Bank Oversight: Fundamental Principles for Modernizing the U.S. Structure
(Testimony, 05/02/96, GAO/T-GGD-96-117).

GAO discussed efforts to modernize the U.S. federal bank oversight
structure, focusing on: (1) how the U.S. oversight structure compares
with five other industrialized countries; and (2) whether these
countries' structures can be used to assist U.S. reform. GAO noted that:
(1) U.S. structural reform should include a more consolidated and
comprehensive oversight of companies owning federally insured banks and
thrifts, independence from undue political pressure, appropriate
accountability and adequate congressional oversight, consistent rules,
and enhanced efficiency and reduced regulatory burden; (2) the five
countries have oversight structures that are diverse, banking industries
that are more concentrated than in the U.S., and banks that are
authorized to conduct broad securities and insurance activities; (3) in
each of the five countries, there are no more than two national agencies
involved in oversight operations; (4) each country was heavily involved
in bank oversight and ensured that its ministry of finance was informed
of important industry and supervisory developments; (5) the countries'
oversight structures have systems of checks and balances to guard
against political pressure and maintain the public trust and stability
in its financial system; (6) each country has given deposit insurers
limited roles and viewed them as primarily a source of funding for bank
failures; (7) the oversight structures incorporate mechanisms to ensure
consistent oversight and limited regulatory burden; and (8) there are a
number of ways that the U.S. can simplify its bank oversight structure.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-GGD-96-117
     TITLE:  Bank Oversight: Fundamental Principles for Modernizing the 
             U.S. Structure
      DATE:  05/02/96
   SUBJECT:  Banking regulation
             Lending institutions
             Foreign corporations
             Bank management
             Bank examination
             Oversight by Congress
             Bank failures
             Foreign governments
             Banking law
IDENTIFIER:  Canada
             France
             Germany
             United Kingdom
             Japan
             
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Cover
================================================================ COVER


Before the Committee on Banking and Financial Services
House of Representatives

For Release on Delivery
Expected at
10:00 a.m., EDT
Thursday
May 2, 1996

BANK OVERSIGHT - FUNDAMENTAL
PRINCIPLES FOR MODERNIZING THE
U.S.  STRUCTURE

Statement of James L.  Bothwell
Director, Financial Institutions and Markets Issues
General Government Division

GAO/T-GGD-96-117

GAO/GGD-96-117T


(233491)


Abbreviations
=============================================================== ABBREV

  FDIC - Federal Deposit Insurance Corporation
  OCC - Office of Comptroller of Currency
  OTS - Office of Thrift Supervision
  U.K.  - United Kingdom

BANK OVERSIGHT:  FUNDAMENTAL
PRINCIPLES FOR MODERNIZING THE
U.S.  STRUCTURE
====================================================== Chapter SUMMARY

GAO's testimony identifies four fundamental principles that GAO
believes Congress could use in considering the best approach for
modernizing the current U.S.  regulatory structure.  Specifically,
GAO believes that structural reform should provide for

  -- consolidated and comprehensive oversight of companies owning
     federally insured banks and thrifts, with coordinated functional
     regulation and supervision of individual components;

  -- independence from undue political pressure, balanced by
     appropriate accountability and adequate congressional oversight;

  -- consistent rules, consistently applied for similar activities;
     and finally,

  -- enhanced efficiency and reduced regulatory burden. 

GAO studies on the structure and operation of bank oversight in
Canada, France, Germany, the United Kingdom (U.K.), and Japan show
that each of the five oversight structures reflects the four
principles cited above in its own way.  With few, if any, exceptions,
each (1) had fewer national agencies involved with bank regulation
and supervision than is the case in the United States; (2) had
substantial oversight roles for their central banks and ensured that
their ministries of finance were, at the least, kept informed of
important industry and supervisory developments; (3) had relatively
narrow roles for their deposit insurers; and (4) incorporated
mechanisms and procedures to ensure consistent, consolidated
oversight and limit regulatory burden. 

GAO's work on these five foreign systems showed that there are a
number of different ways to simplify bank oversight in this country
in accordance with the four principles mentioned above.  While GAO
recognizes that only Congress can make the ultimate policy judgments
in deciding exactly how to restructure, GAO recommends that Congress
do the following: 

  -- Reduce the number of federal agencies with primary
     responsibilities for bank oversight. 

