Federal Reserve System: Update on GAO's 1996 Recommendations
Published: 2002-09-25T00:00:00

Fast Facts:

Highlights:
section_title: What GAO Found
paragraphs: In a 1996 report, GAO made a number of recommendations to the Board of Governors of the Federal Reserve System for reducing spending and improving the operations of the Federal Reserve System (Federal Reserve). The Federal Reserve has taken actions responsive to most of the 1996 report's recommendations. The Federal Reserve has retained its structure but has sought to consolidate operations and bring common management practices to the 12 Federal Reserve District Banks. In particular, the Federal Reserve now manages the payment services it provides to banks on a systemwide basis. The Federal Reserve has also changed its budgeting, internal oversight, and cost accounting processes in an effort to increase accountability. It has taken other steps to decrease costs in areas identified by the 1996 report. Specifically, the Reserve Banks have consolidated their purchase of some services, such as prescription drug coverage, to take advantage of volume discounts, rather than continuing with the former practice of each individual Reserve Bank purchasing services separately. The Federal Reserve, however, continues not charging for bank examinations. Federal Reserve officials explained that they continue to believe that charging for bank examinations would tip the current balance against state charter banks, and thus be inconsistent with maintaining the dual banking system of state and nationally charter banks. Although a strong argument exists for industry funding of federal supervision and regulation, GAO recognizes the benefits of the dual banking system. Ultimately, it is up to Congress to decide how to fund federal regulation and to balance the differences among the different bank regulators.

section_title: Letter
paragraphs: Our June 1996, report, which we prepared at your request, made a number  of recommendations to the Board of Governors of the Federal Reserve  System (the Board) for reducing spending and improving the operations of  the Federal Reserve System (Federal Reserve). This report responds to  your request that we review the status of the Federal Reserve’s response to  our recommendations, which fall into four broad categories: (1)  systemwide mission and management issues, (2) control and oversight  mechanisms, (3) administrative functions, and (4) funding the cost of bank  examinations. For each category, we briefly review the report’s findings  and recommendations and then describe related actions taken by the  Federal Reserve following publication of the 1996 report.
The 1996 report also made a recommendation regarding the Federal  Reserve’s practice of maintaining a surplus account to protect the Federal  Reserve from losses. We address this issue in a separate report.
subsections: section_title: Background
paragraphs: The Federal Reserve Act of 1913 established the Federal Reserve System as  the country’s central bank. The act made the Federal Reserve an  independent, decentralized bank to better ensure that monetary policy  would be based on a broad economic perspective from all regions of the  country. The Federal Reserve System consists of the Board of Governors  located in Washington, D.C., and 12 Reserve Banks, with 25 branches,  located throughout the nation.
Each Reserve Bank is a federally chartered corporation with a Board of  Directors representing the public and member banks in its district. Under  the Federal Reserve Act, Reserve Banks are subject to the general  supervision of the Board. The Board is a federal agency, responsible for  maintaining the stability of financial markets, supervising financial and  bank holding companies and state-chartered banks that are members of the  Federal Reserve and the U.S. operations of foreign banking organizations,  and overseeing the operations of the Reserve Banks. The Board has  delegated some of these responsibilities, including bank examinations, to  the Reserve Banks, which also provide payment services, such as check  clearing and wire transfers, to depository institutions and government  agencies.
In 2001, there were approximately 25,000 staff in the Federal Reserve with  about 93 percent of these employees working at the Reserve Banks. From  1995 to 2001, Federal Reserve employment decreased by 482 employees.  Employment for 2002 is projected to grow by 314, largely because of plans  to increase security staff. Figure 1 shows Federal Reserve employment  from 1995 to 2001.
In the 1996 report, we noted that the Federal Reserve is self-financed, and  that the income it collects but does not use to fund its operations is turned  over to the U.S. Treasury.  In 2001, the Federal Reserve had a total income  of $31.9 billion and expenses of approximately $2.1 billion; it subsequently  transferred $27.1 billion to the U.S. Treasury.
