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Open Recommendations

Home Mortgage Disclosure Act: Reporting Exemptions Had a Minimal Impact on Data Availability, but Additional Information Would Enhance Oversight

GAO-21-350
May 17, 2021
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2 Open Recommendations
Agency Affected Recommendation Status
Congress Congress should consider requiring all HMDA reporters to disclose whether a covered loan or application is for an open-end line of credit. (Matter for Consideration 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Consumer Financial Protection Bureau The Director of CFPB should provide the federal financial regulators with additional information in its analysis to help them oversee lenders' eligibility for partial exemptions and related HMDA reporting. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Financial Stability: Agencies Have Not Found Leveraged Lending to Significantly Threaten Stability but Remain Cautious Amid Pandemic

GAO-21-167
Dec 16, 2020
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1 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury, as Chairperson of FSOC and in consultation with FSOC members, should incorporate regular scenario-based exercises designed to evaluate individual FSOC member and collective capabilities for responding to crises into its risk-assessment activities. These could include tabletop exercises that assume increased financial risks under plausible macroeconomic and financial conditions that may require multiple regulators to respond. (Recommendation 1)
Open
In its written comments to our report, FSOC neither agreed nor disagreed with our recommendation. FSOC noted that it consists of individuals who lead federal and state financial regulatory agencies, and that it often leverages the work and expertise of its member agencies in order to avoid unnecessary overlap or duplication of efforts. It noted that, consistent with this approach, a number of financial regulators organize tabletop exercises, and FSOC staff regularly participate in those activities. It stated that if it determines that further analysis or action is needed, it will act, as appropriate. We maintain that FSOC could improve its members' collective ability to respond to systemic risks by conducting regular tabletop or other scenario-based exercises. We believe that FSOC's own activities could be supplemented with scenario-based exercises that could yield additional insights specifically about regulatory responses to systemic risks. In particular, structured discussions of financial distress scenarios could provide additional insights into the financial system's resilience to adverse economic conditions, as well as FSOC members' abilities and limitations to respond to potential threats. We do not believe that conducting these exercises would lead to overlap or duplication with the efforts of individual member agencies. As we noted in the report, these exercises could be particularly helpful for analyzing risks stemming from broad-based activities like leveraged lending that involve a variety of entities overseen by multiple regulators.

Anti-Money Laundering: Opportunities Exist to Increase Law Enforcement Use of Bank Secrecy Act Reports, and Banks' Costs to Comply with the Act Varied

GAO-20-574
Sep 22, 2020
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1 Open Recommendations
Agency Affected Recommendation Status
Financial Crimes Enforcement Network The Director of FinCEN should develop and implement written policies and procedures to help promote the greater use of BSA reports by law enforcement agencies that do not have direct access to the BSA database. Such policies and procedures could include outreach strategies and educational or training materials. (Recommendation 1)
Open
FinCEN agreed with our recommendation but noted it must also ensure that broader access to BSA reports be balanced against security considerations. In March 2021, FinCEN notified us that it has commenced a review of the policies and procedures relevant to BSA data access, including those under which it evaluates requests for direct access to BSA data and will revise them, as needed, to ensure that the criteria used are optimal to determine appropriate access to BSA data. Additionally, FinCEN has developed an action plan to enhance its outreach efforts while ensuring that the BSA data access framework is capable of handling increased volume that may result. FinCEN expects to complete its action plan by the end of fiscal year 2021.

Bank Supervision: FDIC Could Better Address Regulatory Capture Risks

GAO-20-519
Sep 04, 2020
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4 Open Recommendations
Agency Affected Recommendation Status
Federal Deposit Insurance Corporation The Division Director for Risk Management Supervision (RMS) should require case managers to document how high-risk areas in the scoping plan were considered by the examination team if they were not addressed in the examination report. (Recommendation 1)
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 Division Director for RMS should implement policies to require that higher-level managers review case managers' documentation that describes whether banks have fully addressed MRBAs. (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 Division Director for RMS should revise examination documentation retention policies to increase the retention period beyond one examination cycle for banks with satisfactory or better composite ratings. (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 FDIC Chairman should direct RMS and the Legal Division Ethics Unit to develop a process for systematically requesting and collecting information on where departing examiners, including examiners-in-charge, enter into employment after leaving FDIC. (Recommendation 4)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
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