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Special Inspector General for 

TARP
 

FY 2015
 

President’s Budget
 
 

 

 

 

 

 

Table of Contents 

Section 1 – Purpose........................................................................................................................3

1A – Mission Statement ..............................................................................................................3

1.1 – Appropriations Detail Table ...............................................................................................3

1B – Vision, Priorities and Context.............................................................................................3

Section 2 – Budget Adjustments and Appropriation Language .............................................11

2.1 – Budget Adjustments Table ...............................................................................................11

2A – Budget Increases and Decreases Description ...................................................................11

2.2 – Operating Levels Table ....................................................................................................12

2B – Appropriations Language and Explanation of Changes ...................................................12

2C – Legislative Proposals ........................................................................................................12

Section 3 – Budget and Performance Plan ................................................................................13

3A – Audit .................................................................................................................................13

3.1.1 – Audit Budget and Performance Plan .............................................................................14

3B – Investigations ....................................................................................................................14

3.1.2 – Investigations Budget and Performance Plan ................................................................17

Section 4 – Supplemental Information ......................................................................................18

4A – Summary of Capital Investments .....................................................................................18

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Section 1 – Purpose 

1A – Mission Statement 

To advance economic stability by promoting the efficiency and effectiveness of the management 

of the Troubled Asset Relief Program (TARP), through transparency, coordinated oversight, and 

robust enforcement against those persons and entities, whether inside or outside of government, 

who waste, steal, or abuse TARP funds. 

1.1 – Appropriations Detail Table 

Dollars in Thousands 

Special Inspector General for TARP FY 2013 FY 2014 FY 2015 FY 2014 to FY 2015 

Appropriated Resources Operating Level Enacted Request $ Change % Change 

FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

New Appropriated Resources: 

Audit 83 14,597 83 12,220 75 9,243 (8) (2,977) -9.64% -24.36% 

Investigations 109 27,119 109 22,703 117 24,991 8 2,288 7.34% 10.08% 

Subtotal New Appropriated Resources 192 $41,716 192 $34,923 192 $34,234 0 ($689) 0.00% -1.97% 

Other Resources: 

Unobligated Balances from Prior Years 0 10 0 6,683 0 10,957 0 4,274 NA 63.95% 

Resources from Other Accounts 0 1,644 0 1,536 0 965 0 (571) NA -37.17% 

Subtotal Other Resources 0 $1,654 0 $8,219 0 $11,922 0 $3,703 NA 45.05% 

Total Budgetary Resources 192 $43,370 192 $43,142 192 $46,156 0 $3,014 0.00% 6.99% 

Unobligated funds from prior years include funds provided by P.L. 110-343 for general operating expenses, and by P.L. 111-22 which provided 

funds to “prioritize the performance of audits or investigations of recipients of non-recourse Federal loans made under any “Emergency 

Economic Stabilization Act of 2008, P.L 110-343 program. 

1B – Vision, Priorities and Context 

The Special Inspector General for the Troubled Asset Relief Program (SIGTARP) is an office of 

inspector general with statutory law enforcement authority fulfilling audit and investigative 

functions within its oversight jurisdiction of the Troubled Asset Relief Program (TARP). 

SIGTARP was established by Section 121 of the Emergency Economic Stabilization Act of 2008 

(“EESA”). Under EESA, the Special Inspector General has the duty, among other things, to 

conduct, supervise, and coordinate audits and investigations of the purchase, management, and 

sale of assets under TARP. 

Congress created SIGTARP as the criminal law enforcement agency over TARP, the 

government’s response to the financial crisis. With an understanding that enforcement takes 

time, Congress specified by law that SIGTARP would exist as long as Treasury holds an asset or 

guarantee in TARP. All of SIGTARP’s investigations relate to the financial crisis because they 

involve crime by or against one of the more than 700 TARP recipients or applicants, or relate to 

TARP programs (such as scams against struggling homeowners seeking help under TARP’s 

housing programs). Most SIGTARP investigations are brought under the President’s Financial 

Fraud Enforcement Task Force, with SIGTARP co-chairing the Rescue Fraud Working Group. 

SIGTARP has been responsible for many of the significant financial crisis cases, but these 

complex cases take time to investigate. As of October 29, 2013, SIGTARP with its partners, had 

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criminally charged 154 individuals, and convicted 112 defendants, resulting in prison sentences 

for 65 defendants with others awaiting trial or sentencing. Funding continues to support 

investigating TARP related complex frauds, including bank fraud, securities fraud, and mortgage 

modification scams targeting homeowners who are most vulnerable during these continuing 

tough economic times. Considering most complex financial fraud investigations can take several 

years to complete, SIGTARP’s high arrest and conviction rates are particularly notable. These 

successes reflect the extensive experience and expertise of the staff at SIGTARP and the 

implementation of cutting-edge programs, such as those recognized in SIGTARP’s recent 

Council of Inspectors General for Integrity and Ethics (CIGIE) peer review: 

•	 “The organizational structure, equipment, and policy for SIGTARP’s computer forensics 

division were excellent. The area is well organized and the available equipment, staffing, 

and training make for a highly effective work environment.” The computer forensics unit 

has implemented a web-based electronic evidence review platform that allows geographically 

dispersed agents to review and simultaneously analyze the same evidence. 

•	 SIGTARP’s handling and storage of evidence was particularly noteworthy. SIGTARP has 

implemented an electronic system of evidence handling that allows the evidence custodians 

to electronically manage evidence from entry to destruction or return. This system is based 

off of a bar code system in which each piece of evidence has a printed label with a bar code 

that is scanned each time it is handled and inventoried. This ensures a real-time inventory of 

each piece of evidence in the system. SIGTARP is currently utilizing this product, and it is 

efficient and effective for the large volume of items from computer equipment to documents. 

