Special Inspector General for TARP 

Table of Contents 

Overview.............................................................................1 

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

1A – Description of Vision and Priorities............................... 3 

1B – Program History and Future Outlook............................. 4 

Section 2 – Budget Adjustments and Appropriation Language.........10 

2.1 – Budget Adjustments Table.........................................10 

2A – Budget Increases and Decreases Description....................10 

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

2.3 – Appropriations Detail Table........................................13 

2B – Appropriations Language and Explanation of Changes .......14 

2C – Legislative Proposals................................................14 

Section 3 – Budget and Performance Plan...................................15 

3.1 – Budget by Strategic Goal...........................................15 

3A – Audit....................................................................15 

3.2.1 – Audit Budget and Performance Plans ..........................16 

3.B – Investigation.........................................................17 

3.2.2 – Investigation Budget and Performance Plan....................18 

Section 4 – Supporting Materials...............................................19 

4A – Human Capital Strategy Description..............................19 

4.1 – Summary of IT Resources Table....................................19 

4B – Information Technology Strategy...................................20
SIGTARP ‐ 1

Overview 

Mission Statement 

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

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

oversight, and through robust enforcement against those persons and entities, whether inside or 

outside of government, who waste, steal, or abuse TARP funds. 

Program Summary by Budget Activity 

Dollars in Thousands 

Mandatory and Discretionary Levels FY 2009 FY 2010 FY 2011 

 Enacted Enacted Request 

$ 

Change 

% 

Change 

             

Salaries and Expenses $50,000 $23,300 $49,600 $26,300 113% 

Public Private Investment Fund (PPIP) $15,000 

 

Mandatory Funding $65,000 

Discretionary Funding $23,300 $49,600 $26,300 113% 

 

Total Mandatory and Discretionary1 $65,000 $23,300 $49,600 $26,300 113% 

Available no-year funds - S&E $20,100 ($20,100) -100% 

Available PPIP funds $5,000 $5,000 $0 0% 

Total Budgetary Resources $65,000 $48,400 $54,600 $6,200 13% 

Program Summary By Budget Activity: 

Audit $27,900 $20,700 $23,200 $2,500 12% 

Investigation $37,100 $27,700 $31,400 $3,700 13% 

Total by Budget Activity $65,000 $48,400 $54,600 $6,200 13% 

Total FTE 1002 1333 160 20% 

                                                           

1 The FY 2009 enacted level includes $50 million of no‐year funds provided by Public Law (P.L.) 110—343, the

Emergency Economic Stabilization Act of 2009 as amended, (EESA) and an additional $15 million of no‐year funds

made available pursuant to P. L. 111‐22, for a total of $65 million.  Carry‐forward funds in the amount of $20.1

million, provided by P.L. 110‐343, and $5 million provided by P.L. 111‐22, and the enacted FY 2010 budget of $23.3

million in direct appropriations, provided by P.L. 111‐117, will be used to fund the FY 2010 budget of $48.4 million.  

These amounts do not reflect an additional $10.2 available in carry‐forward from P.L. 110‐343.  The carry‐forward

from P.L. 111‐22 will be used to partially fund the FY 2011 and FY 2012 budget in the amount of $5 million each

year.

2 This represents a target level of approved FTEs; actual usage in FY 2009 was 29 FTE.  

3 This represents the projected usage level for the FY 2010 approved 160 FTE ceiling.  
SIGTARP ‐ 2

FY 2011 Priorities 

• Promote transparency in the management and operation of TARP, ensuring the satisfaction 

of the public’s right to know how Treasury decides to invest the public’s money, how it 

manages the assets it obtains, and how TARP recipients use these funds. 

• Coordinate oversight: 

o Prospectively advise Treasury concerning issues relating to compliance, internal 

controls and fraud prevention. 

o Retrospectively assess the effectiveness of Treasury’s activities, recommend 

improvements, and evaluate whether TARP recipients are satisfying their legal 

obligations. 

• Prevent, detect, investigate and refer for prosecution cases of fraud, waste and abuse 

involving TARP funds or programs. 
SIGTARP ‐ 3

Section 1 – Purpose 

1A – Description of Vision and Priorities 

SIGTARP supports and complements Treasury’s strategic goal of effectively managing the U.S. 

Government’s finances as they relate to the TARP program (which potentially involves more 

that $2 trillion in TARP and TARP-related funds), through the implementation of SIGTARP’s 

priorities: 

 • Promoting transparency in the management and operation of TARP programs; 

 • Coordinating oversight: 

o Prospectively advising Treasury concerning issues relating to compliance, internal 

controls and fraud prevention; 

o Retrospectively assessing the effectiveness of Treasury’s activities and evaluating 

whether TARP recipients are satisfying their legal obligations; and 

• Preventing, detecting, investigating and referring for prosecution cases of fraud, waste and 

abuse involving TARP funds or programs. 

