Submitter:

Name:Owen Ambur

Email:Owen.Ambur@verizon.net

Organization:

Name:Office of the Inspector General

Acronym:FRROIG

Description:
OIG Roles and Responsibilities -- Congress established the OIG as an independent oversight authority within the Board, the government agency component of the broader Federal Reserve System. In addition, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) established the OIG as an independent oversight authority for the Bureau. Within this framework, the OIG conducts audits, investigations, and other reviews of the Board's and the Bureau's program functions. By law, the OIG is not authorized to perform program functions. Consistent with the Inspector General Act of 1978, as amended (IG Act), our office, as the OIG forthe Board and the Bureau, - conducts and supervises independent and objective audits, investigations, and other reviews related to Board and Bureau programs and operations; - promotes economy, efficiency, and effectiveness within the Board and the Bureau; - helps prevent and detect fraud, waste, abuse, and mismanagement in Board and Bureau programs and operations; - reviews existing and proposed legislation and regulations and makes recommendations regarding possible improvements to Board and Bureau programs and operations; and - keeps the Board of Governors, the Director of the Bureau, and Congress fully and timely informed.

Stakeholder(s):

• Elizabeth A. Coleman: Inspector General


• Board of Governors of the Federal Reserve System: Established under different statutes, the Board and the Bureau have separate and distinct roles in the federal financial regulatory system, as described below. Mission of the Board. The Federal Reserve System — the nation's central bank — was established by Congress in 1913. It primarily comprises the Federal Reserve Board, which is an independent federal agency located in Washington, D.C., and 12 regional Federal Reserve Banks, which combine both public and private elements in their makeup and organization. The Board's mission is to foster the stability, integrity, and efficiency of the nation's monetary, financial, and payment systems to promote optimal macroeconomic performance. Within that overall mission, the Federal Reserve System has six primary goals with interrelated and mutually reinforcing elements: - Conduct monetary policy that promotes the achievement of the statutory objectives of maximum employment and stable prices. - Promote a safe, sound, competitive, and accessible banking system and stable financial markets. - Develop certain regulations, policies, and programs designed to inform and protect consumers, enforce federal consumer protection laws, strengthen market competition, and promote access to banking services in historically underserved markets. - Provide high-quality professional oversight of Federal Reserve Banks. - Foster the integrity, efficiency, and accessibility of U.S. payment and settlement systems. - Foster the integrity, efficiency, and effectiveness of Board programs.


• Bureau of Consumer Financial Protection: Mission of the Bureau. In July 2010, the Dodd-Frank Act established the Bureau of Consumer Financial Protection as an independent entity within the Federal Reserve System. The Bureau's statutory mission is to ensure that the markets for consumer financial products and services are fair, transparent, and competitive. The Bureau's primary functions include the following: - Implement and enforce federal consumer financial laws and restrict unfair, deceptive, and abusive practices. - Examine (1) large banks, savings associations, and credit unions (with over $10 billion in assets) and their affiliates; (2) mortgage-related nonbank companies (lenders, brokers, servicers, and loan medication firms), payday lenders, and private education loan providers; and (3) other nonbank participantsin the consumer financial products and services markets, as defined under Bureau regulations. - Monitor the marketplace for new risks to consumers and take appropriate action to make sure markets work as transparently as possible for consumers. - Operate a center for handling consumer complaints, including the establishment of a toll-free consumer hotline and a website for complaints and questions about consumer financial products and services. - Conduct research on consumer financial markets, and develop and promote financial education strategies to help consumers better understand financial products.


• Failed Financial Institutions: Congress has also mandated additional responsibilities that influence the OIG's priorities. Section 38(k) of the Federal Deposit Insurance Act (FDI Act) requires that the OIG review failed financial institutions supervised by the Board that result in a material loss to the Deposit Insurance Fund (DIF) and produce a report within six months. The Dodd Frank Act amended section 38(k) of the FDI Act by raising the materiality threshold, but also by requiring the OIG to report on the results of any nonmaterial losses to the DIF that exhibited unusual circumstances warranting an in-depth review.


• Financial Companies in Receivership: In addition, section 211(f) of the Dodd-Frank Act requires that the OIG review the Board's supervision of any covered financial company that is placed into receivership. The OIG will produce a report that evaluates the effectiveness of the Board's supervision, identifies any acts or omissions by the Board that contributed to or could have prevented the company's receivership status, and recommends appropriate administrative or legislative action.


• Council of Inspectors General on Financial Oversight (CIGFO): Furthermore, section 989E of the Dodd-Frank Act established the Council of Inspectors General on Financial Oversight (CIGFO), which comprises the Inspectors General (IGs) of the Board, the Commodity Futures Trading Commission, the Department of Housing and Urban Development (HUD), the Department of the Treasury (Treasury), the Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Agency, the National Credit Union Administration (NCUA), the Securities and Exchange Commission, and the Troubled Asset Relief Program. The CIGFO is required to meet at least quarterly to share information and discuss the ongoing work of each IG, with a focus on concerns that may apply to the broader financial sector and ways to improve financial oversight. Additionally, the CIGFO is required to annually issue a report that highlights the IGs' concerns and recommendations, as well as issues that may apply to the broader financial sector.


