LARGE BANK HOLDING 

COMPANIES

Expectations of 

Government Support

Statement of Lawrance L. Evans, Jr., PhD, Director

Financial Markets and Community Investment

Testimony 

Before the Subcommittee on Financial 

Institutions and Consumer Protection, 

Committee on Banking, Housing and 

Urban Affairs, U.S. Senate

For Release on Delivery 

Expected at 2:00 p.m. ET

Thursday, July 31, 2014

GAO-14-809T

United States Government Accountability Office
Page 1 GAO-14-809T 

Chairman Brown, Ranking Member Toomey, and Members of the 

Subcommittee:

I am pleased to be here today to discuss the results of our report on 

expectations of government support for large bank holding companies. As 

you know, “too big to fail” is the term commonly used to refer to a market 

notion that the federal government would intervene to prevent the failure 

of a large, interconnected financial institution to avoid harm to the 

economy. Market expectations of government rescues can distort the 

incentives of investors and counterparties to properly price and restrain 

the risks of firms they believe to be too big to fail, potentially giving rise to 

funding cost and other advantages for these firms relative to smaller 

competitors. For example, creditors may be willing to accept lower 

interest rates on debt issued by these firms if they believe the possibility 

of a government rescue reduces the likelihood that they could suffer 

losses. If creditors and other counterparties do not fully charge a firm for 

the risks it is taking, that firm may have incentives to take on greater risks 

in the pursuit of higher returns. Excessive risk-taking in response to such 

incentives can increase the likelihood that such a firm could become 

distressed and disrupt financial markets.

My remarks today are based on our report, released at this hearing, 

entitled Large Bank Holding Companies: Expectations of Government 

Support.

1 As you know, this is the second of two reports we are issuing 

on the topic of economic benefits that the largest bank holding companies 

(those with more than $500 billion in total consolidated assets) have 

received as a result of actual or perceived government support.2

 1

GAO, Large Bank Holding Companies: Expectations of Government Support, 

Accordingly, this testimony discusses (1) what is known about how 

financial reforms have altered market expectations of government 

rescues and the relative advantages or disadvantages of being a large 

GAO-14-621 (Washington, D.C.: July 31, 2014).

2

In November 2013, we issued the first report, which examined (1) actual government 

support for banks and bank holding companies during the financial crisis and (2) recent 

statutory and regulatory changes related to government support for banks and bank 

holding companies. See GAO, Government Support for Bank Holding Companies: 

Statutory Changes to Limit Future Support Are Not Yet Fully Implemented, GAO-14-18 

(Washington, D.C.: Nov. 14, 2013). At a January 2014 hearing, we provided testimony 

based on this report. See GAO, Government Support for Bank Holding Companies: 

Statutory Changes to Limit Future Support Are Not Yet Fully Implemented, GAO-14-174T 

(Washington, D.C.: Jan. 8, 2014).
Page 2 GAO-14-809T 

bank holding company and (2) the extent to which the largest bank 

holding companies have received funding cost advantages as a result of 

perceptions that the government would not allow them to fail.

To conduct this work, we reviewed relevant statutes and rules and 

interviewed regulators, bank holding companies, rating agencies, 

investment firms, and corporate customers of banks. We also reviewed 

relevant studies and interviewed authors of these studies. Finally, we 

conducted quantitative analyses to assess potential “too-big-to-fail” 

funding cost advantages. Our work for the report on which this statement 

is based was conducted in accordance with generally accepted 

government auditing standards. Further details on our scope and 

methodology are included in the report.

In summary, we found that while views varied among market participants 

with whom we spoke, many believed that recent regulatory reforms have 

reduced but not eliminated the likelihood the federal government would 

prevent the failure of one of the largest bank holding companies. Our 

analysis suggests that large bank holding companies had lower funding 

costs than smaller ones during the financial crisis but provides mixed 

evidence of such advantages in recent years. While there were notable 

exceptions, most models suggest that such advantages may have 

declined or reversed. For example, most models we estimated suggest 

that large bank holding companies had higher bond funding costs than 

smaller bank holding companies in 2013. However, the outcomes of our 

econometric models varied with the choice of variables we used to 

capture size, credit risk, and bond liquidity, and some still predicted a 

funding cost advantage for larger banks in 2013. Moreover, in 

hypothetical scenarios in which the level of credit risk in every year from 

2010 through 2013 is assumed to be as high as it was in 2008 during the 

crisis, most of our models suggest that bond funding costs for larger bank 

holding companies would have been lower than those for smaller bank 

holding companies in most years during this period. Given the nature of 

this analysis and associated limitations, our results should be interpreted 

with caution. Changes over time in our estimates of the relationship 

between bond funding costs and size may reflect changes in investors’ 

