Audit Report

OIG-07-034

SAFETY AND SOUNDNESS: OTS Could Further Strengthen Its 

Ability to Assess Risks to Thrifts Following Emergencies 

March 28, 2007 

Office of 

Inspector General 

Department of the Treasury 

Contents 

OTS Could Further Strengthen Its Ability to Assess Risks to Thrifts Page 1 

Following Emergencies (OIG-07-034) 

Audit Report................................................................................................. 3 

Results in Brief ................................................................................................ 3 

Background ................................................................................................... 4 

Findings and Recommendations......................................................................... 7 

 

Improvements Could be Made to OTS’s Guidance to Assess the Financial 

Condition of Affected Thrifts Following Emergencies................................... 7 

 Recommendations ......................................................................... 9 

 Improvements Could be Made to OTS’s Operational Assessment Process for 

Thrifts Following Emergencies .................................................................. 10 

 Recommendations ......................................................................... 14 

Appendices

 Appendix 1: Objectives, Scope, and Methodology ...................................... 16 

 Appendix 2: Management Response ......................................................... 17 

 Appendix 3: Major Contributors to This Report........................................... 20 

 Appendix 4: Report Distribution................................................................ 21 

Abbreviations

 CAMELS Capital, Assets, Management, Earnings, Liquidity, Sensitivity to risk 

 COOP Plan Continuity of Operations Plan 

 FDIC Federal Deposit Insurance Corporation 

 FFIEC Federal Financial Institutions Examination Council 

 OIG Office of Inspector General 

 OTS Office of Thrift Supervision 

 TFR Thrift Financial Report 

 Treasury Department of the Treasury 
 

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This page intentionally left blank. 
OIG Audit 

Report

The Department of the Treasury 

Office of Inspector General 

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Following Emergencies (OIG-07-034) 

March 28, 2007 

John M. Reich 

Director 

Office of Thrift Supervision 

During the 2005 hurricane season, Hurricanes Katrina and Rita 

struck states along the Gulf of Mexico, causing major destruction 

and disruption in portions of Alabama, Louisiana, Mississippi, and 

Texas. Following these hurricanes, we conducted an audit to 

determine (1) how prepared Treasury’s Office of Thrift Supervision 

(OTS) was to address the needs of thrifts1

 and their customers 

during and immediately following the two hurricanes and (2) OTS’s 

plans and abilities to assess and manage increased risks to thrifts 

following the hurricanes. 

Results in Brief 

OTS determined that Hurricanes Katrina and Rita had posed risks to 

thrifts in the Gulf Coast Region. Short term risks were primarily to 

the thrifts’ operations, while long term risks were primarily to the 

thrifts’ financial condition. OTS evaluated these risks by obtaining 

assessments from thrift management and subsequently performing 

analyses and examinations. On average, OTS obtained information 

on four components of financial condition for affected thrifts that 

ranged between 13 and 68 days following the hurricanes. We 

found that OTS could improve its procedures to assess the 

financial condition of affected thrifts following emergencies as: 

• OTS guidance did not specifically address obtaining critical 

financial information from affected thrifts in a consistent 

manner. 

 

1

 In this report, we refer to all financial institutions regulated by OTS as thrifts. 
 

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• OTS guidance did not specify timeframes for analyzing the 

effects of the hurricanes on the affected thrifts’ financial 

condition. 

We also found areas where OTS could improve its operational risk 

assessment of affected thrifts following emergencies as: 

• OTS lacked continuity of operations (COOP) plans for field 

offices in 2 of its 4 regions. 

• OTS had difficulty establishing communication with certain 

thrifts following Hurricane Katrina. 

We are recommending that OTS: (1) develop a process that will 

enable it to obtain critical information about thrifts’ financial 

conditions following emergencies in a consistent manner; (2) 

following an emergency, determine timeframes for analyzing the 

affected thrifts financial condition, based on the gravity of the 

situation; (3) develop COOP plans for its field offices; and (4) 

maintain alternative contact information for thrift personnel. OTS 

agreed to implement the recommendations in its response to our 

report, which is provided as appendix 2. 

Background 

Hurricane Katrina made landfall on the Gulf Coast on August 29, 

2005, with Hurricane Rita following on September 24, 2005. 

These hurricanes, two of the most intense hurricanes ever recorded 

in the nation’s history, caused major destruction and disruption to 

the infrastructure in portions of Alabama, Louisiana, Mississippi, 

and Texas. Over 80 percent of the city of New Orleans flooded and 

more than 800,000 citizens, affected by the storms, were forced 

to live outside of their homes.

