The GAO released its November 2024 report, titled “Bank Supervision: Federal Reserve and FDIC Should Address Weaknesses in Their Process for Escalating Supervisory Concerns,” to the U.S. Senate Committee on Banking, Housing, and Urban Affairs, addressing the supervisory practices of the Fed and the FDIC. The report highlighted weaknesses in the agencies’ processes for escalating supervisory concerns. It noted that the Fed lacks “enforceable guidelines” on corporate governance and risk management, which may have delayed regulatory actions against unsafe banking practices. Additionally, the report noted the Fed has not finalized a rule required by the Dodd-Frank Act for early remediation of issues. The FDIC’s escalation procedures were also critiqued for lacking a centralized system to track supervisory recommendations, which limits the ability to identify emerging risks across supervised banks. Furthermore, the FDIC does not reportedly have formalized processes for consulting with large bank examination teams before making escalation decisions, and it lacks rotation requirements for large bank case managers, which could affect supervisory independence. As such, the report recommended both the Fed and the FDIC strengthen their escalation processes. Of note, the GAO stated the OCC generally adheres to its procedures for escalating supervisory concerns.