Financial Stability Oversight Council: Status of Efforts to Improve Transparency, Accountability, and Collaboration
Published: 2014-09-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The 2007-2009 financial crisis focused attention on weaknesses in the U.S. regulatory structure, including the lack of an agency or mechanism responsible for monitoring and addressing risks across the financial system. To address this weakness, the Dodd-Frank Wall Street Reform and Consumer Protection Act created FSOC to identify and address threats to financial stability. Among other statutorily defined authorities, FSOC may designate nonbank financial companies for heightened supervision by the Board of Governors of the Federal Reserve System. FSOC consists of 10 voting members and 5 nonvoting members. The 10 voting members include 9 federal regulators and an independent insurance expert.
In September 2012, GAO issued a report on FSOC's challenges, efforts to establish management mechanisms, activities for supporting collaboration among its members and external stakeholders, and processes for issuing reports and rules. GAO made nine recommendations to FSOC to improve the transparency and accountability of its decisionmaking, among other things.
This testimony is based on GAO's September 2012 report ( GAO-12-886 ). It discusses FSOC's efforts to respond to GAO's 2012 recommendations. From June through September 2014, GAO obtained updated information from FSOC staff and reviewed documents related to GAO's recommendations.
section_title: What GAO Found
paragraphs: The Financial Stability Oversight Council's (FSOC) has taken steps to address some of GAO's September 2012 recommendations, but additional efforts are needed. GAO made nine recommendations to FSOC in three areas: emerging threats and risks identification, transparency and accountability, and collaboration and coordination. GAO recommended, among other things, that FSOC:
develop a systematic approach that includes collecting and sharing key financial risk indicators to help identify potential threats to financial stability;
develop a strategy to improve communications with the public;
keep detailed records of closed-door sessions;
create a framework for assessing the impact of its decisions to designate nonbanks for enhanced supervision;
develop policies to clarify when collaboration or coordination should occur;
adopt leading practices, such as joint strategies, for collaboration; and
clarify roles and responsibilities for monitoring threats to the financial system.
FSOC still lacks a comprehensive, systematic approach to identify emerging threats to financial stability. In 2012, GAO reported that FSOC's approach might not help identify new risks or threats that member agencies had not already identified. The Office of Financial Research (OFR) has made some progress in developing data tools to support FSOC since the 2012 report, but GAO's observations of two of these tools suggest that one tool does not focus on risks to the financial system, while another remains in a prototype phase.
FSOC has taken steps to improve its communication with the public but could do more to improve transparency and accountability. In May 2014, FSOC approved a revised transparency policy, and FSOC staff said they had attempted to provide more information in the minutes of meetings. But FSOC staff said that they did not intend to keep detailed minutes because of the confidential information discussed. Also, FSOC staff also said that the impact of designating nonbanks for enhanced supervision would be assessed as part of a mandated January 2016 study. However, FSOC has not begun to prepare for this study. GAO has reported on the importance of advance planning for retrospective studies so that needed data are collected.
FSOC has taken steps to improve collaboration and coordination among member agencies but does not plan to act on some of GAO's recommendations on coordination. In May 2014, FSOC approved one formal mechanism that supported coordination—bylaws for the Deputies Committee of senior officials from member agencies that describe its role in coordinating FSOC activities. FSOC staff said they did not plan to clarify the roles and responsibilities of FSOC, OFR, and member agencies because the overlapping responsibilities for monitoring systemic risk had not been problematic. Officials also said that FSOC would not adopt practices to coordinate rulemaking across member agencies, as it does not have the authority to direct independent agencies. GAO maintains that action is needed as its past work has shown that the lack of clear roles and coordination can lead to duplication, confusion, and regulatory gaps.

section_title: Letter
paragraphs: Thank you for the opportunity to be here today to discuss the Financial  Stability Oversight Council (FSOC). As you know, the 2007-2009 financial  crisis focused attention on weaknesses in the U.S. regulatory structure,  including the lack of an agency or mechanism responsible for monitoring  and addressing risks across the financial system and a shortage of timely  information to facilitate that oversight. In response to the crisis, in 2010  Congress passed the Dodd-Frank Wall Street Reform and Consumer  Protection Act (Dodd-Frank Act), which provided for a broad range of  regulatory reforms. Among other things, the act established FSOC to  monitor the stability of the U.S. financial system and take actions to  mitigate risks that might destabilize the system. The Dodd-Frank Act also  created the Office of Financial Research (OFR), in part, to support FSOC  by providing financial research and data. Congress gave FSOC a  number of significant authorities to help it execute its broad mission,  including designating nonbank financial companies for heightened  supervision by the Board of Governors of the Federal Reserve System  (Federal Reserve).
