On May 15, the GAO penned a letter to the Acting Comptroller of the Currency, Rodney E. Hood, highlighting areas it believes warrant the OCC’s focus. First, the GAO recommended that the OCC establish policies and procedures for conducting retrospective reviews that assess whether OCC-enacted rules have had their intended effect. Second, in response to the GAO’s prior finding that financial regulators lacked an ongoing coordination mechanism for addressing blockchain risks in a timely manner, the letter called for the OCC and other federal financial regulators to establish or adapt jointly an existing formal coordination mechanism to identify and address risks posed by blockchain-related products and services.

In addition, the letter also addressed previous recommendations presented to the OCC relating to: (i) the use of alternative data in the underwriting process by fintech lenders; and (ii) the decline in the OCC’s implementation of GAO recommendations. With respect to item (i), the GAO highlights that interagency guidance still does not include specific direction to banks that engage in third-party relationships with fintech lenders regarding the appropriate use of alternative data in the underwriting process.