Status of the Transfer of Office of Thrift Supervision Functions

Appendix 1: Objective, Scope, and Methodology

As required by Title III, Transfer of Powers to the Comptroller of the Currency, the Corporation, and the Board of Governors, of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS) prepared a Joint Implementation Plan (Plan) to accomplish the transfer of functions, employees, property, and funds of OTS as well as implement other provisions of Title III. We conducted this joint review to fulfill our requirement under Section 327(c) of Title III. This section requires the Inspectors General of FRB, FDIC, and the Department of the Treasury (Treasury) to provide a written report on the status of the implementation of the Plan every 6 months until all aspects of the Plan are implemented. The period covered by our audit is September 26, 2012, to January 31, 2013.

For the most part, as we jointly reported previously under the above requirement, the Plan has been implemented in that the functions, people, and property of OTS have transferred in accordance with Title III and the Plan. However, there remain certain open items and time-limited provisions impacting former OTS employees that we continue to monitor. For this reporting period, we reviewed

• certain items related to the collection of supervisory assessments by FRB, and
• additional certification requirements for certain transferred OTS examiners.

For FRB

• We interviewed senior supervisory financial analysts from the Division of Banking Supervision and Regulation and an Assistant Director from the Division of Financial Management.
• We reviewed relevant FRB documentation pertaining to supervisory assessments.

For OCC

• We interviewed the Senior Advisor for Examiner Workforce Planning for Midsize Community Bank Supervision.
• We reviewed the final report of the consultant hired by OCC to assist in developing an alternative qualification process for certain OTS examiners to acquire the National Bank Examiner commission without taking the full Uniform Commission Examination.

In our last report, issued on September 26, 2012, we identified no ongoing issues related to FDIC's implementation of the Plan. In addition, FDIC has not been advised of any new issues regarding the Plan. Therefore, FDIC OIG did not perform field work for this 6-month reporting period.

Consistent with our objective, we did not assess FRB's or OCC's overall internal control or management control structure; obtain data from their information systems; or assess the effectiveness of their information system controls. We conducted our fieldwork at FRB and OCC in Washington, DC, from October 2012 to January 2013.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective.