OIG: Summary of Recommendations

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Summary of Recommendations

OIG Report No. 2014-SR-B-015

Rec. no.	Report page no.	Recommendation	Responsible offices
1	14	Develop a framework to guide planning, vetting, and approving activities for large, complex enforcement strategies that may involve multiple institutions, multiple Board divisions, or multiple Reserve Banks. This framework could include planning and risk assessment activities such as identifying key risks and possible risk-mitigating activities. assessing the feasibility of the intended corrective action. vetting possible alternatives. identifying documentation standards for the relevant initiative. defining performance measures as indicators of success and creating key interim milestones to monitor progress. assessing whether service-level agreements could be used to incentivize vendor performance consistent with expectations. identifying key assumptions. assessing whether the Board has the necessary skill sets and the resources available to oversee the intended corrective action. defining roles and responsibilities among the Board team overseeing the corrective action.	Division of Banking Supervision and Regulation, Division of Consumer and Community Affairs, and Legal Division
2	17	Identify the circumstances in which project management resources should be used and develop a staffing plan to include project management resources with appropriate subject-matter expertise for those situations.	Division of Banking Supervision and Regulation, Division of Consumer and Community Affairs, and Legal Division
3	23	Assess the potential impact of data reliability issues as part of the complex enforcement strategies framework described in recommendation 1. Specifically, consider how data availability or reliability issues may impact the feasibility of the exercise or the consistency of its results. As part of this analysis, consider whether alternative enforcement strategies can be adopted that mitigate or eliminate these challenges. As appropriate, these strategies should be developed, vetted, and approved as part of the planning process.	Division of Banking Supervision and Regulation, Division of Consumer and Community Affairs, and Legal Division
4	25	Finalize an approach to end the payment agreement, including developing, in coordination with the Office of the Comptroller of the Currency, a strategy to appropriately allocate any funds remaining in the Qualified Settlement Funds that have not been cashed or deposited by borrowers, and continuing efforts to locate uncompensated borrowers.	Division of Banking Supervision and Regulation, Division of Consumer and Community Affairs, and Legal Division
5	25	As part of future agreements involving payments to harmed consumers, identify potential options for distributing any residual amounts as part of the planning process.	Division of Banking Supervision and Regulation, Division of Consumer and Community Affairs, and Legal Division

Rec. no.

Report page no.

Recommendation

Responsible offices

Develop a framework to guide planning, vetting, and approving activities for large, complex enforcement strategies that may involve multiple institutions, multiple Board divisions, or multiple Reserve Banks. This framework could include planning and risk assessment activities such as

1. identifying key risks and possible risk-mitigating activities.
2. assessing the feasibility of the intended corrective action.
3. vetting possible alternatives.
4. identifying documentation standards for the relevant initiative.
5. defining performance measures as indicators of success and creating key interim milestones to monitor progress.
6. assessing whether service-level agreements could be used to incentivize vendor performance consistent with expectations.
7. identifying key assumptions.
8. assessing whether the Board has the necessary skill sets and the resources available to oversee the intended corrective action.
9. defining roles and responsibilities among the Board team overseeing the corrective action.