  -- Include both the Federal Reserve and the Treasury Department in
     bank oversight. 

  -- Provide FDIC with necessary authority to protect the deposit
     insurance funds. 

  -- Incorporate mechanisms to ensure consistent oversight and reduce
     regulatory burden. 


BANK OVERSIGHT:  FUNDAMENTAL
PRINCIPLES FOR MODERNIZING THE
U.S.  STRUCTURE
==================================================== Chapter STATEMENT

Mr.  Chairman and Members of the Committee: 

We are pleased to be here today to discuss your efforts to modernize
the federal bank oversight structure.\1 Recent financial market
developments have clearly demonstrated that our existing regulatory
structure has not kept pace with the dramatic and rapid changes that
are occurring in domestic and global financial markets.  Banking,
securities, futures, and insurance are no longer separate and
distinct industries that can be well regulated by the existing
patchwork quilt of federal and state agencies.  We believe that a
critical first step in modernizing oversight is to begin
consolidating the activities of the four federal agencies currently
responsible for the regulation and supervision of almost 12,000
federally insured banks and thrifts.  We recognize, however, that
restructuring involves difficult and long-standing issues, and
commend the efforts of you and your committee to address needed
reforms. 

Our work over the past few years has shown that, despite good faith
efforts to coordinate their policies and procedures, the four federal
banking regulators have often differed on how laws should be
interpreted, implemented, and enforced; how banks should be examined;
and how the federal government should respond to troubled
institutions. 

Bankers also contend that multiple examinations and reporting
requirements add to their regulatory burden and contribute to their
competitive disadvantage with regard to other financial institutions,
both foreign and domestic, that are not subject to the same
regulatory regime.  Furthermore, U.  S.  bank holding companies are
examined by the Federal Reserve, while their subsidiaries can be
examined separately by several other regulatory authorities.  Thus,
there is often overlap and no clear accountability for the operations
of U.  S.  banking organizations as a whole. 


--------------------
\1 Federal bank oversight structure refers to federal oversight of
both bank and thrift institutions along with their related holding
companies. 


   FUNDAMENTAL PRINCIPLES TO GUIDE
   OVERSIGHT MODERNIZATION
-------------------------------------------------- Chapter STATEMENT:1

More than 2 years ago, we voiced our support for regulatory
consolidation based on the extensive work we have done in areas such
as bank supervision, enforcement, and failure resolution, as well as
on innovative financial activities, such as derivatives.  Studies we
have done since then--at the request of Congressman Charles E. 
Schumer--of the bank oversight structures in five other major
industrialized countries have reaffirmed our support for regulatory
consolidation.  In addition, we have identified four fundamental
principles based on all of our work that we believe Congress could
use in considering the best approach for modernizing our current
regulatory structure.  Specifically, we believe that structural
reform should provide for

  -- more consolidated and comprehensive oversight of companies
     owning federally insured banks and thrifts, with coordinated
     functional regulation and supervision of individual components;

  -- independence from undue political pressure, balanced by
     appropriate accountability and adequate congressional oversight;

  -- consistent rules, consistently applied for similar activities;
     and finally,

  -- enhanced efficiency and reduced regulatory burden. 


   ASPECTS OF FOREIGN OVERSIGHT
   STRUCTURES THAT ARE USEFUL TO
   CONSIDER
-------------------------------------------------- Chapter STATEMENT:2

Over the past 2 years, we have completed studies on the structure and
operation of bank oversight in Canada, France, Germany, and the
United Kingdom (U.K.), and are in the process of completing a fifth
report on bank oversight in Japan.  Each of the five foreign
oversight structures we studied reflects an unique history, culture,
and banking industry, and as a result, no two of the five are
identical.  Furthermore, all of the countries we reviewed had more
concentrated banking industries than does the United States, and all
but Japan have authorized their banks to conduct broad securities and
insurance activities in some manner.  Although we did not attempt to
assess the effectiveness of bank oversight in these countries, we
found that each reflected these four principles in some way, and with
few, if any, exceptions, each

  -- had fewer national agencies involved with bank regulation and
     supervision than is the case in the United States;

  -- had substantial oversight roles for their central banks, and
     ensured that their ministries of finance were, at the least,
     kept informed of important industry and supervisory
     developments;

  -- had relatively narrow roles for their deposit insurers; and
     lastly,

  -- incorporated mechanisms and procedures to ensure consistent,
     consolidated oversight and limit regulatory burden. 