Since 1993, the operating expenses of the Federal Reserve have increased  an average of 4.2 percent per year (2.2 percent when adjusted for inflation).  According to its 2002 Budget Review, the Federal Reserve’s operating  expenses are budgeted at $2.8 billion, an increase of 4.5 percent from the  estimated 2001 expenses. Figure 2 shows the Federal Reserve’s operating  expenses from 1993 to 2001.
Our 1996 report identified several inefficiencies in the Federal Reserve’s  policies and practices that had increased the cost of providing its services,  including its costs for travel, personnel benefits, and contracting and  procurement. Many of these inefficiencies related to the decentralized  nature of the Federal Reserve, which allowed each Reserve Bank to set  many of its own policies, and to the absence of traditional cost-minimizing  forces, such as competition or appropriations, that are commonplace in  entities that are either purely private or public sector in nature. With this in  mind, we suggested that the Federal Reserve could do more to increase its  cost consciousness and ensure that it is operating as efficiently as possible.
The 1996 report concluded that major cost reductions ultimately depended  on the Federal Reserve’s carefully reexamining its mission, structure, and  work processes. The report identified areas that had potential for reducing  the Federal Reserve’s costs. The recommendations from the report fall into  four broad categories:   systemwide mission and management issues,  control and oversight mechanisms,   cost of specific Federal Reserve administrative functions, and  charging banks for the costs associated with bank examinations.
section_title: The Federal Reserve Has Taken Steps to Address Systemwide Mission and Management Issues
paragraphs: In 1996, we noted that the Federal Reserve faces major challenges in its  mission and lines of business, particularly in services to depository  institutions and government agencies and in bank supervision. These  challenges included (1) increased competition from the private sector and  increasing difficulties in recovering costs in priced services; (2)  increasingly widespread use of electronic transactions in the financial  services industry; and (3) continuing rapid consolidation of the banking  industry, which could affect both the need for and the distribution of bank  examination staff. Because these areas accounted for the largest part of the  Federal Reserve’s expenses and staffing, we believed that addressing these  challenges effectively would likely result in major changes in how the  Federal Reserve operated.
The Federal Reserve’s strategic plans and programs under development at  the time of the 1996 report generally focused on individual divisions,  Reserve Banks, or functions. While these plans served an important  purpose in defining the direction of these Federal Reserve entities, we also  believed that the emerging issues and challenges facing the Federal  Reserve would necessitate strategic planning focused on the system as a  whole. We also found that each of the Reserve Banks administered various  functions independently, rather than as a single entity that could operate  more efficiently or possibly command more advantageous prices. These  findings led to the recommendations in figure 3.
Since 1996, the Federal Reserve has consolidated the management of the  services provided by the individual Reserve Banks, particularly payment  services. For example, payment system products and new technologies are  now managed on a systemwide basis. The Federal Reserve also has  undertaken an assessment of its role in providing payment services.
In January 1998, the Committee on the Federal Reserve in the Payments  Mechanism, chaired by the Vice Chair of the Board of Governors, issued its  report entitled The Federal Reserve in the Payments Mechanism. The  study examined the payment services provided by the Federal Reserve in  light of the rapid changes occurring in the financial services and technology  sectors. These services include check clearing and automated  clearinghouse services such as direct deposits. The committee undertook a  fundamental review of the Federal Reserve’s role in the payments system  and considered how alternative roles for the Federal Reserve might  enhance or undermine the integrity, efficiency, and accessibility of the  payments system. It concluded that the Federal Reserve’s current role, or  even a slightly enhanced role, in fostering technical change was preferred  by most payment system participants.
In July 1999, the Federal Reserve formed the Payments System  Development Committee (PSDC) to advise the Board and system officials  on medium- and long-term public policy issues surrounding developments  in the retail payments system.  This committee, which includes two  Federal Reserve Board Governors, a Reserve Bank President, and a  Reserve Bank First Vice President, was intended to follow up on the work  of the Committee on the Federal Reserve in the Payments System. PSDC’s  work has included the Check Truncation Act, proposed legislation  designed to remove certain legal impediments to check truncation and  enhance the overall efficiency of the nation’s payments system. It has also  worked with payments industry officials to develop standards to facilitate  increased use of electronic check processing. The Federal Reserve has  introduced new payment products, such as its imaging service, to recognize  the increasing role that image-based services are playing in the evolution of  the U.S. payments system and the migration toward more electronic  payments.