beliefs about the likelihood that a bank holding company will fail, the 

likelihood that it will be rescued by the government if it fails, and the size 

of the losses that the government may impose on investors if it rescues 

the bank holding company. However, we cannot precisely identify the 

influence of each of these factors. In addition, our estimates may also 

reflect differences in the characteristics of bank holding companies that 
Page 3 GAO-14-809T 

do and do not issue bonds or factors we have not captured in our model. 

Finally, our estimates are not indicative of future trends.

U.S. federal financial regulators have made progress in implementing 

provisions of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (Dodd-Frank Act) and related reforms to restrict future 

government support and reduce the likelihood and impacts of the failure 

of a systemically important financial institution (SIFI).3

We found that while views varied among market participants with whom 

we spoke, many believed that recent regulatory reforms have reduced but 

not eliminated the likelihood the federal government would prevent the 

failure of one of the largest bank holding companies. Citing recent 

reforms, two of the three largest credit rating agencies reduced or 

eliminated “uplift”—an increase in the credit rating—they had assigned to 

the credit ratings of eight of the largest bank holding companies due to 

their assumptions of government support for these firms. Credit rating 

agencies and large investors cited the new Orderly Liquidation Authority, 

which gives the Federal Deposit Insurance Corporation new authority to 

resolve large financial firms outside of the bankruptcy process, as a key 

factor influencing their views. While several large investors viewed the 

resolution process as credible, others cited potential challenges, such as 

the risk that multiple failures of large firms could destabilize markets.

These reforms can 

be grouped into four general categories: (1) restrictions on regulators’

emergency authorities to provide assistance to financial institutions; (2) 

new tools and authorities for regulators to resolve a failing SIFI outside of 

bankruptcy if its failure would have serious adverse effects on the U.S. 

financial system; (3) enhanced regulatory standards for SIFIs related to 

capital, liquidity, and risk management; and (4) other reforms intended to 

reduce the potential disruptions to the financial system that could result 

from a SIFI’s failure.

 3

Pub. L. No. 111-203, 124 Stat. 1376 (2010). While the Dodd-Frank Act does not use the 

term “systemically important financial institution,” this term is commonly used by 

academics and other experts to refer to bank holding companies with $50 billion or more 

in total consolidated assets and nonbank financial companies designated by the Financial 

Stability Oversight Council for Federal Reserve supervision and enhanced prudential 

standards. 

Views of Key Market 

Observers on Recent 

Regulatory Reforms
Page 4 GAO-14-809T 

Remaining market expectations of government support can benefit large 

bank holding companies to the extent that these expectations affect 

decisions by investors, counterparties, and customers of these firms. For 

example, market beliefs about government support could benefit a firm by 

lowering its funding costs to the extent that providers of funds—such as 

depositors, bond investors, and stockholders—rely on credit ratings that 

assume government support or incorporate their own expectations of 

government support into their decisions to provide funds. Second, higher 

credit ratings from assumed government support can benefit firms 

through private contracts that reference credit ratings such as derivative 

contracts that tie collateral requirements to a firm’s credit rating. Finally, 

expectations of government support can affect a firm’s ability to attract 

customers to varying degrees.

New and higher fees imposed by the Dodd-Frank Act, stricter regulatory 

standards, and other reforms could increase costs for the largest bank 

holding companies relative to smaller competitors.4 Officials from the 

Financial Stability Oversight Council (FSOC) and its member agencies 

have stated that financial reforms have not completely removed too-bigto-fail perceptions but have made significant progress toward doing so.

According to Department of the Treasury (Treasury) officials, key areas 

that require continued progress include education of market participants 

on reforms and international coordination on regulatory reform efforts, 

such as creating a viable process for resolving a failing financial institution 

with significant cross-border activities.