The peer review team went further by stating the following “The best practices noted above are a 

positive reflection of SIGTARP and how a new agency can be effective in promoting change 

within the CIGIE community.” 

SIGTARP investigations have resulted in federal and state court orders for the return of $4.68 

billion in assets to victims or the U.S. Government as of September 30, 2013. Simply stated, for 

every $1 in cumulative annual funding for SIGTARP, the American people have received $34 in 

orders for the return of ill-gotten gains. In fact, to date, SIGTARP’s investigative work has aided 

in the actual receipt by the government of nearly $185.6 million of the $4.68 billion ordered with 

additional recoveries expected both from new matters and as others reach final resolution. 

Although SIGTARP is a criminal law enforcement agency, it also works with civil authorities to 

bring civil actions for violations of the law. These civil actions may follow criminal charges, or 

in some cases there may be civil charges but not criminal charges. To date SIGTARP 

investigations have resulted in civil charges and other actions against 63 individuals and 51 

corporate entities, resulting so far in 57 settlements yielding over $288 million in civil penalties 

and other actions. 

A company’s repayment or exit from TARP must not, and does not serve as a shield to criminal 

or civil liability. For example, Bank of America repaid TARP in 2010. However, as a result of 

an ongoing SIGTARP investigation in October 2012, the U.S. Attorney for the Southern District 

of New York filed a complaint against the bank alleging that for years, Bank of America used a 

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TARP PROGRAM SCHEDULE 

TARP Program Scheduled Program Dates 

Term Asset-Backed Securities Loan Facility 2015 maturity of last loan 

Home Affordable Modification Program 2021 to pay incentives on modifications 

Hardest Hit Fund 2017 for states to draw on TARP funds 

FHA Short Refinance Program 2020 for TARP-funded letter of credit 

TARP INVESTMENTS IN FINANCIAL INSTITUTIONS 

TARP Program Remaining Treasury Investment 

Capital Purchase Program Preferred stock in 87 banks; warrants for stock in an additional 32 

former CPP banks 

Community Development Capital Initiative Preferred stock in 69 banks/credit unions 

Automotive Industry Financing Program 63% stake in Ally 

Sources: Treasury, Transactions Report, 12/31/2013. 

 

 

 

 

 

program that intentionally processed loans at high speed and without quality checkpoints, to 

defraud Fannie Mae and Freddie Mac into buying thousands of fraudulent or defective loans that 

resulted in over $1 billion in losses and countless foreclosures. 

SIGTARP has aggressively pursued defendants engaged in all fraud related to TARP and been at 

the forefront in bringing cases related to the financial crisis. For example, SIGTARP’s 

investigation resulted in convictions against 4 bank officers at TARP-applicant Bank of the 

Commonwealth and 6 co-conspirators for crimes to hide past-due loans and the bank’s near 

failure condition. Six have been sentenced to prison including the Vice President (sentence to 17 

years) and President of a subsidiary (sentenced to 8 years). The CEO and another officer await 

sentencing. SIGTARP also uncovered an alleged 6-year criminal enterprise at failed Premier 

Bank that led to an indictment against its Chairman and 3 officers/directors. 

SIGTARP will remain vigilant in protecting taxpayer interests in all matters relating to TARP 

and its programs. 

There are two types of ongoing TARP programs as illustrated in the tables below: (1) Programs 

with a scheduled end date all of which exceed 2014 and; (2) Programs where Treasury holds a 

TARP ownership interest in a private company and has to sell that interest. 

To support ongoing investigations as well as oversight of multiple TARP programs that last well 

beyond 2015, SIGTARP needs to be fully staffed to carry out its oversight duties in 2015 and 

beyond. As with SIGTARP’s investigations, audit/evaluation work does not stop just because 

Treasury’s participation in a program or entity has ended. Besides being proactive in making 

recommendations aimed at the prevention of fraud, waste, and abuse in TARP programs, 

SIGTARP’s audit work also examines TARP programs for their effectiveness and efficiency to 

bring transparency to the decision-making process and provide a basis to avoid or minimize 

future financial crises or bailouts. Moreover, Treasury continues to be actively engaged in 

TARP, shifting only the nature of who performs many of the functions. So although TARP has 

decreased its FTEs, it has increased the number of contracting staff supporting their organization. 

Their staff thus remains essentially at the same level. However, the increase in the number of 

contractors adds an additional burden to SIGTARP in the oversight of TARP programs. 

SIGTARP strategically plans its work based on continued discussions with its stakeholders 

including Treasury and federal financial regulators and Congressional requests. SIGTARP 

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continually assesses issues of concern to taxpayers so as to keep focus on its objectives to 

promote economic stability through transparency, robust enforcement, and coordinated 

oversight. For instance, now that HAMP has been operational for a number of years, evidence of 

program performance is becoming evident. Accordingly, with the rising number of homeowners 

re-defaulting on HAMP permanent mortgage modifications, SIGTARP recently made 

recommendations to Treasury including that Treasury research and analyze the causes of HAMP 

re-defaults. These recommendations received bi-partisan support for adoption. It is anticipated 

that TARP will continue to be significant well past 2015, and SIGTARP will continue making 

recommendations to improve the programs and protect them from fraud, waste, and abuse. 

As of October 3, 2010, Treasury had obligated $474.8 billion to 13 announced TARP programs. 

