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DOCUMENT RESUME
00291 - [A1051787]
Financial Disclosure Systems in Banking Regulatory Agencies.
FPCD-77-29; B-118535. March 23, 1977. '9 pp. * appendices (7
pp.).
Report to the Congress; by Elmer B. Staats, Comptroller General.
Issue Area: Personnel Management and Compensation (300).
Contact: Federal Personnel and Compensation D' v.
Budget Function: General Government: Central Personnel
Management (805).
Organization corcerned: Office of the Comptroller of the
Currency; Department of the Treasury.
Congressional Relevance: House Committee on Banking, Currency
and Housing; Senate Committee on Banking, Housing and Urban
Affairsz Congress.
Authority: 12 U.S.C. I et seq. 18 U.S.C. 212, 213, Executive
Order 11222. 31 C.F.R. 0.735-70 et seq.
The Office of the Comptroller of the Currency (OCC)
must make sure that its employees ,aintain the highest ethical
standards when dcing their work. An effective financial
disclosure system can help provide such rssurances. However, the
Comptroller has not yet develcped the disclcsure system to that
point. Findings/Conclusions: The OCC financial disclosure
system needs: adequate criteria for identifying Fositions where
incumbents should file disclosure statements; effective
procedures with adequate criteria for reviewing statements and
identifying conflicts of interest; adequate 1rocedures for
collecting statements; additional financial information reported
on the statements to help enforce statutory prchibitions; and
greater assurance that assistant national bank examiners, who
are not required to file statements, do not hold interests that
violate statutory and/or administrative pLohibitions.
Recommendations: The Comptroller of the Currency should: require
national bank examiners to file annual financial disclosure
statements; develop specific criteria for identifying positions
and employees who should file statements and apply those
criteria to all positions; develop consistent and comprehensive
written regulations encompassing the various restrictions placed
on employees' interests by Federal regulations; develop
comprehensive guidelines for employees as to the types of
interests that are prohibited; develop and maintain a listing of
all employees required to file statements and obtain approval as
needed from the Department of the Treasury and the Civil Sqrvice
Commission; revise the disclosure statement to require
disclosure of employee loans and bank credit cards; develop
procedures to insure that stateievts are properly and promptly
collected; require assistant national bank examiners to update
annually financial information on indebtedness and ownership of
national bank stock; and review the questionable interests and
take appropriate corrective action. (Author/OH)](ViewImageLocal?handle=hein.gao/gaobaabvg0001&div=1&collection=&method=preview&ext=.png&size=3)