The Lacuna Project

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Exhibit 786

Federal Reserve Bank Governance: Opportunities Exist to Broaden Director Recruitment Efforts and Increase Transparency (GAO-12-18)

Exhibit 786 ยท GAO report

Federal Reserve Bank Governance: Opportunities Exist to Broaden Director Recruitment Efforts and Increase Transparency (GAO-12-18)

We identified at least 18 former and current Class A, B, and C directors from 9 Reserve Banks who were affiliated with institutions that used at least one emergency program.

GAO's Dodd-Frank sec. 1109(b) study of Reserve Bank boards. Directors have a limited role in supervision. p. 32: "in practice, most Class A directors are officers or directors of member banks in the district," and the requirement "creates an appearance of a conflict of interest" because the System supervises state-chartered member banks and holding companies. pp. 38-40: at least 18 current and former directors from 9 Reserve Banks were affiliated with institutions that used an emergency program, including 11 Class A directors who served 2008-2010. Four recommendations; the Board agreed.

Source
U.S. Government Accountability Office
Date
October 2011
Quoted from
p. 39 (printed page; the continuation page prints its footer as "Page 31")
Grade
Primary record
Document
https://www.gao.gov/assets/gao-12-18.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Cited by

Finding POL-8.6
Primary record GAO identified at least 18 current and former directors from 9 Reserve Banks who were affiliated with institutions that used at least one emergency program, including 11 Class A directors who served between 2008 and 2010, and wrote that member-bank representatives on Reserve Bank boards create an appearance of a conflict of interest. GAO also found no evidence of systemic bias toward favoring particular institutions in the emergency programs.