Of the four primary oversight bodies referenced in the Emergency Economic Stabilization Act of 

2008, P.L. 110-343 (EESA), (i.e., SIGTARP, the Financial Stability Oversight Board, the 

Congressional Oversight Panel, and the Government Accountability Office), SIGTARP stands as 

the sole TARP oversight body charged with criminal law enforcement responsibility: as the cop 

on the beat. Being the lone cop on the beat would be an intimidating task in a $700 billion 

purchase and guarantee program as was originally envisioned under EESA. The task, however, 

has become exponentially more challenging as Treasury has thus far committed TARP funds to 

12 separate programs that potentially involve more than $2 trillion. To accomplish SIGTARP’s 

mission to oversee this vast amount of money for the American taxpayer, SIGTARP focuses on 

its goals of transparency, coordinated oversight, and robust criminal and civil law enforcement. 

Promoting transparency in the management and operations of TARP programs is vital. Through 

EESA, the American taxpayer has been asked to fund an unprecedented effort to stabilize the 

financial system and foster economic recovery. In this context, the public has a right to know 

how Treasury decides to invest its money, how it manages the assets it acquires, and how TARP 

recipients use the funds. Transparency is a powerful tool to ensure accountability and that all 

those managing and receiving TARP funds will act appropriately and in the best interest of the 

country. 

SIGTARP views its oversight role prospectively, retrospectively, internally, and externally. 

Prospectively, SIGTARP, among other things, advises Treasury on issues relating to compliance, 

internal controls and fraud prevention. Retrospectively, SIGTARP assesses the effectiveness of 

TARP activities over time and suggests improvements. Internally, SIGTARP’s oversight role 

reaches to Treasury officials and to other government employees who manage TARP-related 

programs. Externally, it reaches to the recipients of TARP funds, the other private participants in 
SIGTARP ‐ 4

TARP-related programs and to vendors that have been retained to assist Treasury in 

implementing TARP. SIGTARP also plays a significant external coordinating role among 

TARP oversight bodies both to ensure maximum oversight coverage and to avoid redundant and 

unduly burdensome requests on Treasury personnel who manage the programs. 

Robust criminal and civil law enforcement involves the prevention, detection, and investigation 

of instances of fraud, waste, and abuse relating to TARP funds or operations. Through our audit 

and investigative resources, and through partnership with other relevant law enforcement 

agencies, SIGTARP is committed to deterring, detecting, investigating and referring for 

prosecution those persons and entities, inside or outside of the government, who waste, steal, or 

abuse TARP funds. 

1B – Program History and Future Outlook 

Background: EESA created the TARP and authorized Treasury to purchase, manage, and sell 

troubled assets under section 101, and to guarantee such assets under section 102. Additionally, 

section 121 of EESA, as amended, which incorporated selected provisions of the Inspector 

General Act of 1978, 5 U.S.C. App. 3, created SIGTARP as an independent agency within 

Treasury responsible to conduct, supervise, and coordinate audits and investigations of any 

actions taken under EESA. 

General Management: SIGTARP commenced operations on December 15, 2008, with the 

swearing in of the Special Inspector General (SIG). Between December 2008 and September 30, 

2009, the SIG and SIGTARP have been extraordinarily productive: building infrastructure, 

hiring staff, leveraging oversight resources, opening more than 61 investigations, initiating 13 

audits, publishing three audit reports and issuing three substantial reports to Congress. In the 

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

contracted for permanent space and the rehabilitation of the same; has contracted with public and 

private vendors for personnel services, procurement assistance, publication consulting, data 

processing and analysis, and office equipment and services. 

Simultaneous with building the infrastructure to enable SIGTARP to carry out its mission, the 

SIG rapidly designed a staffing and hiring plan. As of January 1, 2010, SIGTARP has hired 99 

managers, lawyers, auditors, investigators, and other professionals with a wealth of experience in 

program auditing, investment banking, securities enforcement, and other relevant curricula. To 

successfully accomplish this hiring challenge, SIGTARP relied on direct hire authority and dual 

compensation authority waiver delegated by the Office of Personnel Management. Recently, the 

Special Inspector General for the Troubled Asset Relief Program Act of 2009, P.L. 111-15, 

supplemented SIGTARP’s dual compensation waiver authority and granted additional hiring 

incentives included in 5 U.S.C. § 3161. 

The TARP has evolved from a $700 billion purchase and guarantee program potentially 

involving up to a $2 trillion amalgamation of a dozen separate programs, which in some cases 

are being or will be implemented by government agencies other than Treasury (i.e., the Federal 

Reserve and the Federal Deposit Insurance Corporation (FDIC)). Accordingly, SIGTARP 

determined that leveraging other oversight resources would be necessary. In addition to meeting 

extensively with Treasury and the Federal Reserve concerning program proposals, SIGTARP 

regularly and continually coordinates with the Financial Stability Oversight Board, the 
SIGTARP ‐ 5

Congressional Oversight Panel, and the Government Accountability Office concerning our 

overlapping oversight responsibilities under EESA. 