The Federal Reserve has also undertaken numerous initiatives to  streamline management structures, consolidate operations, and apply  emerging technologies to the Reserve Banks’ business processes in order  to improve quality and reduce costs. Federal Reserve officials explained  that many of their initiatives have the effect of consolidating functions of  the Federal Reserve without consolidating the 12 Reserve Banks. For  example, in 1999, the Treasury Direct customer support function was  consolidated so that only 3 Reserve Banks are providing customer service  support to individuals who purchase Treasury securities directly from the  Treasury. From 1999 to 2002, the Federal Reserve consolidated several  aspects of Fedwire funds and securities transfer operations. Similarly, in  2000, the Treasury Investment Program was implemented, centralizing  services that the Federal Reserve provides to the Treasury Tax and Loan  Program.
The Federal Reserve continues to standardize and centralize the  management of computer applications used for common business needs. It  has selected a central site to develop and implement a centralized  application for the Reserve Bank Planning and Control System. The  Federal Reserve estimates that the centralization of applications such as  the budget application will result in systemwide savings of $2.6 million over  a 5-year period.
section_title: The Federal Reserve Has Strengthened Its Control and Oversight Mechanisms
paragraphs: In 1996, we noted a number of weaknesses in the Federal Reserve’s  budgeting and internal oversight processes. In reviewing the budgeting  process for both the Board and Reserve Banks, we found that it was based  on a current services approach that assumed both that existing functions  would be retained and that the budget would continue to grow  incrementally. We concluded that such an approach did not adequately  support top management in controlling costs and imposing the internal  self-discipline necessary for the Federal Reserve to respond effectively to  future priorities. We found that internal oversight processes, such as  performance measurement, internal audit, and financial audits, either did  not support performance evaluation from a systemwide perspective or  were becoming increasingly inappropriate in the changing environment.  We also noted that the Office of Inspector General was authorized to  review the activities of the Board, but not the Reserve Banks. As a result,  we concluded that the Federal Reserve might not be making the most use  of its resources devoted to Federal Reserve oversight. These findings led to  the recommendation in figure 4.
In addition to incorporating systemwide business strategies and resource  needs into the Federal Reserve Bank budget planning process, the Federal  Reserve Banks have changed their cost accounting system and have altered  their internal and external auditing practices.
The Federal Reserve recognized that its budget process required too much  effort and yielded an unrealistic spending outlook. Therefore, the Federal  Reserve’s Financial Support Office proposed changes to the budget process  in which system budget targets would be based on systemwide guidance  rather than on Reserve Bank projections of their expenses. Banks provided  their expense information later in the process when their budget  development would be further along—an approach that also could help  align budget planning with goal-setting for business strategies. In 2001, the  Federal Reserve’s Conference of First Vice Presidents recommended  incorporating this guidance to align the Reserve Bank budget projections  more closely with business strategies. The conference identified “national  business leaders,” that is, Federal Reserve staff with responsibility for most  Reserve Bank functions. These leaders provide business guidance as input  to the Reserve Banks as they prepare their Reserve Bank Budget Outlook.  They are responsible for almost 90 percent of the total Reserve Bank  spending. (The remaining 10 percent of spending is largely in support of  Federal Reserve monetary policy formulation and is not covered by  systemwide budget goals.)
The Board of Governors has also redefined its strategic plan and has now  implemented a more rigorous 4-year planning process and a 2-year budget  process. With this new plan in place, the Board has consolidated overhead  and several support functions to reduce costs.
In March 2000, the Conference of First Vice Presidents approved  recommendations designed to improve the cost-accounting practices of the  Federal Reserve Banks. Board staff told us that Reserve Bank staffs have  implemented these recommendations. Changes, according to Board staff,  include the following:   Simplifying expense allocation by tying expenses to departments and  organizational units in Reserve Banks rather than to specific activities.  This change will eliminate a major portion of the manual process  currently in place, and in turn, will reduce the opportunity for erroneous  activity charges.
