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    Subject Term: Banking

    12 publications with a total of 41 open recommendations including 1 priority recommendation
    Director: Anne-Marie Fennell
    Phone: (202) 512-3841

    1 open recommendations
    Recommendation: To help improve FWS's ability to evaluate the effectiveness of its compensatory mitigation strategies and ensure that the agency appropriately plans the obligations necessary for this purpose, the Director of the U.S. Fish and Wildlife Service should establish a timetable with milestones for modifying the RIBITS database to incorporate FWS's in-lieu fee program information.

    Agency: Department of the Interior: United States Fish and Wildlife Service
    Status: Open

    Comments: The U.S. Fish and Wildlife Service concurred with this recommendation. As of March 2017, we are awaiting further 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: Melissa Emrey-Arras
    Phone: (617) 788-0534

    5 open recommendations
    Recommendation: To help ensure quality information is conveyed to servicemembers about how the Servicemembers Civil Relief Act (SCRA) interest rate cap applies to student loans, the Secretary of Defense should direct the secretaries of each service branch, and work with other secretaries as appropriate, to ensure that all information about the SCRA interest rate cap for student loans is accurate when provided to servicemembers and to those who work with servicemembers to help them obtain SCRA benefits, including information contained in outreach materials.

    Agency: Department of Defense
    Status: Open

    Comments: The Department of Defense (DOD) disagreed with this recommendation believing it to be unnecessary because it is already providing accurate information. Specifically, DOD noted that the information provided in several documents GAO reviewed is accurately based on statute whereas Education's updated requirement to automatically apply the cap is based on policy that could change in the future. Moreover, the automated process applies only to federal and commercial FFEL student loans in contrast to other types of debt. DOD said that providing information based on statute rather than policy would cause less confusion and was a better approach than what we recommend. However, our report noted that Education formalized the automated process through federal regulations, effective July 2016, which legally require servicers to use this process for all federal and commercial FFEL loans. In addition, DOD said it was unable to verify whether DOD's Military OneSource website inaccurately states that the SCRA rate cap does not apply to commercial FFEL loans. However, our searches of the website still turned up this inaccuracy. DOD said it would look into a means of verifying website information but that in the meantime, it is satisfied that its training provides correct information. Given that Military OneSource is a key source of information for servicemembers and that some documents DOD provided state that the SCRA rate cap does not apply to student loans, we continue to believe that servicemembers are not always receiving accurate and up-to-date information.
    Recommendation: To ensure that all eligible servicemembers with student loans receive the SCRA interest rate cap, the Attorney General should direct the Department of Justice to consider modifying its proposed changes to SCRA to require use of the automatic eligibility check for private student loans.

    Agency: Department of Justice: Office of the Attorney General
    Status: Open

    Comments: The Department of Justice (DOJ) stated that its current package of proposed legislative changes provides benefits to servicemembers with all kinds of loans, including private student loans. Rather than requiring servicemembers to submit written notice and a copy of military orders, they need only give oral or written notice of eligibility for the cap to their creditors. Creditors would then have to search the Department of Defense's records to verify the servicemembers' military service and apply the SCRA interest rate cap, when applicable. DOJ believes that these changes would significantly benefit all servicemembers with loans while providing a uniform standard for all types of creditors. The department added that it will consider its proposed changes to SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how to improve SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans. The agency said that it would consider these changes to the SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how the agency can propose to improve the SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans.
    Recommendation: To enhance customer service, the Secretary of Education should direct the Office of Federal Student Aid to identify ways to modify the data collected in its unified borrower complaint system to allow the agency to more precisely identify and analyze complaints specifically about the SCRA interest rate cap.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education said it is committed to accurately tracking the types of complaints it receives and will create a complainant subcategory for SCRA under the "Military and Veterans Benefit" category. In addition, it will continue to run periodic key word searches to identify other complaints that may have been miscategorized by the complainant, related to the requirements of the SCRA, and ensure that they are considered appropriately. GAO will consider closing this recommendation when the department has provided evidence that it has completed these efforts.
    Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: The Consumer Financial Protection Bureau (CFPB) stated that it is committed to working with the Department of Justice (DOJ) and federal financial regulators, when possible, to facilitate oversight of SCRA compliance and that it will support all relevant federal agencies in using their respective authorities to identify and address SCRA violations as efficiently and effectively as possible. While CFPB coordinates with DOJ and other federal regulators in general, there is still no single agency authorized to enforce SCRA compliance among nonbank private student loan lenders and servicers, and no entity is conducting onsite supervisory reviews of these lenders and servicers. In addition, while CFPB may refer complaints from servicemembers about the SCRA rate cap for private student loans to DOJ and other financial regulators, we believe this does not constitute routine, proactive oversight and also presumes servicemembers are aware of the SCRA rate cap. GAO will consider closing this recommendation when the bureau has provided evidence of actions it has taken to facilitate routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers.
    Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

