administration
    Status: Open

    Comments: In July 2015, we recommended that the National Credit Union Administration (NCUA) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. In July 2016, NCUA told us that it and the other federal financial institution regulators issued the Cybersecurity Assessment Tool (Tool) in June 2015 to provide a comprehensive method for institutions to benchmark their cybersecurity programs. Officials believe that the Tool will allow examiners to consistently and methodically look at credit union risks and trends, as well as collect detailed information on the risks and mitigating controls employed by credit unions. When the Tool is fully implemented, officials expect to be able to aggregate risk indicators and program gaps across the credit union industry to improve resource deployment and enhance cybersecurity supervisory oversight. NCUA plans to begin pilot testing the Tool in late 2016 with program integration targeted for July 2017. We will continue to monitor NCUA's progress with this program and revisit our recommendation in July 2017.
    Director: Lawrance L. Evans, Jr.
    Phone: (202) 512-8678

    5 open recommendations
    Recommendation: To improve FSOC's control activities and help ensure that it better manages its determination process and achieves intended results, the Secretary of the Treasury, in his capacity as the Chairperson of FSOC and in consultation with FSOC members, should systematically record the staff contributing to determination evaluations, and monitor such information to help assess the progress and efficiency of determination evaluations..

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: FSOC has created a document to track agencies participating in evaluations and has said that it will record and monitor information as new companies are evaluated. Although FSOC has created a template to record agency participation, FSOC still needs to collect and monitor such information including information on the agency staff participating in determination evaluations.
    Recommendation: To enhance disclosure and strengthen transparency, the Secretary of the Treasury, in consultation with FSOC members, for future determinations, to the maximum extent possible, should include additional details in its public basis documentation about why FSOC determined that the company met one or both of the statutory determination standards. Specifically, in addition to identifying that the size, significance, or other attributes of the company's characteristics could pose a threat to U.S. financial stability, FSOC should explain--without revealing sensitive information--how it concluded that the characteristics were sufficiently large or significant enough, or had other attributes, to meet one or both of the statutory determination standards.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: FSOC stated that it intends to include more detail in its public basis document while meeting its legal obligations to protect confidential information. In February 2015, FSOC issued supplemental procedures for nonbank financial company designations that stated its commitment to continuing to set forth sufficient information in its public bases to provide the public with an understanding of the Council's analysis while protecting sensitive, confidential information submitted by the company to the Council. FSOC's public basis document for its most recent designation, issued on December 18, 2014, included additional information compared to prior basis documents. However, the recent basis document did not fully explain how FSOC concluded that the company's characteristics were sufficiently large or significant enough, or had other attributes, to meet a determination standard.
    Recommendation: To help ensure that FSOC is comprehensively identifying and considering companies, the Secretary of the Treasury in consultation with FSOC members, should establish procedures to evaluate companies in Stage 2 and Stage 3 under both statutory determination standards when an evaluation in either stage concludes that a company does not meet one of the standards, or document--on a company-specific or more general basis--why the second determination standard is not relevant for determination evaluations.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: FSOC conducted a review of its nonbank designation procedures, including consideration of this recommendation, which resulted in issuance of supplemental procedures in February 2015. FSOC stated that it has not adopted formal changes to implement this recommendation but noted that the Council will continue to work to identify and evaluate potential changes to its practices and procedures and will revisit this recommendation in mid-2016.
    Recommendation: To help ensure that FSOC is comprehensively identifying and considering companies, the Secretary of the Treasury in consultation with FSOC members, should develop a process to collect information necessary for Stage 1 analysis, as appropriate, from certain nonbank financial companies for which public or regulatory information is otherwise unavailable. For example, FSOC could have companies for which such information is unavailable and that meet certain characteristics (such as quantitative thresholds similar to those used in Stage 1) report necessary information to the Office of Financial Research.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: FSOC staff are currently reviewing potential ways to supplement the existing public and regulatory information available to identify companies for evaluation in Stage 1. FSOC stated that it will revisit this recommendation in mid-2016.
    Recommendation: To improve FSOC's control activities and help ensure that it better manages its determination process and achieves intended results, the Secretary of the Treasury, in his capacity as the Chairperson of FSOC and in consultation with FSOC members, should systematically record the dates of key process steps.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: FSOC has created a document to centrally track key dates in each evaluation and has said that it will record and monitor the information as new companies are evaluated. However, FSOC has not yet recorded these dates in the document that it has created for this purpose.
    Director: Lawrance L. Evans, Jr.
    Phone: (202) 512-8678