Additionally, SIGTARP has initiated several efforts designed to augment audit and investigative 

resources. For example, SIGTARP founded the TARP Inspector General Council (TARP-IG 

Council), which includes the Comptroller General, the Inspectors General for Treasury, the 

Federal Reserve Board, the FDIC, the Securities and Exchange Commission (SEC), the Federal 

Housing Finance Agency, the Department of Housing and Urban Development, the Small 

Business Administration, and the Treasury Inspector General for Tax Administration. The 

TARP-IG Council meets monthly to discuss developments in TARP and coordinate 

interconnected audit and investigative issues. Similarly, SIGTARP established the Term AssetBased Securities Loan Facility (TALF) Task Force, which includes the Inspector General for the 

Federal Reserve Board, the Federal Bureau of Investigation (FBI), the Financial Crimes 

Enforcement Network (FinCEN), U.S. Immigration and Customs Enforcement, the Internal 

Revenue Service Criminal Investigation Division (IRS-CID), the SEC, and the U.S. Postal 

Inspection Service. The task force members participate in regular briefings about the TALF, 

collectively identify areas of fraud vulnerability, engage in training exercises, and coordinate 

audit and investigative efforts. SIGTARP has established a TALF Public Private Investment 

Program task force, and forged partnerships and launched joint investigations with the FBI, the 

SEC, IRS-CID, and the New York High Intensity Financial Crime Area (NY HIFCA). In the 

latter regard, SIGTARP’s partnership with NY HIFCA provides SIGTARP with two experienced 

financial analysts who use FinCEN and other available data resources to identify indicators of 

fraud associated with the TARP and furnish analytical support with respect to ongoing 

investigations. 

Further, consistent with significant reporting requirements set forth in EESA, on February 6, 

April 21, July 21, and October 21, 2009, SIGTARP issued wide-ranging reports to Congress, 

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

programs (both implemented and announced); 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. In the latter regard, recommendations included in SIGTARP’s April 

21st report were largely adopted and enacted into law by section 402 of Public Law No. 111-22. 

SIGTARP’s reports also satisfied 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 such 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. SIGTARP expends substantial time and resources on its reports to Congress, 

which are designed to be the comprehensive reference concerning TARP activities for policy 

makers, Congress and the American people. These reports are available at 

http://www.sigtarp.gov/reports.shtml. 
SIGTARP ‐ 6

In addition to management and operations/overhead staff, SIGTARP carries out its mission via 

audit and investigative staff. 

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

with respect to Treasury’s operation of TARP and recipients’ compliance with their obligations 

under relevant law and contracts; evaluates TARP policies and procedures; and provides 

technical assistance to Treasury. 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 the fast-evolving TARP. 

In July 2009, AD issued its first formal audit report concerning how recipients of CPP funds reported 

their use of such funds based upon a February 2009 survey that SIGTARP sent to more than 360 

financial and other institutions that had completed TARP funding agreements through January 2009. 

Although most banks reported they did not segregate or track TARP fund usage on a dollar-for-dollar 

basis, they were able to provide insights into their actual or planned future use of TARP funds. For 

some respondents the infusion of TARP funds helped to avoid a “managed” reduction of their 

activities; others reported that their lending activities would have come to a standstill without TARP 

funds; and others explained that they used TARP funds to acquire other institutions, invest in 

securities, pay off debts, or that they retained the funds to serve as a cushion against future losses. 

Many survey respondents also highlighted the importance of the TARP funds to the bank’s capital 

base, and by extension, the impact of the funds on lending. 

AD also completed an audit examining undue external influences over the CPP decision-making 

process. This audit addressed the extent to which Treasury and the banking regulators have controls 

to safeguard against external influences over the CPP decision-making process and whether there 

were any indications of external parties having unduly influenced CPP decision-making. SIGTARP 

found no information indicating that external inquiries on CPP applications had affected the decisionmaking process, but gaps in the internal controls by the government agencies conducting the CPP 

application process makes it impossible to determine if all attempts to influence TARP decisions 

were captured by the audit. Of the 56 institutions SIGTARP identified that were the subjects of 

external inquiries, three institutions did not meet all the CPP quantitative criteria but were approved 

based on mitigating factors considered by Treasury and banking agency officials. Among these 

three, one institution stood out. SIGTARP’s analysis indicated that discretion afforded this applicant 

in its approval was greater than that afforded other applicants. In connection with the audit, 

SIGTARP made recommendations regarding the improvement of internal controls and record 

keeping, which Treasury has adopted. 

AD also issued an audit examining executive compensation restriction compliance. This audit 

examined the efforts of TARP recipients’ to comply with executive compensation restrictions in 

place at the time of SIGTARP’s survey of banks use of funds. The audit was set against a 

background of the evolving rules on executive compensation for TARP recipients. Although 

recipients expressed frustration with changing compensation guidance, they were able to report the 

actions that they have been taking. 
SIGTARP ‐ 7

AD also has audits nearing completion examining AIG bonuses, AIG counterparty payments and an 

update on SIGTARP’s use of funds survey. In addition, SIGTARP is undertaking a series of new 

audits, as follows: 

• TARP assistance to the first nine CPP recipients, with emphasis on additional assistance to 

Bank of America subsequently authorized under the Targeted Investment and the Asset 

Guarantee Programs (“TIP” and “AGP”). 