Shifting some expenses from overhead to the service line that they  support to reflect expenses more accurately.
Eliminating sharing of costs among Reserve Banks for all services and  operations that are provided centrally. Instead, the Reserve Bank that  provides the service will now report associated expenses in an effort to  enhance accountability.
The Board adopted several new policies aimed at safeguarding the  independence of its external auditor. An external auditor, under a contract  administered by Board staff, reviews each Reserve Bank’s financial  statements. To enhance independence, in May 2002, the Board placed  restrictions on Reserve Banks’ ability to contract with the Board’s external  audit firm or to hire an auditor that has worked on the audit of a Reserve  Bank. The Board currently requires that the external auditor of the Reserve  Banks remain independent of Reserve Bank management, and that it  provide a written statement to the Board delineating all relationships  between the external auditor and the Reserve Banks.
In 2001, the Board revised its policy on Reserve Bank audit committee  duties and responsibilities, requiring that (1) audit committees adopt  formal written charters, (2) audit committee members be independent and  financially literate, and (3) audit committees meet with external auditors to  discuss the Reserve Bank’s financial statements and issues arising from the  annual external audit. The audit authority of the Inspector General remains  unchanged.
section_title: The Federal Reserve Has Consolidated Some of Its Administrative Functions
paragraphs: In 1996, we concluded that opportunities existed to reduce the Federal  Reserve’s spending in a number of different administrative areas. We found  in 1996 that Federal Reserve personnel compensation (pay and benefits)  varied within the Federal Reserve and included benefits that were  relatively generous compared with those of government agencies with  similar responsibilities.
We also found that the Federal Reserve’s health care benefits were  managed on a decentralized basis, with each Bank negotiating its own  health care coverage. We noted that although the Reserve Banks had  individually made efforts to reduce health care costs, the Reserve Banks  had not worked together to determine whether their combined bargaining  powers would further reduce these expenses.
We found in 1996 that travel policies differed between the Board and the  Reserve Banks and among the Reserve Banks. Therefore, the same trip  could present different costs to different Reserve Banks. The differing  travel policies made it necessary for each Reserve Bank to manage its own  travel costs rather than allowing the Federal Reserve to manage travel  costs on a centralized basis.
We also found in 1996 that the Board and the Reserve Banks used different  procurement guidelines. The Board, while not specifically directed to do so  by the Federal Reserve Act, followed the spirit of the federal government  contracting rules. The Reserve Banks were required to follow Uniform  Acquisition Guidelines, which were adopted by the Reserve Banks in 1985.  These guidelines were designed to provide minimum requirements for  Reserve Bank procurement activities. By providing opportunities for all  interested bidders to become a selected source, the guidelines attempted to  ensure that Reserve Banks treated sources fairly and impartially. By  fostering competition in the procurement process, Reserve Banks would  have greater opportunity to realize cost savings through lower competitive  pricing. Despite the Uniform Acquisition Guidelines, we observed instances  in which  practices at individual Reserve Banks differed significantly and some  practices favored certain sources over others and   proper controls over conflict of interest were not followed at certain  Reserve Banks.
Practices at certain Reserve Banks lacked independent checks and  reconciliations, and best practices used by certain Reserve Banks were not  disseminated among the Reserve Banks. These findings led to the  recommendations in figure 5.
The Federal Reserve has taken or begun a number of actions in response to  the findings and recommendations in our 1996 report. These actions  include reassessing the compensation approach for the Federal Reserve,  consolidating health insurance for the Reserve Banks, and changing its  travel and acquisition practices.
A work group of senior Reserve Bank and Board officials was established  to reassess the compensation philosophy within the Federal Reserve  System. The Board approved a new Reserve Bank total compensation  philosophy on June 18, 1997. The philosophy provided broad principles for  the design of benefit plans that were intended to be competitive within  relevant labor markets and sufficiently flexible to attract, retain, and  motivate the staff and officers required to fulfill the mission of the Federal  Reserve. The policy indicates the purpose and objectives of Reserve Bank  compensation and benefit programs as well as relevant labor markets and  competitive position. In 1999, the Board approved in concept a Reserve  Bank strategic benefits plan, which was developed to be a more specific  plan for ensuring that benefits will be appropriately competitive into the  future.