My remarks are based on our September 2012 report on FSOC and OFR  and updates conducted from June through September 2014. Specifically, in our 2012 report we reviewed FSOC’s challenges in achieving its  mission, efforts to establish management mechanisms, activities for  supporting collaboration among their members and external stakeholders,  and its processes for issuing reports and rules and made nine  recommendations to FSOC for improving its ability to identify systemic  risk and emerging threats, its transparency and accountability, and  collaboration and coordination across members and member agencies.In my comments today, I will discuss FSOC’s progress in addressing  these recommendations.
GAO, Internal Control: Standards for Internal Control in the Federal Government,  GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999); and Internal Control  Standards: Internal Control Management and Evaluation Tool, GAO-01-1008G  (Washington, D.C.: August 2001) and GAO, Millennium Challenge Corporation: Progress  Made on Key Challenges in First Year of Operations, GAO-05-625T (Washington, D.C.:  Apr. 27, 2005) and Troubled Asset Relief Program: Additional Actions Needed to Better  Ensure Integrity, Accountability, and Transparency, GAO-09-161 (Washington, D.C.: Dec.  2, 2008). our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: FSOC has 10 voting and 5 nonvoting members (fig. 1). The 10 voting  members include 9 federal regulators and an independent insurance  expert. The five nonvoting members include representatives from state  bank, securities, and insurance regulators and the directors of OFR and  the Federal Insurance Office. As the chairperson of FSOC, the Secretary  of the Treasury has certain powers and responsibilities related to FSOC’s  meetings, rulemakings, recommendations, and reports and testimony to  Congress. The Secretary, in consultation with the other FSOC members,  is also responsible for regular consultation with the financial regulatory  entities and other appropriate organizations of foreign governments or  international organizations. To help carry out the council’s business,  FSOC has established seven standing committees that are generally  composed of staff of FSOC members and member agencies.
The Dodd-Frank Act established OFR to serve FSOC and its member  agencies by improving the quality, transparency, and accessibility of  financial data and information; conducting and sponsoring research  related to financial stability; and promoting best practices in risk  management. The act requires OFR to perform applied and essential long-term research; develop tools for risk measurement and monitoring; and make the results of its activities available to financial regulatory  collect and provide data to FSOC and member agencies;  standardize the types and formats of data reported and collected;  agencies.
To help achieve these goals, the OFR must set up a data center and a  research and analysis center.
section_title: FSOC Has Made Some Progress in Responding to GAO’s 2012 Recommendations
paragraphs: FSOC has taken steps to address some of our recommendations, such  as those related to communication. However, it needs to take further  action to fully address all of our recommendations.
subsections: section_title: Monitoring Systemic Risks and Identifying Emerging Threats
paragraphs: In September 2012, we made two recommendations to FSOC that were  designed to improve its efforts to identify and report on sources of  systemic risk and emerging threats to financial stability. First, we  recommended that FSOC develop an approach that included systematic  sharing of key financial risk indicators across FSOC members and  member agencies to assist in identifying potential threats for further  monitoring or analysis. We reported that FSOC had taken steps to meet  its statutory responsibilities related to identifying risks and potential  emerging threats to U.S. financial stability, including by setting up a  Systemic Risk Committee—one of the seven standing FSOC  committees—that is responsible for systemic risk monitoring and plays a  key role in reviewing sources of systemic risk. The committee primarily  relies on an approach that begins with suggestions from member agency  staff of risks or threats that, in their view, may benefit from interagency  coordination. As we noted in 2012 this approach may facilitate analysis of  risks that could benefit from interagency discussions and responses, but  may not help to identify new risks or threats that FSOC member agencies  have not already identified on their own.
