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As of January 31, 2023, there are 4840 open recommendations that still need to be addressed. 471 of these are priority recommendations, those that we believe warrant priority attention. Learn more about our priority designation on our Recommendations page.

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1 - 10 of 10 Recommendations, including 1 Priority Recommendations

Bank Supervision: Lessons Learned from Remote Supervision during Pandemic Could Inform Future Disruptions

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1 Open Recommendations
Agency Recommendation Status
Office of the Comptroller of the Currency OCC's Senior Deputy Comptrollers of Large Bank Supervision and Mid-Size and Community Bank Supervision should review potential lessons learned related to how OCC managed adjustments to supervisory activities during the COVID-19 pandemic. This review should include collection and analysis of information to identify aspects of fully remote examinations that worked well and areas for improvement. (Recommendation 2)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Fair Lending: Opportunities Exist to Enhance OCC's Oversight of Banks' Lending Practices

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2 Open Recommendations
Agency Recommendation Status
Office of the Comptroller of the Currency As OCC updates its redlining examination procedures, the Comptroller of the Currency should ensure the Compliance Risk Policy Division takes into account the new types of analysis being performed when it documents the steps that the examiners should take as they evaluate whether a bank has potentially engaged in redlining in violation of fair lending laws. (Recommendation 1)
Open

OCC stated that the updated examination procedures will clarify and expand the list of redlining risk factors, highlight certain key points regarding redlining case elements that have historically raised concerns, and update information from public redlining cases that concluded since the interagency fair lending examination procedures were published in 2010. The updated booklet is expected to be published no later than December 31, 2022. OCC will also develop additional training for examiners to highlight redlining examination best practices. Training will include live multi-part agency wide

Office of the Comptroller of the Currency The Comptroller of the Currency should ensure the Compliance Risk Policy Division and the Office of Midsize and Community Bank Supervision establish time frames for carrying out their plan to centrally track information on midsize and community bank fair lending examination screening, selection, and outcomes. The Compliance Risk Policy Division should use this information to analyze its screening and selection processes on an ongoing basis to ensure an appropriate balance of (1) effective identification of fair lending deficiencies and violations and (2) efficiency given available resources. (Recommendation 2)
Open

OCC's offices will work collaboratively to develop a centralized process and procedures to collect and monitor information on fair lending activities. The new process will include procedures regarding the selection and non-selection of identified focal points, the disposition of focal points not selected, and the documentation of examination outcomes, including whether supervisory activities identified fair lending deficiencies or potential violations. The target date to implement a data collection and monitoring process is January 1, 2023.

Banking Services: Regulators Have Taken Actions to Increase Access, but Measurement of Actions' Effectiveness Could Be Improved

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1 Open Recommendations
Agency Recommendation Status
Office of the Comptroller of the Currency The Comptroller of the Currency should complete efforts to develop and implement performance measures to cover the agency's key efforts for its strategic objective to promote financial inclusion through fair access to financial services—including Project REACh—that reflect leading practices, including demonstrating results, measuring outcomes, and providing useful information for decision-making. (Recommendation 3)
Open

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

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5 Open Recommendations
Agency Recommendation Status
Office of the Comptroller of the Currency 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)
Open

As of September 2022, OCC has not provided us an update with regard to this recommendation in response to our request for information. In 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

Office of the Comptroller of the Currency 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)
Open

As of September 2022, OCC has not provided evidence that it has taken action to address this recommendation. In 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.

Office of the Comptroller of the Currency 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)
Open

As of September 2022, OCC has not provided evidence that it has taken action with regard to this recommendation. In 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.

Office of the Comptroller of the Currency 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)
Open

As of September 2022, OCC has not provided evidence that it has taken action with regard to this recommendation. In 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.

Office of the Comptroller of the Currency The Senior Deputy Comptroller for Large Bank Supervision should systematically track and monitor Large Bank Supervisions use of informal recommendations. (Recommendation 4)
Open

As of September 2022, OCC has not provided us an update with regard to this recommendation in response to our request for information. In 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.

Financial Technology: Agencies Should Provide Clarification on Lenders' Use of Alternative Data [Reissued with revisions on Mar. 12, 2019.]

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1 Open Recommendations
1 Priority
Agency Recommendation Status
Office of the Comptroller of the Currency
Priority Rec.
This is a priority 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)
Open

The Comptroller of the Currency agreed with the recommendation. 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 (OCC) 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. However, the statement does not provide

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For questions about a specific recommendation, contact the person or office listed with the recommendation. For general information about recommendations, contact GAO's Audit Policy and Quality Assurance office at (202) 512-6100 or apqa@gao.gov.