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    Subject Term: "Financial services"

    12 publications with a total of 36 open recommendations including 4 priority recommendations
    Director: David Powner
    Phone: (202) 512-9286

    1 open recommendations
    Recommendation: To improve the reliability and reporting of investment performance information and management of selected major investments, the Commissioner of the IRS should direct the Chief Technology Officer to modify reporting of the Affordable Care Act Administration testing status to senior management to include a comprehensive report on all impacted systems--including an explanation for why impacted systems were not tested at a particular level--and ensure this reporting is aligned with the manner in which testing is being performed.

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

    Comments: IRS disagreed with this recommendation at the time we made it stating that it followed a rigorous risk-based process for planning the tests of ACA-impacted systems, including the types and levels of testing, and that it had comprehensive reporting for the filing season 2015 release, which included ACA impacted systems. However, as noted in our report, our review of ACA Testing Review Checkpoint reports and filing season reports, which officials stated were used to provide comprehensive reports to senior managers, did not identify the status of testing for all systems impacted by ACA Releases 5.0 and 6.0. We therefore concluded that the recommendation was still valid. As of July 2017, IRS had not changed its position. We will be following up with the agency to discuss the recommendation.
    Director: Malenich, J Lawrence
    Phone: (202) 512-3406

    2 open recommendations
    Recommendation: The CFPB should direct the Chief Financial Officer to design and implement control procedures that require coordination between the Office of Procurement and other program offices at the time of capitalization to ensure that property and equipment costs, including costs associated with internal-use software, are properly capitalized or expensed as appropriate.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: Although CFPB took actions to attempt to address this recommendation, as of September 30, 2016, it was still in the process of implementing additional corrective actions. In addition, our fiscal year 2016 audit continued to identify deficiencies over the recording of property, equipment, and software costs. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2017 financial statement audit.
    Recommendation: The CFPB should direct the Chief Financial Officer to strengthen the design and implementation of control procedures to require, as part of the Office of the Chief Financial Officer's quarterly review procedures, review of underlying supporting documents, including tracking schedules, invoices, and obligating documents, to ensure that property and equipment transactions are properly identified and capitalized or expensed as appropriate.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: As of September 30, 2016, we continued to find that the Office of the Chief Financial Officer's review was not always effective in timely detecting and correcting classification errors between costs that should be capitalized and costs that should be expensed. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2017 financial statement audit.
    Director: Clowers, Angela N
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: To help ensure that OMB, in consultation with federal financial regulators, consistently classifies Dodd-Frank rules as major under CRA, the Director of OMB, through the Administrator of the Office of Information and Regulatory Affairs, should issue additional guidance to help standardize processes for identifying major rules under CRA, including on the extent to which agencies should submit rules to OMB for review, such as whether agencies should submit only those rules their analyses indicate are major or all rules.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: OMB originally disagreed with the recommendation and has not taken any action to implement the recommendation as of June 2017.
    Recommendation: To help ensure that OMB, in consultation with federal financial regulators, consistently classifies Dodd-Frank rules as major under CRA, the Director of OMB, through the Administrator of the Office of Information and Regulatory Affairs, should issue additional guidance to help standardize processes for identifying major rules under CRA, including on how agencies should apply CRA's major rule criteria in their analyses, such as whether agencies should include indirect benefits or costs, combine benefits or costs of separate but related rules, or aggregate benefits or costs for jointly issued rules.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: OMB originally disagreed with the recommendation and has not taken any action to implement the recommendation as of June 2017.
    Director: Powner, David A
    Phone: (202)512-9286

    3 open recommendations
    Recommendation: To improve the reliability of reported cost and schedule variance information for the seven major investments we reviewed, the Acting Commissioner of IRS should direct the Chief Technology Officer to improve the reliability of cost estimates by addressing the weaknesses we identified in this report so that each investment at least substantially meets each of the characteristics of a reliable cost estimate.

