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Recommendations Database

GAO’s recommendations database contains report recommendations that still need to be addressed. GAO’s priority recommendations are those that we believe warrant priority attention. We sent letters to the heads of key departments and agencies, urging them to continue focusing on these issues. Below you can search only priority recommendations, or search all recommendations.

Our recommendations help congressional and agency leaders prepare for appropriations and oversight activities, as well as help improve government operations. Moreover, when implemented, some of our priority recommendations can save large amounts of money, help Congress make decisions on major issues, and substantially improve or transform major government programs or agencies, among other benefits.

As of October 25, 2020, there are 4812 open recommendations, of which 473 are priority recommendations. Recommendations remain open until they are designated as Closed-implemented or Closed-not implemented.

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Results:

Federal Agency: "Department of the Treasury: Office of the Comptroller of the Currency"

4 publications with a total of 8 open recommendations including 1 priority recommendation
Download these results in CSV format or XLSX format.
Bank Secrecy Act: Examiners Need More Information on How to Assess Banks' Compliance Controls for Money Transmitter Accounts
GAO-20-46, Dec 3, 2019
Director: Michael E. Clements
Phone: (202) 512-8678

1 open recommendations
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Recommendation: The Comptroller of the Currency should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 2)

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.
Large Bank Supervision: OCC Could Better Address Risk of Regulatory Capture
GAO-19-69, Jan 24, 2019
Director: Michael Clements
Phone: (202) 512-8678

5 open recommendations
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Recommendation: The Senior Deputy Comptroller for Large Bank Supervision should revise Large Bank Supervisions policy to require documentation of examination teams internal deliberations that lead to consequential decisions for the bank, such as the decision whether to issue a Matter Requiring Attention, among others. (Recommendation 1)

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

Comments: As of July 2020, OCC continued to disagree with GAO's recommendation and stated that it neither has taken nor plans to take any actions to address it. We maintain that consistently documenting internal deliberations that lead to consequential decisions for the bank could increase the transparency and accountability of examination teams' findings and decisions.
Recommendation: The Senior Deputy Comptroller for Large Bank Supervision should revise Large Bank Supervisions policy to require that bank examination teams retain drafts of key documents, including the conclusion memorandum and supervisory letter, that record the supervisory review process. (Recommendation 2)

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

Comments: As of July 2020, OCC continued to disagree with GAO's recommendation and stated that it neither has taken nor plans to take any actions to address it. We maintain that revising the policy to ensure that drafts of key documents are not deleted will help OCC increase the transparency and accountability of the supervisory review process.
Recommendation: The Senior Deputy Comptroller for Large Bank Supervision should revise Large Bank Supervisions policy to require documentation of communications with banks, including those between executive and senior management and banks, that inform supervisory decisions. (Recommendation 3)

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

Comments: As of July 2020, OCC continued to disagree with GAO's recommendation and stated that it neither has taken nor plans to take any actions to address it. We maintain that having meeting minutes and other documentation of key communications would provide OCC with a more complete and transparent record of the information banks provide to examiners and how that information impacts supervisory decisions.
Recommendation: The Senior Deputy Comptroller for Large Bank Supervision should systematically track and monitor Large Bank Supervisions use of informal recommendations. (Recommendation 4)

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

Comments: As of July 2020, OCC continued to disagree with GAO's recommendation and stated that it neither has taken nor plans to take any actions to address it. We maintain that tracking and monitoring the use of informal recommendations could increase transparency of the supervisory process, which could help Large Bank Supervision mitigate the risk of regulatory capture.
Recommendation: The Chief Counsel should develop a policy for Large Bank Supervision (1) to check employees active conflicts of interests during the staffing process for examinations and other supervisory activities and (2) to document the results of this check. (Recommendation 6)

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

Comments: As of July 2020,, OCC continued to disagree with GAO's recommendation and does not plan to develop a policy to check if employees have active conflicts of interest during the staffing process for examinations and other supervisory activities. OCC noted in its December 2018 response letter to the report that they believed such a policy would shift the responsibility for ensuring compliance with recusal requirements from employees to those responsible for staffing. We maintain that this recommendation does not aim to alleviate the personal responsibility all employees have to comply with recusal requirements. Rather, our recommendation aims to strengthen the due diligence of those responsible for staffing by requiring an independent, preliminary check of active conflicts of interest.
Financial Technology: Agencies Should Provide Clarification on Lenders' Use of Alternative Data [Reissued with revisions on Mar. 12, 2019.]
GAO-19-111, Dec 19, 2018
Director: Michael E. Clements
Phone: (202) 512-8678

1 open recommendations
including 1 priority recommendation
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Recommendation: The Comptroller of the Currency should, in coordination with the other federal banking regulators and the Bureau of Consumer Financial Protection and with input from relevant stakeholders, communicate in writing to banks that engage in third-party relationships with fintech lenders on the appropriate use of alternative data in the underwriting process, including issues to consider when selecting types of alternative data to use. (Recommendation 4)

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

Comments: In December 2019, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the agencies) issued an interagency statement on the use of alternative data in credit underwriting. The statement broadly highlights some potential benefits and risks of using alternative data and encourages firms to responsibly use alternative data, but does not provide firms or banks with specific direction on the appropriate use of alternative data, including issues to consider when selecting types of alternative data to use. We will continue to monitor the agencies' actions related to this recommendation.
Financial Technology: Additional Steps by Regulators Could Better Protect Consumers and Aid Regulatory Oversight
GAO-18-254, Mar 22, 2018
Director: Lawrance L. Evans, Jr.
Phone: (202) 512-8678

1 open recommendations
Display
Recommendation: The Comptroller of the Currency should engage in collaborative discussions with other relevant financial regulators in a group that includes all relevant stakeholders and has defined agency roles and outcomes to address issues related to consumers' use of account aggregation services. (Recommendation 9)

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

Comments: In a May 2018 letter, OCC noted that its staff have met with the other banking regulators and with market participants about account aggregation issues in the past. In October 2018, OCC staff advised us that issues related to data aggregation were discussed at a June 28, 2018 meeting of the Fintech Interagency Discussion Group, which includes OCC, the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Bureau of Consumer Financial Protection. We followed up in January 2020 and they confirmed that their collaboration had yet to produce outcomes that would satisfy the recommendation. We plan to follow up with OCC staff to obtain updates on these efforts in the future.