The Federal Reserve is in the process of consolidating the administration  and selection of health benefits so that all Reserve Banks have similar plans  that are administered uniformly. Initiatives in managing benefits also have  led to the consolidation of the administration and record keeping of several  other benefits, including the Thrift Plan, retirement plans, retiree  prescription plans, and worker’s compensation plans. According to Federal  Reserve staff, the thrift and retirement plans were consolidated a number  of years ago and are fully outsourced to a single vendor. Moreover, the  Board’s Office of Employee Benefits projects that it will save $4 million  from implementing the consolidated health care plans.
In 2001, the Reserve Banks began a plan to reduce travel costs by  upgrading videoconferencing capabilities. A vendor for this system was  selected in the first quarter of 2002, and Federal Reserve officials said  installation of new facilities has been completed in offices that previously  had videoconferencing. The next phase of this effort will include installing  videoconferencing facilities in offices that did not previously have them.  The Board has also encouraged travel savings through pursuing  government discounts and traveling at nonpeak hours.
In March 1997, the Federal Reserve completed a fundamental review of its  Uniform Acquisition Guidance. As part of this effort, it reviewed  benchmarking and best practices efforts to determine if any changes were  necessary. In July 1998, a new Model Acquisition Guideline was approved,  replacing the 1985 Uniform Acquisition Guidelines. The Federal Reserve  has continued to engage in its benchmarking process. Federal Reserve staff  said that this process has revealed continued declines in the cost of  providing procurement services through the use of streamlined purchasing  procedures. Benchmarking studies have concluded that the Federal  Reserve’s enhanced use of the System Purchasing Service to gain  economies of scale has resulted in significant savings. Board staff  explained that, where it makes sense, the Board uses procurement  resources available to government agencies, such as the General Services  Administration. However, they said that in some cases, such as in their  procurement of telecommunication services, the Board and the Reserve  Banks might negotiate together to enhance their bargaining position.
section_title: The Federal Reserve Has Continued Its Policy of Not Charging for Bank Examinations
paragraphs: Our 1996 report noted that the Federal Reserve’s revenues, and hence its  return to the taxpayers, would be enhanced by charging fees for bank  examinations. Federal bank regulators differ in their policies regarding the  assessment of fees for bank examinations. The Office of the Comptroller of  the Currency (OCC) charges national banks for examinations that it  conducts. In contrast, state-chartered banks, which are supervised by  either the Federal Reserve or the Federal Deposit Insurance Corporation  (FDIC) in conjunction with state banking agencies, are charged fees by  those state banking agencies but not by their federal regulator. Thus, the  costs of the Federal Reserve’s federal bank examinations are borne by the  taxpayers, while for national banks, the costs of examination are borne by  the banks that are examined. The Federal Reserve Act authorizes the  Federal Reserve to charge fees for bank examinations, but the Federal  Reserve has not done so, for the state member banks it examines. In  addition, the Federal Reserve inspects bank holding companies but does  not charge the institutions for those inspections. Similarly, FDIC is  authorized to charge for bank examinations but it does not do so. These  findings led to the recommendation in figure 6.
The Federal Reserve continues to believe that it should not charge for bank  examinations. Federal Reserve officials told us that, since state member  banks already pay state banking commissions for examinations, an  additional charge for a Federal Reserve examination would increase the  cost and lessen the value of a state banking charter, thus compromising the  nation’s dual banking system.  Banks pay an array of annual charges and  assessments associated with their charters, as table 1 indicates.