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

    Comments: We followed up on the status of IRS's actions to address this recommendation for the Customer Account Data Engine (CADE) 2, the Return Review Program (RRP), and IRS.gov, the three investments with significant planned expenditures for development in fiscal year 2017, according to data reported on the Federal IT dashboard (the remaining four investments in our 2013 review are primarily in operations and maintenance based on the same IT dashboard data). We selected CADE 2, RRP, and IRS.gov because they would benefit most from improvements to cost estimates given their life cycle stage. In the Summer of 2017, IRS provided documentation to demonstrate actions taken to address the weaknesses we had identified with the CADE 2, and RRP cost estimates. We are currently analyzing this information. For IRS.gov, IRS told us the investment had been in operations and maintenance for several years and was therefore not producing the cost documentation that is typically associated with development efforts. We requested documentation supporting this claim and as of September 2017 were waiting to receive it.
    Recommendation: To improve the reliability of reported cost and schedule variance information for the seven major investments we reviewed, the Acting Commissioner of IRS should direct the Chief Technology Officer to improve the extent to which schedules are well-constructed and controlled by addressing the weaknesses we identified in this report so that each investment at least substantially meets each of these characteristics.

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

    Comments: We followed up on the status of IRS's actions to address this recommendation for the Customer Account Data Engine (CADE) 2, the Return Review Program (RRP), and IRS.gov, the three investments with significant expenditures planned for development in fiscal year 2017, according to data reported on the Federal IT dashboard (the remaining four investments in our 2013 review are primarily in operations and maintenance based on the same IT dashboard data). We selected CADE 2, RRP, and IRS.gov because they would benefit most from improvements to schedule estimates given their life cycle stage. In the Summer of 2017, IRS provided documentation to demonstrate actions taken to address the weaknesses we had identified with the CADE 2, and RRP schedule estimates. We are currently analyzing this documentation. For IRS.gov, IRS told us the investment had been in operations and maintenance for several years and was therefore not producing the schedule estimates that are typically associated with development efforts. We requested documentation supporting this claim and as of September 2017 were waiting to receive it.
    Recommendation: To improve the reliability of reported cost and schedule variance information for the seven major investments we reviewed, the Acting Commissioner of IRS should direct the Chief Technology Officer to develop and implement guidance that specifies best practices--such as including evaluating critical path (for projected schedule), using earned value management data, evaluating the performance of completed work and comparing it to the remaining budget, assessing commitment values for material needed to complete remaining work, and estimating future conditions--to consider when determining projected cost and schedule amounts.

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

    Comments: In June 2016, we reported on IRS's development and implementation of its Investment Performance Tool for tracking cost, schedule and scope metrics for its IT investments. At the time, IRS was using the tool for two investments. As of September 2017, we were reviewing the agency?s use of the tool as part of an ongoing review. We plan to further examine the use of the tool and the supporting guidance to determine the extent to which they address this recommendation.
    Director: Shear, William B
    Phone: (202)512-4325

    8 open recommendations
    including 4 priority recommendations
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should consistently collect information that would enable them to track the specific type of assistance programs provide and the entrepreneurs they serve and use this information to help administer their programs.

    Agency: Department of Agriculture
    Status: Open

    Comments: In March 2017, USDA noted that its Rural Business-Cooperative Service had implemented procedures to improve data collected on program performance, including procedures to validate data entered into its Guarantee Loan System. In addition, USDA participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce?s Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for USDA to follow through on the initiatives described above.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should consistently collect information that would enable them to track the specific type of assistance programs provide and the entrepreneurs they serve and use this information to help administer their programs.

    Agency: Department of Commerce
    Status: Open
    Priority recommendation

    Comments: In March 2017, Commerce's Economic Development Administration (EDA) noted that it announced additional reporting requirements for grantees as part of its Fiscal Year 2017 Economic Development Assistance Programs federal funding opportunity that are intended to improve program evaluation. EDA added that it plans to work with the Office of Management and Budget (OMB) to finalize the new survey forms needed to implement the new requirements with a goal of piloting them in fiscal year 2017. In addition, Commerce participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce's Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for Commerce to follow through on the initiatives described above.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should consistently collect information that would enable them to track the specific type of assistance programs provide and the entrepreneurs they serve and use this information to help administer their programs.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: In February 2017, HUD noted that the department had completed its effort to clean up its Community Development Block Grant data and is working to resolve issues with grantees for which costs have been disallowed. HUD expects to resolve these issues by December 2017.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should consistently collect information that would enable them to track the specific type of assistance programs provide and the entrepreneurs they serve and use this information to help administer their programs.

