Audit Report

OIG-07-038

SAFETY AND SOUNDNESS: OCC Could Further Strengthen Its

Ability to Assess Risks to Community Banks Following

Emergencies

May 25, 2007

Office of

Inspector General

Department of the Treasury

Contents

OCC Could Further Strengthen Its Ability to Assess Risks to Community Banks Page 1

Following Emergencies (OIG-07-038)

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

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

Background ................................................................................................... 5

Findings and Recommendations......................................................................... 8

Improvements Could be Made to OCCs Guidance to Assess the Financial

Condition of At Risk Community Banks Following Emergencies .................... 9

Recommendations................................................................................... 11

Improvements Could be Made to OCCs Operational Assessment Process for

Community Banks Following Emergencies.................................................. 12

Recommendations................................................................................... 15

Appendices

Appendix 1: Objectives, Scope, and Methodology ...................................... 17

Appendix 2: Management Response ......................................................... 18

Appendix 3: Major Contributors to This Report........................................... 21

Appendix 4: Report Distribution................................................................ 22

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

FRB Board of Governors of the Federal Reserve System

NCUA National Credit Union Administration

OIG Office of Inspector General

OCC Office of the Comptroller of the Currency

OTS Office of Thrift Supervision

Treasury Department of the Treasury
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OIG Audit

Report

The Department of the Treasury

Office of Inspector General

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Following Emergencies (OIG-07-038)

May 25, 2007

John C. Dugan

Comptroller

Office of the Comptroller of the Currency

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 the Office of

the Comptroller of the Currency (OCC) was to address the

needs of national banks and their customers during and

immediately following the hurricanes and (2) OCCs plans and

abilities to assess and manage increased risks to national banks

following the hurricanes. We focused our audit on OCCs

supervision of community banks because, with the exception of

one large bank and one midsize bank, all affected banks

determined to be at risk by OCC were community banks.

Results in Brief

OCC determined that Hurricanes Katrina and Rita had posed

risks to community banks in the Gulf Coast Region. Short term,

the risks were primarily to the banks operations, while long

term risks were primarily to the banks financial condition. OCC

evaluated these risks by obtaining assessments from bank

management and subsequently performing analyses and

examinations.

OCC obtained initial financial information on at risk community

banks within 45 days after Hurricane Katrina and 19 days after

Hurricane Rita. We found that OCC could improve its
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procedures to assess the financial condition of at risk1

community banks following emergencies as:

OCC Emergency Event Procedures did not specifically

address documenting all important elements of financial

condition from at risk community banks in a consistent

manner.

OCC did not specify timeframes for analyzing the effects of

the hurricanes on the at risk community banks financial

condition.

We also found areas where OCC could improve its operational

risk assessment of community banks following emergencies as:

OCC could not provide evidence of contact with all

community banks in areas affected by Hurricane Rita and

weaknesses existed in the identification of banks in these

areas.

OCC had difficulty establishing communication with

community banks following Hurricane Katrina.

We are recommending that OCC: (1) modify its Emergency

Event Procedures to require documentation and summarization

of all important elements of financial condition for at risk

community banks in a consistent manner; (2) modify its

Emergency Event Procedures to require that following such an

event, OCC determine timeframes for analyzing the effects on

at risk community banks financial condition, based on the

gravity of the situation; (3) document its contact made with

individual banks following an emergency event and develop a

methodology to accurately identify banks to be monitored in

emergency events; and (4) maintain alternative contact

information for bank personnel.

While OCC agreed to address our recommendations, it

expressed a concern that the report may give the impression

that OCC did not take appropriate responsive action to

Hurricanes Katrina and Rita, as opposed to not fully document

its action. Our report did focus more on improvements in

1 OCC categorized 12 community banks at risk based on their lending exposure in areas most affected

by the hurricanes.
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documentation rather than actions taken by OCC, as the

documentation we reviewed did not allow for a clear

determination of when elements of the condition of at risk

banks were established. OCC also stated that at no time was it

unaware of either storms effect on its institutions, their

markets, or their communities. However, OCC did not fully

demonstrate its awareness of each storms effect.

