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    Subject Term: "Financial institutions"

    20 publications with a total of 76 open recommendations including 1 priority recommendation
    Director: Michael Clements
    Phone: (202) 512-8678

    1 open recommendations
    Recommendation: To promote transparency and accountability of federal spending, the Commissioner of the Fiscal Service should make basic information about Fiscal Service's use of financial agents publicly available in a central location, including compensation paid to each financial agent under its financial agency agreement and a description of the services provided.

    Agency: Department of the Treasury: Bureau of the Fiscal Service
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: David Wise
    Phone: (202) 512-2834

    1 open recommendations
    Recommendation: The Administrator of the General Services Administration should determine whether the beneficial owner of high-security space that GSA leases is a foreign entity and, if so, share that information with the tenant agencies so they can adequately assess and mitigate any security risks.

    Agency: General Services Administration
    Status: Open

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

    1 open recommendations
    Recommendation: To ensure that FHFA has adequate authority to ensure the safety and soundness of the enterprises and to clarify its supervisory role, Congress should consider granting FHFA explicit authority to examine third parties that do business with and play a critical role in the operations of the enterprises.

    Agency: Congress
    Status: Open

    Comments: As of April 2017, Congress has not taken any action on this matter.
    Director: Lawrance Evans, Jr.
    Phone: (202) 512-8678

    6 open recommendations
    Recommendation: Congress should consider whether additional changes to the financial regulatory structure are needed to reduce or better manage fragmentation and overlap in the oversight of financial institutions and activities to improve (1) the efficiency and effectiveness of oversight; (2) the consistency of consumer and investor protections; and (3) the consistency of financial oversight for similar institutions, products, risks, and services. For example, Congress could consider consolidating the number of federal agencies involved in overseeing the safety and soundness of depository institutions, combining the entities involved in overseeing the securities and derivatives markets, transferring the remaining prudential regulators' consumer protection authorities over large depository institutions to the Consumer Financial Protection Bureau, and the optimal role for the federal government in insurance regulation, among other considerations.

    Agency: Congress
    Status: Open

    Comments: One bill has been introduced in the 115th Congress that would change the financial regulatory structure to address fragmented and overlapping regulatory authorities among agencies, as GAO suggested in February 2016. H.R. 594 was introduced on January 20, 2017, and calls for the functions of the Commodity Futures Trading Commission and the Securities and Exchange Commission to be combined in a single independent regulatory commission. Such an action could help to address fragmentation and overlap between the two agencies, and reduce opportunities for inefficiencies in the regulatory process and inconsistencies in how regulators conduct oversight activities over similar types of institutions, products, and risks.
    Recommendation: Congress should consider whether legislative changes are necessary to align FSOC's authorities with its mission to respond to systemic risks. Congress could do so by making changes to FSOC's mission, its authorities, or both, or to the missions and authorities of one or more of the FSOC member agencies to support a stronger link between the responsibility and capacity to respond to systemic risks. In doing so, Congress could solicit information from FSOC on the effective scope of its collective designation authorities, including any gaps.

    Agency: Congress
    Status: Open

    Comments: No legislative action identified. As of March 1, 2017, no legislation had been introduced that would align FSOC's authorities with its mission to respond to systemic risks, as GAO suggested in February 2016. Without such legislative changes, FSOC may lack the tools it needs to comprehensively address systemic risks that may emerge, and a gap will continue to exist in the post Dodd-Frank Wall Street Reform and Consumer Protection Act mechanisms for the mitigation of systemic risks.
    Recommendation: To help regulators address regulatory fragmentation and improve FSOC's ability to identify emerging systemic risks, as OFR develops and refines its financial stability monitoring tools, it should work with FSOC to determine ways in which to fully and regularly incorporate current and future monitors and assessments into Systemic Risk Committee deliberations, including, where relevant, those that present disaggregated or otherwise confidential supervisory information.