OTS is the primary regulator of all federal and many state-chartered 

thrift institutions, which include savings banks and savings and 

loan associations. Its mission is to supervise thrifts and their 

holding companies in order to maintain their safety and soundness 

and compliance with consumer laws and to encourage a 

competitive industry that meets the nation’s financial services 

needs. 
 

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Following Emergencies (OIG-07-034) 

In keeping with its mission, OTS had to determine which thrifts 

were affected by Hurricanes Katrina and Rita and what types of 

assistance the thrifts might require as a consequence. OTS, the 

other federal financial institution regulators, and the Federal 

Financial Institution Examination Council (FFIEC)2

 issued 

information that addressed a variety of issues that arose following 

the hurricanes. The topics covered included assistance to affected 

customers, availability of additional supervisory guidance on 

regulatory and reporting issues, establishment of Community 

Reinvestment Act credits to stimulate support for disaster relief in 

the financial industry,3

 and examination guidance for regulatory 

personnel for institutions affected by Hurricane Katrina.4

 

FFIEC-issued guidance specifically intended to help financial 

institutions recover from the hurricanes addressed such topics as 

granting extensions to financial institutions for filing 3rd quarter 

Thrift Financial Reports (TFRs);5 permitting financial institutions to 

use estimates to determine their loss reserves for the 3rd quarter 

TFR until a determination on the collectibility of loans was 

confirmed; allowing institutions, for liquidity purposes, to 

immediately sell securities designated as held to maturity;6 and 

exempting institutions from appraisal requirements for real estate 

transactions in designated counties affected by the hurricanes.7

OTS coordinated with thrifts’ Technology Service Providers to 

expedite the repair of data lines, worked through the Financial and 

 

2

 FFIEC is an interagency body empowered to prescribe uniform principles, standards, and report forms 

for the federal examination of financial institutions by the Board of Governors of the Federal Reserve 

System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office 

of the Comptroller of the Currency, and OTS. 

3

 OTS CEO Letter 232, “Community Reinvestment Act (CRA) Consideration for Activities Related to 

Hurricanes Katrina and Rita,” (Dec. 20, 2005). 

4

 OTS CEO Letter 234, “Interagency Supervisory Guidance for Institutions Affected by 

Hurricane Katrina,” (Feb. 3, 2006). 

5

 Every federally insured savings institution regulated by OTS files a quarterly TFR. These institutions 

are required to file a consolidated TFR that includes detailed information about the institution's 

operations and financial condition as of the close of business on the last day of the calendar quarter. 

Five thrifts availed themselves of extensions for their 3rd quarter TFR filings and filed between 14 and 

45 days after the deadline. 

6

 “FFIEC Agencies Announce Additional Guidance for Financial Institutions in Response to 

Hurricane Katrina and Rita” (FFIEC press release, Oct. 6, 2005). 

7

 OTS CEO Letter 229, “Appraisal Exceptions in Major Disaster Areas” (Oct. 12, 2005). 
 

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Banking Information Infrastructure Committee (FBIIC) to provide a 

military escort for thrift personnel into restricted areas, worked 

with the Federal Reserve to provide armored car service for thrifts 

in affected areas, and posted information on its web site to help 

thrifts and consumers affected by Hurricanes Katrina and Rita. 

OTS also participated in the FFIEC’s lessons learned review for 

Hurricane Katrina. In particular, the review identified the 

importance of alternate means of communication. OTS is 

considering requiring thrifts to maintain emergency telephone 

numbers at their data provider to ensure OTS contact following an 

emergency. 

A total of 50 OTS-supervised financial institutions were in the 

areas affected by Hurricanes Katrina and Rita – 26 in Louisiana, 5 

in Mississippi, and 19 in Texas. Of this total, OTS identified 19 

institutions that it considered affected by the storms. Of these, 18 

were considered affected8

 by Hurricane Katrina and 1 by Hurricane 

Rita. OTS contacted the affected thrifts to collect information on 

their financial condition and subsequently conducted analyses that 

covered the financial effects of the hurricanes on the thrifts’ 

CAMELS ratings.9 Assets of the affected thrifts totaled $4 billion 

and deposits $2.9 billion respectively. As of December 31, 2005, 

12 of the affected thrifts had increased their combined loss 

reserves in the preceding 6 month period by $20 million, 

representing 3.9 percent of the combined June 30, 2005, capital 

levels for the 19 affected thrifts.10 These 12 thrifts had all been 

affected by Katrina. 