Subsequent to the expiration of Treasury’s investment authority, Treasury has deobligated funds 

previously designated for some programs. As of September 30, 2013, $456.6 billion is obligated 

to TARP programs. Of that amount, $421.2 billion had been spent. Taxpayers are owed $53.4 

billion as of September 30, 2013. Of the $53.4 billion owned to taxpayers, Treasury, as of 

September 30, 2013, had written off or realized losses of $30.7 billion that taxpayers will never 

get back. This leaves $22.7 billion in TARP funds outstanding. Additionally, these amounts do 

not include $9.5 billion in TARP funds spent on housing programs, which are designed as a 

Government subsidy, with no repayments to taxpayers expected. According to Treasury, $0.9 

billion of TARP funds were spent on housing programs leaving $29 billion obligated and 

available to be spent. The outstanding $22.7 billion in TARP funds continues to represent 

significant exposure for the American taxpayers and SIGTARP remains committed to 

aggressively pursuing our mission. 

SIGTARP’s oversight responsibilities include providing recommendations related to TARP to 

Treasury and other federal agencies to facilitate effective oversight and transparency and to 

prevent fraud, waste, and abuse. As of October 29, 2013, SIGTARP has made 128 

recommendations. Additionally, SIGTARP brings transparency through audits and evaluations. 

SIGTARP has published 22 audits and evaluations as well as 5 special reports. 

SIGTARP continues to work hard to deliver the accountability the American people demand and 

deserve. As of September 30, 2013, SIGTARP had more than 150 ongoing criminal and civil 

investigations, many in partnership with other law enforcement agencies in order to leverage 

resources throughout the government. 

SIGTARP supports and complements one of Treasury’s five enumerated strategic goals: (1) to 

promote domestic economic growth and stability while continuing reforms of the financial 

system. In particular, SIGTARP supports strategic objectives (1.1) promoting savings and 

access to credit and affordable housing options, (1.2) wind down emergency financial crisis 

response programs, and (1.3) complete implementation of financial regulatory reform initiatives 

and continue monitoring the markets for threats to stability. 

SIGTARP’s FY 2015 budget request of $34,234,000 will provide resources to: 

•	 Quickly detect, stop and investigate fraud related to TARP; 

•	 Provide significant oversight and transparency over the largest remaining TARP investments, 

including Ally Financial Inc. (ALLY) and the 212 financial institutions remaining in TARP 

as of September 30, 2013; 

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•	 Protect taxpayer investments in the Term Asset-Backed Securities Loan Facility (TALF), 

which are scheduled to last as late as 2017; and 

•	 Provide oversight and transparency over TARP-funded housing programs which are 

scheduled to last as late as 2021. 

In accordance with the requirements of Section 6(f)(1) of the Inspector General Act of 1978 (as 

amended), the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) 

submits the following information related to the FY 2015 budget submission: 

•	 The aggregate budget request for the operations of SIGTARP is $34,234,000 

•	 The portion of this amount needed for SIGTARP training is $455,000; 

•	 The portion of this amount needed to support the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE) is estimated at $63,792; and 

•	 The amount requested for training satisfies all SIGTARP training needs for fiscal year 2015. 

Key Accomplishments and Challenges 

Since its commencement in December of 2008, SIGTARP has been extraordinarily productive: 

publishing 20 comprehensive quarterly reports to Congress concerning TARP, opening over 150 

investigations, initiating 30 audits and six evaluations, issuing 22 audit and evaluation reports, 

issuing 128 recommendations, leveraging oversight resources, testifying or providing written 

testimony at 30 Congressional hearings, building infrastructure, and hiring staff. In the latter 

regard, SIGTARP has secured permanent office space and equipment for staff; and has 

contracted with public and private vendors for procurement assistance, publication consulting, 

data processing and analysis, and office equipment and services. SIGTARP’s headquarters are 

in Washington, DC, with regional offices in New York City, Los Angeles, San Francisco, and 

Atlanta. As of December 2013, SIGTARP has on staff 170 managers, lawyers, auditors, 

investigators, and other professionals with a wealth of experience in program auditing, criminal 

law enforcement, securities enforcement, and other relevant curricula. To successfully overcome 

hiring challenges, SIGTARP relies on direct hire authority and reemployed annuitant salary 

offset waiver authority delegated by the Office of Personnel Management, as well as authority 

provided by the Special Inspector General for the Troubled Asset Relief Program Act of 2009, 

P.L. 111-15. 

Quarterly Reports to Congress: SIGTARP has issued 20 quarterly reports to Congress, 

describing the activities and plans of SIGTARP; explaining and evaluating the various TARP 

programs; reviewing the operations of the Office of Financial Stability which administers TARP; 

and recommending changes to TARP programs and procedures to increase transparency and 

effective oversight and decrease the potential for fraud, waste and abuse. SIGTARP’s reports 

satisfy the requisite reporting requirements of SIGTARP’s authorizing statute by detailing its 

operations; describing the categories of troubled assets purchased or otherwise procured by 

Treasury; explaining the reasons Treasury deemed it necessary to purchase each troubled asset; 

listing each financial institution from which such troubled assets were purchased; listing and 

detailing biographical information on each person or entity hired to manage such troubled assets; 

estimating the total amount of troubled assets purchased, the amount of troubled assets held, the 

amount of troubled assets sold, and the profit or loss incurred on each sale or disposition of each 

such troubled asset; and listing the insurance contracts issued. During FY 2013, SIGTARP 

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released three special reports on the subjects of (1) Ally, (2) HAMP re-defaults and (3) Hardest 

Hit Fund. All special reports are included in the quarterly report to Congress in the respective 

quarter in which they are published. SIGTARP’s quarterly reports are available at 

http://www.sigtarp.gov/pages/reportsaudits.aspx. 