OFR participates in the Systemic Risk Committee and, since the  publication of our 2012 report, has developed a tool known as the  Markets Monitor, which provides an update on financial and economic  developments, that OFR presents at each meeting of the committee. OFR  also continues to develop a Financial Stability Monitor for assessing  vulnerabilities in the financial system, which it first presented publicly in its  2013 Annual Report. However, the Markets Monitor does not appear to  be focused on risks to the financial system, and the Financial Stability  Monitor remains in a prototype phase—and neither yet reflect the  systematic sharing of key financial risk indicators to assist in identifying  potential threats to financial stability. OFR’s continued work to develop  indicator-driven tools to assess risks to the financial system is  encouraging, but without a more systematic approach and  comprehensive information, FSOC cannot be assured that it is fully  informed about critical vulnerabilities in the financial system.
Second, in 2012 we recommended that FSOC develop more systematic,  forward-looking approaches that would help in separating emerging  threats to financial stability from more current risks and prioritizing them in  its annual report. Since then, FSOC made some progress in addressing  this recommendation but could do more. When we last reviewed the  emerging threats identified in FSOC’s annual report in 2012, FSOC had  not developed a structure that supported having a systematic or  comprehensive process for identifying and separating them from other  risks. Further, FSOC had identified a large number of threats without  explicitly prioritizing them. In contrast, other entities, such as the  International Monetary Fund and European Central Bank, have issued  reports that explicitly prioritized potentially significant threats.
Since our 2012 report, however, the ongoing work of the Systemic Risk  Committee has become more tightly integrated into FSOC’s annual  reports according to FSOC officials. FSOC officials told us that the  Systemic Risk Committee’s efforts to identify and monitor threats to  financial stability now served as a basis for the annual report. However,  as noted previously, despite some new contributions from OFR, the work  of the Systemic Risk Committee is not yet driven by a systematic and  comprehensive approach. Instead, FSOC continues to rely on member  agency staff to suggest various threats. Although FSOC staff  distinguished between current known risks and potentially emerging  threats to financial stability, the two are not clearly distinguished in the  2014 FSOC Annual Report. For example, the first threat identified in the  2014 Annual Report was the risk posed by financial institutions’ reliance  on short-term financing—a risk that had been identified for some time.  Moreover, FSOC staff told us that they had not and did not plan to  prioritize the threats they identified in the annual reports. FSOC staff said  that prioritization could detract attention and resources from some of the  identified threats. Until FSOC improves its processes for identifying and  prioritizing potential emerging threats to financial stability in its annual  reports, policymakers and market participants will not have the  information they need to develop effective and timely responses to those  threats.
section_title: Transparency and Accountability
paragraphs: Although FSOC had adopted communication methods to provide  information on their activities to the public and taken steps to be  transparent and accountable, we reported in 2012 that some of these  efforts could be strengthened and made four recommendations. FSOC  should develop a communication strategy to improve communications with  the public;  keep detailed records of closed door sessions of principals meetings  and to the extent possible make them publicly available after an  amount of time has passed; make recommendations in its annual report more specific by  identifying which member agency or agencies, as appropriate, are  recommended to monitor or implement such actions within specified  time frames; and establish a collaborative and comprehensive framework for assessing  the impact of decisions for designating financial market utilities (FMU)  and nonbank financial companies on those entities and the wider  economy.
subsections: section_title: Communication Strategy
paragraphs: In our 2012 report, we noted that FSOC had not taken full advantage of  modern communication tools to provide information about its activities  and its website did not provide a mechanism for the public to receive  updates about the council’s activities and decisions. In May 2014, FSOC  updated its transparency policy. FSOC staff said that this effort was the  result of a review of other entities’ governance practices and that the  policy reflected a commitment to improve communication with the public.  For example, the council will now publicly announce its meetings at least  seven days in advance of the meeting and will have a live web stream of  its open meetings. In addition, FSOC staff said the decision to provide  summaries of the meetings as soon as practicable afterwards was an  effort to provide information in a timelier manner. Prior to the change to  providing these summaries, the public would have to wait until the next  FSOC meeting when the minutes were approved for the prior meeting.  FSOC staff said that they have worked to make sure the website is  updated more frequently, such as posting minutes soon after the council  approves them. In addition, the website now offers the public the ability to  sign up for email updates.
section_title: Detailed Record Keeping
paragraphs: In our 2012 report, we found that FSOC did not keep detailed records of  deliberations or discussions at the council’s meetings or at the committee  level. FSOC has said it will provide more information in its minutes but  has also argued that some of the information discussed is protected. No  specific level of detail is required for FSOC minutes, but the limited  documentation of their discussions has made it difficult to assess FSOC’s  performance. For instance, we reported in 2012 that the minutes typically  described agenda items for the meetings and information on the  presenters but lacked additional detail even if the information being  discussed was not likely to be market sensitive or if disclosing it would not  affect the deliberations. As a result, the minutes provided the public with  little information about FSOC’s activities and deliberations.