• CPP Warrant Valuation and Disposition Process: The audit will seek to determine: (i) the 

extent to which financial institutions have repaid Treasury’s investment under CPP and the 

extent to which the warrants associated with that process were repurchased or sold; and (ii) 

what process and procedures Treasury has established to ensure the Government receives fair 

market value for the warrants and the extent to which Treasury follows a clear, consistent, and 

objective process in reaching decisions where differing valuations of warrants exist. This 

audit complements a July 10, 2009, report by the Congressional Oversight Panel examining 

the warrant valuation process. 

 

• Governance Issues Where U.S. Holds Large Ownership Interests: The audit will examine 

governance issues when the U.S. Government has obtained a large ownership interest in a 

particular institution, including: (i) what is the extent of Government involvement in 

management of companies in which it has made sizeable investments, including direction and 

control over such elements as governance, compensation, spending, and other corporate 

decision-making; (ii) to what extent are effective risk management, monitoring, and internal 

controls in place to protect and balance the Government’s interests and corporate needs; (iii) 

are there performance measures in place that can be used to track progress against long-term 

goals and timeframes affecting the Government’s ability to wind down its investments and 

disengage from these companies; and (iv) is there adequate transparency to support decision 

making and to provide full disclosure to the Congress and the public. 

• Status of the Government’s Asset Guarantee Program with Citigroup: The audit will examine 

the Government’s AGP program with Citigroup. Specifically, the audit will address: (i) how 

was the program for Citigroup developed; (ii) what are the current cash flows from the 

affected assets; and (iii) what are the potential for losses to Treasury, the FDIC, and the 

Federal Reserve. 

• Making Home Affordable Mortgage Modification Program: The audit will examine the 

Making Home Affordable mortgage modification program to assess the status of the program, 

the effectiveness of outreach efforts, capabilities of loan servicers to provide services to 

eligible recipients, and challenges confronting the program as it goes forward. 

• Auto dealership terminations: The audit will examine the process used by General Motors 

(“GM”) and Chrysler to identify which automotive dealerships should be maintained or 

terminated. GM and Chrysler reportedly have announced plans to terminate more than 

two thousand automotive dealerships as part of their restructuring process. 

For FY 2011, AD expects to initiate an average of five to seven audits per quarter. 
SIGTARP ‐ 8

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

appropriate internal controls are in place and are complied with, both 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 are found ineffective at reaching TARP’s goals, AD assists the SIG 

to fashion recommendations to resolve such issues. 

Investigations: 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. The division is comprised of experienced financial and 

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

critically, attorney advisors. This structure provides SIGTARP with a broad array of expertise 

and perspective in developing even 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 to leverage SIGTARP’s expertise and unique 

position. 

Since SIGTARP’s inception, ID has opened over 77 investigations and closed nine, but it is 

SIGTARP’s policy not to discuss the scope or substance of pending investigations. However, 

the following activities have been publicly disclosed: 

• Taylor, Bean and Whitaker Mortgage Corporation(TBW) and Colonial Search Warrants: On 

August 3, 2009, SIGTARP, with the FBI, HUD OIG, and FDIC OIG, executed search 

warrants at the offices of Taylor, Bean and Whitaker, formerly the nation’s 12th-largest loan 

originator and servicer, and Colonial Bank, which applied for assistance under the Capital 

Purchase Program (“CPP”). Prior to the execution of these warrants, SIGTARP had served 

subpoenas on Colonial after it had announced that it had received preliminary contingent 

approval from the Treasury to receive $553 million in TARP funding. Based upon 

SIGTARP’s advice, the funding was never made and this investigation, which is being 

conducted with both the Department of Justice and the SEC, is ongoing. 

• Federal Felony Charges Against Gordon Grigg: On April 23, 2009, Federal felony charges 

were filed against Gordon B. Grigg in the U.S. District Court for the Middle District of 

Tennessee, charging him with four counts of mail fraud and four counts of wire fraud. The 

charges are based on Grigg’s role in embezzling approximately $11 million in client 

investment funds that he garnered through false claims, including that he had invested $5 

million in pooled client funds toward the purchase of the TARP-guaranteed debt. Grigg 

pleaded guilty to all charges and was sentenced to 10 years imprisonment. 

• Federal Trade Commission (FTC) Action Against Misleading Use of 

“MakingHomeAffordable.gov”: On May 15, 2009, based upon an action brought by the 

FTC, a Federal district court issued an order to stop an Internet-based operation that 

pretended to operate “MakingHomeAffordable.gov,” the official website of the Federal 

Making Home Affordable program. The FTC’s action, which was developed with the 

investigative assistance of SIGTARP, alleges that the defendants purchased sponsored links 

as advertising on the results pages of Internet search engines, and, when consumers searched 
SIGTARP ‐ 9

for “making home affordable” or similar search terms, the defendants’ ads prominently and 

conspicuously displayed “MakingHomeAffordable.gov.” Consumers who clicked on this 

link were not directed to the official website, but were diverted to sites that solicit applicants 

for paid loan modification services. The operators of these websites either purport to offer 

loan modification services themselves or sold the victims’ personally identifying information 

to others. 

 

• National Housing Modification Center: On September 16, 2009, the FTC filed a complaint 

against the Nations Housing Modification Center (“NHMC”) and its principals in the U.S. 