 

8

 OTS considered a thrift to have been affected if it experienced any disruption of business due to the 

hurricanes. Office closure was commonly used to determine whether an institution had experienced a 

disruption of business and had therefore been affected by the storms. 

9

 The Uniform Financial Institutions Rating System was adopted by the FFIEC on November 13, 1979. 

The rating system, called CAMELS, is used to evaluate the safety and soundness of a savings 

association or a bank. CAMELS is an acronym for the six component elements that are evaluated: 

capital, asset quality, management, earnings, liquidity and sensitivity to risk. Each of these elements is 

rated on a scale of 1 to 5.

10 A financial institution’s loss reserve is an estimate of the amount needed to offset possible losses on 

loans. After the hurricanes, financial institution’s estimated the storm related losses to their loan 

portfolios and increased loss reserves to cover the estimated losses. 
 

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Following Emergencies (OIG-07-034) 

Findings and Recommendations 

Emergencies pose serious risks to the safety and soundness of 

thrifts. In the short term, the risks are primarily to the thrifts’ 

operations while long term, the risks are primarily to the thrifts’ 

financial condition. OTS’s supervisory responsibility to determine 

the thrifts’ safety and soundness is therefore paramount following 

emergencies. 

Improvements Could be Made to OTS’s Guidance to 

Assess the Financial Condition of Affected Thrifts 

Following Emergencies 

The OTS Examination Handbook11 states that although it may be 

sufficient for OTS’s monitoring of non-high-risk12 thrifts to consist 

of quarterly compliance and summary monitoring reports, OTS’s 

monitoring of high-risk thrifts should be more extensive and more 

frequent. The Examination Handbook further states that all phases 

of the regulatory process, from off-site monitoring between 

examinations to the final report of examination (ROE), involve some 

form of interpretation of financial data through careful and 

questioning study. 

OTS’s Examination Handbook does not contain timeframes by 

which OTS should assess and report on the condition of thrifts 

after emergency events, such as Hurricanes Katrina and Rita. 

OTS identified 19 thrifts as having been adversely affected by the 

hurricanes. OTS was in contact with these thrifts on an ongoing 

basis. OTS initially used standardized daily summaries to obtain 

operational assessments of the affected thrifts following the 

hurricanes, and then transitioned to narrative weekly summaries to 

monitor the overall condition of the thrifts including their financial 

condition. While, the daily operational assessments gave an overall 

view of the thrifts’ operational condition, depending on the week, 

the weekly updates focused on one or more elements of the thrifts’ 

 

11 The OTS Examination Handbook (May 2006). 12 High-risk thrifts may include those that have a higher overall risk profile based on such factors as 

asset quality, asset composition, earnings and operations, liquidity, or capital. 
 

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operational or financial condition. As a result these weekly 

summaries did not consistently cover all elements of thrifts’ 

financial condition. OTS also obtained financial condition from the 

thrifts’ 3rd quarter TFRs. On average, it took OTS 68 days after 

hurricane landfall to obtain post storm information on capital, 62 

days to obtain post storm earnings-related information, 50 days to 

obtain post storm information on asset quality, and 13 days to 

obtain post storm information on liquidity from the 19 adversely 

affected thrifts. OTS informed us, that with the exception of 1 

thrift, they considered capital levels and bank management to be 

sound. It should be noted that as of June 30, 2006, none of these 

19 financial institutions had failed as a result of Hurricanes Katrina 

and Rita. 

The information provided by the thrifts in their communications 

with OTS was often limited and consisted of initial estimates. For 

example, in a report dated October 20, 2005, 1 thrift reported that 

it had performed a zip code analysis to determine the potential 

losses caused by the hurricanes. The thrift estimated the potential 

for losses at approximately $6 million, but “management was sure 

that the actual loss would not be that great.” OTS also performed 

an initial review of the affected thrifts’ potential exposure to credit 

and liquidity risks in late September 2005. This review provided 

limited information, covered only 12 of the 19 adversely affected 

thrifts, used 2003 Home Mortgage Disclosure Act data and June 

2005 TFR data.13

OTS subsequently performed two sets of analyses on the financial 

condition of adversely affected thrifts. OTS’s first set of analyses 

of the affected thrifts’ financial condition appeared in a report 

dated January 11, 2006, or 41⁄2 months after Hurricane Katrina. 