FSOC staff indicated that the council had been trying to include more  detail in its minutes since October 2013. In July 2014, the Council of  Inspectors General on Financial Oversight audited FSOC’s compliance  with its transparency policy and recommended that the council continue  its efforts to provide greater detail in the meeting minutes for closed  sessions. For example, it specifically noted that FSOC could have  provided more information than it did about a presentation on housing  finance rules from its December 2013 meeting because the rules were  final. In 2012, we reported that similar bodies, such as the Federal Open  Market Committee, publish minutes that provide greater detail and  voluntarily release transcriptions of their meetings 5 years after a meeting  occurs. FSOC staff recognized the need for transparency but also noted  that certain information was protected from disclosure under various  statutes and could not be released. They noted more recently that  discussions often touched on confidential information, some of which  would remain sensitive for long periods of time. However, even if FSOC  determines that some information should not be made public, its current  practices do not provide detailed records even for policymakers, including  members of FSOC, to assess decisions.
section_title: Accountability in Annual Report Recommendations
paragraphs: FSOC’s annual reports serve as a key accountability document. FSOC  staff noted that FSOC’s annual reports provided Congress and the public  with a description of FSOC’s activities, its views on potential emerging  threats to U.S. financial stability, and recommendations to enhance the  integrity, efficiency, competitiveness, and stability of U.S. financial  markets. However, in 2012 we found that the annual reports did not  consistently designate an FSOC member or members to monitor or  implement the recommendations or establish time frames for certain  actions, such as reporting to the council on the status of  recommendations. Without such detail, we noted, it is difficult to hold  FSOC or the responsible member agency accountable for progress in  implementing the prescribed recommendation(s).
In March 2013, Treasury officials told us that FSOC had begun to develop  a process for the 2013 annual report and that our recommendations were  provided to the team assigned to pull together the annual report for  consideration. In June 2014, they told us that they had identified  responsible agencies or others for certain recommendations in its most  recent reports, as appropriate. In September 2014, FSOC staff explained  that staff supporting the Systemic Risk Committee were monitoring  progress and actions related to the annual report recommendations and  providing updates on previous recommendations in the following year’s  annual report. We found that the 2014 annual report reflected progress in  identifying member agencies that would address certain  recommendations compared to the 2012 report. However, several  recommendations continue to include specific actions without identifying  an agency or agencies responsible for them. For example, the council  recommends developing a plan to implement a smooth transition to any  new interest rate benchmarks—rates such as the London Interbank  Offered Rate (LIBOR), which are the basis for hundreds of trillions of  dollars in financial contracts—but does not identify any specific member  agencies or others who would develop the plan. We continue to believe  that FSOC should hold responsible parties accountable for its  recommendations and identify them in its annual report as appropriate.
section_title: Framework for Assessing Designation Decisions
paragraphs: The Dodd-Frank Act also subjects large bank holding companies with total consolidated  assets of $50 billion or more to enhanced supervision and prudential standards. No FSOC  designation is required for these bank holding companies to be subjected to enhanced  supervision and standards. In addition, some potential nonbank holding companies that  may be designated are already subject to some Federal Reserve oversight because they  are thrift holding companies. The Dodd-Frank Act transferred the oversight of these  companies from the Office of Thrift Supervision to the Federal Reserve. interconnectedness, or mix of the company’s activities could pose a threat  to U.S. financial stability. In our September 2012 report, we  recommended that FSOC develop a comprehensive framework for  assessing the impact of its designation decisions. While FSOC has done  some limited reviews, it has not planned for a comprehensive review that  would provide a broad picture of the impact of designating these firms.