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

    Comments: At the FSOC Systemic Risk Committee meeting held in December 2016, Treasury indicated that Office of Financial Research staff presented on the agency's Financial Stability Report. Officials indicated that they provided an assessment on potential financial stability risks, including macroeconomic, market, credit, funding and liquidity, and contagion risks. Systemic Risk Committee meeting attendees were able to compare and contrast these with the results from the Federal Reserve's systemic risk monitoring activities, which were also presented at the meeting. Office of Financial Research officials stated that there was general consensus at the meeting that these discussions were useful and that they should continue. GAO does not believe that this action is consistent with the intent of if February 2016 recommendation to fully and regularly incorporate current and future monitors and assessments into FSOC's Systemic Risk Committee deliberations. While GAO encourages sharing this type of information, the Office of Financial Research's Financial Stability Report is a publicly-available report. The intent of GAO's recommendation was to encourage the agency to fully incorporate all of its monitors into Systemic Risk Committee discussions, including its Financial Stability Monitor--its benchmark tool for assessing risks across the financial system. In addition, in its February 2016 report, GAO encouraged the agency to seek ways in which monitors that present disaggregated or otherwise confidential supervisory information can be incorporated in committee discussions. Without sharing such monitors and information, the Systemic Risk Committee may identify and advance the analysis of only a subset of systemic risks in a timely manner and may identify others too late or miss others altogether. The Financial CHOICE Act of 2016 was introduced in the 114th Congress. The act called for the Office of Financial Research to be eliminated. It was not passed before the end of the 114th Congress.
    Recommendation: To help regulators address regulatory fragmentation and improve FSOC's ability to identify emerging systemic risks, the Federal Reserve should work with FSOC to regularly incorporate the comprehensive results of its systemic risk monitoring activities into Systemic Risk Committee deliberations.

    Agency: Federal Reserve System
    Status: Open

    Comments: As of March 1, 2017, Federal Reserve officials indicated that they provided a presentation to FSOC's Systemic Risk Committee in December 2016, which included comprehensive results from its systemic risk monitoring activities. This action appears to be consistent with GAO's February 2016 recommendation, but the documentation provided by the Federal Reserve did not provide sufficient evidence that the agency has regularly incorporated these results into Systemic Risk Committee meetings. GAO will continue to monitor the Federal Reserve's participation in Systemic Risk Committee meetings to ensure that the agency continues to provide both regular and comprehensive results to the committee. Without better access to systemic risk monitoring tools and other outputs, the Systemic Risk Committee may identify and advance the analysis of only a subset of systemic risks in a timely manner and may identify others too late or miss others altogether.
    Recommendation: To more efficiently and effectively monitor the financial system for systemic risks and reduce the risk of unnecessary duplication, OFR and the Federal Reserve should jointly articulate individual and common goals for their systemic risk monitoring activities, including a plan to monitor progress toward articulated goals, and formalize regular strategic and technical discussions around their activities and outputs to support those goals.

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

    Comments: As of March 1, 2017, the Federal Reserve and the Office of Financial Research had coordinated to organize semi-annual meetings to jointly discuss views from their respective monitoring of the financial system for risks; but these meetings had not yet taken place. The first of these meetings is to be held in May 2017 following the agencies' respective systemic risk exercises. Initiating these discussions addresses part of GAO's February 2016 recommendation. GAO plans to review documentation from these meetings in 2017 to further assess if the agencies will use these meetings to jointly articulate individual and common goals, including developing a plan to monitor progress toward the goals. Fully addressing GAO's recommendation could help to ensure comprehensiveness in systemic risk surveillance and reduced risk of duplication. On September 9, 2016, the Financial CHOICE Act of 2016 was introduced. It called for the Office of Financial Research to be eliminated. The legislation did not pass before the 114th Congress ended.
    Recommendation: To more efficiently and effectively monitor the financial system for systemic risks and reduce the risk of unnecessary duplication, OFR and the Federal Reserve should jointly articulate individual and common goals for their systemic risk monitoring activities, including a plan to monitor progress toward articulated goals, and formalize regular strategic and technical discussions around their activities and outputs to support those goals.