As of October 29, 2013, SIGTARP’s quarterly reports include 128 detailed recommendations to 

facilitate effective oversight and transparency and to prevent fraud, waste, and abuse. Treasury 

and the federal banking regulators have implemented 36 of these recommendations and partially 

implemented 20 recommendations and 7 recommendations are in the process of being 

implemented. The current quarterly report dated October 29, 2013, includes discussions of 

recommendations made to Treasury regarding: (1) appointing Directors to the boards of Capital 

Purchase Program ("CPP”) Banks; (2) homeowners re-defaulting on modified mortgages under 

the Home Affordable Modification Program (“HAMP”) re-defaults; and (3) the reporting of 

Small Business Lending Fund (“SBLF”) funds not as TARP repayments. 

SIGTARP’s recommendations may be reviewed in their entirety at 

http://www.sigtarp.gov/Quarterly%20Reports/October_29_2013_Report_to_Congress.pdf pages 

283-304. 

Investigative Activities: SIGTARP’s Investigations Division (ID) is a sophisticated whitecollar law enforcement agency. Currently, ID has more than 150 ongoing criminal and civil 

investigations, many in partnership with other law enforcement agencies in order to leverage 

resources throughout the government. SIGTARP investigates white-collar fraud related to 

TARP. These investigations include accounting fraud, securities fraud, insider trading, bank 

fraud, mortgage fraud, mortgage modification fraud, fraudulent advance-fee schemes, false 

statements, obstruction of justice, money laundering, and tax crimes. 

In August 2012, SIGTARP’s Investigations Division also passed its mandated external peer 

review with the highest rating possible, a peer review rating of compliance with the quality 

standards established by the CIGIE and the applicable Attorney General Guidelines. 

Significant public developments that occur in SIGTARP’s cases may be reviewed at 

http://www.sigtarp.gov/pages/investigations.aspx. 

SIGTARP’s investigations have delivered substantial results. As of October 29, 2013, 

investigative efforts have resulted in: 

•	 Criminal actions against 154 individuals, including 98 senior officers (Chief Executive 

Officers, owners, founders, or senior executives) of their organizations; 

•	 Criminal convictions of 112 defendants, of whom 65 have been sentenced to prison (others 

are awaiting sentencing); 

•	 Civil cases and other actions against 63 individuals (including 49 senior officers) and 51 

entities (in some instances an individual will face both criminal and civil charges); 

•	 SIGTARP’s investigations have also resulted in sizeable recoveries and prevented the loss of 

millions of TARP dollars. Orders of restitution and forfeiture and civil judgments have been 

entered for $4.68 billion. This breaks down as follows: restitution orders entered for $4.2 

billion, forfeiture orders entered for $233.1 million, and civil judgments and other orders 

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entered for $288 million. Although the ultimate recovery of these amounts is not known, 

SIGTARP has already assisted in the recovery of $185.6 million. 

•	 Savings of $553 million in TARP funds that SIGTARP prevented from going to the nowfailed Colonial Bank. 

Audit Activities: SIGTARP’s Audit Division (AD) conducts, supervises, and coordinates 

programmatic audits and evaluations related to TARP. The audit results identify program 

deficiencies or weaknesses and their impact on the efficiency and effectiveness of the program, 

how funds were expended, and recommendations to improve the operations of TARP and to 

prevent fraud, waste, and abuse. Since its inception, SIGTARP has initiated a total of 30 audits 

and 6 evaluations. SIGTARP has issued 22 published audits and evaluations. 

In September 2012, SIGTARP’s Audit Division passed its mandated external peer review with 

the highest rating possible, a peer review rating of pass in accordance with Government Auditing 

Standards and guidelines established by CIGIE. 

SIGTARP’s audit and/or evaluation reports, including the following released since October 1, 

2012, may be reviewed in their entirety at http://www.sigtarp.gov/pages/reportsaudits.aspx 

•	 Excessive Executive Compensation: In the January 2013 report, “Treasury Continues 

Approving Excessive Pay for Top Executives at Bailed-Out Companies”, SIGTARP 

reviewed the process and decisions of Treasury’s Office of the Special Master for TARP 

Executive Compensation (“OSM”) in setting 2012 pay packages at the three remaining 

TARP exceptional assistance companies: American International Group, Inc. (“AIG”), 

General Motors Company (“GM”), and GMAC, Inc., later rebranded as Ally Financial Inc. 

(“Ally”). SIGTARP found that Treasury failed to make any meaningful reform from 

SIGTARP’s prior findings or fully implement SIGTARP’s recommendations. It is not 

surprising that without meaningful reform to its process, Treasury continued to approve 

excessive pay packages in 2012 for the top 25 employees at AIG, GM, and Ally. Indeed, in 

2012, Treasury approved pay packages of $3 million or more for 54 percent of the 69 Top 25 

employees at AIG, GM, and Ally – 23 percent of these top executives (16 of 69) received 

Treasury-approved pay packages of $5 million or more, and 30 percent (21 of 69) received 

from $3 million to $4.9 million. In fact, in 2012, Treasury approved pay of more than $1 

million for all but one top 25 employee at AIG, GM, and Ally. The report also included four 

new recommendations to Treasury regarding compensation. 

•	 Banks that used the Small Business Lending Fund To Exit TARP: On April 9, 2013, 

SIGTARP released this report which reviewed how, in 2011, 137 of the small banks bailed 

out by TARP used more than $2 billion from another government program, the Small 

Business Lending Fund (“SBLF”), to repay and exit TARP. SBLF was viewed by members 

of Congress as a fix for TARP’s failure to require or incentivize banks to lend the money. 

SBLF provided participating banks with incentives to increase small-business lending. 