 4

In our report, we did not attempt to quantify the extent to which such higher costs for the 

largest firms could offset benefits they receive as a result of expectations of government 

support. For example, we did not attempt to determine the differential impacts of various 

Dodd-Frank Act provisions on bank holding companies of different sizes. Implementation 

of some Dodd-Frank Act provisions specifically targets only SIFIs, while other provisions 

affect both SIFIs and non-SIFIs. Representatives of community banks and other non-SIFIs 

have noted that while some Dodd-Frank Act provisions—such as the Volcker rule, which 

prohibits proprietary trading by insured depository institutions and their affiliates and 

restricts sponsorship or investment in hedge and private equity funds—were intended to 

target activities at the largest bank holding companies, smaller banks can still face 

burdens associated with ensuring they comply with these rules. Federal financial 

regulators have acknowledged the importance of minimizing regulatory burdens for 

financial institutions and particularly for smaller banks, whose fixed costs arising from 

regulatory compliance must be spread over a smaller base of revenues.
Page 5 GAO-14-809T 

We analyzed the relationship between a bank holding company’s size 

and its funding costs, taking into account a broad set of other factors that 

can influence funding costs. To inform this analysis and to understand the 

breadth of methodological approaches and results, we reviewed selected 

studies that estimated funding cost differences between large and small 

financial institutions that could be associated with the perception that 

some institutions are too big to fail. Studies we reviewed generally found 

that the largest financial institutions had lower funding costs during the 

2007-2009 financial crisis but that the difference between the funding 

costs of the largest and smaller institutions has since declined. However, 

these empirical analyses contain a number of limitations that could 

reduce their validity or applicability to U.S. bank holding companies. For 

example, some studies used credit ratings, which provide only an indirect 

measure of funding costs. In addition, studies that pooled a large number 

of countries in their analysis have results that may not be applicable to 

U.S. bank holding companies and studies that did not include data past 

2011 have results that may not reflect recent changes in the regulatory 

environment.

Our analysis, which addresses some limitations of these studies, 

suggests that large bank holding companies had lower funding costs than 

smaller ones during the financial crisis but provides mixed evidence of 

such advantages in recent years. However, most models suggest that 

such advantages may have declined or reversed.

To conduct our analysis, we developed a series of econometric models—

models that use statistical techniques to estimate the relationships 

between quantitative economic and financial variables—based on our 

assessment of relevant studies and expert views. These models estimate 

the relationship between bank holding companies’ bond funding costs 

and their size, while also controlling for other drivers of bond funding 

costs, such as bank holding company credit risk. Key features of our 

approach include the following:

• U.S. bank holding companies. To better understand the relationship 

between bank holding company funding costs and size in the context 

of the U.S. economic and regulatory environment, we only analyzed 

U.S. bank holding companies. In contrast, some of the literature we 

reviewed analyzed nonbank financial companies and foreign 

companies.

• 2006-2013 time period. To better understand the relationship 

between bank holding company funding costs and size in the context 

Analysis of Funding 

Cost Differences 

between Large and 

Small Banks
Page 6 GAO-14-809T 

of the current economic and regulatory environment, we analyzed the 

period from 2006 through 2013, which includes the recent financial 

crisis as well as years before the crisis and following the enactment of 

the Dodd-Frank Act. In contrast, some of the literature we reviewed 

did not analyze data in the years after the financial crisis.

• Bond funding costs. We used bond yield spreads—the difference 

between the yield or rate of return on a bond and the yield on a 

Treasury bond of comparable maturity—as our measure of bank 

holding company funding costs because they are a direct measure of 

what investors charge bank holding companies to borrow money and 

because they are sensitive to credit risk and hence expected 

government support. This indicator of funding costs has distinct 

advantages over certain other indicators used in studies we reviewed, 

including credit ratings, which do not directly measure funding costs, 

and total interest expense, which mixes the costs of funding from 

multiple sources.

• Alternative measures of size. Size or systemic importance can be 

measured in multiple ways, as reflected in our review of the literature. 

Based on that review and the comments we received from external 

reviewers, we used four different measures of size or systemic 

importance: total assets, total assets and the square of total assets, 

whether or not a bank holding company was designated a global 

systemically important bank by the Financial Stability Board in 

November 2013, and whether or not a bank holding company had 

assets of $50 billion or more.