    Agency: Small Business Administration
    Status: Open
    Priority recommendation

    Comments: In March 2017, SBA noted that it continues to evaluate its entrepreneurial development programs through third-party evaluations and limited data collected from their resource partners and will use this information to guide program development. In addition, SBA participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce's Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for SBA to follow through on the initiatives described above and collect information for the additional six programs identified in our report as lacking information.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should conduct more program evaluations to better understand why programs have not met performance goals and their overall effectiveness.

    Agency: Department of Agriculture
    Status: Open

    Comments: In March 2017, USDA noted that its Rural Business-Cooperative Service had implemented procedures to improve data collected on program performance, including procedures to validate data entered into its Guarantee Loan System. In addition, USDA participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce's Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for USDA to follow through on the initiatives described above that are intended to improve the evaluation of programs that provide assistance to entrepreneurs.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should conduct more program evaluations to better understand why programs have not met performance goals and their overall effectiveness.

    Agency: Department of Commerce
    Status: Open
    Priority recommendation

    Comments: In March 2017, Commerce's Economic Development Administration (EDA) noted that it announced additional reporting requirements for grantees as part of its Fiscal Year 2017 Economic Development Assistance Programs federal funding opportunity that are intended to improve program evaluation. EDA added that it plans to work with the Office of Management and Budget (OMB) to finalize the new survey forms needed to implement the new requirements with a goal of piloting them in fiscal year 2017. In addition, Commerce participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce's Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for Commerce to follow through on the initiatives described above and conduct evaluations of the three economic development programs that have not yet been assessed.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should conduct more program evaluations to better understand why programs have not met performance goals and their overall effectiveness.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: In February 2017, HUD noted that the department had completed its effort to clean up its Community Development Block Grant data and is working to resolve issues with grantees for which costs have been disallowed. HUD expects to resolve these issues by December 2017.
    Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should conduct more program evaluations to better understand why programs have not met performance goals and their overall effectiveness.

    Agency: Small Business Administration
    Status: Open
    Priority recommendation

    Comments: In March 2017, SBA noted that it had taken a number of steps to build its program evaluation function, including (1) hiring its first lead program evaluator in August 2016 to manage new and coordinate ongoing agency program evaluations, (2) drafting a program evaluation framework that will support the agency's efforts to conduct, monitor, and implement findings from evaluations, and (3) creating a performance and evaluation community of practice that meets on a monthly basis to discuss program evaluation principles and address questions for the framework (e.g., data sharing, definitions, learning agendas). SBA expects to start new program evaluations in 2017. In addition, SBA participates in an OMB-led interagency working group convened to share best practices in program evaluation, data sharing, and technical assistance analysis. In March 2017, OMB noted that SBA and Commerce's Office of Performance and Risk Management plan to co-publish a report outlining several best practices in program evaluation, data sharing, and technical assistance. It will be important for SBA to follow through on the initiatives described above that are intended to improve the evaluation of programs that provide assistance to entrepreneurs.
    Director: Scire, Mathew J
    Phone: (202) 512-8678

    1 open recommendations
    Recommendation: To help meet the requirements of the Recovery Act's Section 1602 provisions to help ensure the long-term viability of the buildings, the Secretary of the Treasury should assess the extent to which HFAs are utilizing information provided to them by project owners duringthe 15-year compliance period, taking into account the level of investor equity in projects.