However, the scope and scale of SBLF were not as expected, with Treasury investing only $4 

billion of the available $30 billion, two-thirds of which went to TARP banks that used SBLF 

to repay TARP in 2011. Although Congress allowed TARP banks to participate, Congress 

intended that the banks would increase their loans to small businesses, and as a safeguard, 

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required that applicant banks submit to their federal banking regulator a “small business 

lending plan” detailing how the bank would increase lending. However, former TARP banks 

in SBLF have not effectively increased small-business lending and are significantly 

underperforming compared to non-TARP banks. Twenty-four former TARP banks have not 

increased their lending while in SBLF, despite those banks collectively receiving $501 

million in SBLF funds. The remaining former TARP banks have increased lending by $1.13 

for each SBLF dollar they received. By comparison, banks that did not participate in TARP 

but received SBLF funding have increased small-business lending by more than three times 

that amount – $3.45 for each dollar in SBLF funds. The 132 of 137 former TARP banks 

remaining in SBLF have not effectively increased small-business lending because they used 

approximately 80 percent of SBLF funds ($2.1 billion of the $2.7 billion) to repay TARP. 

Although as a group, the former TARP banks remaining in SBLF increased lending by $1.13 

for each dollar in SBLF funds received, there was a significant difference in lending 

depending on whether the bank received only enough SBLF funds to repay TARP or 

received additional funds. TARP banks that received only enough SBLF funds to repay 

TARP have lent out significantly less than they received in SBLF funds – increasing lending 

by only 25 cents for each dollar in SBLF funds. TARP banks that received additional SBLF 

money beyond the outstanding TARP balance have increased lending by $1.67 for every 

dollar in SBLF funds, a fraction of lending increases by non-TARP banks in SBLF. The 

report included three recommendations to Treasury and the federal banking regulators to 

improve coordination when collaborating on current and future initiatives. 

On August 15, 2013, SIGTARP issued the report, “Treasury’s Role in the Decision for GM 

To Provide Pension Payments to Delphi Employees.” The U.S. Department of the Treasury’s 

(“Treasury”) injection of Troubled Asset Relief Program (“TARP”) funds in General Motors 

Corporation (“GM”) and Chrysler Group LLC (“Chrysler”) was the only bailout with a 

President’s Designee overseeing the companies’ restructurings – the Presidential Task Force 

on the Auto Industry (“Auto Task Force”). The Auto Task Force delegated the responsibility 

for GM’s restructuring to four primary officials who were part of an Auto Team led by 

Steven Rattner. GM’s bankruptcy would be one of the largest and fastest bankruptcies in our 

nation’s history. A new company, “New GM,” emerged from GM’s bankruptcy in July 

2009, with Treasury owning 61 percent of its common stock. New GM purchased 

substantially all of GM’s assets while leaving behind many of its liabilities. One of the 

liabilities that New GM agreed to honor related to the pensions of certain former GM 

employees paid an hourly wage and represented by certain unions, and who had worked in 

GM’s automobile parts division that was spun off into Delphi Corporation (“Delphi”). The 

four Treasury Auto Team officials made it clear to SIGTARP that the decisions made and 

Treasury’s role related to Delphi pensions had to be viewed in the broader context of GM’s 

restructuring. SIGTARP found that the role of these Treasury officials sharply contrasted 

with the role played by Treasury officials under other TARP programs. The four Treasury 

Auto Team officials played a direct role in GM’s decisions and operations up to and through 

GM’s bankruptcy. As GM’s only lender and later GM’s largest investor, Treasury’s Auto 

Team had significant leverage and influence on GM’s decisions, and in practice, the Auto 

Team’s role was more than advisory. 

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Dollars in Thousands 

Special Inspector General for TARP FTE Amount 

FY 2014 Enacted 192 $34,923 

Changes to Base: 

Maintaining Current Levels (MCLs): - $823 

Pay-Raise - $300 

FERS Contribution Increase - $260 

Non-Pay - $263 

Efficiency Savings: - ($1,512) 

Operations Partially Funded from No-Year Resources - ($1,512) 

Subtotal Changes to Base - ($689) 

Total FY 2015 Base 192 $34,234 

Total FY 2015 Request 192 $34,234 

 

 

 

 

Section 2 – Budget Adjustments and Appropriation Language 

2.1 – Budget Adjustments Table 

2A – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ......................................................... +$823,000 / +0 FTE 

Pay-Raise +$300,000 / +0 FTE 

Funds are requested for the proposed January 2015 pay-raise and the annualization of the 2014 

pay-raise. 

FERS Contribution Increase +$260,000 / +0 FTE 

Funds are requested for increases in agency contributions to the Federal Employee Retirement 

System based on updated actuarial estimates. 

Non-Pay +$263,000 / +0 FTE 

Funds are requested for non-labor costs such as travel, contracts, rent, supplies, and equipment. 

Efficiency Savings ...................................................................................... -$1,512,000 / +0 FTE
 

Operations Partially Funded from No-Year Resources -$1,512,000/ +0 FTE 

Reduction in general operating costs to occur from the annual account. SIGTARP will instead 

continue to use its mandatory funding. 

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Special Inspector General for TARP FY 2013 FY 2014 FY 2015 

Object Classification Actual Enacted Request 

11.1 - Full-time permanent 17,029 17,838 20,820 

11.3 - Other than full-time permanent 2,764 2,730 2,113 

11.5 - Other personnel compensation 1,708 1,725 1,809 

11.9 - Personnel Compensation (Total) 21,501 22,293 24,742 

12.0 - Personnel benefits 5,547 5,545 6,596 

Total Personnel and Compensation Benefits $27,048 $27,838 $31,338 

21.0 - Travel and transportation of persons 948 943 943 

23.2 - Rental payments to others 301 303 236 

23.3 - Communication, utilities, and misc charges 91 105 85 

24.0 - Printing and reproduction 180 161 161 

25.1 - Advisory and assistance services 3,431 2,613 2,669 

25.2 - Other services 416 511 520 

25.3 - Other purchases of goods & serv from Govt accounts 8,000 9,931 9,510 

26.0 - Supplies and materials 475 462 462 

31.0 - Equipment 272 245 231 

42.0 - Insurance claims and indemnities 17 30 1 

Total Non-Personnel 14,131 15,304 14,818 

Subtotal New Appropriated Resources $41,179 $43,142 $46,156 

Budget Activities: 