OCC has agreed to modify its Emergency Event Procedures to

incorporate its risk based approach to supervision. To the extent

that the modification to the procedures leads to documentation

and summarization of the financial condition of at risk banks

and addresses the establishment of timeframes after disasters,

the corrective action will be responsive to recommendations (1)

and (2). OCCs conveyance to its senior district management of

its belief that documentation of significant events could be

improved does not address the need to better identify banks

included in recommendation (3). OCCs agreement to ensure

their systems include alternative contact information for bank

personnel is responsive to recommendation (4).

Background

Hurricane Katrina made landfall on the Gulf Coast on August

29, 2005, with Hurricane Rita following on September 24,

2005. These two hurricanes caused major destruction and

disruption in portions of Alabama, Louisiana, Mississippi, and

Texas.

OCC is the primary regulator of all national2 banks. Its mission is

to charter national banks, oversee a nationwide system of

banking institutions, and assure that national banks are safe and

sound, competitive and profitable, and capable of serving in the

best possible manner the banking needs of their customers.

To assure functions essential to accomplishing its mission could

be performed during and in the aftermath of an emergency,

OCC developed an Emergency Management Handbook

2

In this report, the terms banks and national banks are used interchangeably, as all banks regulated by

OCC are national banks.
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consisting of emergency management procedures and

Continuity of Operations (COOP) plans, including COOP plans

for OCCs headquarters, district offices, field, satellite, and large

bank offices.3 OCCs emergency procedures distinguish

between market events and emergency events. While both may

affect the safety and soundness of national banks, OCC defines

a market event as a disruption in the normal operation of any

domestic or global market that could result in meaningfully

elevated risk exposures to a national bank company, group of

companies, or the banking system as a whole, and an

emergency event as a disruption of lesser impact that OCC

needs to monitor for supervision or reporting purposes. OCC

considered Hurricanes Katrina and Rita to be emergency events

and not market events. OCC used their Emergency Event

Procedures during and immediately following the hurricanes, to

capture reports on operational assessments of national banks

operating in and close to areas affected by Hurricanes Katrina

and Rita.

OCC, other federal financial institution regulators, and the

Federal Financial Institutions Examination Council (FFIEC)4

issued information that addressed a variety of issues that arose

after the hurricanes. The topics covered included assistance to

affected customers, availability of additional supervisory

guidance on regulatory and reporting issues, availability of

Community Reinvestment Act consideration for bank activities

that revitalize or stabilize designated disaster areas,5and

examination guidance for regulatory personnel for financial

institutions affected by Hurricane Katrina.6

3 OCC headquarters is in Washington, D.C. and four district offices: the Central District office in

Chicago, Il.; the Southern District Office in Dallas, Tex.; the Western District office in Denver, Co.; and

the Northeastern District office in New York, N.Y. The OCC also has 52 field offices and 25 satellite

locations in cities throughout the U.S., and resident examiner teams in the 23 largest banking

companies.

4 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 (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union

Administration (NCUA), the OCC, and the Office of Thrift Supervision (OTS).

5 Joint Release of the FRB, FDIC, and OCC, Banking Agencies Issue Final Community Reinvestment

Guidance (Mar. 2, 2006).

6 OCC Bulletin 2006-5, federal financial institutions regulatory agencies and the state supervisory

authorities in Alabama, Louisiana, and Mississippi jointly issued, Hurricane Katrina: Guidance to

Examiners (Feb. 3, 2006).
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FFIEC-issued guidance specifically intended to help financial

institutions recover from the hurricanes addressed such topics

as granting extensions to financial institutions for filing thirdquarter Consolidated Reports of Condition and Income (Call

Reports);7 permitting financial institutions to use estimates to

determine their loan loss reserves for their third quarter Call

Reports until a determination on the collectibility of loans was

confirmed; allowing financial institutions, for liquidity purposes,

to immediately sell securities designated as held to maturity,8

and exempting institutions from real estate appraisal

requirements for real estate transactions in designated counties

affected by the hurricanes.9

OCC coordinated with banks technology service providers,

worked with the United States Postal Service on mail service

issues, and posted information, including frequently asked

questions, on its Web site to help banks and consumers

affected by the hurricanes.