    Agency: Federal Reserve System
    Status: Open

    Comments: As of March 1, 2017, the Federal Reserve and the Office of Financial Research had coordinated to organize semi-annual meetings to jointly discuss views from their respective monitoring of the financial system for risks; but these meetings had not yet taken place. The first of these meetings is to be held in May 2017 following the agencies' respective systemic risk exercises. Initiating these discussions addresses part of GAO's February 2016 recommendation. GAO plans to review documentation from these meetings in 2017 to further assess if the agencies will use these meetings to jointly articulate individual and common goals, including developing a plan to monitor progress toward the goals. Fully addressing GAO's recommendation could help to ensure comprehensiveness in systemic risk surveillance and reduced risk of duplication. On September 9, 2016, the Financial CHOICE Act of 2016 was introduced. It called for the Office of Financial Research to be eliminated. The legislation did not pass before the 114th Congress ended.
    Director: Gregory C. Wilshusen
    Phone: (202) 512-6244

    1 open recommendations
    Recommendation: To better facilitate adoption of the NIST Framework for Improving Critical Infrastructure Cybersecurity, the Secretary of Homeland Security should direct officials responsible for the Critical Infrastructure Cyber Community Voluntary Program to develop metrics for measuring the effectiveness of efforts to promote and support the framework.

    Agency: Department of Homeland Security
    Status: Open

    Comments: In December 2016, DHS officials stated that they will continue to work with sector-specific agency partners and NIST to determine how to develop measurement activities and collect information on C3VP outreach and its effectiveness in promoting and supporting the Cybersecurity Framework. We will continue to monitor their efforts and verify whether implementation of metrics has occurred.
    Director: Kimberly M. Gianopoulos
    Phone: (202) 512-8612

    1 open recommendations
    Recommendation: To further improve OPIC's monitoring processes, the President and CEO of OPIC should assess the current monitoring processes to ensure that the risk associated with the use of client-reported data and limited site visits for monitoring is acceptable for meeting OPIC's program goals.

    Agency: Overseas Private Investment Corporation
    Status: Open

    Comments: In written comments on the draft report, the Overseas Private Investment Corporation (OPIC) concurred with the recommendation. In February 2017, OPIC executed two contracts with an external group to assist it in assessing the Office of Information Policy's current monitoring processes to ensure that the risks associated with the use of client-reported data and limited site visits for monitoring are acceptable and meet OPIC's program goals. The work is currently underway.
    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: Daniel Garcia-Diaz
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: To better align program goals with agency missions and improve program administration and oversight, Congress should consider designating the Department of Housing and Urban Development as a joint administrator of the program responsible for oversight. As part of the deliberation, Congress also should direct HUD to estimate the costs to monitor and perform the additional oversight responsibilities, including a discussion of funding options.

    Agency: Congress
    Status: Open

    Comments: As of July 2017, Congress had not enacted legislation to give HUD an oversight role for LIHTC.
    Recommendation: To improve the utility of the credit allocation information contained in IRS's database, IRS should address weaknesses identified in data entry and programming controls to ensure reliable data are collected.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS acknowledged the need for improvements in its controls and procedures (including data entry and quality reviews). IRS officials agreed that these problems should be corrected and data quality reviews should be conducted on an ongoing basis. As of March 2017, in response to our recommendation, IRS officials said that they had explored possibilities to improve the database, which not only houses credit allocation information, but also data from noncompliance and building disposition forms. Specifically, IRS is working to move the database to a new and updated server, which will address weaknesses identified in data entry and programming controls. IRS expects to complete the data migration step by early fall of 2017. Until IRS implements its plan to improve the data, this recommendation will remain open.
    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: Mathew J. Scirè
    Phone: (202) 512-8678