      FOREIGN OVERSIGHT STRUCTURES
      HAD MORE CONSOLIDATED AND
      COMPREHENSIVE OVERSIGHT
      AUTHORITY AND FEWER
      OVERSIGHT ENTITIES
------------------------------------------------ Chapter STATEMENT:2.1

In the five countries we studied, banking organizations typically
were subject to more consolidated and comprehensive oversight, with
an oversight entity being legally responsible and accountable for the
entire banking organization, including its subsidiaries.  If
securities, insurance, or other nontraditional banking activities
were permissible in bank subsidiaries, functional regulation of those
subsidiaries was generally provided by the appropriate supervisory
authority.  Bank supervisors generally relied on those functional
regulators for information, but remained responsible for ascertaining
the safety and soundness of the consolidated banking organization as
a whole. 

The number of national bank oversight entities in the countries we
studied ranged from one in the U.K., to three in France.  In all five
countries, however, no more than two national agencies were ever
significantly involved in any one major aspect of bank oversight,
such as chartering, regulation, supervision, or enforcement. 
Commercial bank chartering, for example, was the direct
responsibility of only one entity in each country. 

In those countries where two entities were involved in the same
aspect of oversight, the division of oversight responsibilities was
generally based on which entity had the required expertise.  In
Germany, for example, many oversight responsibilities were shared
between the central bank and the federal bank supervisor.  Yet, each
of the two had a relatively well-defined role, agreed upon by both
entities, based on their relative strengths and certain legal
requirements.  For example, the central bank, with more staff and a
broader geographic presence than the federal bank supervisor,
collected and analyzed bank data and had responsibility for most
day-to-day supervision.  The federal bank supervisor, on the other
hand, had more responsibilities based in law, such as those of
issuing banking regulations and taking formal enforcement actions. 


      OVERSIGHT STRUCTURES
      GENERALLY INCLUDED ROLES FOR
      BOTH CENTRAL BANKS AND
      FINANCE MINISTRIES
------------------------------------------------ Chapter STATEMENT:2.2

The central banks in the countries we studied generally had
significant roles in supervisory and regulatory decisionmaking.  In
large part, central bank involvement was based on the premise that
traditional central bank responsibilities for monetary policy,
payment systems, liquidity lending, and crisis intervention are
closely interrelated with oversight of commercial banks.  While no
two countries had identical oversight roles for their central banks,
each country had an oversight structure that ensured that its central
bank had access to information about, and certain influence over, the
banking industry.  In the U.K., for example, the central bank was the
only bank supervisor.  In France, Germany, and Japan, the central
bank was one of two principal oversight agencies.  And while the Bank
of Canada had no direct responsibility for bank oversight, it was
included on the deposit insurance board and two advisory committees,
which gave it access to information about the banking industry and
some influence in supervisory matters. 

In each of the five countries, the national government recognized
that it had the ultimate responsibility to maintain public confidence
and stability in the financial system.  Thus, each of the bank
oversight structures that we reviewed also provided the Ministry of
Finance, or its equivalent, with some degree of influence over bank
oversight and access to information.  In France, for example, the
Ministry of Economic Affairs was represented on each of three bank
oversight committees and chaired one of them.  In Germany and Canada,
the principal bank supervisor reported to the Minister of Finance. 
Similarly, the Bank of England reported to the Chancellor of the
Exchequer.  And in Japan, the Minister of Finance was the principal
banking supervisor. 

While each country included its central bank and finance ministry in
some capacity in its oversight structure, most also recognized the
need to guard against undue political influence by incorporating
checks and balances unique to each country.  In France, for example,
a three committee bank oversight structure was designed expressly to
ensure that no single entity could dominate or dictate
decisionmaking.  Likewise, Canada's oversight structure had multiple
committees designed to share information and responsibilities among
all of the oversight entities.  And in Germany, the influence of a
strongly independent central bank helped balance decisionmaking. 