District Court for the District of Columbia. With investigative support from SIGTARP and 

other federal, state and local enforcement partners, the FTC alleged violations of the FTC Act 

and Telemarketing Sales Rules by NHMC by misrepresenting itself as a Federal government 

agency or affiliate and falsely claiming that they would obtain mortgage modifications for 

consumers for a $3,000 fee. SIGTARP’s joint investigation is continuing. 

• Bank of America: SIGTARP continues to play a significant role in the investigations by the 

New York State Attorney General’s Office, the SEC and the Department of Justice into the 

circumstances of Bank of America’s merger with Merrill Lynch and its receipt of additional 

TARP funds under the Targeted Investment Program. 

For FY 2011, although it is difficult to forecast for a variety of reasons, SIGTARP anticipates 

opening 75 investigations. In addition, SIGTARP’s Hotline, which fields complaints and tips 

about wrongdoing, as of December 31, 2009, had already processed more than 9,900 contacts. 
SIGTARP ‐ 10

Section 2 – Budget Adjustments and Appropriation Language 

2.1 – Budget Adjustments Table 

Dollars in Thousands 

 Special Inspector General for the Troubled Asset Relief Program 

FTE Amount 

FY 2010 Enacted 133 $ 23,300 

Adjustments to FY 2010 Enacted 

 Base Realignment 

 FY 2010 Base Realignment 27 $ 25,015 

 Subtotal, Base Realignment 27 $ 25,015 

 

 Maintaining Current Levels $ 1,285 

 FERS % Change 9 

 Non-Pay Inflation Adjustment 278 

 Pay Annualization 702 

 Pay Inflation Adjustment 296 

 

Subtotal, Adjustments to FY 2010 Enacted $ 26,300 

Total FY 2011 President’s Budget Request 160 $ 49,600 

 

Carryover from Pub. Law No. 111-22 160 $ 5,000 

 

Total FY 2011 Budgetary Resources 160 $ 54,600 

 

2A – Budget Increases and Decreases Description 

SIGTARP has an appropriation of $23,300,000 for FY 2010. In addition, section 402(c)(1) of 

the Helping Families Save Their Homes Act of 2009, Pub. Law No. 111-22, provided SIGTARP 

with $15,000,000. However, section 402(c)(2) requires SIGTARP, in using these funds, to 

“prioritize the performance of audits or investigations of recipients of non-recourse Federal loans 

made under any” EESA program. The supplemental funding, thus, is not available for 

SIGTARP’s general operational uses, and SIGTARP expects that it will take approximately three 

fiscal years, i.e., $5,000,000 per year for FY 2010, FY 2011, and FY 2012, to expend the 

supplemental funding in a manner consistent with the statute. 

Maintaining Current Levels (MCLs) ........................................... +$1,285,000 / +0 FTE 

FERS % change +$9,000 / +0 FTE Funds are requested for the increase in agency retirement 

contribution percentages for GS employees from 11.2% to 11.5% for FY 2011 as required by 

OPM. 

Non-Pay Inflation Adjustment +$278,000 / +0 FTE SIGTARP anticipates reaching steady state 

(i.e., full staffing level, permanent office space, and most critical contracts in place) in the second 

quarter of FY 2010, and, thus, increases in non-personnel costs are largely expected to reflect 

inflationary pressures, as opposed to new contracting activity. 

Pay Annualization +$702,000 / +0 FTE Although FTEs do not increase in FY 2011, SIGTARP 

estimates being at steady state at the beginning of FY 2011. SIGTARP does not anticipate that it 
SIGTARP ‐ 11

will have completed its hiring efforts until after the conclusion of the second quarter of FY 2010; 

personnel costs in FY 2011 will be slightly higher on an annualized basis. 

Pay Inflation Adjustment +$296,000 / +0 FTE Funds are requested to mitigate the impact of the 

FY 2011 pay raise. 

Because SIGTARP is nascent organization, its capital expenditures, program launches, and 

hiring has occurred or will occur in FY 2009 and FY 2010. It is, thus, unlikely that capital items 

purchased will have exhausted their useful life and requires replacement or that programs will be 

discontinued as early as FY 2011. With respect to program increases, however, Treasury or 

Congress could expand the TARP. Such an action may prompt SIGTARP to adjust its mission 

requirements, but this is impossible to predict and, accordingly, SIGTARP has not integrated it 

into its projections. 
SIGTARP ‐ 12

2.2 – Operating Levels Table 

Dollars in Thousands 

 FY 2009 FY 2010 FY 2011 % Change 

 Enacted Enacted Requested FY 2010 

Bureau: Special Inspector General for TARP Level Level Level to FY 2011 

FTE 100 133 160 20% 

Object Classification: 