    8 open recommendations
    Recommendation: To enhance the effectiveness of its preparations for conducting a retrospective review of its QM regulations, CFPB should complete its plan. The plan should identify what outcomes CFPB will examine to measure the effects of the regulations and the specific metrics, baselines, and analytical methods to be used. Furthermore, to account for and help mitigate the limitations of existing data and the uncertain availability of enhanced datasets, CFPB should include in its plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: In January 2017, CFPB staff noted that the Bureau produced a high-level research plan in November 2016 and organized a research team for the ATR-QM Assessment. CFPB staff stated that they are working to identify the outcomes CFPB will examine to measure the effects of the regulations, including the specific metrics, baselines, and analytical methods to be used. CFPB staff noted that they have also begun analyzing the data the Bureau has on-hand, planning for the collection of additional data, and drafting a Federal Register notice request for information regarding the plan.
    Recommendation: To enhance the effectiveness of its preparations for conducting a retrospective review of its QM regulations, HUD should develop a plan that identifies the metrics, baselines, and analytical methods to be used. Furthermore, to account for and help mitigate the limitations of existing data and the uncertain availability of enhanced datasets, HUD should include in its plan alternate metrics, baselines, and analytical methods that could be used data were to remain unavailable.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: In February 2017, HUD noted that it does not currently collect data on the annual percentage rate (APR) for each loan that would allow for a perfect comparison to the average prime offer rate. According to HUD, its Office of Housing has on its long-term list of systems priorities to collect specific information from the Uniform Closing Data that could be used to conduct such a comparison. However, HUD stated that it has not received adequate funding to meet these systems enhancements. According to HUD, it is considering the feasibility and potential utility of alternative data sources or the use of a proxy in an appropriate methodology. For instance, whether it may be possible to approximate the APR based upon the note rate and information on closing costs that is collected in the current data system, or alternatively, whether the APR could be obtained or approximated through matching Home Mortgage Disclosure Act data for FHA loans.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

    Agency: Federal Housing Finance Agency
    Status: Open

    Comments: In January 2017, FHFA informed GAO that SEC had shared its draft plan with the other participating agencies and there was an interagency call to discuss the plan on December 20, 2016. FHFA confirmed that there was an interagency call on that date to discuss the QRM review. FHFA noted that it was developing its own plan, and anticipated that the plan would be completed by June 30, 2017. Depending on changes in the structure of the mortgage market, FHFA stated that it will further update the plan as the agency approaches the start of the official QRM definition review in 2019. As with the 2014 final rule, FHFA staff expected that FHFA's participation will focus on the analysis of Fannie Mae and Freddie Mac residential mortgage data.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: In February 2017, HUD stated that it has engaged in preliminary discussions both internally and with the other five partner agencies to the 2014 QRM Joint Regulation: OCC, the Federal Reserve Board, FDIC, FHFA and SEC. Based on GAO's recommendations, HUD stated that it has also conducted initial reviews of existing and potential methodologies and data sources that may inform the review. HUD also noted that as a fundamental matter, FHA insured mortgages are only securitized through the Government National Mortgage Association (GNMA). Both FHA and GNMA have extensive underlying requirements regarding both mortgage terms and conditions as well as requirements related to the securitization of those mortgages. According to HUD, its retrospective review of the QRM rule, in terms of any impact on FHA single family insurance programs, will take into account the existing underlying FHA and GNMA statutes and regulations that already govern those programs.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

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

    Comments: In its comment letter on the draft report, OCC indicated that it planned to take GAO's recommendation into account as it monitored mortgage market conditions and prepared for upcoming QRM reviews. OCC stated that it planned to periodically meet with the other agencies to discuss the implications of any trends it observes and coordinate on studies to better focus and support its evaluation of the review factors.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

    Agency: Federal Deposit Insurance Corporation
    Status: Open

    Comments: In February 2017, FDIC indicated that it developed a plan that outlines the baseline, data, metrics, and analytical methods that it plans to utilize in the QRM definition review. According to FDIC, the plan also outlines FDIC's commitment to working collaboratively with the other agencies. As a baseline, FDIC plans to use the data, metrics, and analytical methods used in the final rulemaking process as outlined in the Supplementary Information to the credit risk retention (CRR) regulation as well as data and analytical methods that the FDIC currently uses to monitor the mortgage and securitization markets and economy on an ongoing basis. FDIC stated that it continues to plan to coordinate with the other agencies on the QRM definition review by allocating responsibilities based on expertise, data, and other resources within each agency as the agencies did in the CRR rulemaking process.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