      DEPOSIT INSURERS GENERALLY
      HAD MORE NARROW ROLES AND
      OFTEN WERE NOT GOVERNMENT
      FUNDED OR ADMINISTERED
------------------------------------------------ Chapter STATEMENT:2.3

While central banks and finance ministries generally had substantial
roles in bank oversight, deposit insurers, with the exception of the
Canada Deposit Insurance Corporation, did not.  Their lack of a
substantial oversight role may be attributable to the fact that
deposit insurers in these countries were often industry funded and
administered, with the national governments providing no explicit
guarantees of the deposit insurance funds.  Thus, in most of these
countries, deposit insurers were viewed primarily as a source of
funds to help resolve bank failures--either by covering insured
deposits or by helping to finance acquisitions of failed or failing
institutions by healthy institutions.  Supervisory information was
generally not shared with these deposit insurers, and resolution
decisions for failed or failing banks were commonly made by the
primary bank oversight entities with the insurer frequently only
involved when its funds were needed to help finance resolutions. 
Even the Canadian deposit insurer, which is similar to the Federal
Deposit Insurance Corporation (FDIC) in many ways, relied principally
on the primary banking supervisor for examination information to
safeguard its insurance funds.  It did, however, sometimes use its
backup oversight authority--including requesting special
examinations--to obtain additional information and insight into the
safety and soundness of high-risk institutions. 


      FOREIGN STRUCTURES
      INCORPORATED MECHANISMS AND
      PROCEDURES TO HELP ENSURE
      CONSISTENT OVERSIGHT AND
      LIMIT REGULATORY BURDEN
------------------------------------------------ Chapter STATEMENT:2.4

Most of the foreign structures with multiple oversight entities
incorporated mechanisms and procedures designed to ensure consistent
oversight and limit regulatory burden.  As a result, banking
institutions that were conducting the same lines of business were
generally subject to a single set of rules, standards, or guidelines. 
Coordination mechanisms included having oversight committees or
commissions with interlocking boards, shared staff, or mandates to
share information.  In France, for example, central bank employees
staffed all three committees charged with oversight responsibilities
for chartering, rule-making, and supervision.  And the central bank
and Ministry of Economic Affairs also had a seat on each of the three
committees.  In Canada, the federal bank supervisor, central bank,
and finance ministry each had seats on the Canada Deposit Insurance
Corporation's board of directors and together with the deposit
insurer, participated on various advisory committees.  In Germany,
the central bank and federal bank supervisor used the same data
collection instruments and were legally required to share information
that could be significant in the performance of their duties. 

To reduce staffing needs and avoid duplication of effort, bank
supervisors in three of the five countries also used the banks'
external auditors to provide supervisory information.  In Germany and
the U.K., for example, external auditors conducted audits in lieu of
full-scope bank examinations and were the principal source of
examination-like information.  In Canada, examinations were conducted
by employees of the federal banking supervisor, but information from
the banks' external auditors was used to supplement and guide these
examinations.  In all three countries, the oversight agencies had
considerable authority over the scope and conduct of external audits
of banking institutions.  In Germany and the U.K., external audits
were conducted using specific guidelines developed by the bank
regulators, and the scope of individual audits could be expanded by
the regulators, or special audits ordered, to address issues of
regulatory concern.  Supervisors in all three countries recognized
that the auditors' objectives for reviewing a bank's activities could
differ from those of a supervisor, and that a degree of conflict
could exist between the external auditors' responsibilities to report
to both their bank clients and to the bank supervisory authorities. 
However, they believed that their authority over auditors'
engagements was sufficient to ensure that the external auditors
properly discharged their responsibilities and openly communicated
with both their bank clients and the oversight authorities. 

Unlike in the United States, bank oversight in the countries we
studied also avoided a potential area of added burden by focusing
almost exclusively on ensuring the safety and soundness of banking
institutions and the stability of financial markets, and not on
consumer protection or social policy issues.  Rather than using the
bank oversight function, the national governments in these countries
used other mechanisms to promote social goals.  Specifically, some of
the policy mechanisms used to encourage credit and other services in
low- and moderate-income areas in these countries included the
chartering of specialized financial institutions and direct
government subsidies for programs to benefit such areas.  In France,
for example, specialized financial institutions provided financing
for affordable housing.  In Canada, France, and the U.K., the banking
industries, not regulators, developed voluntary guidelines related to
consumer and small business lending.  Only in France were bank
supervisors responsible for enforcing compliance with these kinds of
guidelines and best practices. 