These analyses consisted of 3rd quarter 2005 TFR information 

together with information provided by thrift officials and did not 

always include an assessment of all components of the thrifts’ 

CAMELS ratings. While FFIEC-issued guidance permitted 

institutions to use estimates to determine their loss reserves for the 

3rd quarter TFR until a determination on the collectibility of loans 

was confirmed, only 1 affected thrift made a provision for losses in 

its 3rd quarter TFR filing, representing less than 2 percent of its 

 

13 The Home Mortgage Disclosure Act (HMDA), enacted by Congress in 1975 and implemented by the 

Federal Reserve Board's Regulation C, requires lending institutions to report public loan data. 
 

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mid-year capital. 11 of the other thrifts made a provision for losses 

in their 4th quarter TFR filings. For 2 of these thrifts, these 4th 

quarter provisions represented more than 18 percent of their midyear capital. 

OTS deferred all regular examinations until thrifts had time to 

restore operations and OTS examiners had time to work through 

personal affairs. It took OTS an average of nearly 6 months after 

Katrina, to complete a comprehensive on-site set of analyses of the 

financial condition of affected thrifts, while off-site analysis was 

ongoing. The analysis conducted through on-site examinations 

covered 17 of the 19 affected thrifts as OTS determined that 1 

thrift was so minimally affected by the hurricanes as not to warrant 

an examination, and another thrift was no longer regulated by OTS 

at that time. OTS performed 13 special limited scope examinations 

and 4 comprehensive federal examinations conducted between 41⁄2 

to 8 months after Katrina on these remaining 17 affected thrifts.14 

Prior to Hurricane Katrina, OTS had identified 1 thrift as being in a 

less than satisfactory financial condition. After Hurricane Katrina, 

OTS assigned an examiner to remain on site at the thrift to monitor 

the condition of the thrift. 

By not using a structured or standardized approach to gathering 

financial condition information following an emergency, OTS might 

not obtain critical information about the thrifts’ financial conditions 

for further analysis in a consistent manner. 

Recommendations 

We recommend that the Director of OTS do the following: 

1. Ensure that OTS develops a process that will enable the 

collection of critical information about thrifts’ financial 

conditions following an emergency in a consistent manner. As 

 

14 OTS undertakes comprehensive exams with limited scope whenever it needs to conduct an 

examination outside the normal cycle. A comprehensive examination with limited scope can be 

conducted on- or off-site and CAMELS ratings are not required. A comprehensive federal examination is 

conducted on-site every 12-18 months, based on size and condition of the thrift. It is sufficient to 

assess a thrifts composite and component CAMELS ratings. 
 

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part of this process, OTS should consider developing a 

structured questionnaire for obtaining critical information. 

 

2. Ensure that, following an emergency, OTS determine and 

establish appropriate timeframes based on the gravity of the 

situation, for analyzing the effects on affected thrifts financial 

condition. 

Management Response

OTS concurred with these two recommendations. Its supervision 

staff in Washington will work with the Regional offices to develop 

a structured approach for collecting critical information from thrifts 

following an emergency. OTS will also establish appropriate 

timeframes based on the gravity of the situation, for analyzing the 

effects on affected thrifts financial condition. Its staff will complete 

this work by July 31, 2007. 

OIG Comment

Management’s planned corrective action is responsive to the intent 

of our recommendations. 

Improvements Could be Made to OTS’s Operational 

Assessment Process of Thrifts Following Emergencies 

Presidential Decision Directive 67 requires federal agencies to 

establish continuity of operations (COOP) plans,15 and Federal 

Preparedness Circular 65 provides guidance for use by federal 

executive branch agencies and their subcomponents in developing 

COOP plans to facilitate performance of essential functions during 

any emergency or situation that may disrupt normal operations.16

The COOP plan elements outlined in the circular apply to all levels 

 

15 Presidential Decision Directive 67 (PDD 67), “Enduring Constitutional Government and Continuity of 

Government Operations” (Oct. 21, 1998), required Federal agencies to develop COOP plans for 

essential operations. The plans are to identify those requirements, such as emergency communications, 

establishing a chain of command, and delegation of authority, necessary to support the primary function 

of the agency. 

16 Federal Preparedness Circular 65, “Federal Executive Branch Continuity of Operations (COOP),” was 

issued by the Federal Emergency Management Agency on June 15, 2004 (superseding the previous 

version, dated July 26, 1999). 
 