11.1 - Full-time permanent 11,500 14,200 19,600 38% 

11.3 - Other than Full-time permanent 

11.5 - Other Premium and Differential Pay 

11.6 - Overtime 

11.7 - Other Personnel Compensation 1,300 1,000 1,000 0% 

11.8 - Special Personal Services Payments 

12.0 - Personnel Benefits 4,200 4,100 5,300 29% 

21.0 - Transportation of Persons 2,300 3,200 

22.0 - Transportation of Things - 200 

23.0 Rents, Communications, Utilities and 2,100 2,300 

Miscellaneous Charges 

24.0 - Printing and Reproduction 300 300 

25.1 - Consulting Services 9,700 4,000 6,500 63% 

25.2 - Other Services 

25.3 - Purchase of Goods and Services from Other 7,300 6,900 

Government Accounts 

25.4 - Operation and Maintenance of Facilities 500 400 

25.7 - Operations and Maintenance of Equipment 600 300 

26.0 - Supplies and Materials 800 1,000 

31.0 Equipment 5,700 1,700 

32.1 Leasehold Improvements 3,000 500 

42.0 Insurance Claims and Indemnities 600 200 

91.0 Unvouchered Expenditures 100 - 200 

Subtotal Budget Authority 50,000 23,300 49,600 113% 

PPIP 15,000 

Mandatory Funding 65,000 

Discretionary Funding 23,300 49,600 113% 

Total Mandatory and Discretionary Funding4 65,000 23,300 49,600 113% 

Available no-year funds 20,100 

Available PPIP 5,000 5,000 

Total Budgetary Resources 65,000 48,400 54,600 13% 

Budget Activities: 

TARP Oversight 65,000 48,400 54,600 13% 

 Audit 27,900 20,700 23,200 12% 

 Investigations 37,100 27,700 31,400 13% 

Total Budget Authority 65,000 48,400 54,600 13% 

                                                           

4 The FY 2009 enacted level includes $50 million of no‐year funds provided by Public Law (P.L.) 110—343, the

Emergency Economic Stabilization Act of 2009 as amended, (EESA) and an additional $15 million of no‐year funds

made available pursuant to P. L. 111‐22, for a total of $65 million.  Carry‐forward funds in the amount of $20.1

million, provided by P.L. 110‐343, and $5 million provided by P.L. 111‐22, and the enacted FY 2010 budget of $23.3

million in direct appropriations, provided by P.L. 111‐117, will be used to fund the FY 2010 budget of $48.4 million.  

These amounts do not reflect an additional $10.2 available in carry‐forward from P.L. 110‐343.  The carry‐forward

from P.L. 111‐22 will be used to partially fund the FY 2011 and FY 2012 budget in the amount of $5 million each

year.
SIGTARP ‐ 13

2.3 – Appropriation Detail Table 

Dollars in Thousands 

 % Change 

 FY2009 FY2009 FY2010 FY2011 FY2010 

Resources Available for Obligation Obligations Enacted Enacted Request to FY2011 

 FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

Investigations 17 11,624 58 28,800 72 13,400 92 28,600 21% 113% 

Audit 12 8,002 42 21,200 61 9,900 68 21,000 19% 112% 

Mandatory Funding 29 19,626 

 

100 50,000 

Discretionary Funding 

 

133 23,300 

 

160 49,600 20% 113% 

Total Mandatory and Discretionary 

Funding5 29 19,626 

 

100 50,000 

 

133 23,300 

 

160 49,600 20% 113% 

Other Resources: 

 Available no-year funds 20,100 0.00% -100% 

 PPIP 0 0 0 15,000 0 5,000 0 5,000 0.00% 0% 

Subtotal Other Resources 0 0 0 15,000 0 25,100 0 5,000 0.00% -80% 

Total Resources Availabel for Obligation 29 19,626 

 

100 65,000 

 

133 48,400 

 

160 54,600 20% 13% 

                                                           

5 The FY 2009 enacted level includes $50 million of no‐year funds provided by Public Law (P.L.) 110—343, the

Emergency Economic Stabilization Act of 2009 as amended, (EESA) and an additional $15 million of no‐year funds

made available pursuant to P. L. 111‐22, for a total of $65 million.  Carry‐forward funds in the amount of $20.1

million, provided by P.L. 110‐343, and $5 million provided by P.L. 111‐22, and the enacted FY 2010 budget of $23.3

million in direct appropriations, provided by P.L. 111‐117, will be used to fund the FY 2010 budget of $48.4 million.  

These amounts do not reflect an additional $10.2 available in carry‐forward from P.L. 110‐343.  The carry‐forward

from P.L. 111‐22 will be used to partially fund the FY 2011 and FY 2012 budget in the amount of $5 million each

year.
SIGTARP ‐ 14

2B – Appropriation Language and Explanation of Changes 

Appropriations Language Explanation of Changes 

DEPARTMENT OF THE TREASURY 

SPECIAL INSPECTOR GENERAL FOR THE TROUBLED 

ASSET RELIEF PROGRAM 

Federal funds 

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), as 

amended, [$23,300,000]$49,600,000. (Consolidated 

Appropriations Act, 2010) 

2C – Legislative Proposals 

SIGTARP does not have any legislative proposals for FY 2011. 
SIGTARP ‐ 15

Section 3 – Budget and Performance Plan 

This table lists all FY 2011 resources by strategic goal, objective and outcome outlined in the FY 

2007-2011 Treasury Strategic Plan. The Treasury Strategic Plan is a corporate level plan for the 

Department that provides a description of what the agency intends to accomplish over the next 

five years. 

 For detailed information about the FY 2007-2011 Treasury Strategic Plan, please go to: 

http://www.treasury.gov/offices/management/budget/strategic_plan.shtml. 