   RECOMMENDATIONS
-------------------------------------------------- Chapter STATEMENT:3

Our work on these five foreign systems showed that there are a number
of different ways to simplify bank oversight in this country in
accordance with the four principles mentioned earlier--i.e.,
consolidated oversight with coordinated functional regulation,
independence, consistent rule-making, and enhanced efficiency and
reduced regulatory burden.  And we note that the approach taken in
H.R.  17 is consistent with each of these principles.  While we
recognize that only Congress can make the ultimate policy judgments
in deciding exactly how to restructure, we have the following four
recommendations to make based on the extensive work we have done on
both U.S.  and foreign banking systems. 

1.  Reduce the number of federal agencies with primary
responsibilities for bank oversight:  We believe that a logical step
in consolidating is to combine the Office of Thrift Supervision
(OTS), the Office of the Comptroller of the Currency (OCC), and
FDIC's primary supervisory responsibilities for state-chartered banks
that are not members of the Federal Reserve into a new federal
banking agency or commission.  Congress could provide for this new
agency's independence in a variety of ways, including making it
organizationally independent like FDIC or the Federal Reserve.  This
new independent agency, together with the Federal Reserve, could be
assigned responsibility for comprehensive, consolidated supervision
of those banking organizations under their purview, with appropriate
functional supervision of individual components. 

2.  Include both the Federal Reserve and the Treasury Department in
bank oversight:  To carry out its primary responsibilities
effectively, the Federal Reserve should, in some capacity, have
direct access to supervisory information, as well as some ability to
influence supervisory decisionmaking.  The foreign oversight
structures we reviewed showed that this could be accomplished by
having the Federal Reserve be either a direct or indirect participant
in bank oversight.  For example, the Federal Reserve could maintain
its current direct oversight responsibilities for state chartered
member banks or be given new responsibility for some segment of the
banking industry, such as the largest banking organizations. 
Alternatively, the Federal Reserve could be given major roles on the
board of a new consolidated banking agency and on FDIC's board of
directors.  Under this alternative, Federal Reserve staff could help
support some of the examination or other activities of a consolidated
banking agency to better ensure that the Federal Reserve receives
first hand information about, and access to, the banking industry. 
Even if the Federal Reserve maintains its current direct role in bank
supervision, Congress may wish to consider having the Federal Reserve
replace OTS on the FDIC board of directors if Congress decides to
merge OTS with another agency. 

To carry out its mission effectively, the Treasury Department also
needs access to supervisory information about the condition of the
banking industry, as well as the safety and soundness of those
banking institutions that could affect the stability of the overall
financial system.  Our reviews of foreign regulatory structures
showed that this goal could also be accomplished in several ways,
such as having Treasury represented on the board of the new banking
agency or commission and perhaps on the board of the FDIC as well. 
Currently, both OCC and OTS, which are within the Treasury
Department, have seats on FDIC's board. 

3.  Provide FDIC with necessary authority to protect the deposit
insurance funds:  Under any restructuring, we believe FDIC should
maintain its explicit backup supervisory authority to enable it to
effectively discharge its responsibility for protecting the deposit
insurance funds.  Such authority should require coordination with
other responsible regulators, but should also allow FDIC to go into
any problem institution on its own without the prior approval of any
other regulatory agency.  FDIC also needs backup enforcement power
and the capability to assess the quality of bank and thrift
examinations generally. 

4.  Incorporate mechanisms to help ensure consistent oversight and
reduce regulatory burden:  Just reducing the number of federal bank
oversight agencies from the current four would, of course, help
improve the consistency of oversight and reduce regulatory burden. 
Should Congress decide to continue to have more than one primary
federal bank regulator, we believe that mechanisms should be
incorporated to enhance their cooperation and coordination and reduce
burden.  Such mechanisms could include

  -- expanding the current mandate of the Federal Financial
     Institutions Examination Council to ensure consistency in
     rule-making for similar activities as well as consistency in
     examinations;

  -- assigning specific rule-making authority in statute to a single
     agency, as has been done in the past when the Federal Reserve
     was given statutory authority to issue rules for several
     consumer protection regulations that are enforced by all of the
     bank regulators;

  -- requiring enhanced cooperation between examiners and banks'
     external auditors; (While we strongly support requirements for
     annual full-scope, on-site examinations for large banking
     organizations, we believe that examiners could take better
     advantage of the work already being done by external auditors to
     better plan and target their examinations.)

  -- requiring enhanced off-site monitoring to better plan and target
     examinations, as well as to identify and raise supervisory
     concerns at an earlier stage. 


