Treasury Continues to Implement Its Oversight System for Addressing TARP Conflicts of Interest.

摘要

Treasury has taken a number of actions since 2008, in part in response to recommendations we made, to establish a structured system to manage potential conflicts of interest involving its contractors and financial agents. The system is based on a formal regulation Treasury issued in interim form in 2009 and final form in 2011, which prohibits organizational or personal conflicts of interest unless they have been waived or mitigated under a Treasury-approved plan. The regulation sets forth requirements to address actual and potential conflicts that may arise, establishes responsibilities for contractors and financial agents in preventing conflicts from occurring, and outlines Treasury's process for reviewing and addressing conflicts. Treasury has developed a multifaceted process to manage and oversee potential conflicts of interest, which is managed by OFS's Office of the Chief Compliance Officer. The process includes reviewing proposed contracts and financial agency agreements, approving contractor and financial agent mitigation plans, addressing conflicts of interest inquiries, reviewing conflicts of interest certifications, and preparing feedback reports for contractors and financial agents. In addition, because the monitoring of conflicts of interest was based to some degree on self-reported information submitted by contractors and financial agents, Treasury began conducting on-site design and compliance reviews in 2011 to evaluate the effectiveness of its contractors' and financial agents' internal controls and procedures for conflicts of interest. Treasury has also established an internal database to document and track financial agent and contractor conflicts of interest certifications, inquiries, and requests for waivers.