3.1 – Budget by Strategic Outcome 

Dollars in Thousands 

Treasury Strategic Outcome FY2010 FY2011 Percent 

 Enacted Request Changes 

Effectively managing the U.S. Government's resources: 

 New appropriation6 23,300 49,600 112.9% 

 Available no-year 20,100 

 Available PPIP 5,000 5,000 

Total 48,400 54,600 13% 

3A – Audit ($21,000,000 from direct appropriations):

7

 AD conducts, supervises, and 

coordinates programmatic audits with respect to Treasury’s operation of TARP and the 

recipients’ compliance with their obligations under relevant law and contracts; evaluates TARP 

policies and procedures; and provides technical assistance to Treasury. 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 the fast-evolving TARP. For FY 2011, AD 

expects to initiate an average of five to seven audits per quarter. 

                                                           

6 The FY 2009 enacted level includes $50 million of no‐year funds provided by Public Law (P.L.) 110—343, the

Emergency Economic Stabilization Act of 2009 as amended, (EESA) and an additional $15 million of no‐year funds

made available pursuant to P. L. 111‐22, for a total of $65 million.  The remaining carry‐forward in addition to the

enacted FY 2010 budget of $23.3 million in direct appropriations, provided by P.L. 111‐117, will be used to fund the

FY 2010 budget of $48.4 million.  Additionally, the carry‐forward from P.L. 111‐22 will be used to partially fund the

FY 2011 and FY 2012 budget.

7

In addition to the SIG and his central office staff (CO), SIGTARP is comprised of the AD, the ID, the Operations 

Division (OD), and the Division of Chief Counsel (DCC). The basic statutory mission of SIGTARP (i.e., audit and 

investigation) is largely carried out by AD and ID. The CO, OD, and DCC lend support AD and ID as they fulfill the 

mission.
SIGTARP ‐ 16

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

appropriate internal controls are in place and are complied with, both 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 are found ineffective at reaching TARP’s goals, AD assists the SIG 

to fashion recommendations to resolve such issues. 

3.2.1 – Audit Budget and Performance Plan 

Audit Budget Activity 

 FY 2007 FY2008 FY2009 FY2010 FY2011 

Resource Level Obligated Obligated Obligated Enacted Request 

Appropriated Resources n/a n/a n/a 9,900 21,000 

Available no-year 8,002 10,800 2,200 

Total Resources n/a n/a 8,002 20,700 23,200 

Budget Activity Total n/a n/a 8,002 20,700 23,200 

Audit Budget Activity FY 2007 FY2008 FY2009 FY2010 FY2011 

Measure Actual Actual Actual Target Target 

Number of completed audit products (Ot) n/a n/a 3 12 16 

Percent of recommendations implemented (%) (Oe) n/a n/a 100 70 70 

Congressional requests for testimony completed (Ot) n/a n/a 9 4 4 

Key: Oe- Outcome Measure, E - Efficiency Measure, Ot - Output/Workload Measure 

Description of Performance: As discussed in section 1B, AD issued three audit reports and 

initiated 13 audits. 

AD also prolifically reviewed TARP policies and procedures. SIGTARP’s March 6th and April 

21st reports to Congress (see http://www.sigtarp.gov/reports.shtml) detail the results of these 

reviews and re-print the recommendations. Among the policies that SIGTARP reviewed and 

commented upon are TARP agreements, the TALF, Public-Private Investment Program (PPIP), 

Capital Assistance Program, and Making Home Affordable programs. For example, with respect 

to: 

• TARP Agreements: SIGTARP recommended that Treasury require program participants to 

use best efforts to account for their use of TARP funds and to report periodically to Treasury 

concerning such use. (See February report at page 97 from the above website link.) 

Treasury has not fully implemented this recommendation, for among other reasons, because 

financial assistance is “fungible.” SIGTARP is testing Treasury’s response with an audit that 

includes a survey of 364 financial institutions’ use of TARP assistance. The audit is not yet 

complete, and the survey responses need to be fully analyzed, but one thing is clear: 

arguments to the effect that the inherent fungibility of money makes accounting for the use of 
SIGTARP ‐ 17

TARP funds impossible or impractical is unfounded. Many of the 364 financial institutions 

generally provided a reasonable level of detail regarding their use of TARP funds. 

• Public Private Investment Program (PPIP): SIGTARP recommended, among other things, 

that Treasury impose conflict of interest rules on PPIP fund managers, require PPIP fund 

managers to screen and identify investors, and mandate that PPIP fund managers 

acknowledge that they owe a fiduciary duty to the taxpayer. SIGTARP also recommended 

that Treasury clarify SIGTARP’s right of access to all PPIP books and records. Senate 

Amendment 1043 to Senate Bill No. 896, which passed the Senate by a unanimous vote and 

was later enacted in P.L. 111-22, essentially incorporated these recommendations. 

3B – Investigation ($28,600,000 from direct appropriations): 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. The division is comprised of experienced 

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

analysts and, critically, attorney advisors. This structure provides SIGTARP with a broad array 

of expertise and perspectives in developing even 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 to leverage SIGTARP’s expertise and unique 

position. For FY 2011, although it is difficult to forecast for a variety of reasons, SIGTARP 

anticipates opening 75 investigations. 