    Agency: Department of the Treasury
    Status: Open

    Comments: In an email from Treasury on September 14, 2015, officials stated that they have taken no additional actions since the report was issued. At that time, they sent copies of the report to the state HFAs with instructions for the HFAs to fulfill their duties. However, this does not insure the HFAs maintain their asset management responsibilities during the 15 year compliance period as required by Section 1602. On January 24, 2017, the agency informed us that they plan no further action on this recommendation.
    Director: Scire, Mathew J
    Phone: (202)512-3000

    1 open recommendations
    Recommendation: To help estimate, reduce, and recover improper payments in the Section 521 rental assistance program, the Secretary of Agriculture should draft proposed legislation for congressional consideration that would grant RHS access to SSA benefits data for purposes of verifying tenant incomes.

    Agency: Department of Agriculture
    Status: Open

    Comments: As of July 2016, USDA had not drafted proposed legislation that would grant RHS access to SSA benefits data.
    Director: Clowers, Angela N
    Phone: (202) 512-8678

    2 open recommendations
    Recommendation: As SEC works to enhance its oversight of FINRA, the SEC Chairman should encourage FINRA to conduct retrospective reviews of its rules and establish a process for examining FINRA's reviews.

    Agency: United States Securities and Exchange Commission
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: As SEC works to enhance its oversight of FINRA, the SEC Chairman should direct Office of Compliance Inspections and Examinations (OCIE) to follow all elements of a risk-management framework as it develops plans for an enhanced risk-based approach to FINRA oversight, such as developing plans for how it will prioritize risks related to oversight of FINRA and assessing the effectiveness of its risk-based model.

    Agency: United States Securities and Exchange Commission
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Scire, Mathew J
    Phone: (202)512-3000

    2 open recommendations
    Recommendation: To help reduce voucher program costs or better ensure the efficient use of voucher program funds, the HUD Secretary should provide information to Congress on housing agencies' estimated amount of excess subsidy reserves. In taking these steps, the Secretary should determine a level of subsidy reserves housing agencies should retain on an ongoing basis to effectively manage their voucher programs.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: According to HUD officials, the Department quarterly reports to Congress and the Inspector General (1) total housing agency reserves and (2) 8.5 percent of total housing agency reserves, the amount the Department has determined that housing agencies collectively should maintain on an ongoing basis to manage the voucher program (all other reserves are generally considered "excess"). HUD has also taken steps to determine an appropriate level of subsidy reserves that individual housing agencies should retain on an ongoing basis to effectively manage their voucher programs. Specifically, HUD has proposed that small housing agencies (fewer than 50 vouchers) should maintain 12 percent of their monthly renewal budget authority in reserves; medium housing agencies (50-249 vouchers) should maintain 6 percent of monthly renewal budget authority; and large housing agencies (250 or more vouchers) should maintain 4 percent of monthly renewal budget authority. In setting these reserve levels, HUD considered several factors including program size and budget and voucher utilization rates, among other things. This recommendation will remain open until HUD implements these proposed changes. As of September 2017, HUD officials said that the administration was determining whether or not to move forward with this proposal.
    Recommendation: To help reduce voucher program costs or better ensure the efficient use of voucher program funds, the HUD Secretary should provide information to Congress on its criteria for how it will redistribute excess reserves among housing agencies so that they can serve more households. In taking these steps, the Secretary should determine a level of subsidy reserves housing agencies should retain on an ongoing basis to effectively manage their voucher programs.

    Agency: Department of Housing and Urban Development
    Status: Open

    Comments: According to HUD officials, the Department quarterly reports to Congress and the Inspector General (1) total housing agency reserves and (2) 8.5 percent of total housing agency reserves, the amount the Department has determined that housing agencies collectively should maintain on an ongoing basis to manage the voucher program (all other reserves are generally considered "excess"). HUD has also taken steps to determine an appropriate level of subsidy reserves that individual housing agencies should retain on an ongoing basis to effectively manage their voucher programs. Specifically, HUD has proposed that small housing agencies (fewer than 50 vouchers) should maintain 12 percent of their monthly renewal budget authority in reserves; medium housing agencies (50-249 vouchers) should maintain 6 percent of monthly renewal budget authority; and large housing agencies (250 or more vouchers) should maintain 4 percent of monthly renewal budget authority. In setting these reserve levels, HUD considered several factors including program size and budget and voucher utilization rates, among other things. This recommendation will remain open until HUD implements these proposed changes. As of September 2017, HUD officials said that the administration was determining whether or not to move forward with this proposal.
    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)512-3000