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of executive branch organizations, regardless of location. 

According to the circular: (1) the COOP plans of agencies and their 

subcomponents must include plans and procedures that delineate 

essential functions; (2) specify succession to office and emergency 

delegation of authority; (3) provide for the safekeeping of vital 

records and databases; (4) identify alternate operating facilities; (5) 

provide for interoperable communications; (6) and validate the 

capability through tests, training, and exercises. In particular, 

COOP plans should contain a human capital component 

encompassing methods of employee communication. All federal 

agencies, regardless of location, are to have in place a viable COOP 

capability to ensure continued performance of essential functions 

from alternate operating sites during any emergency or situation 

that may disrupt normal operations. The absence of field office 

COOP plans may have impeded OTS’s ability to quickly establish 

communication with key OTS Field Office personnel as well as with 

the thrifts themselves. 

Also, under the FFIEC “Supervisory Emergency Communication 

Protocols,”17 each member agency is to establish and maintain the 

capability of rapidly communicating during emergencies with the 

institutions over which it has primary supervisory authority. Gaps in 

OTS’s COOP plans and the lack of alternative methods of 

communication increase the risk that OTS will not be able to 

communicate effectively with its field office staff and thrifts during 

emergencies. 

We found the following areas where OTS could strengthen its 

ability to assess risk following emergency events: 

• Field Office Continuity of Operations Plans. 

• Communication with thrifts following emergencies. 

 

 Field Offices Lacked Continuity of Operations Plans 

During our audit, we found that OTS did not have COOP plans for 

its field offices and field office staff. Although OTS had established 

COOP plans at the headquarters and regional office levels, neither 

the headquarters nor the regional office COOP plans were activated 

 

17 FFIEC “Supervisory Emergency Communication Protocols” (updated Mar 31, 2005). 
 

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during Hurricanes Katrina and Rita because those locations were 

not affected by the storms. 

OTS established a COOP plan at the headquarters level in March 

2003. COOP plans were also established at the regional office 

level. OTS did not have a COOP plan covering its New Orleans field 

office personnel at the field office facility or at off-site locations 

and, as a result, did not have procedures addressing 

communications between OTS field office personnel and other OTS 

personnel in emergencies. 

We reviewed COOP plans for 2 of OTS’s 4 regions and found that 

they did not include COOP plans for field offices in these regions. 

Furthermore, OTS could not provide us COOP plans for these field 

offices, including the region covering areas affected by the 

hurricanes. OTS management initially stated that COOP plans for 

small field offices were not necessary because of their intermittent 

use. However, OTS management subsequently informed us that 

they had identified a need for COOP plans for all field offices. 

Without a field office COOP plan containing alternate procedures 

for contacting field office personnel, it took OTS regional office 

personnel 3 to 4 days after Hurricane Katrina to contact its New 

Orleans field office personnel. While communication efforts were 

hampered by power outages and loss of telephone service, lack of 

timely communication among OTS personnel during emergencies 

could increase the risk of disruptions to the operations of affected 

thrifts and delay resumption of normal service. 

OTS Had Difficulty Establishing Communication with Thrifts 

Following Hurricane Katrina 

OTS’s Midwest Regional Office18 started assessing Hurricane 

Katrina’s impact on thrifts on August 30, 2005, the day after the 

hurricane made landfall. The contact information that OTS 

maintained for thrift personnel consisted mostly of thrift office 

 

18 OTS has four regional offices: the Midwest Regional Office, in Dallas, Tex.; the Southeast Regional 

Office, in Atlanta, Ga.; the Northeast Regional Office, in Jersey City, N.J.; and, covering the West, the 

San Francisco Regional Office, in San Francisco, Ca. The Midwest Regional Office supervises 

institutions in Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Mississippi, Nebraska, 

Oklahoma, Tennessee, Texas, and Wisconsin. 
 

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telephone numbers and thrift office e-mail addresses. As a result of 

damage to power lines and telephone lines caused by Hurricane 

Katrina, OTS had difficulty contacting thrifts through these 

channels. OTS staff who attempted the contacts estimated that it 

took approximately a week to make contact with all the potentially 

affected Katrina thrifts and that establishing contact was very 

difficult in the first few days after Hurricane Katrina made landfall. 