    Agency: Department of Justice: Office of the Attorney General
    Status: Open

    Comments: The Department of Justice (DOJ) believes that it is in full compliance with this recommendation and that the four federal financial regulators do not have statutory authority to examine nonbank private student loan lenders and servicers unaffiliated with a depository institution. DOJ stated that it already coordinates extensively with the Consumer Financial Protection Bureau (CFPB) and the financial regulators concerning SCRA compliance through such mechanisms as referrals from CFPB for any SCRA-related violations and access to its consumer complaint database, and regular meetings with CFPB, and that it will continue to be built upon these efforts. While these mechanisms are commendable, GAO believes they do not constitute exercising routine oversight of nonbank private student loan lenders and servicers who are not affiliated with a depository institution. We believe that additional interagency coordination, including working with CFPB to seek additional statutory authority, as needed, is necessary to ensure routine SCRA compliance.
    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: 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: St James, Lorelei
    Phone: (202) 512-2834

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

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

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

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

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

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

    Comments: As of August 2017, GAO is reviewing information provided by the Federal Reserve. The Federal Reserve has indicated that they have begun work to implement a more formal assessment program for forecasting new coin orders. In addition, the Cash Product Office has begun work to refine the accuracy of these forecasts.
    Director: Mctigue Jr, James R
    Phone: (202) 512-7968

    2 open recommendations
    including 1 priority recommendation
    Recommendation: The Acting Commissioner of the Internal Revenue Service should direct appropriate officials to develop a long-term strategy to improve web services provided to taxpayers, in accordance with Howto.gov and other federal guidance outlined in our report. To accomplish this, the IRS should establish a numerical or other measureable goal to improve taxpayer satisfaction and a timeframe for achieving it.

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

    Comments: IRS has made progress in improving its online services strategy, as we recommended, but as of March 2017, IRS has not yet completed its efforts. IRS's strategy has evolved from a singular focus on on-line services to a more comprehensive strategy of taxpayer interaction through all service channels. In February 2016, IRS announced an agency-wide Future State Initiative, which in part, aims to deliver service improvements across different taxpayer interactions such as individual online accounts assistance, exams, and collections. In July 2016, the official responsible for IRS's on-line office reported that the agency is working towards developing an overall customer service satisfaction goal as part of the IRS Future State Initiative. The official said that this goal is broadly meant to cover various ways the public interacts with IRS, including web, phone, correspondence and walk in. In November 2016, IRS provided documentation on the goals of the Future State Initiative. However, this documentation does not include specific numerical targets for the performance measures that IRS expects to achieve for each goal or a timeline to achieve those goals. As of March 2017, IRS is continuing to incorporate a customer service satisfaction goal in its upcoming strategic plan.
    Recommendation: The Acting Commissioner of the Internal Revenue Service should direct appropriate officials to develop a long-term strategy to improve web services provided to taxpayers, in accordance with Howto.gov and other federal guidance outlined in our report. To accomplish this, the IRS should develop business cases for all new online services, describing the potential benefits and costs of the project, and use them to prioritize future projects.

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

    Comments: IRS has made progress in improving its online services strategy, as we recommended, but as of March 2017, IRS has not yet completed its efforts. IRS's strategy has evolved from a singular focus on on-line services to a more comprehensive strategy of taxpayer interaction through all service channels. In February 2016, IRS announced an agency-wide Future State Initiative, which in part, aims to deliver service improvements across different taxpayer interactions such as individual online accounts assistance, exams, and collections. In addition, IRS revised its business case template in 2014 to include, among other things, a discussion of costs, benefits, and risks of future projects, consistent with our recommendation. However, IRS did not use the template to develop its Online Account business case, which it provided to us as an example in September 2015. We reviewed IRS documentation and found that the business case contained some of the information we recommended, such as high level time frames, but was missing other information, such as the benefits and costs of the project. Further, it is unclear how IRS plans to use the business case to prioritize future projects. In March 2016, IRS reported they implemented a new process for online investments that requires details on expected benefits and costs to be reviewed by the senior executives for prioritization and follow-up. As of March 2017, we requested additional documentation concerning this process. Analyses of benefits and costs can help agencies decide which new projects to start in a manner that maximizes the benefits derived from agency resources.
    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: 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: Cackley, Alicia P
    Phone: (202)512-3000

    1 open recommendations
    Recommendation: The Interagency Council and the Office of Management and Budget; in conjunction with the Secretaries of HHS, HUD, Labor, and VA should consider examining inefficiencies that may result from overlap and fragmentation in their programs for persons experiencing homelessness. As a starting point, the agencies could use the program information from this report to further analyze the degree and effects of overlap and fragmentation. The results of this assessment could be used to take actions to reduce any identified inefficiencies and therefore better leverage their resources. Actions may include streamlining services offered within specific programs or by agencies, identifying programs that could benefit from further research or evaluations, or consolidating programs or services to reduce administrative costs.