OCC also conducted a lessons learned review of the hurricanes

to address future emergencies. In particular, the review

identified the importance of alternate means of communication,

such as satellite telephones, resulting in OCCs purchase of

satellite telephones for all of its field offices. OCC is considering

encouraging banks to do the same.

OCC categorizes national banks as large, midsize, or

community. OCCs community banks are generally defined as

banks with less than $1 billion in assets. OCC conducted

operational assessments on 48 community banks following the

hurricanes between August 30, 2005, and October 12, 2005.

The operational assessments covered major areas such as bank

7 National banks are required to file quarterly Call Reports, which contain detailed information about the

banks operations and financial condition. Reports are due on the 30

th day after the end of each

calendar quarter. However, banks with a foreign office(s) have 40 days after the end of each calendar

quarter to file.

8

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

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

9

In OCC Bulletin 2005-36, FRB, FDIC, OTS, NCUA, and OCC jointly issued, Real Estate Appraisal

Exemptions in Major Disaster Areas (Oct. 14, 2005).
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closings, bank staffing issues, cash shipments to banks, and

transaction processing issues.

On October 13, 2005, OCC categorized 12 community banks

as at risk based on their lending exposure in areas most

affected by the hurricanes. Of the 12 banks, 8 were considered

affected by Hurricane Katrina and 4 by Hurricane Rita. OCC

contacted the at risk banks to collect information on their

financial condition and subsequently conducted analyses that

covered the financial effects of the hurricanes on the banks

CAMELS ratings.10 Assets and deposits of the at risk

community banks totaled $2.6 billion and $2.1 billion,

respectively. As of December 31, 2005, these 12 at risk

community banks had increased their loan loss reserves in the

preceding 6 month period by a combined total of $5.8 million,

representing 2.4 percent of the combined June 30, 2005,

capital level for the banks.11 The increase to loan loss reserves

compared to capital was therefore not significant.

Findings and Recommendations

Emergencies pose serious risks to the safety and soundness of

banks. Short term, the risks are primarily to the banks

operations while long term, the risks are primarily to the banks

financial condition. OCCs supervisory responsibility to

determine the banks safety and soundness is therefore

important following emergencies.

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

The rating system, called CAMEL, was used to evaluate the safety and soundness of a savings

association or a bank. On January 1, 1997, the rating system referred to as CAMEL became CAMELS.

CAMELS is an acronym for the six component elements that are evaluated: capital, asset quality,

management, earnings, liquidity and sensitivity to market risk. Each of these elements is rated on a

scale of 1 to 5.

11 A financial institutions loan loss reserve is an estimate of the amount needed to offset possible

losses on loans. After the hurricanes, financial institutions estimated the storm related losses to their

loan portfolios and increased loan loss reserves to cover the estimated losses.
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Improvements Could be Made to OCCs Guidance to

Assess the Financial Condition of At Risk Banks

Following Emergencies

We found that although OCC has specific procedures to follow

when market disruptions occur, it lacks equivalent procedures

for emergency events. OCCs market disruption procedures

state that their objective is to ensure that within hours of a

market disruption event, OCCs executive management and key

staff has an assessment of the event that includes an opinion

on the immediate and anticipated effects on the safety and

soundness of individual companies as well as the National

Banking System.12 OCCs COOP plan for its Committee on Bank

Supervision states that OCCs first critical function starting on

the second day after a market disruption event is to continue to

assess and report on the condition of the national banks. In

contrast, OCCs Emergency Event Procedures do not contain

timeframes by which OCC should assess and report on the

condition of banks after emergency events, such as Hurricanes

Katrina and Rita. OCC also has crisis management procedures

that call for the creation of a crisis management team to be

activated during an emergency event.13 The objective of these

procedures is to ensure that appropriate OCC action is taken as

expeditiously as possible, although no timetable is specified

within the procedures.

OCC identified 12 community banks as at risk based on their

lending exposure in areas most affected by the hurricanes. Of

these 12 banks, 8 were affected by Hurricane Katrina and 4 by

Hurricane Rita. OCC initially obtained assessments from the

banks affected by Katrina within days after that hurricane.

