The Federal Deposit Insurance Corporation's Financial Disclosure Regulations Should Be Improved
FPCD-77-49: Published: Jun 1, 1977. Publicly Released: Jun 1, 1977.
- Full Report:
The close relationship between the Federal Deposit Insurance Corporation (FDIC) and the banking industry requires the Corporation to have an effective financial disclosure system for its employees. The Corporation has established several disclosure systems to prevent and detect employee conflicts of interest.
FDIC required 89 of its 3,400 employees to file annual disclosure statements with the ethics counselor. Over 1,000 other FDIC employees should be required to file statements.
Recommendation for Executive Action
Comments: Please call 202/512-6100 for additional information.
Recommendation: The Chairman of the FDIC should improve the effectiveness of the financial disclosure systems by: (1) coordinating administration of the three financial disclosure reporting systems in the office of the ethics counselor; (2) requiring employees in bank examiner positions to file annual financial disclosure statements; (3) developing specific criteria for determining which other employees should file statements and applying these criteria to all positions; (4) developing specific regulations for restricting loans from State banks which the Corporation examines, and affiliates of those banks, for employees in policy and decisionmaking positions; (5) seeking Civil Service Commission approval to revise the FDIC annual financial disclosure form to include additional data on employee loans, bank credit cards, and other bank related financial interests; (6) developing procedures to collect financial disclosure statements from employees entering positions which require them; and (7) reviewing questionable interests to determine whether action is necessary to prevent possible conflict of interest.