Board Report: OIG-11-109 September 28, 2011
Title III of the Dodd-Frank Act established provisions for the transfer of authority from the Office of Thrift Supervision (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 was to receive 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 thatdetailed 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 of the Joint Implementation Plan.
On March 28, 2011, the IGs jointly issued a report concluding that the actions described in the Joint Implementation Plan generally conformed to the provisions of Title III. In April 2011, in response to the IGs' report, the Joint Implementation Plan was amended to expand on the protections for transferred OTS employees.
Title III requires the IGs to report on the status of implementing the Joint Implementation Plan every six months following the issuance of the initial IG report. Accordingly, the IGs issued a status report on September 28, 2011, that concluded that the Board, the FDIC, the OCC, and the OTS have substantially implemented the actions in the Joint Implementation Plan that were necessary to transfer OTS functions, employees, funds, and property to the Board, the FDIC, and the OCC, as appropriate. However, certain elements of the plan are ongoing or were not yet required to be completed as provided in Title III. 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.