    1 open recommendations
    Recommendation: To help ensure that foreclosure prevention principles are being incorporated into servicers' practices, the Chairman of the Board of Governors of the Federal Reserve System should ensure that the planned activities to oversee the foreclosure prevention principles include evaluation and testing of servicers' implementation of the principles.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: In October 2016, Federal Reserve staff indicated that examiners are continuing to review servicers' efforts to incorporate the foreclosure prevention principles into their practices. Our assessment of the extent to which those reviews include evaluation and testing of servicers' implementation of the principles is pending additional discussions with the Federal Reserve.
    Director: St James, Lorelei
    Phone: (202) 512-2834

    3 open recommendations
    Recommendation: To ensure efficient management of the circulating coin inventory, the Board of Governors should direct Cash Product Office (CPO) to develop a process to assess the factors that have influenced increasing coin operations costs and differences in costs across Reserve Banks and a process to use this information to identify practices that could lead to cost-savings.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: As of August 2017, GAO is reviewing the recommendation update information the Federal Reserve. The Federal Reserve has indicated that they have developed and approved a methodology to determine the differences in coin costs among different Reserve Banks and thhave begun to identify cost differences among Reserve Banks and also begun to decrease overall coin costs.
    Recommendation: To ensure efficient management of the circulating coin inventory, the Board of Governors should direct CPO to establish, document, and annually report to the Board performance goals and metrics for managing the circulating coin inventory, (e.g., Reserve Bank coin management costs) and measure performance towards those goals and metrics.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: As of August 2017, GAO is reviewing information provided by the Federal Reserve. The Federal Reserve has indicated that the Cash Advisory Group has endorsed CPO's coin metric methodology. In addition, the CPO is working with the Board of Governors to understand variances in unit costs and working to reduce those costs.
    Recommendation: To ensure efficient management of the circulating coin inventory, the Board of Governors should direct CPO to establish and implement a process to assess the accuracy of forecasts for new coin orders and revise the forecasts as needed.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: As of August 2017, GAO is reviewing information provided by the Federal Reserve. The Federal Reserve has indicated that they have begun work to implement a more formal assessment program for forecasting new coin orders. In addition, the Cash Product Office has begun work to refine the accuracy of these forecasts.
    Director: Clowers, Angela N
    Phone: (202) 512-8678

    4 open recommendations
    including 1 priority recommendation
    Recommendation: FSOC and OFR should clarify responsibility for implementing requirements to monitor threats to financial stability across FSOC and OFR, including FSOC members and member agencies, to better ensure that the monitoring and analysis of the financial system are comprehensive and not unnecessarily duplicative.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open
    Priority recommendation

    Comments: As of October 2016, FSOC staff have said FSOC and its members, including OFR, understand their responsibilities, saying that meetings of FSOC's Systemic Risk Committee help to ensure that FSOC member agencies have clarity on their responsibilities and noted that the committee operated under a charter. However, our review of the charter found that it does not clarify responsibilities for monitoring threats to financial stability. They also stated that actions OFR and the Federal Reserve (both of which serve on the Systemic Risk Committee) agreed to take in response to a recommendation in a GAO report issued in February 2016 would help to clarify these responsibilities. However, these represent just two of FSOC's member agencies; similar collaborative steps by other agencies would support the clarity of roles for monitoring threats to financial stability. We maintain that more specific action from FSOC and OFR, including FSOC member and member agencies, is needed to address this recommendation that ensures clarity of roles and responsibilities in proactively and comprehensively monitoring for potential emerging threats in the financial system. Our past work has shown that the lack of clear roles and coordination can lead to duplication, confusion, and regulatory gaps.
    Recommendation: FSOC and OFR should clarify responsibility for implementing requirements to monitor threats to financial stability across FSOC and OFR, including FSOC members and member agencies, to better ensure that the monitoring and analysis of the financial system are comprehensive and not unnecessarily duplicative.

