Opportunities Exist to Enhance the Board’s Oversight of Future Complex Enforcement Actions

September 30, 2014

Memorandum

The Office of Inspector General (OIG) has completed its final report on the subject evaluation. We conducted this evaluation to (1) evaluate the Board of Governors of the Federal Reserve System's (Board) overall approach to oversight of the amended consent orders, (2) determine the effectiveness of the Board's oversight of the slotting process, and (3) determine the effectiveness of the Board's oversight of the paying agent, Rust Consulting, Inc.

Our report contains five recommendations to enhance the Board's oversight of future complex enforcement actions. In your response, you stated that you generally agreed with our recommendations and that you will leverage information learned throughout the IFR process and the implementation of the payment agreement for similar complex enforcement actions in the future. We have included your response as appendix C in our report.

We appreciate the cooperation that we received from the Board's Division of Banking Supervision and Regulation, the Division of Consumer and Community Affairs, and the Legal Division. Please contact me if you would like to discuss this report or any related issues.