• Extensive controls for bond liquidity, credit risk, and other key 

factors. To account for the many factors that could influence funding 

costs, we controlled for credit risk, bond liquidity, and other key factors 

in our models. We included a number of variables that are associated 

with the risk of default, including measures of capital adequacy, asset 

quality, earnings, and volatility. We also included a number of 

variables that can be used to measure bond liquidity. Finally, we 

included variables that measure other key characteristics of bonds, 

such as time to maturity, and key characteristics of bank holding 

companies, such as operating expenses. Our models include a 

broader set of controls for credit risk and bond liquidity than some 

studies we reviewed and we directly assess the sensitivity of our 

results to using alternative controls on our estimates of funding costs.

• Multiple model specifications. In order to assess the sensitivity of 

our results to using alternative measures of size, bond liquidity, and 
Page 7 GAO-14-809T 

credit risk, we estimated multiple different model specifications. We 

developed models using four alternative measures of size, two 

alternative sets of measures of capital adequacy, six alternative 

measures of volatility, and three alternative measures of bond 

liquidity. In contrast, some of the studies we reviewed estimated a 

more limited number of model specifications.

• Link between size and credit risk. To account for the possibility that 

investors’ beliefs about government rescues affect their 

responsiveness to credit risk, our models allow the relationships 

between bank holding company funding costs and credit risk to 

depend on size.

Altogether, we estimated 42 different models for each year from 2006 

through 2013 and then used those models to compare bond yield 

spreads—our measure of bond funding costs—for bank holding 

companies of different sizes but with the same level of credit risk.5 Figure 

1 shows our models’ comparisons of bond funding costs for bank holding 

companies with $1 trillion in assets and average credit risk and bond 

funding costs for similar bank holding companies with $10 billion in 

assets, for each model and for each year.6 Each circle and dash in figure 

1 shows the comparison for a different model. Circles show modelestimated differences that were statistically significant at the 10 percent 

level, while dashes represent differences that were not statistically 

significant at that level.7

 5

Our models allow the size of a bank holding company to influence its bond funding costs 

directly and also indirectly through the interaction between size and credit risk. As a result, 

no single parameter is sufficient to describe the relationship between bond funding costs 

and size. To summarize the overall relationship between bond funding costs and size 

reflected in each specification, we calculated bond funding costs for bank holding 

companies of different sizes and credit risk levels using our estimates of the parameters 

for each specification for each year. See appendix I of 

Circles and dashes below zero correspond to 

models suggesting that bank holding companies with $1 trillion in assets 

have lower bond funding costs than bank holding companies with $10 

billion in assets, and vice versa. For example, for 2013, a total of 18 

GAO-14-621 for more details on 

these calculations.

6

We also compared funding costs for bank holding companies with $50 billion, $100 

billion, $250 billion, and $500 billion in assets to bank holding companies with $10 billion 

in assets. See appendix I of GAO-14-621.

7

Many of the estimates that were statistically significant at the 10 percent level were also 

statistically significant at the 5 percent or 1 percent level. See table 5 in appendix I of 

GAO-14-621.
Page 8 GAO-14-809T 

models predicted statistically significant differences above zero and a 

total of eight models predicted statistically significant differences below 

zero.

Figure 1: Estimates from 42 Models of Average Bond Funding Cost Differences between Bank Holding Companies with $1 

Trillion and $10 Billion in Assets, 2006-2013

Notes: We estimated econometric models of the relationship between bank holding company size 

and funding costs using data for U.S. bank holding companies and their outstanding senior 

unsecured bonds for the first quarter of 2006 through the fourth quarter of 2013. The models used 

bond yield spreads to measure funding costs and controlled for credit risk factors such as capital 

adequacy, asset quality, earnings, maturity mismatch, and volatility, as well as bond liquidity and 

other characteristics of bonds and bank holding companies that can affect funding costs. We 

estimated 42 models for each year from 2006 through 2013 to assess the sensitivity of estimated 

funding cost differences to alternative measures of capital adequacy, volatility, bond liquidity, and size 

or systemic importance. We used the models to compare bond funding costs for bank holding 

companies of different sizes but the same levels of credit risk, bond liquidity, and other 

characteristics. This figure compares bond funding costs for bank holding companies with $1 trillion 

and $10 billion in assets, for each model and for each year, with average levels of credit risk. Each 

circle and dash shows the comparison for a different model, where points below zero suggest bank 

holding companies with $1 trillion in assets have lower bond funding costs than bank holding 

companies with $10 billion in assets, and vice versa.

Our analysis provides evidence that the largest bank holding companies 

had lower funding costs during the 2007-2009 financial crisis but that 
Page 9 GAO-14-809T 

these differences may have declined or reversed in recent years. 