    Agency: Department of the Treasury: Financial Stability Oversight Council: Office of Financial Research
    Status: Open

    Comments: As of March 2017, OFR has taken some steps to work with the Board of Governors of the Federal Reserve System, a member agency of FSOC, to organize semi-annual meetings to jointly discuss views from their respective monitoring of the financial system for risks. We continue to monitor FSOC and OFR actions that would be responsive to clarifying responsibilities for monitoring threats to financial stability across all the agencies that are members of FSOC.
    Recommendation: To strengthen accountability and collaboration in FSOC's decision making, FSOC should establish a collaborative and comprehensive framework for assessing the impact of its decisions for designating FMUs and nonbank financial companies on the wider economy and those entities. This framework should include assessing the effects of subjecting designated FMUs and nonbank financial companies to new regulatory standards, requirements, and restrictions; establishing a baseline from which to measure the effects; and documenting the approach.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: In response to an April 2017 presidential memorandum, Treasury is conducting a review of FSOC's designation process, including an assessment of the effects of designating FMUs and nonbank financial companies. This review will result in a report. We will update the status of this recommendation after we have reviewed the report.
    Recommendation: To strengthen accountability and collaboration in FSOC's decision making, FSOC should develop more systematic forward-looking approaches for reporting on potential emerging threats to financial stability in annual reports. Such an approach should provide methodological insight into why certain threats to financial stability are included or excluded over time, separate current or past threats from those that are potentially emerging, and prioritize the latter.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: When FSOC publishes its annual report for 2017 and we have reviewed it, we will provide updated information.
    Director: Clowers, Angela N
    Phone: (202)512-3000

    11 open recommendations
    Recommendation: In order to improve the efficiency and effectiveness of their efforts, the federal financial regulators have begun to take steps to address challenges associated with promulgating hundreds of new rules required under the Dodd-Frank Act. To strengthen the rigor and transparency of their regulatory analyses, the federal financial regulators should take steps to better ensure that the specific practices in OMB's regulatory analysis guidance are more fully incorporated into their rulemaking policies and consistently applied.

    Agency: National Credit Union Administration
    Status: Open

    Comments: In June 2016, NCUA told us that it is nearing completion of agency internal policies that standardize and institutionalize the rulemaking process within NCUA. According to agency officials, these policies will document NCUA's current practice related to OMB's regulatory analysis guidance. The policies will be issued to appropriate staff by the end of 2016. At that time, we will review the policies to review the extent to which they incorporate the practices in OMB's regulatory analysis guidance.
    Recommendation: In order to improve the efficiency and effectiveness of their efforts, the federal financial regulators have begun to take steps to address challenges associated with promulgating hundreds of new rules required under the Dodd-Frank Act. To maximize the usefulness of the required retrospective reviews, the federal financial regulatory agencies should develop plans that determine how they will measure the impact of Dodd-Frank Act regulations--for example, determining how and when to collect, analyze, and report needed data.

    Agency: National Credit Union Administration
    Status: Open

    Comments: In June 2016, NCUA noted that all of the agency's regulations are reviewed at least every three years, during an established rotation, so that every year one-third of the agency's regulations are open to comment from the public. NCUA reported that it recently launched a comprehensive multi-year project to update the agency's main data collection and analytic systems. Agency officials stated that the updates will ensure that the agency collects the data needed to assess the effectiveness and impact of applicable regulations. We will continue to monitor NCUA's progress in updating its information systems for purposes of retrospective reviews.
    Recommendation: In order to improve the efficiency and effectiveness of their efforts, the federal financial regulators have begun to take steps to address challenges associated with promulgating hundreds of new rules required under the Dodd-Frank Act. To maximize the usefulness of the required retrospective reviews, the federal financial regulatory agencies should develop plans that determine how they will measure the impact of Dodd-Frank Act regulations--for example, determining how and when to collect, analyze, and report needed data.

    Agency: Department of the Treasury: Office of the Comptroller of the Currency
    Status: Open

    Comments: In March 2017, the federal banking regulators sent Congress their report of the second Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA). Under EGRPRA, the regulators must jointly conduct a review of their regulations every 10 years and consider whether any of the regulations are outdated, unnecessary, or unduly burdensome. The regulators included within their review's scope some regulations issued pursuant to the Dodd-Frank Act. To carry out the EGRPRA review, the regulators generally solicited public comments on their covered regulations through Federal Register notices and public outreach meetings. Although the regulators addressed some of the issues raised by EGRPRA commenters to reduce regulatory burden, they generally focused on identifying regulatory burdens, as required by the law, and not on measuring the impact of the Dodd-Frank Act regulations to assess the extent to which they are achieving their intended purposes. For this reason, our recommendation remains open.
    Recommendation: In order to improve the efficiency and effectiveness of their efforts, the federal financial regulators have begun to take steps to address challenges associated with promulgating hundreds of new rules required under the Dodd-Frank Act. To strengthen the rigor and transparency of their regulatory analyses, the federal financial regulators should take steps to better ensure that the specific practices in OMB's regulatory analysis guidance are more fully incorporated into their rulemaking policies and consistently applied.