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

    Comments: We have contacted OMB three times recently regarding this recommendation, most recently on August 24, 2017. We have yet to receive a response.
    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: Williams, Mccoy
    Phone: (202)512-3000

    2 open recommendations
    Recommendation: The Senior Civilian Official for the Office of the Assistant Secretary of the Navy should develop a review process so that data call information on sponsor owned material is correctly reported.

    Agency: Department of Defense: Department of the Navy: Office of the Assistant Secretary of the Navy (Financial Management): Senior Civilian Official
    Status: Open

    Comments: According to Navy officials, sponsor owned material is a subset of Operating Materials and Supplies (OM&S) contained within the OM&S--Remainder (OM&S-R) category. The Navy's Office of Financial Operations (FMO) is providing direction to the various Navy budget submitting offices (BSOs) to guide the development of a complete, accurate, and validated population of the OM&S-R balances reported in the Navy's financial statements--to include sponsor owned material. Specifically, FMO is working with the BSOs to develop a review process in which the BSOs will reconcile their Accountable Property System of Record asset listings to the Navy's financial statements on a quarterly basis. FMO has performed a reconciliation for the third and fourth quarter of fiscal year 2016, and is currently performing a reconciliation for the first quarter of fiscal year 2017. However, FMO has yet to achieve a 100 percent accurate reconciliation. According to Navy FMO officials, the projected implementation date for this review process is expected to be after September 30, 2017. We will continue to follow-up on this recommendation.
    Recommendation: The Senior Civilian Official for the Office of the Assistant Secretary of the Navy should revise the Navy's policies for compiling its financial statements so that they are in accordance with federal accounting standards and the DOD Financial Management Regulation. Specifically: (1) ammunition items needing repair and those categorized as excess, obsolete, and unserviceable should be revalued appropriately to comply with SFFAS No. 3 and the DOD Financial Management Regulation; and (2) shipboard inventories aboard smaller combatant ships should be reported as operating materials and supplies in accordance with federal accounting standards.

    Agency: Department of Defense: Department of the Navy: Office of the Assistant Secretary of the Navy (Financial Management): Senior Civilian Official
    Status: Open

    Comments: Regarding the first part of this recommendation, Navy's procedures for financially reporting ammunition items deemed excess, obsolete, or unserviceable and ammunition items needing repair are not in compliance with federal accounting standards. The Statement of Federal Financial Accounting Standard Number 3 (SFFAS 3) states that excess, obsolete, and unserviceable operating material and supplies shall be valued at their net realizable value. The standard further states that repair costs for inventory held for repair must be accounted for and adjusted accordingly based on the method of accounting used. Specifically, for ammunition items needing repair, entities should revalue, or reduce, such items by the estimated repair costs for financial statement reporting purposes. However, the Navy is currently devaluing its excess, obsolete, and unserviceable ammunition to zero and reporting it as such on the financial statements. Further, although the Navy has identified an annual maintenance cost for ammunition items needing repair, the Navy currently does not devalue its ordnance, or ammunition, amounts by the estimated repair costs. The Navy contends that these are routine maintenance events and will elect to expense the ordnance maintenance cost as it is incurred in opposition to SFFAS 3. Regarding the second part of this recommendation, SFFAS 3 states that Operating Materials and Supplies (OM&S) should be accounted for using the consumption method; in that materials are to be reported as an asset until they are issued to an end user for consumption in normal operations, at which point they would be expensed. Navy acknowledges, in its fiscal year 2016 financial statements, that due to current system limitations, the consumption method of accounting for all of the Navy's OM&S is not feasible, although long-term efforts are underway to transition to the consumption method for the recognition OM&S expenses to address this previously identified material weakness. Until these efforts are completed, the Navy has granted the Fleet Forces Command and Pacific Fleet a waiver to account for OM&S utilizing the purchase method of accounting. Under the purchase method, the OM&S supplies are expensed upon purchase for the smaller combatant command ships, as opposed to federal accounting standards requiring them to be recognized as an asset on the balance sheet and then expensed when consumed in the normal course of operations. We will continue to follow-up on this recommendation and the related issues in future Navy Operating Material and Supplies audit work.