Audit 14,409 15,296 12,201 

Investigations 26,770 27,846 33,955 

Total Budgetary Resources $41,179 $43,142 $46,156 

FTE 168 192 192 

 

 

2.2 – Operating Levels Table 

Dollars in Thousands 

2B – Appropriations Language and Explanation of Changes 

Appropriations Language 

Explanation of 

Changes 

DEPARTMENT OF THE TREASURY 

SPECIAL INSPECTOR GENERAL FOR THE TROUBLED ASSET 

RELIEF PROGRAM 

SALARIES AND EXPENSES 

For necessary expenses of the Office of the Special Inspector General in 

carrying out the provisions of the Emergency Economic Stabilization Act 

of 2008 (Public Law 110-343) [$34,923,000] $34,234,000. (Department 

of the Treasury Appropriations Act, 2014.) 

2C – Legislative Proposals 

SIGTARP has no legislative proposals. 

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Section 3 – Budget and Performance Plan 

3A – Audit 

($9,243,000 from direct appropriations): 

SIGTARP estimates that $2,958,000 from unobligated balances from prior-years will be used in 

FY 2015 to cover specific operating expenses in support of the Audit program since appropriated 

funds are insufficient for these expenses. Public Law 111-22 of the Emergency Economic 

Stabilization Act of 2008 (“EESA”) provided SIGTARP with an initial allocation of $50 million, 

(available until expended) to fund its operations. 

The Audit program supports SIGTARP’s priority of coordinated oversight by providing 

recommendations to Treasury so that TARP programs can be designed or modified to facilitate 

effective oversight and transparency to prevent fraud, waste, and abuse. This program also 

supports and complements Treasury’s strategic goal to promote domestic economic growth and 

stability while continuing to reforms of the financial system by assessing the effectiveness of 

Treasury’s activities in TARP. It also supports Treasury’s strategic goal to manage the 

government’s finances in a fiscally responsible manner as they relate to TARP. 

The Audit Division (AD) conducts, supervises, and coordinates programmatic audits with 

respect to Treasury’s operation of TARP as well as evaluations of TARP policies and 

procedures. With respect to auditing, the division is designed to provide SIGTARP with 

maximum flexibility in the size, timing, and scope of audits so that, without sacrificing the rigor 

of the methodology, audit results, whenever possible, can be generated rapidly both for general 

transparency’s sake and so that the resulting data can be used to improve the operations of 

TARP. 

Regarding policy review and technical assistance, a particular focus of AD is ensuring that 

appropriate internal controls are in place and followed by Treasury in its management of TARP 

and by the recipients of TARP funds, including vendors and the entities in which money is 

invested. Where controls or compliance are found to be lacking, or where particular aspects or 

policies risk being ineffective at reaching TARP’s goals, AD assists the Special Inspector 

General to fashion recommendations to resolve such issues. 

The goal owner for this budget activity is Bruce Gimbel, Acting Assistant Deputy Special 

Inspector General Audit, and Evaluations. 

Description of Performance: 

One of the primary functions of SIGTARP is to ensure that members of Congress remain 

adequately and promptly informed of developments in TARP initiatives and of SIGTARP’s 

oversight activities. To fulfill that role, the Special Inspector General and staff meet regularly 

with Congress and staff. In FY 2013 SIGTARP exceeded its performance goal, “Congressional 

Requests for Testimony Completed” by completing five testimonies by September 30, 2013. 

SIGTARP anticipates that Congress will continue to have interest in SIGTARP’s work and will 

continue to request three testimonies in FY 2014 and three testimonies in FY 2015. 

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The performance goal, “Number of Completed Audit Products” includes issuing audit reports, 

and memoranda that promote the efficiency and effectiveness of the TARP. SIGTARP 

developed an audit plan using a risk-based planning process to identify projects that will provide 

the maximum benefit to TARP, Congress and the taxpayers. The maximum benefit is to assure 

the general public that TARP funds are not expended by recipients or other entities on waste, 

fraud, or abuse. Presently there are three on-going audits and three evaluations that have been 

requested by Congress in addition to SIGTARP’s four self-initiated reviews. The ongoing audits 

and evaluations cover a variety of TARP-related areas including the Capital Purchase Program, 

General Motors, and Hardest Hit Fund. SIGTARP completed 10 audit products in FY 2013, 

meeting the goal of 10 during the reporting period. The number of audit products is 8 in FY 

2014 and 8 in FY 2015. Throughout this process, SIGTARP’s risk assessment plan will be used 

to determine audit requirements as well as requests made by Congress and the required quarterly 

report. 

3.1.1 – Audit Budget and Performance Plan 

Dollars in Thousands 

Audit Budget Activity 

Resource Level FY 2009 FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual Actual Actual Actual Operating Enacted Request 

Plan 

Appropriated Resources $0 $9,900 $10,581 $14,626 $14,597 $12,220 $9,243 

Budget Activity Total $0 $9,900 $10,581 $14,626 $14,597 $12,220 $9,243 

Measure FY 2008 FY 2009 FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual Actual Actual Actual Actual Actual Target Target 

Congressional Requests for N/A 9 7 5 4 5 3 3

Testimony Completed (Units) 

Number of Completed Audit N/A 3 9 13 13 10 8 8

Products (Units) 

Key: DISC - Discontinued and B - Baseline 

3B – Investigations 

($24,991,000 from direct appropriations): 

SIGTARP estimates that $8,964,000 from unobligated balances from prior-years will be used in 

FY 2015 for Investigations activities. Public Law 111-22 of the Emergency Economic 

Stabilization Act of 2008 (“EESA”) provided SIGTARP with an initial allocation of $50 million, 

(available until expended) to fund its operations. In FY 2015 SIGTARP estimates that 

$7,999,000 of these remaining funds will be used to cover specific operating expenses in support 

of the Investigations program since appropriated funds are insufficient for these expenses. 