While these assessments were primarily operational, they did

touch on the immediate liquidity needs of the banks. OCC

informed us that they tried to obtain financial information from

the banks in late September 2005 to enable them to make

financial assessments of the banks conditions. However, the

earliest documented evidence of financial information on asset

12 OCC, Market Disruption Procedures and Checklist, Emergency Management Handbook, (updated

Sep. 2, 2003).

13 OCC, Crisis Management Procedures, (issued Feb. 10, 2006).
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quality and earnings from 11 of the 12 community banks was

October 13, 2005, 45 days after Katrinas landfall and 19 days

after Ritas landfall. This first summary information was

prompted by a request from the Comptroller of the Currency on

October 12, 2005, who was responding to an inquiry from the

White House. Specifically, the request asked for an OCC

determination of which banks might experience problems that

would significantly affect capital and for an assessment of the

financial impact. OCC provided the summary information to

OCC Headquarters on October 14, 2005, and subsequently

updated it on November 25, 2005. OCC stated in a November

27, 2005 internal communication that it would have a better

understanding of banks loss exposure in the 1

st quarter of

2006. While not making formal risk assessments,14 OCC staff

informed us that they used the summaries as financial

assessments and, based on the information provided by the

banks, determined that the risk to the banks was not substantial

following the hurricanes. As a result, OCC decided it was not

necessary to further update the summaries. The continuation of

OCCs supervisory process led to OCC completing quarterly

analysis reports or full scope examination reports on these 12

banks. On average, it took OCC 4 1⁄2 months following the

hurricanes to complete these reports.

Unlike the standardized questionnaire OCC used to obtain

operational assessments following Hurricane Katrina, OCC used

narrative summaries to describe the financial condition of its

banks. In its October and November 2005 summaries, the type

of information covered was inconsistent. Some bank summaries

included capital information and others did not. For example, in

the October 13, 2005 summary, OCCs narrative summary for

one bank included the following statement about capital,

Demand deposit accounts were up from 32 million dollars

before to 53 million dollars after the storm and that has driven

capital down to 7.3%. In contrast, its summary for another

bank was less specific about the impact of the storm to capital,

No huge individual loan losses. Expect some losses to come

14 To ensure effective supervision of community banks by risk, the OCC requires a common framework

to document decisions about risk. The Risk Assessment System (RAS) provides a concise method of

communicating and documenting judgments regarding the quantity of risk, the quality of risk

management, the level of supervisory concern and the direction of risk.
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from deficiency balances after insurance payoffs. Expect a spike

in bankruptcies. Bank has given 400 extensionsgave 90 day

extensions across the board. Loan demand is high with $4.5

million new loans in 3rd quarter 2005 not storm relateddeposit

growthconcerned about insurance companies fighting claims,

not paying anything, and fighting between flood and hazard and

bank and customer will be caught in the middle

By not using a structured or standardized approach to gathering

financial condition information following an emergency, OCC

might not obtain critical information about the banks financial

conditions for further analysis in a consistent manner.

Recommendations

We recommend that the Comptroller of the Currency do the

following:

1. Ensure that OCC modify its Emergency Event Procedures to

require documentation and summarization of all important

elements of financial condition for at risk banks in a

consistent manner.

2. Ensure that OCC modify its Emergency Event Procedures to

require that following such an event, OCC determine and

establish appropriate timeframes based on the gravity of the

situation, for analyzing the effects on at risk banks financial

condition.

Management Response

In its response, provided in appendix 2, OCC noted that its

actions flowed from its risk-based approach to supervision. OCC

plans to respond to recommendations (1) and (2) by fully

reflecting this risk-based approach to supervision in its

Emergency Event Procedures, by July 31, 2007. OCC also

expressed a concern that the report may give the impression

that OCC did not take appropriate responsive action to

Hurricanes Katrina and Rita, as opposed to not fully document

its action.
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OIG Comment

To the extent that the modification to the Emergency Event

Procedures leads to documentation and summarization of the

financial condition of at risk banks and addresses the

establishment of timeframes after disasters, the corrective

action will be responsive to recommendations (1) and (2).