However, we found that the outcomes of our econometric models varied 

with the various controls we used to capture size, credit risk, and bond 

liquidity. This variation indicates that uncertainty related to how to model 

funding costs has an important impact on estimated funding cost 

differences between large and small bank holding companies. As figure 1 

shows, most models found that larger bank holding companies had lower 

bond funding costs than smaller bank holding companies during the 

2007-2009 financial crisis, but the magnitude of the difference varied 

widely across models, as indicated by the range of results for each year. 

For example, for 2008, our models suggest that bond funding costs for 

bank holding companies with $1 trillion in assets and average credit risk 

were from 17 to 630 basis points lower than bond funding costs for similar 

bank holding companies with $10 billion in assets.

Our models’ comparisons of bond funding costs for different-sized bank 

holding companies for 2010 through 2013 also vary widely. For bank 

holding companies with average credit risk, more than half of our models 

suggest that larger bank holding companies had higher bond funding 

costs than smaller bank holding companies from 2011 through 2013, but 

many models suggest that larger bank holding companies still had lower 

bond funding costs than smaller ones during this period. For example, for 

2013, our models suggest that bond funding costs for average credit risk 

bank holding companies with $1 trillion in assets ranged from 196 basis 

points lower to 63 basis points higher than bond funding costs for similar 

bank holding companies with $10 billion in assets (see fig. 1). For 2013, 

30 of our models suggest that the larger banks had higher funding costs, 

and 12 of our models suggest that the larger banks had lower funding 

costs.

To assess how investors’ beliefs that the government will support failing 

bank holding companies have changed over time, we compared bond 

funding costs for bank holding companies of various sizes while holding 

the level of credit risk constant over time at the average for 2008—a 

relatively high level of credit risk that prevailed during the financial crisis. 

In these hypothetical scenarios, most models suggest that bond funding 

costs for larger bank holding companies would have been lower than 

bond funding costs for smaller bank holding companies in most years 

from 2010 to 2013. For example, most models for 2013 predict that bond 

funding costs for larger bank holding companies would be higher than for 

smaller bank holding companies at the average level of credit risk in that 

year, but would be lower at financial crisis levels of credit risk (see fig. 2). 

These results suggest that changes over time in funding cost differences 
Page 10 GAO-14-809T 

we estimated (depicted in fig. 1) have been driven at least in part by 

improvements in the financial condition of bank holding companies.8 At 

the same time, more models predict lower bond funding costs for larger 

bank holding companies in 2008 than in 2013 when we assume that 

financial crisis levels of credit risk prevailed in both years, which suggests 

that investors’ expectations of government support have changed over 

time.9 However, it is important to note that the relationships between 

variables estimated by our models could be sensitive to the average level 

of credit risk among bank holding companies, making these estimates of 

the potential impact of the level of credit risk from 2008 in the current 

environment even more uncertain.10

 8

As discussed earlier in this testimony, many investment firm representatives with whom 

we spoke credited enhanced regulatory standards with improving the safety and 

soundness of the largest bank holding companies and reducing the likelihood that they 

would experience distress that could result in failure or government support. 

Moreover, Dodd-Frank Act reforms 

discussed earlier in this statement, such as enhanced regulatory 

standards for capital and liquidity, could enhance the stability of the U.S. 

financial system and make such a credit risk scenario less likely.

9

To see this, compare the 2008 estimates in figure 1 to the “financial-crisis level”

estimates for 2013 in figure 2. Both sets of estimates are derived assuming that the level 

of credit risk is equal to the average for 2008.

10The average values of the credit risk variables for 2008 were less than the maximum 

values of the credit risk variables for 2013, with the exceptions of the variables measuring 

equity price volatility, option implied volatility, equity return volatility, and excess equity 

return volatility.
Page 11 GAO-14-809T 

Figure 2: Difference in Estimated Bond Funding Costs for Bank Holding Companies 

with $1 Trillion versus $10 Billion in Assets by Level of Credit Risk, 2013

Notes: We estimated econometric models of the relationship between bank holding company size 

and funding costs using data for U.S. bank holding companies and their outstanding senior 

unsecured bonds for the first quarter of 2006 through the fourth quarter of 2013. The models used 

bond yield spreads to measure funding costs and controlled for credit risk factors such as capital 

