Board Report: OIG-11-064 March 28, 2011
Title III of the Dodd-Frank Act established provisions for the transfer of authority from the OTS to the Office of the Comptroller of the Currency (OCC), the FDIC, and the Board within one year after the July 21, 2010, date of enactment. Under Title III, the Board receives the functions and rulemaking authority for consolidated supervision of savings and loan holding companies and their non-depository subsidiaries. The Dodd-Frank Act required that, within 180 days after its enactment, the OTS, the OCC, the FDIC, and the Board jointly submit a plan (Joint Implementation Plan) to Congress and the IGs of the Treasury, the FDIC, and the Board that detailed the steps each agency would take to implement the Title III provisions.
The Joint Implementation Plan was submitted to Congress and the IGs onTitle III of the Dodd-Frank Act established provisions for the transfer of authority from the OTS to the OCC, the FDIC, and the Board within one year after the July 21, 2010, date of enactment. Under Title III, the Board receives the functions and rulemaking authority for consolidated supervision of savings and loan holding companies and their non-depository subsidiaries.
The Dodd-Frank Act required that, within 180 days after its enactment, the OTS, the OCC, the FDIC, and the Board jointly submit a plan (Joint Implementation Plan) to Congress and the IGs of the Treasury, the FDIC, and the Board that detailed the steps each agency would take to implement the Title III provisions. The Joint Implementation Plan was submitted to Congress and the IGs on January 25, 2011. The Dodd-Frank Act required that the IGs conduct a review to determine whether the implementation plan conformed to the Title III provisions and issue a report within 60 days after the submission of the Joint Implementation Plan.
On March 28, 2011, 60 days after the Joint Implementation Plan was submitted, the IGs jointly issued a report concluding that the actions described in the Joint Implementation Plan generally conformed to the provisions of Title III. The report stated that the Board’s component of the implementation plan sufficiently addressed the applicable Title III requirements. The report noted, however, that the Joint Implementation Plan did not address the prohibition against involuntary separation or relocation of transferred OTS employees for 30 months (except under certain circumstances) and, therefore, recommended that the Joint Implementation Plan be amended to address this requirement. The FDIC and the OCC are the agencies receiving OTS employees. In written comments on the IGs’ report, the FDIC and the OCC, along with the OTS, concurred with the recommendation. The Board stated in its written comments that it agreed with the conclusion that the Board’s part of the plan complied with Title III.