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

    Comments: In January 2017, the Federal Reserve Board stated that it has an ongoing program to monitor the mortgage and securitization markets as part of its monetary policy, regulatory, and financial stability responsibilities. According to the Federal Reserve, Board staff are continuously researching new data sources, analytical methods, and metrics as part of that program. The Federal Reserve also noted that Board staff with responsibility for implementing this recommendation continue to meet with their counterparts at other agencies.
    Recommendation: To enhance the effectiveness of their preparations for conducting a retrospective review of the QRM regulations, the agencies responsible for the QRM regulations--Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, HUD, Office of the Comptroller of the Currency, and Securities and Exchange Commission--should develop a plan that identifies the metrics, baselines, and analytical methods to be used and specify the roles and responsibilities of each agency in the review process. Furthermore, to account for and help mitigate limitations of existing data and the uncertain availability of enhanced datasets, the six agencies should include in their plan alternate metrics, baselines, and analytical methods that could be used if data were to remain unavailable.

    Agency: United States Securities and Exchange Commission
    Status: Open

    Comments: In January 2017, SEC staff stated that they had developed a preliminary review plan for the QRM rule in December 2016. SEC staff noted that although the review plan describes several proposed analytical approaches, the precise analytical approach to review the mortgage market conditions and the definition of QRM will depend on future data availability, future mortgage market conditions, and the role of Fannie Mae, Freddie Mac, and other participants in those markets at that time. To prepare for this review, SEC staff noted that they intend to meet on a periodic basis with the staff of the other agencies to share the results of the analyses discussed above, understand the analyses being performed by the other agencies, and discuss what additional data or analyses may be helpful. As part of these discussions, SEC staff stated that the agencies will likely divide responsibilities for conducting the review according to agency expertise and resources, consistent with each agency's statutory authority and role.
    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: James R. White
    Phone: (202) 512-9110

    3 open recommendations
    Recommendation: Congress should consider providing the Secretary of the Treasury with the regulatory authority to lower the threshold for electronic filing of W-2s from 250 returns annually to between 5 to 10 returns, as appropriate.

    Agency: Congress
    Status: Open

    Comments: As of March 2017, no legislative action identified. Lowering the threshold would help IRS prevent identity theft refund fraud by enhancing its ability to verify the employment information reported on tax returns before issuing refunds. Additionally, lowering the threshold would reduce the Social Security Administration's administrative costs of processing W-2 information.
    Recommendation: To provide timely, accurate, and actionable feedback to all relevant lead-generating third parties, the Commissioner of Internal Revenue should provide aggregated information on (1) the success of external party leads in identifying suspicious returns and (2) emerging trends (pursuant to section 6103 restrictions).