To date, FSOC has designated eight FMUs and three nonbank financial  companies. On September 4, 2014, it announced that it proposed to  designate another nonbank financial company. The designations were  intended to address certain risks that these entities posed to financial  stability and have the potential to confer other benefits and costs on the  wider economy (as well as on the designees). We noted in our March  2013 testimony that FSOC had some limited processes in place to review  its designations of nonbank financial companies, including an annual  review and a review of the stage one thresholds stated in dollar terms at   FSOC reported that at its July 31, 2014, meeting, it  least every 5 years.held a discussion that included an annual review of two nonbank financial  companies designated in July 2013: American International Group, Inc.  and General Electric Capital Corporation. The council did not rescind  either company’s designation. However, we also had noted in our 2013  testimony that FSOC had not set up processes to conduct a  comprehensive assessment of the overall impact of the designations and  to determine whether they were achieving the intended result.
We recognize that doing a comprehensive analysis to assess whether  designations are having their intended impact of providing greater  financial stability and the extent of any other impacts will be challenging.  For example, establishing a baseline from which to evaluate the overall  impact of the designations will likely be complex because the impact will  depend on the application of a number of rules being written by multiple  independent regulatory agencies—the Commodity Futures Trading  Commission, Federal Deposit Insurance Corporation, the Federal  Reserve, and Securities and Exchange Commission—and issued over a  span of time.challenges associated with such an analysis. FSOC is responsible for  designating FMUs and nonbank financial companies, and its member  agencies are responsible for writing the rules that will impact these  designated entities. Moreover, FSOC with OFR’s help has already  collected information on both designated and other companies that could  help in creating a baseline. FSOC could also continue to rely on OFR for  some further data collection and analysis. But without a comprehensive  assessment, decision makers may not have the information they need to  determine whether designating new entities for enhanced supervision and  other requirements and restrictions is addressing a perceived gap in the  regulatory system and improving the financial system’s stability or  whether policy changes should be considered.
However, FSOC is uniquely positioned to address  According to FSOC staff, the recurring study required under Section 123  of the Dodd-Frank Act (next required no later than January 2016) is the  appropriate mechanism for evaluating the overall impact of the  designations process. Section 123 requires FSOC’s Chairperson to carry  out a study of the economic impact of possible financial services  regulatory limitations on financial institutions that are intended to reduce  systemic risk. According to the act, such a study should estimate the  benefits and costs on the efficiency of capital markets, on the financial  sector, and on national economic growth of limitations on the activities or  structures of financial institutions that may be useful to limit systemic risk,  such as limits on the organizational complexity and diversification of large  financial institutions. FSOC staff said that they had not begun planning for  a study and did not know when planning for it would begin. We noted in  our 2012 report that such an evaluation would require collaboration  among several members of FSOC and emphasized the importance of  advance planning for retrospective studies so that needed data are  collected. We have ongoing work examining FSOC’s designation  process, including the data collection, analyses, and criteria used in  making determinations. We plan to issue this report later this fall.
section_title: Collaboration and Coordination
paragraphs: In our September 2012 report, we also made three recommendations to  improve FSOC’s collaboration and coordination. Title I of the Dodd-Frank  Act directs FSOC to facilitate information sharing and coordination among  its member agencies and other federal and state agencies regarding  domestic financial services policy development, rulemaking,  examinations, reporting requirements, and enforcement actions. The  Dodd-Frank Act encourages collaboration between FSOC and external  stakeholders, especially state regulators and international entities.
However, we found FSOC could do more to promote collaboration and  coordination. We recommended that it establish formal collaboration and  coordination policies that clarify issues such as when collaboration or  coordination should occur and FSOC’s role in facilitating that  coordination. In October 2010, FSOC issued an integrated  implementation road map for the Dodd-Frank Act that included a list of  the rules regulators were required to promulgate, provided a time line for  those rulemakings, and identified the agencies responsible for each one.  FSOC has also developed a consultation framework for the agencies  involved in rulemakings. In a November 2011 report, we noted that  although FSOC’s road map and consultation framework were a positive  development in facilitating coordination, they had limited usefulness. example, the consultation framework does not provide any specifics  about staff responsibilities or processes to facilitate coordination, and  according to FSOC staff, it is not intended to provide such information. It  also does not describe when interagency coordination is required or what  happens when rules conflict with or duplicate each other.