In many cases, OTS was able to contact thrifts only by calling their 

Technology Service Providers, establishing that the thrift had been 

in contact with the Technology Service Provider, and implementing 

system backup plans, and obtaining from the Technology Service 

Provider emergency contact information that had been provided by 

the thrift. 

OTS developed reports providing information gained from contact 

with the thrifts on their operational condition. The September 1, 

2005 report showed that, as of that date, OTS had been unable to 

contact 8 of 18 thrifts. The next report provided was dated 

September 6, 2005; by that date, all of the 18 thrifts had been 

contacted. 

Thrifts could also have initiated contact with OTS. Under normal 

circumstances, according to OTS personnel, thrifts have their local 

field manager’s cell phone number and e-mail address, their 

examiners’ contact information, and OTS regional office contact 

information. However, OTS personnel were unsure exactly what 

contact information thrifts had in their contingency plans. Because 

of the infrastructure damage caused by Hurricane Katrina, thrifts 

would have found it difficult to contact OTS personnel by 

conventional means using non-emergency contact information. 

Furthermore, OTS also informed us that the initial priority for the 

thrifts was to ensure the safety of their staff, rather than being 

operational. 

As a result of the communication difficulties experienced after 

Katrina, OTS took steps to ensure that its personnel had alternate 

emergency contact information for potentially affected thrifts in 

preparing for Hurricane Rita. While Rita had a lesser impact, OTS 

contacted all the thrifts affected by Rita within 3 days of landfall. 

OTS subsequently developed suggested actions from lessons 

learned following Katrina. In particular, OTS suggested including 
 

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Following Emergencies (OIG-07-034) 

thrifts’ needs as part of its COOP plans, requiring thrifts to 

maintain emergency telephone numbers at their technology service 

providers to ensure contact by regulators, and recommending 

thrifts to maintain a satellite or cellular telephone with a remote 

area code. 

Recommendations 

We recommend that the Director of OTS do the following: 

3. Ensure that field offices are included in its COOP planning to 

address potential disruptions of service during emergencies at 

those locations. 

4. Ensure that OTS maintains current alternative contact 

information for thrifts and alternative channels of 

communication for use by OTS personnel to contact thrifts 

during emergencies. OTS should also encourage thrifts to 

contact OTS during emergencies and provide thrifts alternative 

OTS contact information to facilitate communications. 

Management Response

OTS indicated that it has initiated efforts to comply with these two 

recommendations. OTS will complete this work by July 31, 2007. 

OIG Comment

Management’s planned corrective action is responsive to the intent 

of our recommendations. 
 

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* * * * * 

We appreciate the courtesies and cooperation provided to our staff during 

the audit. If you wish to discuss this report, you may contact me at (202) 

927-0382. Major contributors to this report are listed in appendix 4. 

Alain Dubois 

Director, Banking Audits 
Appendix 1 

Objectives, Scope, and Methodology 

 

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Our audit objectives were to (1) determine the preparedness for 

and responsiveness of OTS with respect to addressing the needs of 

thrifts and their customers during Hurricanes Katrina and Rita and 

(2) determine OTS’s plans and abilities to assess and manage 

increased risks to thrifts following the hurricanes. 

To accomplish these objectives, we performed the following 

activities: 

• Conducted interviews with OTS personnel from OTS 

headquarters in Washington, D.C., the Midwest Regional Office 

in Dallas, Tex, and the OTS New Orleans Field Office 

• Reviewed OTS documentation obtained from thrifts and OTS 

personnel 

• Reviewed Reports of Examination and Visitation Reports 

• Reviewed headquarters and regional office COOP plans 

• Reviewed Uniform Thrift Performance Reports for thrifts in the 

affected areas 

We performed our fieldwork from November 2005 through August 

2006. We performed our audit in accordance with generally 

accepted government auditing standards.
Appendix 2 

Management Response 

 

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Appendix 2 

Management Response 

 

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Appendix 2 

Management Response 

 

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Appendix 3 

Major Contributors to This Report 

 

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Office of Inspector General, Office of Audit

Alain Dubois, Director, Banking Audits 

Esther Tepper, Program Analyst 

Andras Schneider, Referencer 

Bobbie Gambrill, Auditor 

Vicky F. Liu, Auditor 
Appendix 4 

Report Distribution 

 

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Department of the Treasury

Office of Accounting and Internal Control 

Office of Strategic Planning and Performance Management 

Office of Thrift Supervision

Director, Office of Thrift Supervision 

Liaison Officer 

Office of Management and Budget

OIG Budget Examiner