GAO
October 19, 2011
Congressional Addressees
The Federal Reserve System, which consists of the Board of Governors
of the Federal Reserve System (Federal Reserve Board), 12 regional
Reserve Banks, and the Federal Open Market Committee (FOMC), played a
key role in the U.S. government’s policy responses to the financial
crisis that began in the summer of 2007.1 From late 2007 through
mid-2010, Reserve Banks provided more than a trillion dollars in
emergency loans to the financial sector to address strains in credit
markets and to avert failures of individual institutions believed to be a
threat to the stability of the financial system. The scale and nature
of this assistance amounted to a rare and significant exercise of the
Federal Reserve System’s emergency powers as a lender of last resort.
Unlike the Federal Reserve Board, the Reserve Banks are not federal
agencies. Each Reserve Bank is a federally chartered corporation with a
board of directors. The membership of each Reserve Bank board includes
three directors who represent commercial banks that are members of the
Federal Reserve System and six directors who represent the public.
During the crisis, the Federal Reserve System came under scrutiny when
it became known that several institutions that borrowed from the
emergency programs were affiliated with Reserve Bank directors. Some
Members of Congress and others raised concerns about actual or potential
conflicts of interest that may have been created by these affiliations
and the possibility that some directors had exerted influence on the
emergency lending activities of the Reserve Banks. More broadly, the
Reserve Bank board structure that includes three directors who represent
banks supervised by the Reserve Banks caused public concern about the
governance of the banks, including the selection and roles of directors
and the extent to which directors elected to represent the public do so.
For example, questions were raised as to whether the directors
representing member banks had any involvement in the Reserve Banks’ role
in supervising member banks.
go to this website for the entire report…
sanders.senate.gov/imo/media/doc/d1218%20%282%29.pdf
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