Financial Disclosure Systems in Banking Regulatory Agencies

FPCD-77-29: Published: Mar 23, 1977. Publicly Released: Mar 23, 1977.

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The Office of the Comptroller of the Currency (OCC) must make sure that its employees maintain the highest ethical standards when doing their work. An effective financial disclosure system can help provide such assurances. However, the Comptroller has not yet developed the disclosure system to that point.

The OCC financial disclosure system needs: (1) adequate criteria for identifying positions where incumbents should file disclosure statements; (2) effective procedures with adequate criteria for reviewing statements and identifying conflicts of interest; (3) adequate procedures for collecting statements; (4) additional financial information reported on the statements to help enforce statutory prohibitions; and (5) greater assurance that assistant national bank examiners, who are not required to file statements, do not hold interests that violate statutory and/or administrative prohibitions.

Recommendation for Executive Action

  1. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Comptroller of the Currency should: (1) require national bank examiners to file annual financial disclosure statements; (2) develop specific criteria for identifying positions and employees who should file statements and apply those criteria to all positions; (3) develop consistent and comprehensive written regulations encompassing the various restrictions placed on employees' interests by federal regulations; (4) develop comprehensive guidelines for employees as to the types of interests that are prohibited; develop and maintain a listing of all employees required to file statements and obtain approval as needed from the Department of the Treasury and the Civil Service Commission; (5) revise the disclosure statement to require disclosure of employee loans and bank credit cards; (6) develop procedures to ensure that statements are properly and promptly collected; (7) require assistant national bank examiners to update annually financial information on indebtedness and ownership of national bank stock; and (8) review the questionable interests and take appropriate corrective action.

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