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: As of March 2017, IRS had taken steps to address GAO's August 2014 recommendation, including developing timeliness metrics for managing leads and holding six feedback sessions with financial institutions participating in the External Leads Program, but had not provided GAO with documentation that the agency is providing meaningful feedback to external parties. In November 2015, IRS reported that it had developed a database to track leads submitted by financial institutions and the results of those leads. IRS also stated that it had held six sessions with financial institutions to provide feedback on external leads provided to IRS. These quarterly feedback sessions contained various types of information, including overall statistics for the External Leads Program, individual statistics tailored to a specific external party, and solicitations for how to improve the program. In December 2015, IRS officials stated that the agency sent a customer satisfaction survey asking financial institutions for feedback on the external leads process and was considering other ways to provide feedback to financial institutions. In August 2016, an industry group representing financial institutions reported that IRS had not begun providing meaningful feedback to financial institutions that are providing leads to IRS. In March 2017, IRS officials told us they were holding more frequent, monthly, feedback sessions with financial institutions. GAO will follow up with financial institutions to understand the extent to which IRS's feedback has been timely and is actionable. Without accurate, timely, and actionable feedback, the more than 600 external parties participating in the External Leads Program do not know if the leads they provide to IRS are useful and they may not be able to assess their success in identifying IDT refund fraud or improve their detection tools.
    Recommendation: To provide timely, accurate, and actionable feedback to all relevant lead-generating third parties, the Commissioner of Internal Revenue should develop a set of metrics to track external leads by the submitting third party.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: As of March 2017, IRS had taken steps to address GAO's August 2014 recommendation, including developing timeliness metrics for managing leads and holding six feedback sessions with financial institutions participating in the External Leads Program, but had not provided GAO with documentation that the agency is providing meaningful feedback to external parties. In November 2015, IRS reported that it had developed a database to track leads submitted by financial institutions and the results of those leads. IRS also stated that it had held six sessions with financial institutions to provide feedback on external leads provided to IRS. These quarterly feedback sessions contained various types of information, including overall statistics for the External Leads Program, individual statistics tailored to a specific external party, and solicitations for how to improve the program. In December 2015, IRS officials stated that the agency sent a customer satisfaction survey asking financial institutions for feedback on the external leads process and was considering other ways to provide feedback to financial institutions. In August 2016, an industry group representing financial institutions reported that IRS had not begun providing meaningful feedback to financial institutions that are providing leads to IRS. In March 2017, IRS officials told us they were holding more frequent, monthly, feedback sessions with financial institutions. GAO will follow up with financial institutions to understand the extent to which IRS's feedback has been timely and is actionable. Without accurate, timely, and actionable feedback, the more than 600 external parties participating in the External Leads Program do not know if the leads they provide to IRS are useful and they may not be able to assess their success in identifying IDT refund fraud or improve their detection tools.
    Director: Cackley, Alicia P
    Phone: (202) 512-8678

    1 open recommendations
    Recommendation: Congress should consider strengthening the current consumer privacy framework to reflect the effects of changes in technology and the marketplace--particularly in relation to consumer data used for marketing purposes--while also ensuring that any limitations on data collection and sharing do not unduly inhibit the economic and other benefits to industry and consumers that data sharing can accord. Among the issues that should be considered are: (1) the adequacy of consumers' ability to access, correct, and control their personal information in circumstances beyond those currently accorded under FCRA; (2) whether there should be additional controls on the types of personal or sensitive information that may or may not be collected and shared; (3) changes needed, if any, in the permitted sources and methods for data collection; and (4) privacy controls related to new technologies, such as web tracking and mobile devices.

    Agency: Congress
    Status: Open

    Comments: As of April 2017, Congress has not taken action on this matter.
    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.
    Director: White, James R
    Phone: (202)512-9039

    1 open recommendations
    Recommendation: Should the program be extended beyond 2009, to ensure that the maximum amount of capital ends up in low-income community businesses, Congress may wish to consider offering grants to CDEs that would provide the funds to low-income community businesses. If it does so, Congress may wish to require Treasury to gather appropriate data to assess whether and to what extent the grant program increases the amount of federal subsidy provided to low-income community businesses compared to the NMTC; whether the grant program otherwise affects the success of efforts to assist low-income communities; and how costs for administering the program incurred by the CDFI Fund, CDEs, and investors would change. One option may be for Congress to set aside a portion of funds to be used as grants and a portion to be used as tax credit allocation authority under the current structure of the program in a future allocation round to facilitate comparison of the two program structures.

    Agency: Congress
    Status: Open

    Comments: The Consolidated Appropriations Act of 2016 extended the NMTC through 2019 (Public Law 114-113). However, the act did not modify the program to include grants in lieu of credits, as GAO suggested in January 2010. The Joint Committee on Taxation estimates the cost of this extension to be approximately $2.6 billion. As of June 2017, Congress has not taken additional action that would address this matter for consideration.
    Director: Williams, Orice M
    Phone: (202)512-5837

    1 open recommendations
    Recommendation: To address the current information gap in Regulation SHO for prime brokerage arrangements and mitigate the impact of any unintended consequences caused by SEC rules, as well as ensure consistent implementation of SEC rules by the industry, the Chairman of the Securities and Exchange Commission should finalize, in an expedited manner upon finalization of the temporary rule, the revised 1994 Prime Broker Letter.

    Agency: United States Securities and Exchange Commission
    Status: Open

    Comments: As of 7/18/13, the revised Prime Broker letter has not been finalized.