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Open Recommendations

Bank Regulatory Reviews: Action Needed to Better Identify and Address Unnecessary or Unduly Burdensome Requirements
GAO-26-108027
Jul 23, 2026
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6 Open Recommendations
Agency Affected Recommendation Status
Federal Reserve System The Chair of the Board of Governors of the Federal Reserve System should complete the development and implementation of documented procedures for identifying outdated, unnecessary, or unduly burdensome regulations and taking action to address them during the EGRPRA review. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Reserve System The Chair of the Board of Governors of the Federal Reserve System should incorporate into the agency's EGRPRA review, to the extent practicable, (1) a framework for prioritizing rules for retrospective analysis; (2) cost-benefit analysis; and (3) an assessment of cumulative regulatory burden, where feasible. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Deposit Insurance Corporation The Chairman of FDIC should complete the development and implementation of documented procedures for identifying outdated, unnecessary, or unduly burdensome regulations and taking action to address them during the EGRPRA review. (Recommendation 3)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Deposit Insurance Corporation The Chairman of FDIC should incorporate into the agency's EGRPRA review, to the extent practicable, (1) a framework for prioritizing rules for retrospective analysis; (2) cost-benefit analysis; and (3) an assessment of cumulative regulatory burden, where feasible. (Recommendation 4)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Office of the Comptroller of the Currency The Comptroller of the Currency should develop and implement documented procedures for identifying outdated, unnecessary, or unduly burdensome regulations and taking action to address them during the EGRPRA review. (Recommendation 5)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Office of the Comptroller of the Currency The Comptroller of the Currency should incorporate into the agency's EGRPRA review, to the extent practicable, (1) a framework for prioritizing rules for retrospective analysis; (2) cost-benefit analysis; and (3) an assessment of cumulative regulatory burden, where feasible. (Recommendation 6)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Securities and Exchange Commission: Updating Assessments of Staff Procedures Could Improve Key Agency Operations
GAO-26-107823
Mar 27, 2026
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4 Open Recommendations
Agency Affected Recommendation Status
United States Securities and Exchange Commission The Chairman of SEC should ensure that the Director of the Division of Enforcement test the operating effectiveness of internal supervisory controls using specific, measurable testing standards. (Recommendation 1)
Open
SEC agreed with the recommendation, and we will continue to monitor its implementation efforts.
United States Securities and Exchange Commission The Chairman of SEC should ensure that the Directors of the Division of Enforcement and Office of Credit Ratings update their respective written plans for assessing staff procedures to include all recommended elements of the Reference Guide for Compliance with Section 961 of the Dodd-Frank Act. (Recommendation 4)
Open
SEC agreed with the recommendation, and we will continue to monitor its implementation efforts.
United States Securities and Exchange Commission The Chairman of SEC should ensure that the Directors of the Division of Enforcement, Division of Corporation Finance, and Office of Credit Ratings update their written plans for assessing staff procedures to include an evaluation of their respective staff procedure development frameworks. (Recommendation 5)
Open
SEC agreed with the recommendation, and we will continue to monitor its implementation efforts.
United States Securities and Exchange Commission The Chairman of SEC should ensure that the Directors of the Division of Enforcement, Division of Corporation Finance, and Office of Credit Ratings evaluate their respective staff procedure development frameworks for the section 961 assessment. (Recommendation 6)
Open
SEC agreed with the recommendation, and we will continue to monitor its implementation efforts.

Nonbank Mortgage Companies: Ginnie Mae and FHFA Could Enhance Financial Monitoring
GAO-26-107436
Feb 10, 2026
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2 Open Recommendations
Agency Affected Recommendation Status
Federal Housing Finance Agency The Director of FHFA should ensure that the Counterparty Risk and Policy Branch develops procedures for assessing the reliability of MBFRF data used for monitoring activities and for treating potentially unreliable data. (Recommendation 1)
Open
In April 2026, FHFA said it planned to implement this recommendation by September 30, 2026.
Government National Mortgage Association The President of Ginnie Mae should ensure that the Office of Enterprise Risk develops guidance requiring analysts to consistently review key components of warehouse lending risk, including the committed funding amount, as part of the manual credit review process. (Recommendation 2)
Open – Partially Addressed
In June 2026, Ginnie Mae updated its procedures for the Counterparty Risk Analysis Division to clarify that credit analysts should review key components of warehouse lending risk, including diversification, utilization, maturity, and covenant violations. While generally consistent with our recommendation, the update did not specifically address the part of our recommendation about the amount of funding available from committed warehouse credit lines. As discussed in our report, the distinction between committed and uncommitted credit lines is important because committed lines are more stable sources of financing.
Federal Housing Finance Agency The Director of FHFA should ensure that the Counterparty Risk and Policy Branch assesses the feasibility and utility of incorporating all key components of warehouse lending risk in its risk scoring process. (Recommendation 3)
Open
In April 2026, FHFA said it planned to implement this recommendation by September 30, 2026.
Government National Mortgage Association The President of Ginnie Mae should ensure that the Office of Enterprise Risk incorporates consideration of alternative economic scenarios into Ginnie Mae's stress testing framework. (Recommendation 4)
Open – Partially Addressed
In April 2026, Ginnie Mae said it had expanded the number of adverse economic scenarios it evaluates as part its stress testing framework. For example, in December 2025, Ginnie Mae included a stagflation scenario in its stress tests. While Ginnie Mae's actions were generally consistent with our recommendation, as of July 2026, Ginnie Mae had not provided documentation showing that consideration of alternative economic scenarios is a permanent part of its stress testing framework. We will update the status of this recommendation when Ginnie Mae provides that documentation.

Artificial Intelligence: Use and Oversight in Financial Services
GAO-25-107197
May 19, 2025
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1 Open Recommendations
Agency Affected Recommendation Status
National Credit Union Administration The Chair of NCUA should update the agency's model risk management guidance to encompass a broader variety of models used by credit unions and provide additional details on key aspects of effective model risk management. (Recommendation 1)
Open
In March 2026, the Office of the Executive Director stated that NCUA launched an Artificial Intelligence (AI) resources page that provides information on AI implementation, risk management, data security, use cases, and cybersecurity risks. While the information compiled on NCUA's AI Resource Page could help federal credit unions implement AI, it does not provide detailed model risk management guidance that covers a broad variety of models, including AI models. Developing such guidance would strengthen NCUA's ability to address risks to consumers and to the safety and soundness of credit unions arising from the use of AI. We will continue to follow-up with NCUA regarding its model risk management guidance.
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