• Financial Sector


• Commodity Futures Trading Commission (CFTC)


• Department of Housing and Urban Development (HUD)


• Department of the Treasury (Treasury)


• Federal Deposit Insurance Corporation (FDIC)


• Federal Housing Finance Agency


• National Credit Union Administration (NCUA)


• Securities and Exchange Commission (SEC)


• Troubled Asset Relief Program (TARP)


• Office of Thrift Supervision (OTS): The Dodd-Frank Act abolishes the Office of Thrift Supervision (OTS) and divides its authorities among the Board, the FDIC, and the Office of the Comptroller of the Currency (OCC) effective July 21, 2011. The Board will receive OTS's authority for consolidated supervision of savings and loan holding companies and their non-depository subsidiaries; however, no OTS employees are required to be transferred to the Board. The act required that, within 180 days of enactment, the Board, the FDIC, the OCC, and the OTS jointly submit a plan to Congress and the IGs of the Board, the FDIC, and the Treasury detailing the steps the agencies will take to implement specified provisions of the act. We received the plan fulfilling this requirement on January 25, 2011. The DoddFrank Act required that, within 60 days of receiving the plan, the IGs of the Board, the FDIC, and the Treasury jointly provide a written report to the Board, the FDIC, the OCC, and the OTS, with copies to Congress, that detailed whether the plan conformed to the specified provisions of the act and included any additional recommendations for an orderly and effective process. This report was issued on March 28, 2011. Going forward, asrequired by the Dodd-Frank Act, the IGs of the Board, the FDIC, and the Treasury are to provide a written report on the status of the implementation of the plan every six months until all aspects of the plan are implemented.


• Office of the Comptroller of the Currency (OCC)


• The Public: Under section 1103(b) of the Dodd-Frank Act, the OIG is required, within 30 months of enactment, to conduct a study of a Freedom of Information Act (FOIA) exemption related to the Board's disclosure of certain information on emergency credit facilities, discount window lending programs, and open market transactions that are authorized or conducted by the Board or a Federal Reserve Bank. The OIG is required to study the impact of the FOIA exemption on the ability of the public to access information about the Board's administration of emergency credit facilities, discount window lending programs, and open market operations. In addition, the OIG's study must include any recommendations on whether the FOIA exemption should remain in effect.


• FRB's FISMA Manager: With respect to information technology (IT), the Federal Information Security Management Act of 2002 (FISMA), 44 U.S.C. §§3541-3549, establishes a legislative mandate for ensuring the effectiveness of information security controls over resources that support federal operations and assets. Consistent with FISMA's requirements, we perform an annual independent evaluation of the Board's information security program and practices, including the effectiveness of security controls and techniques for selected information systems. We also will conduct an annual independent evaluation of the Bureau's information security program and practices after the Bureau is fully operational.


• FRB Law Enforcement Officials: The USA PATRIOT Act of 2001 (USA PATRIOT Act), Public Law No. 107-56, grants the Board certain federal law enforcement authorities. Our office serves as the external oversight function (EOF) for the Board's law enforcement program and operations.


• Federal Financial Institutions Examination Council (FFIEC): In addition, section 726 of the Gramm-Leach-Bliley Act of 1999 amended the Federal Reserve Act by adding section 11B, which mandated annual independent audits of the financial statements of each Federal Reserve Bank and of the Board. We oversee the annual financial statement audits of the Board and the Federal Financial Institutions Examination Council (FFIEC).


• FRB OIG Programs: The OIG carries out these roles and responsibilities through an organizational structure aligned with the following program areas:


• Audits and Attestations: The Audits and Attestations program area assesses aspects of economy, efficiency, and effectiveness of Board and Bureau programs and operations, including (1) the presentation and accuracy of the Board's and the FFIEC's financial statements; (2)the efficiency and effectiveness of processes and internal controls over the agencies' programs and operations; (3)the adequacy of controls and security measures governing the agencies'financial and management information systems and the safeguarding of assets and sensitive information; and (4) compliance with applicable laws and regulations related to the agencies'financial, administrative, and program operations.


• Inspections and Evaluations: The Inspections and Evaluations program area conducts reviews of Board and Bureau programs and activities, including inspections, program evaluations, enterprise risk management activities, and process design and life-cycle evaluations. It also performs statutorily mandated reviews of failed financial institutions supervised by the Board.


• Investigations: The Investigations program area conducts criminal, civil, and administrative investigations of alleged fraud, waste, abuse, and employee misconduct related to Board and Bureau programs and operations.


• Legal Services: In addition, our organizational structure includes a Legal Services program that provides independent legal counsel to the IG, provides legal support for OIG programs and projects, serves as the OIG congressional and media liaison, and conducts legislative and regulatory reviews for the OIG.


• Management and Quality Assurance: Also, consistent with applicable standards that guide our work, we have a Management and Quality Assurance function to guide, expand, and enhance our strategic planning processes; communication protocols; products and reports; quality and internal control framework for audits, inspections, evaluations, and investigations; and internal administration.


• IT Infrastructure Staff: Finally, consistent with the independence of our office, we also maintain a separate IT infrastructure that provides the essential automation resources and support that enables us to effectively and efficiently carry out our program functions.