------------------------------------------------ Chapter STATEMENT:3.1

Mr.  Chairman, this concludes my statement, and I would be pleased to
respond to any questions that you or other Members of the Committee
may have. 


==================================================== Appendix Appendix

   Figure I.1 :  Responsibility
   for U.S.  Bank Oversight
   Functions

   (See figure in printed
   edition.)

\a OCC and OTS report to Treasury. 

\b The Board of Directors of the FDIC includes the heads of OCC and
OTS as well as three independent members, including the Chairman and
the Vice-Chairman who are appointed by the President and confirmed by
the Senate. 

   Figure I.2:  Regulation of a
   Hypothetical Bank Holding
   Company

   (See figure in printed
   edition.)



                                    Table I.1
                     
                       Aspects of Bank Oversight in Canada,
                       France, Germany, Japan, and the U.K.

                                CANADA    FRANCE    GERMANY   JAPAN     U.K.
------------------------------  --------  --------  --------  --------  --------
Number of national agencies     2         1         1         1         1
authorized to issue bank
regulations

Number of national agencies     2         1         2         2         1
authorized to perform major
supervisory functions

Consolidated and comprehensive  Yes       Yes       Yes       No        Yes
oversight of a banking
organization?

Mechanisms to ensure            Yes       Yes       Yes       No        N/A
cooperation and coordination
among regulatory bodies built
into oversight system?

Consistent supervisory and      Yes       Yes       Yes       No        Yes
regulatory standards?

Finance ministry included in    Yes       Yes       Yes       Yes       Yes
key decisionmaking?

Central bank had supervisory    Yes       Yes       Yes       Yes       Yes
access to and influence over
banking industry?

Deposit insurer had             Yes       No        No        No        No
supervisory access to and
influence over banking
industry?

Bank supervisors relied         Yes       Yes       Yes       No        Yes
extensively on external
auditors' work, or intended to
increase their reliance?

Social policy goals were major  No        No        No        No        No
part of banking legislation,
regulations, or oversight?
--------------------------------------------------------------------------------
RELATED GAO PRODUCTS

Bank Regulatory Structure:  Canada (GAO/GGD-95-223, Sept.  28, 1995). 

Bank Regulatory Structure:  France (GAO/GGD-95-152, Aug.  31, 1995). 

Bank Regulatory Structure:  The United Kingdom (GAO/GGD-95-38, Dec. 
29, 1994). 

Bank Regulatory Structure:  The Federal Republic of Germany
(GAO/GGD-94-134BR, May 9, 1994). 

Financial Derivatives:  Actions Needed to Protect the Financial
System (GAO/GGD-94-133, May 18, 1994). 

Financial Regulation:  Modernization of the Financial Services
Regulatory System (GAO/T-GGD-95-121, March 15, 1995). 

Bank Regulation:  Consolidation of the Regulatory Agencies
(GAO/T-GGD-94-106, Mar.4, 1994). 

Bank and Thrift Regulation:  FDICIA Safety and Soundness Reforms Need
to Be Maintained (GAO/T-AIMD-93-5, Sept.  23, 1993). 

Bank Regulation:  Regulatory Impediments to Small Business Lending
Should Be Removed (GAO/GGD-93-121, Sept.  7, 1993). 

Bank Examination Quality:  OCC Examinations Do Not Fully Assess Bank
Safety and Soundness (GAO/AFMD-93-14, Feb.  16, 1993). 

Bank and Thrift Regulation:  Improvements Needed in Examination
Quality and Regulatory Structure (GAO/AFMD-93-15, Feb.  16, 1993). 

Bank Examination Quality:  FDIC Examinations Do Not Fully Assess Bank
Safety and Soundness (GAO/AFMD-93-12, Feb.  16, 1993). 

Bank Examination Quality:  FRB Examinations and Inspections Do Not
Fully Assess Bank Safety and Soundness (GAO/AFMD-93-13, Feb.  16,
1993). 

Banks and Thrifts:  Safety and Soundness Reforms Need to Be
Maintained (GAO/T-GGD-93-3, Jan.  27, 1993). 

Bank Supervision:  OCC's Supervision of the Bank of New England Was
Not Timely or Forceful (GAO/GGD-91-128, Sept.  16, 1991). 


*** End of document. ***