    Agency: Federal Reserve System
    Status: Open

    Comments: We sought information from the Board of Governors of the Federal Reserve System in May 2016 regarding the status of the recommendation, but did not receive any new information. Therefore, the recommendation remains open.
    Recommendation: In order to improve the efficiency and effectiveness of their efforts, the federal financial regulators have begun to take steps to address challenges associated with promulgating hundreds of new rules required under the Dodd-Frank Act. To maximize the usefulness of the required retrospective reviews, the federal financial regulatory agencies should develop plans that determine how they will measure the impact of Dodd-Frank Act regulations--for example, determining how and when to collect, analyze, and report needed data.

    Agency: Federal Reserve System
    Status: Open

    Comments: In March 2017, the federal banking regulators sent Congress their report of the second Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA). Under EGRPRA, the regulators must jointly conduct a review of their regulations every 10 years and consider whether any of the regulations are outdated, unnecessary, or unduly burdensome. The regulators included within their review's scope some regulations issued pursuant to the Dodd-Frank Act. To carry out the EGRPRA review, the regulators generally solicited public comments on their covered regulations through Federal Register notices and public outreach meetings. Although the regulators addressed some of the issues raised by EGRPRA commenters to reduce regulatory burden, they generally focused on identifying regulatory burdens, as required by the law, and not on measuring the impact of the Dodd-Frank Act regulations to assess the extent to which they are achieving their intended purposes. For this reason, our recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: Department of the Treasury: Financial Stability Oversight Council
    Status: Open

    Comments: In May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: Federal Reserve System
    Status: Open

    Comments: In May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: Department of the Treasury: Office of the Comptroller of the Currency
    Status: Open

    Comments: In May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: United States Securities and Exchange Commission
    Status: Open

    Comments: In May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: Commodity Futures Trading Commission
    Status: Open

    Comments: In June 2016, CFTC officials stated that FSOC has written protocols for consulting on rules for which coordination is required under the Dodd-Frank Act. Specifically, in May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Recommendation: To enhance interagency coordination on regulations issued pursuant to the Dodd-Frank Act, the FSOC should work with the federal financial regulatory agencies to establish formal coordination policies that clarify issues such as when coordination should occur, the process that will be used to solicit and address comments, and what role FSOC should play in facilitating coordination.

    Agency: National Credit Union Administration
    Status: Open

    Comments: In June 2016, NCUA stated that it continues to work closely with the other federal financial agencies regarding rulemaking, and formally coordinates with them during joint rulemaking initiatives. Agency officials said they would comply with any future coordination guidance provided by FSOC. In May 2015, FSOC created the Regulations and Resolutions Committee to identify potential gaps in regulation that could pose risks to the U.S. financial stability. The committee's duties include serving as a forum for information sharing and coordination among the FSOC staff, member agencies and other federal and state agencies, as appropriate, regarding domestic financial services policy development, and consulting, as appropriate, on the development of regulations to implement the Dodd-Frank Act's orderly liquidation authority. While the committee's duties should help promote greater collaboration, they do not constitute a formal rulemaking coordination policy addressing, for example, when coordination should occur, processes for soliciting and addressing comments, and FSOC role in facilitating coordination among and between the financial regulators. In its 2010 comment letter, FSOC noted that it provides a forum for interagency collaboration and consultation, in part through its committees, and has not indicated any plans to develop a formal rulemaking coordination policy as we recommended, in part because of its need to preserve the independence of the regulators. Therefore, the recommendation remains open.
    Director: Brown, Orice Williams
    Phone: (202)512-5837

    4 open recommendations
    Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to strengthen procedures in place to guide Reserve Banks' efforts to manage emergency program access for higher-risk borrowers by providing more specific guidance on how Reserve Bank staff should exercise discretion and document decisions to restrict or deny program access for depository institutions and primary dealers that would otherwise be eligible for emergency assistance.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document a plan for estimating and tracking losses that could occur under more adverse economic conditions within and across all emergency lending activities and for using this information to inform policy decisions, such as decisions to limit risk exposures through program design or restrictions applied to eligible borrowing institutions.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff, in drafting regulations to establish the policies and procedures governing emergency lending under section 13(3) of the Federal Reserve Act, to set forth the Federal Reserve Board's process for documenting, to the extent not otherwise required by law, its justification for each use of this authority.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document the Federal Reserve Board's guidance to Reserve Banks on types of emergency program decisions and risk events that require approval by or consultation with the Board of Governors, the Federal Open Market Committee, or other designated groups or officials at the Federal Reserve Board.

    Agency: Federal Reserve System: Board of Governors
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.