GAO-12-151. us that FSOC has an ongoing effort to develop charters for the other  committees that serve the council. The Deputies Committee’s bylaws and  the ongoing effort to review FSOC’s governance structures are positive  developments in providing additional clarification on the roles and  responsibilities of FSOC committees. We will continue to monitor these  efforts and the extent to which they clarify coordination and collaboration  across member agencies.
Similarly, in our September 2012 report, we recommended that FSOC  more fully incorporate key practices for successful collaboration that we  have previously identified, which could include working jointly with  agencies to coordinate schedules for rulemakings, conduct collaborative  systemwide stress tests, or create external advisory committees. FSOC  staff told us that the statute did not give FSOC the authority to direct  actions of individual members including requiring members to coordinate  rulemakings.  While we understand the sensitivity to respecting members’  independence, we maintain that additional collaboration practices can be  adopted without impinging on the regulators’ independence. Further,  although the Dodd-Frank Act gave FSOC a certain statutory exemption to  encourage the development of external advisory committees that could  include industry representatives, academics, and state regulators, it has  not formed any such committees. However, over the last year, FSOC has  reached out to external stakeholders in some other ways. In May 2014,  FSOC held a public conference on the asset management industry and  its activities, at which they solicited input from the industry and other  stakeholders, including academics and public interest groups. FSOC staff  at Treasury also told us in June 2014 that a banker had briefed FSOC  principals on cybersecurity issues.
Finally, we recommended in our September 2012 report that FSOC and  OFR clarify responsibility for implementing requirements to monitor  threats to financial stability across FSOC and OFR, including among  FSOC members and member agencies. As noted earlier, FSOC is tasked  with monitoring the financial services marketplace to identify potential  threats to U.S. financial stability, and OFR’s Research and Analysis  Center must develop and maintain metrics and reporting systems for risks  to U.S. financial stability as well as monitor, investigate, and report on  changes in systemwide risk levels. The Dodd-Frank Act defines certain  responsibilities for FSOC and OFR, but the lack of clear responsibility for  implementation can lead to duplication, confusion, and gaps in their  efforts. This risk is further compounded by the fact that many FSOC  member agencies have risk analysis and data collection functions  associated with their supervisory responsibilities. Some of these functions  are explicitly focused on risks to financial stability, and some member  agencies have created their own programs to examine them. To the  extent that these programs provide unique information to FSOC, they will  be contributing to the overall effort. However, if not properly coordinated,  these separate efforts could be less effective and duplicative, resulting in  wasted time and resources.
FSOC staff told us that FSOC and OFR work well together and that there  was no need to make formal distinctions when both entities were  statutorily required to monitor risks to financial stability. They also stated  that though some overlap existed in the roles of the council and member  agencies in terms of overseeing threats to financial stability, the council  provided a forum for sharing and working together on these issues. We  maintain that actions to address these recommendations are needed. Our  past work has shown that the lack of clear roles and coordination can  lead to duplication, confusion, and regulatory gaps. We have ongoing  work reviewing duplication, overlap, and fragmentation in the financial  regulatory structure and as part of that work will be reviewing the various  roles and responsibilities of federal agencies that oversee risks to  financial stability.
In conclusion, FSOC has worked to establish accountability and  transparency mechanisms and promote collaboration among FSOC  members and with external stakeholders. However, further efforts  continue to be needed, including fully implementing our September 2012  recommendations. Fully addressing our recommendations will help shed  more light on FSOC’s decision making and activities and allow Congress  to hold the council accountable for results. Addressing our  recommendations can also help FSOC enhance collaboration among its  members and with external stakeholders that are critical to their ability to  achieve their missions. We will continue to monitor FSOC’s progress in  implementing our recommendations and stand ready to assist Congress  as it continues its oversight of these entities.
Chairman McHenry, Ranking Member Green, and Members of the  Subcommittee, this completes my prepared statement. I would be  pleased to respond to any questions that you may have at this time.
section_title: GAO Contact and Staff Acknowledgements
paragraphs: For questions regarding this testimony, please contact A. Nicole Clowers  at (202) 512-8678 or clowersa@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Other individuals who made key contributions to this  testimony statement include Kay Kuhlman (Assistant Director), Nancy  Barry, Emily Chalmers, and Michael Hoffman.
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