adequacy, asset quality, earnings, maturity mismatch, and volatility, as well as bond liquidity and 

other characteristics of bonds and bank holding companies that can affect funding costs. We 

estimated 42 models for each year from 2006 through 2013 to assess the sensitivity of estimated 

funding cost differences to alternative measures of capital adequacy, volatility, bond liquidity, and size 

or systemic importance. We used the models to compare bond funding costs for bank holding 

companies of different sizes but the same levels of credit risk, bond liquidity, and other 

characteristics. This figure compares bond funding costs for bank holding companies with $1 trillion 

and $10 billion in assets, for each model for 2013, with the average level of credit risk in 2013 and the 

average level of credit risk in 2008 during the financial crisis. Each circle and dash shows the 

comparison for a different model, where circles and dashes below zero suggest bank holding 

companies with $1 trillion in assets have lower bond funding costs than bank holding companies with 

$10 billion in assets, and vice versa.

This analysis builds on certain aspects of prior studies, but our estimates 

of the relationship between the size of a bank holding company and the 

yield spreads on its bonds are limited by several factors and should be 

interpreted with caution. Our estimates of differences in funding costs 
Page 12 GAO-14-809T 

reflect a combination of several factors, including investors’ beliefs about 

the likelihood that a bank holding company will fail, the likelihood that it 

will be rescued by the government if it fails, and the size of the losses that 

the government may impose on investors if it rescues the bank holding 

company. Like the methodologies used in the literature we reviewed, our 

methodology does not allow us to precisely identify the influence of each 

of these components. As a result, changes over time in our estimates of 

the relationship between bond funding costs and size may reflect 

changes in one or more of these components, but we cannot identify 

which with certainty. In addition, these estimates may reflect factors other 

than investors’ beliefs about the likelihood of government support and 

may also reflect differences in the characteristics of bank holding 

companies that do and do not issue bonds. If a factor that we have not 

taken into account is associated with size, then our results may reflect the 

relationship between bond funding costs and this omitted factor instead 

of, or in addition to, the relationship between bond funding costs and bank 

holding company size. Finally, our estimates are not indicative of future 

trends.

After reviewing the draft report, Treasury provided general comments and 

Treasury, FDIC, the Federal Reserve Board, and OCC provided technical 

comments. In its written comments, Treasury commented that our draft 

report represents a meaningful contribution to the literature and that our 

results reflect increased market recognition that the Dodd-Frank Act 

ended “too big to fail” as a matter of law. While our results do suggest 

bond funding cost differences between large and smaller bank holding 

companies may have declined or reversed since the 2007-2009 financial 

crisis, we also found that a higher credit risk environment could be 

associated with lower bond funding costs for large bank holding 

companies than for small ones. Furthermore, as we have noted, many 

market participants we spoke with believe that recent regulatory reforms 

have reduced but not eliminated the perception of “too big to fail” and 

both they and Treasury officials indicated that additional steps were 

required to address “too big to fail.”As discussed, changes over time in 

our estimates of the relationship between bond funding costs and size 

may reflect changes in one or more components of investors’ beliefs 

about government support—such as their views on the likelihood that a 

bank holding company will fail and the likelihood it will be rescued if it 

fails—but we cannot precisely identify the influence of each factor with 

certainty. In addition, Treasury and other agencies provided via email 

technical comments related to the draft report’s analysis of funding cost 

differences between large and small bank holding companies. We 

incorporated these comments into the report, as appropriate. A complete
Page 13 GAO-14-809T 

discussion of the agencies’ comments and our evaluation are provided in 

the report.

Chairman Brown, Ranking Member Toomey, and Members of the 

Subcommittee, this concludes my prepared remarks. I would be happy to 

answer any questions that you or other Members of the Subcommittee

may have.

For future contacts regarding this statement, please contact Lawrance L. 

Evans, Jr. at (202) 512-4802 or at evansl@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this statement. Other GAO staff who made significant 

contributions to this statement and the report it is based on include: Karen 

Tremba, Assistant Director; John Fisher (Analyst-in-Charge); Bethany 

Benitez; Michael Hoffman; Risto Laboski; Courtney LaFountain; Rob 

Letzler; Marc Molino; Jason Wildhagen; and Jennifer Schwartz. Other 

assistance was provided by Abigail Brown; Rudy Chatlos; Stephanie 

Cheng; and José R. Peña.

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