ID also implements SIGTARP’s Hotline, which accepts and processes telephone, e-mail, 

website, and in-person complaints. The Hotline is administered in a manner designed to ensure 

conformity with all applicable whistleblower protections. 
SIGTARP ‐ 18

3.2.2 – Investigation Budget and Performance Plan 

Investigations Budget Activity 

 FY 2007 FY2008 FY2009 FY2010 FY2011 

Resource Level Obligated Obligated Obligated Enacted Request 

 

Appropriated Resources n/a n/a n/a 13,400 28,600 

 

Available no-year 11,624 14,300 2,800 

Total Resources n/a n/a 

 

11,624 

 

27,700 

 

31,400 

Budget Activity Total n/a n/a 

 

11,624 

 

27,700 

 

31,400 

Investigations Budget Activity FY 2007 FY2008 FY2009 FY2010 FY2011 

Measure Actual Actual Actual Target Target 

Percentage of investigations accepted by prosecutors (%) (Oe) n/a n/a 95 50 55 

Percentage of "preliminary investigations" that are converted to "full" 

investigations (%) (Oe) n/a n/a 50 35 40 

Percentage of all cases that are joint agency/task force investigations 

(%) (Oe) n/a n/a 60 30 35 

Percentage of Hotline complaints referred for investigation or to OFS 

within 14 days of receipt (%) (E) n/a n/a 77 60 65 

Key: Oe- Outcome Measure, E - Efficiency Measure, Ot - Output/Workload Measure 

Description of Performance: ID has opened over 77 investigations and closed nine as of January 

4, 2010. Specific case results are discussed in section 1B. Additionally, as of December 31, 

2009, SIGTARP had processed well over 9,900 Hotline contacts. 
SIGTARP ‐ 19

Section 4 – Supporting Materials 

4A – Human Capital Strategy Description 

The SIGTARP’s strategic management of human capital is consistent with its mission, vision 

and priorities and supports Treasury’s strategic goal of managing the U.S. Government’s 

finances as they relate to the TARP program effectively. SIGTARP projects that it will reach 

steady state (i.e., full staffing level, permanent office space, and most critical contracts in place) 

in the second quarter of FY 2010. Moreover, SIGTARP, pursuant to section 121(k) of EESA, as 

amended, is a temporary organization that is scheduled to cease operations on the date that the 

last troubled asset is disposed or the last guarantee contract expires, whichever is later. 

Accordingly, SIGTARP does not foresee that it will confront human capital challenges in FY 

2011. 

4.1 – Summary of IT Resources Table 

Dollars in Thousands 

Information Technology Investments 

 FY 2008 FY2009 % Change FY2010 % Change FY2011 % Change 

 & Earlier from FY08 from FY09 

From 

FY10 

Major IT investments/Funding Source Enacted 1/ Enacted to FY09 Enacted to FY10 Request to FY11 

Audit/Investigations n/a 1,680 n/a 1,726 2.7% 1,133 -34% 

Subtotal Major IT Investments 1,680 n/a 1,726 2.7% 1,133 -34% 

Non-Major IT Investments 

Continuing Operating Costs s/a 354 n/a 359 1.5% 243 -32% 

Subtotal Non-Major Investments 354 n/a 359 1.5% 243 -32% 

Infrastructure Investments 1,590 n/a 318 -80.0% 318 0% 

Enterprise Architecture n/a 0 n/a 0 n/a 0 n/a 

Total IT Investments n/a 3,624 n/a 2,403 -33.7% 1,694 -30% 

1/ The Agency was created in FY2009 and has no prior year activity. 
SIGTARP ‐ 20

4B – Information Technology (IT) Strategy 

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

coordinated oversight, and robust enforcement. Presently, SIGTARP is in the midst of building 

an infrastructure that is fully capable of supporting the mission and administrative requirements 

of a fully-operational government agency with the technology security requirements appropriate 

to an audit and investigative organization. The major IT investments are for acquisition, 

installation, integration and training for mission systems such as hotline information 

management, investigative management, audit management, and electronic storage and for 

administrative systems such as records management, document management, content 

management, asset management and training management which are not normally provided by 

shared services operations. A steady state of IT expenditures is expected to be achieved in FY 

2011, and since SIGTARP is a temporary agency, only maintenance and routine enhancements 

and modifications are required on an ongoing basis thereafter. 

The significant infrastructure investments reflected in FY 2009 and FY 2010 support the 

complete build-out of SIGTARP’s facility, including infrastructure planning and installation of 

cabling to desktops, computer room, telephone room, data storage room, wireless antenna 

system, additional cooling and backup power and all of the connections required to connect to 

one or more external voice and data providers. After these initial start-up years, funds are 

budgeted for standard upgrades in capacity and functionality and for remote office operations. 

Accordingly, SIGTARP’s IT strategy is currently being finalized, and refreshment needs are not 

expected to arise until FY 2012. For FY 2011, SIGTARP anticipates only minor IT 

modifications and additions designed to improve security and streamline procedures.