Page 1 GAO-25-108046 OCC Priority Recommendations
Comptroller General
of the United States
May 15, 2025
The Honorable Rodney E. Hood
Acting Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th St. SW
Washington, D.C. 20219
Priority Open Recommendations: Office of the Comptroller of the Currency
Dear Mr. Hood:
The purpose of this letter is to call your personal attention to two areas based on GAO’s past
work and three open priority recommendations, which are enclosed.
1
Additionally, there are
eight other GAO open recommendations that we will continue to work with your staff to address.
We are highlighting the following areas that warrant your timely and focused attention.
Specifically:
Financial services regulations. Leading practices for rulemaking call for assessing the
potential and actual effects of proposed and final rules, such as costs and benefits. However, in
July 2024, we found that regulators conducted few retrospective reviews of the effects of their
existing rules. We also found that the Office of the Comptroller of the Currency (OCC) lacked
policies and procedures for conducting such reviews. Systematically conducting retrospective
reviews could help OCC assess whether its rules have had their intended effects and inform
future rulemaking, as we recommended.
Blockchain technology. In 2023, we found that financial regulators lacked an ongoing
coordination mechanism for addressing blockchain risks in a timely manner. For example,
regulators identified financial stability risks posed by stablecoins in 2019 but did not identify the
need for action to address these risks until November 2021. We recommended that OCC and
other federal financial regulators jointly establish or adapt an existing formal coordination
mechanism to identify and address risks posed by blockchain-related products and services.
Such a mechanism would help OCC and the other regulators collectively identify risks and
develop and implement a regulatory response in a timely manner.
Please see Enclosure 1 for additional details about the status and actions needed to fully
implement the three open priority recommendations out of the 11 total recommendations that
remain open. These include a priority recommendation on financial technology.
1
GAO considers a recommendation to be a priority if, when implemented, it may significantly improve government
operations—for example, by realizing large dollar savings; eliminating mismanagement, fraud, and abuse; or making
progress toward addressing a high-risk or duplication issue.