All three federal bank regulators are self-funded. Differences in their  funding mechanisms, however, may lead to differences in who ultimately  pays the costs of supervision and regulation, even if the supervisory and  regulatory actions serve the common purposes of ensuring that banks are  operated in a safe and sound manner. The Federal Reserve funds its  operations from the earnings on its portfolio of Treasury securities, as  previously noted. Since the Federal Reserve’s transfers to the Treasury are  reduced by the expenses of its bank supervisory and regulatory activities,  the taxpayer ultimately pays for Federal Reserve activities. FDIC may fund  its operations from the premiums that banks pay for deposit insurance.  However, since the Bank Insurance Fund is 1.25 percent of bank deposits,  which it has been since 1995, FDIC generally does not charge banks  premiums for deposit insurance. If FDIC were to begin charging insurance  premiums, then either the bank’s owners or customers, including  depositors, would be paying for FDIC examinations. OCC is funded by  assessments on the assets held by national banks and fees for services.  Under this arrangement, the owners or customers of national banks pay for  OCC operations. The differences among the funding approaches of the  federal bank regulators continue to raise questions about whether these  impose unequal burdens on banks—varying with their charter—and their  customers. “The dual banking system not only fosters and preserves innovation but also constitutes our  main protection against overly zealous and rigid federal regulation and supervision. A bank  must have a choice of more than one federal regulator, and must be permitted to change  charters, to protect itself against arbitrary and capricious regulatory behavior. Naturally,  some observers are concerned that two or more federal agencies will engage in a  ‘competition in laxity,’ and we must guard against that; but the greater danger, I believe, is  that a single federal regulator would become rigid and insensitive to the needs of the  marketplace.”
Further, Federal Reserve officials note that the roughly even shares of  banks across the charters, and consistent shares of deposits among the  charters, suggest that the relative costs and benefits of the charters  balance. National banks, they believe, see a value in their charter that at  least offsets any additional costs. “Healthy competition in the quality of supervision and innovation in meeting the needs of  banks and their customers should lie at the heart of our dual banking system. Unfortunately,  today a primary focus of this competition is on price. Because state banks receive a federal  subsidy for the predominant part of their supervision, there is a cost incentive for banks to  avoid or depart from the national charter in favor of the heavily subsidized state charter.  This inevitably tends to undermine a vigorous and healthy dual banking system.”
OCC has proposed that the costs of supervising national banks (which OCC  performs) and state supervision of state-chartered banks be paid from  FDIC insurance funds. This approach would attempt to provide  consistency at the federal regulator-level by having the costs of regulation  borne by taxpayers or depositors. We have generally favored an approach  in which regulated entities pay for their own federal regulation.
Since the Federal Reserve continues to strongly disagree with our  recommendation regarding charging for bank examinations, actions to  implement the recommendation are unlikely. While we continue to believe  that a strong argument exists for industry funding of federal supervision  and regulation, we also recognize the benefits of the dual banking system.  Ultimately, however, it is up to Congress to decide how to fund federal  regulation and to balance the differences among the different bank  regulators.
section_title: Scope and Methodology
paragraphs: To review the Federal Reserve’s actions in response to our  recommendations, we interviewed staff from the Federal Reserve Board’s  Division of Reserve Bank Operations, Division of Banking Supervision and  Regulation, Office of Inspector General, as well as the Board’s Staff  Director for Management. We reviewed relevant policies and other Board  actions and documents. We did not visit any Reserve Banks to verify or  review implementation of these new policies.
We conducted our work in Washington, D.C., between April and August,  2002, in accordance with generally accepted government auditing  standards.
section_title: Agency Comments
paragraphs: We requested comments on a draft of this report from the Board. In these  comments, the Director of the Division of Reserve Bank Operations and  Payment Systems agreed with the information presented in this report; the  comments are reprinted in appendix I. We incorporated the Board’s  technical comments where appropriate.
As agreed with your offices, unless you publicly release its contents earlier,  we plan no further distribution of this report until 30 days from its date. At  that time, we will send copies of this report to the Chairmen and Ranking  Minority Members of the Senate Committee on Banking, Housing, and  Urban Affairs, and the House Committee on Financial Services. We will  also send copies to the Chairman of the Board of Governors of the Federal  Reserve System, and we will make copies available to others on request. In  addition, this report is available at no charge on our Web site at  http://www.gao.gov.
Please contact me or James McDermott, Assistant Director, at  (202) 512-8678 if you or your staff have any questions concerning this  report. Other key contributors to this report were Thomas Conahan and  Josie Sigl.
section_title: Comments from the Federal Reserve System
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