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authority. This review should include a comparison of data that banks provide examiners with information as reported by each bank in its quarterly call report, an evaluation of bank insurance policies, and an increased emphasis on Regulation O recordkeeping requirements. (See ch. 5.)

To improve the communication between examiners and bank directors
and increase the likelihood that directors will initiate appropriate
corrective actions, Gao is making a further recommendation. Gao also
recommends that federal bank regulators direct examiners to better
ensure through examination reports, exit conferences, and other means
(including recommending training to directors when appropriate)—that all
directors understand (1) the primary issues in need of directors' attention,
(2) that the problems facing a bank are most often a consequence of
deficiencies in the overall management and oversight by the directors, and
(3) that directors must see that effective corrective action is taken. (See
ch. 6.)

Agency Comments

GAO requested comments on a draft of this report from oCC, FDIC, and the Federal Reserve. These written comments appear along with GAO's responses in appendixes VII, VIII, and IX.

occ officials agreed with GAO's recommendations, saying it plans to take corrective actions. These include revising the section of the Comptroller's Handbook for National Bank Examiners for reviewing insider activities and including a discussion of call report requirements and a reemphasis of the importance of recordkeeping and reporting requirements.

FDIC and the Federal Reserve, while in substantial agreement with GAO's findings and conclusions, stated that they already have policies in place to address these recommendations. GAO believes that there are additional opportunities for improving communication between regulators and bank boards and management that are not included in FDIC's and the Federal Reserve's policies. Further, based on Gao's review of federal regulators' examination files for failed and open banks, Gao found that FDIC has not consistently adhered to its policies. In a subsequent letter (see app. VIII), FDIC agreed to reemphasize to its field staff the importance of a thorough analysis of insider activities, effective communication with boards of directors, and adherence to established policies and procedures.

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