OCC is correct that our reports main focus is on improvements

to documentation rather than on actions taken by OCC, as the

documentation we reviewed did not allow for a clear

determination of when elements of the condition of at risk

banks were established.

Improvements Could be Made to OCCs Operational

Assessment Process for Community Banks Following

Emergencies

OCC Southern District Office guidance states that the Field

Office Assistant Deputy Comptroller is responsible for

identifying national banks that may have been affected by a

disaster, that the District Deputy Comptroller is responsible for

requesting regular status reports on the situation and the impact

on banks in a disaster area, and for communicating banks

status to appropriate OCC management. The guidance further

states that the Field Office Assistant Deputy Comptroller is

responsible for coordinating with the field office staff and

portfolio managers to conduct an efficient and effective

assessment of the disasters impact on and damage to banks,

and contacting the District Deputy Comptroller when they can

not account for a bank.15 Additionally, guidance found in OCC

Emergency Event Procedures calls for reports of impact on

OCC-supervised banks.

Also, under the FFIEC Supervisory Emergency Communication

Protocols,

16 each FFIEC member agency is to establish and

maintain the capability of rapidly communicating during

15 OCC, Southern District Disaster Guidance and Emergency Response, Southern District Risk Tip,

(dated Aug. 31, 2004).

16 FFIEC, Supervisory Emergency Communication Protocols, (updated Mar. 31, 2005).
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Following Emergencies (OIG-07-038)

emergencies with the institutions over which it has primary

supervisory authority.

If OCC is not able to identify a distinct universe of banks in or

close to disaster areas, OCC increases the risk that it will not be

able to communicate with the banks effectively during an

emergency and without documentation of communication with

banks in or close to an affected area, OCC management cannot

be assured that banks were contacted as appropriate.

We found the following areas where OCC could strengthen its

ability to assess risk following emergency events:

Documentation of contact with community banks in areas

affected by an emergency event and identification of banks

in these areas.

Communication with community banks following emergency

events.

OCC could not provide evidence of contact with all community

banks in areas affected by Hurricane Rita and weaknesses

existed in the identification of banks in these areas

While Hurricane Ritas impact was significantly less than

Hurricane Katrinas impact, OCC stated in internal

communication that it had contacted all the community banks in

areas affected by Hurricane Rita. However, OCC was not able

to provide documented evidence of contact with all community

banks on lists prepared by OCC in anticipation of Hurricane Rita.

OCCs division of Supervision provided us with 2 different lists

of banks that had been developed by 2 separate areas within

OCC in anticipation of Hurricane Rita. One list identified 52

community banks in or close to the forecasted path of Rita,

while the other identified 33. In OCCs lessons learned review

for the hurricanes, OCC identified duplicative efforts in

developing lists of banks affected by Katrina and Rita as an area

to be improved.

Adjusting for additional banks subsequently identified by OCC

as well as for banks in areas where OCC judged that Rita had

had no impact and therefore did not contact, OCC agreed that it
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did not have documented evidence of contact with 5 banks

using the first list or 3 banks using the second list. We also

found that 4 banks should not have been on the first list as they

were either no longer regulated by OCC as a result of liquidation

or merger or had merged with other OCC-regulated banks on

the list, with 1 of these also incorrectly identified on the second

list. FDIC requested a list of banks that OCC had contacted for

Hurricane Rita. An official from OCCs Southern District office

responded that he did not have an accurate list of all the banks

contacted by the field offices.

OCC Had Difficulty Establishing Communication with

Community Banks Following Hurricane Katrina

OCC had difficulty establishing communication with community

banks following Hurricane Katrina as its communication efforts

were hampered by power and telephone outages, also, OCC

often did not have alternate contact information for bank

personnel. In preparation for Hurricane Rita, OCC enhanced its

communication efforts with banks by taking steps such as

broadly disseminating the telephone number for the Southern

District office and personal telephone numbers for officials who

were out of the path of the hurricane.