Public Law 111-22 provided an additional $15 million to prioritize the performance of audits or 

investigations of non-recourse federal loans, including the Public Private Investment Program 

(“PPIP”) and the Term Asset Back Securities Loan Facility Program (“TALF”) made under any 

“Emergency Economic Stabilization Act of 2008, Public Law 110-343 program. These funds 

are available until expended; $965,000 will be used in FY 2015 for personnel and other operating 

expenses related to PPIP/TALF. 

SIGTARP - 14
 
 

 

 

The Investigations program supports SIGTARP’s priority of robust enforcement by preventing, 

detecting, investigating, and referring for prosecution cases of fraud, waste, and abuse related to 

TARP. This program also supports and complements Treasury’s strategic goal to promote 

domestic economic growth and stability and continue reforms the financial system by assessing 

the effectiveness of Treasury’s activities. It also supports Treasury’s strategic goal to manage 

the government’s finances in a fiscally responsible manner as they relate to TARP. 

The Investigations Division (ID) supervises and conducts criminal and civil investigations into 

those persons and entities, whether inside or outside of government, who waste, steal, or abuse 

TARP funds or programs. The division is comprised of experienced financial and corporate 

fraud investigators, including not only special agents, but also forensic analysts, and 

investigative attorneys. This structure provides SIGTARP with a broad array of expertise and 

perspectives in developing the most sophisticated investigations. In the interests of maximizing 

criminal and civil enforcement, ID coordinates closely with other law enforcement agencies with 

the goal of forming law enforcement partnerships, including task force relationships, across the 

federal government and state governments to leverage SIGTARP’s expertise and unique 

position. 

The goal owner for this budget activity is Scott Rebein, Deputy Special Inspector General 

Investigations Division. 

Description of Performance: 

One of SIGTARP’s primary investigative priorities is to operate the SIGTARP Hotline that 

provides a simple, accessible way for the American public to report concerns, suggestions, 

information, and evidence of violations of criminal and civil laws in connection with TARP. 

From its inception in February 2009 through October 29, 2013, the SIGTARP Hotline has 

received and analyzed more than 33,052 Hotline contacts. During FY 2013, considerable effort 

was spent reviewing and referring complaints to meet the public’s demand for action regarding 

the mortgage crisis. “Percentage of Hotline Complaints Responded to or Referred for 

Investigation or Further Action within 14 days of Receipt” was 83, exceeding the annual goal of 

70 percent. These contacts run the gamut from expressions of concern over the economy to 

serious allegations of fraud involving TARP. Overall, there are more than 150 ongoing 

investigations, a number of which were generated as a result of a Hotline contact. These 

investigations include accounting fraud, securities fraud, insider trading, bank fraud, mortgage 

fraud, mortgage modification fraud, fraudulent advance-fee schemes, false statements, 

obstruction of justice, money laundering, and tax crimes. SIGTARP anticipates a 70 percent 

referral rate of these complaints for FY 2014 and a 75 percent referral rate for FY 2015. In 

addition, SIGTARP continues to streamline the complaint referral process through the use of 

information technology, additional training for staff members, and concerted outreach to 

prosecutorial agencies. 

During FY 2013, the “Percentage of Investigations Accepted for Consideration by Prosecutors”, 

including criminal or civil investigations that a federal, state, or local prosecutor has formally 

accepted for consideration for criminal prosecution or civil or administrative action, was an 

average of 94 percent, exceeding the target of 60 percent. This success is directly related to the 

still-significant public interest in TARP related cases and the well-crafted investigative files 

SIGTARP - 15
 
 

 

developed by SIGTARP’s Investigations Division. SIGTARP’s investigative strategies have 

already produced significant cases; bringing to justice those who have sought to profit criminally 

from TARP. 

As of October 29, 2013, the results are: criminal charges against 154 individuals, including 98 

senior officers (CEOs, owners, founders, or senior executives) of their organizations; criminal 

convictions of 112 defendants, of whom 65 have been sentenced to prison (others are awaiting 

sentencing); civil cases and other actions against 63 individuals (including 49 senior officers) 

and 51 entities (in some instances an individual will face both criminal and civil charges); orders 

of restitution and forfeiture and civil judgments entered for $4.68 billion. Although the ultimate 

recovery of these amounts is not known, SIGTARP has already assisted in the recovery of 

$185.6 million; as well as savings of $553 million in TARP funds that SIGTARP prevented from 

going to the now-failed Colonial Bank. SIGTARP anticipates a 70 percent acceptance rate in FY 

2014 and FY 2015. 

SIGTARP has seen an increase in press coverage due to several high profile mortgage fraud and 

bank fraud cases, resulting in numerous arrests and convictions. This has caused a sustained 

interest among prosecutors when considering TARP related cases for prosecution. This 

performance metric will remain at 70 percent in FY 2015. The Investigations Division will 

continue to aggressively engage the U.S. Attorneys across the nation capable of prosecuting 

sophisticated white-collar criminal investigations involving TARP-related fraud to ensure their 

understanding of the importance and viability of SIGTARP investigations, the magnitude, and 

complexity of the fraud in our investigations, and the impact these investigations have on the 

economic crisis. SIGTARP investigations have a major deterrent effect not only on those 

currently participating in financial fraud, but also deterring those considering participation in 

future fraud schemes. 