    1 open recommendations
    Recommendation: To help ensure that CFTC and SEC are strategically positioned to implement the joint report's recommendations and address remaining harmonization opportunities, as CFTC and SEC continue to develop the charter for the Joint Advisory Committee, the Chairmen of CFTC and SEC should take steps to establish, with associated time frames, clearer goals for future harmonization efforts and requirements for reporting and evaluating progress toward these goals. Specifically, the agencies could benefit from formalizing a plan to assess implementation of the joint report's recommendations and harmonization opportunities that may not have been fully addressed by the joint report, such as differences in market structure and investor definitions. Such a plan could include goals for future harmonization efforts, such as time frames for implementing the recommendations; assessment of whether remaining differences in statutes and regulations result in inconsistent regulation of similar products and entities that could lead to opportunities for regulatory arbitrage; and periodic reports to Congress on their progress, including the implementation and impact of the recommendations.

    Agency: Commodity Futures Trading Commission
    Status: Open

    Comments: In August 2014, CFTC staff confirmed that CFTC had not taken steps to implement this recommendation. According to CFTC staff, since the issuance of the GAO report in April 2010, CFTC has prioritized implementing Dodd-Frank Act requirements related to harmonization and has not established a plan or specific goals related to harmonization.
    Director: Shear, William B
    Phone: (202)512-8678

    2 open recommendations
    Recommendation: To better address the purpose of the 8(a) program, meet the needs and expectations of the firms in the program, and improve SBA's ability to determine how well the program is working, the Administrator, SBA, should periodically perform a nationwide sample survey of 8(a) firms to obtain measurable program data. At a minimum, the survey should assess whether SBA assistance is meeting the firms' expectations and needs.

    Agency: Small Business Administration
    Status: Open

    Comments: SBA drafted a plan for providing individualized business development assistance to 8(a) firms, along with an assessment tool--the 8(a) Business Development Assessment Tool (BDAT). A subsequent evaluation of BDAT revealed that the tool would not provide the expected outcome. Consequently, the Office of Government Contracting and Business Development launched a more broad modernization effort in December of 2011. One of the outcomes of that effort was the conceptualization of the One Track Certification Management System (One Track CMS), which included many of the requirements from the BDAT. However, SBA experienced some delays regarding the contract for development and the ultimate implementation of the One Track CMS. On June 3, 2015, SBA and GAO staff met to discuss the status of open SBA 8(a) program recommendations. This recommendation was mentioned, but, no updates on the current status of this recommendation were provided. The One Track CMS was not yet operational as of the date of that meeting.
    Recommendation: To better address the purpose of the 8(a) program, meet the needs and expectations of the firms in the program, and improve SBA's ability to determine how well the program is working, the Administrator, SBA, should provide a method for collecting data on each firm's training needs for tracking the assistance provided.

    Agency: Small Business Administration
    Status: Open

    Comments: With the deployment of the Business Development Management Information System on July 28, 2008, along with an 8(a) Business Development Assessment Tool (BDAT)--which will entail an enhancement of SBA's Business Development Management Information System--SBA stated that it will be able to annually collect data that will be used to assess an 8(a) participant's needs for technical assistance and training. A subsequent evaluation of BDAT revealed that the tool would not provide the expected outcome. Consequently, the Office of Government Contracting and Business Development launched a more broad modernization effort in December of 2011. One of the outcomes of that effort was the conceptualization of One Track Certification Management System (One Track CMS), which included many of the requirements from the BDAT. However, SBA experienced some delays regarding the contract for development and the ultimate implementation of the One Track CMS. On June 3, 2015, SBA and GAO staff met to discuss the status of open SBA 8(a) program recommendations. This recommendation was mentioned, but no updates on the current status of this recommendation were provided. The One Track CMS was not yet operational as of the date of that meeting.