OCC contacted 32 community banks, operating in or close to

areas affected by Katrina, which it believed at risk. OCC contact

information for banks consists primarily of bank office telephone

numbers and bank office e-mail addresses. An OCC New

Orleans field office official stated that OCC needed bank

contact numbers and e-mail addresses outside of the banks and

that communication attempts should be made by both OCC and

the banks.

OCCs contact effort was a coordinated one, involving OCC

staff from several Southern District field offices. Based on the

dates of communication provided by OCC, initial contact was

made within 1 or 2 days following the hurricanes for the

majority of the banks. It took 8 days to contact 2 of those

banks. In some instances, before making direct contact, OCC

had obtained information on banks operational conditions
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Following Emergencies (OIG-07-038)

through secondary sources such as other bankers, a banks data

processing service provider, and local officials.

Recommendations

We recommend that the Comptroller of the Currency do the

following:

3. Ensure that OCC document its contact made with individual

banks following an emergency event and develop a

methodology to accurately identify banks to be monitored in

emergency events.

4. Ensure that OCC maintains current alternative contact

information for banks and alternative channels of

communication for use by OCC personnel to contact banks

during emergencies. OCC should also consider encouraging

banks to contact OCC during emergencies and provide banks

alternative OCC contact information to facilitate

communications.

Management Response

In its response, OCC stated that while their bank supervision

procedures require documentation of significant events, it

believes that its documentation of significant events affecting

its banks could be improved. In response to recommendation

(3), OCC stated that it has conveyed this to its senior district

management. OCC plans to respond to recommendation (4) by

ensuring that its systems include alternative contact information

by August 31, 2007. Whenever possible, OCC plans to contact

its institutions prior to an emergency, ensure bankers also have

alternative contact information for OCC and encourage banks to

contact OCC if necessary. OCC also commented that at no time

was it unaware of either storms effect on its institutions, their

markets, or their communities.

OIG Comment

To the extent that OCC clearly conveys to senior district

management its belief that its documentation of significant
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events needs improvement, the corrective action will be

responsive to the first part of recommendation 3. However,

OCCs response did not address the second part of

recommendation 3 which is to develop a methodology to

accurately identify banks to be monitored in emergency events.

We believe such a methodology is important as OCC identified

duplicative efforts in developing lists of banks affected by

Katrina and Rita as an area to be improved.

OCCs agreement to ensure its systems include alternative

contact information for bank personnel by August 31, 2007, is

responsive to recommendation 4.

We were unable to substantiate OCCs assertion that at no time

was it unaware of either storms effect on its institutions, since

as noted this report, OCC agreed that it did not have

documented evidence of contact with several banks after

hurricane Rita and it took OCC 8 days to contact 2 banks after

Katrina.

* * * * *

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 OCC with respect to addressing the

needs of banks and their customers during Hurricanes Katrina

and Rita and (2) determine OCCs plans and abilities to assess

and manage increased risks to banks following the hurricanes.

We focused our audit on OCCs supervision of community

banks because, with the exception of one large bank and one

midsize bank, all affected banks determined to be at risk by

OCC were community banks.

To accomplish these objectives, we performed the following

activities:

Conducted interviews with OCC headquarters personnel in

Washington, DC, the OCC New Orleans Field Office, and

OCC midsize and large bank examiners

Reviewed OCC documentation for information gathered from

OCC personnel regarding banks related to the hurricanes

Reviewed OCCs completed Reports of Examination and

quarterly analyses for 12 at risk community banks

Reviewed headquarters, district office, and field office COOP

plans in OCCs Emergency Management Handbook

We performed our fieldwork from November 2005 through

January 2007. 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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Alain Dubois, Director, Banking Audits

Bobbie Gambrill, Auditor

Vicky Liu, Program Analyst

Esther Tepper, Communications Analyst

Maryann Costello, Referencer
Appendix 4

Report Distribution

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Following Emergencies (OIG-07-038)

Department of the Treasury

Office of Accounting and Internal Control

Office of Strategic Planning and Performance Management

Comptroller of the Currency

Comptroller of the Currency

Liaison Officer

Office of Management and Budget

OIG Budget Examiner