A preliminary investigation is the period during which the investigator gathers fundamental 

information to evaluate the need to continue the case by converting it to a full investigation or to 

close the case. During FY 2013, “Percentage of Preliminary Investigations Converted to Full 

Investigations within 180 days” was an average of 82 percent, exceeding the goal of 50 percent. 

SIGTARP’s success is attributed to proactively identifying indicators of fraud related to TARP, 

receiving substantial case leads and complaint referrals from other agencies as ID has developed 

its identity as a premier white collar crime law enforcement agency. As ID has evolved, so has 

the depth and complexity of the cases under investigation. 

SIGTARP has efficiently leveraged its resources to enable ID to handle its growing inventory 

and to expedite these investigations. In FY 2014, SIGTARP will increase this metric to 60 

percent because as ID’s workforce has expanded, so has the ability to respond quickly to 

allegations and to devote the necessary resources. SIGTARP has involved the prosecutors in the 

early stages of the preliminary investigations to ensure that allegations, if proven, will be 

prosecuted. This resulted in a greater number of preliminary investigations being converted to 

full investigations or closed within the 180-day timeframe; therefore this performance metric will 

increase to 60 percent in FY 2014 and to 70 percent in FY 2015. The Investigations Division 

will continue to prioritize leads and fraud allegations and make effective, informed decisions 

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when opening preliminary investigations to ensure an appropriate commitment of investigative 

resources are available to devote to these investigations. 

As previously mentioned, SIGTARP ID coordinates closely with other law enforcement 

agencies, forming law enforcement partnerships across Federal, state and local government that 

leverage SIGTARP’s expertise and unique position. Frequently other Federal law enforcement 

partners may pursue a lead or open a case and then request SIGTARP’s expertise and resources 

to lead the case. During FY 2013, “Percentage of cases that are joint agency/task force 

Investigations” with other law enforcement agencies was an average of 79 percent, exceeding the 

target of 45 percent. This was driven by the significant number of high profile cases opened in 

FY 2012. SIGTARP continues to work both as an independent entity and with other law 

enforcement partners as cases dictate. SIGTARP is projecting a goal of 45 percent for FY 2014 

and 50 percent for FY 2015. 

3.1.2 – Investigations Budget and Performance Plan 

Dollars in Thousands 

Investigations Budget Activity 

Resource Level FY 2009 FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual Actual Actual Actual Operating Enacted Request 

Plan 

Appropriated Resources $0 $13,339 $25,433 $27,174 $27,119 $22,703 $24,991 

Budget Activity Total $0 $13,339 $25,433 $27,174 $27,119 $22,703 $24,991 

Measure FY 2008 FY 2009 FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual Actual Actual Actual Actual Actual Target Target 

Percentage of Hotline N/A 77.0 74.0 76.0 77.0 83.0 70.0 75.0 

Complaints Responded to or 

Referred for Investigation or 

further action within 14 days of 

Receipt (%) 

Percentage of Investigations 

Accepted for Consideration by 

Prosecutors (%) 

N/A 95.0 100.0 94.0 95.0 94.0 70.0 70.0 

Percentage of Preliminary 

Investigations Converted to Full 

Investigations Within 180 Days 

(%) 

N/A 50.0 80.0 88.0 77.0 82.0 60.0 70.0 

Percentage of cases that are 

joint agency/task force 

investigations (%) 

N/A 60.0 50.0 40.0 65.0 79.0 45.0 50.0 

Key: DISC - Discontinued and B – Baseline 

SIGTARP - 17
 
 

 

Section 4 – Supplemental Information 

4A – Summary of Capital Investments 

IT funding has been critical in enabling SIGTARP to fulfill its mission of transparency, 

coordinated oversight, and robust enforcement. SIGTARP uses the services provided by 

Treasury Departmental Offices and Government Security Operations Center as part of 

Treasury’s headquarters operations. SIGTARP relies on the Treasury’s Office of the Chief 

Information Officer and Departmental Offices Operations to provide a secure infrastructure that 

is fully capable of supporting the mission and administrative requirements of a completely 

functional, bureau-level government agency with the technology requirements appropriate to an 

audit and investigative organization. 

SIGTARP’s IT strategy continues with limited IT investments including updates, modifications, 

and maintenance and equipment refreshment, consistent with its role as a temporary agency. For 

FY 2015, SIGTARP expects only ongoing infrastructure charges for headquarters and for remote 

office operations and routine maintenance, enhancements and modifications of its existing 

systems required to support its mission. SIGTARP has no capital investments. 

Non-Major IT Investment Summary 

The non-major IT investments are for the acquisition, installation, integration, training and 

modifications of mission essential systems such as hotline information management, 

investigative case management, investigations database, investigations evidence network, 

counsel case management, forensic system management, SIGTARP website and intranet, video 

teleconferencing, and asset management which were established by SIGTARP because they were 

not provided by Treasury. SIGTARP migrated most of these systems to Treasury for hosting 

services and began to use Treasury’s shared services offerings (“cloud computing”) for content 

management such as document management, Freedom of Information Act tracking, and records 

management. 

Non-IT Investment Summary 

SIGTARP’s non-IT investments include technical surveillance equipment. The Investigations 

Division requires specialized surveillance equipment in order to conduct criminal investigations 

in cooperation with the Federal Bureau of Investigations, Internal Revenue Service-Criminal 

Investigation, other federal agencies, and state/local law enforcement agencies. This specialized 

equipment ensures officer/agent safety to obtain evidence for prosecution while allowing 

interoperability with equipment used by the other agencies. 

A summary of capital investment resources, including major information technology and nontechnology investments, can be viewed/downloaded at: http://www.treasury.gov/about/budgetperformance/Pages/summary-of-capital-investments.aspx 

SIGTARP - 18