Dodd-Frank Act
Eleven Agencies' Estimates of Resources for Implementing Regulatory Reform Gao ID: GAO-11-808T July 14, 2011In Process
The amount of new funding the agencies reported as associated with implementing the Dodd-Frank Act varied significantly across the 11 agencies. For example, new funding resources related to Dodd- Frank responsibilities during the years 2011-2012 ranged from a low of $0 for Federal Trade Commission (FTC) to a high of around $329 million for Consumer Financial Protection Bureau (CFPB). Funding resources to implement the Dodd-Frank Act accounted for at least 25 percent of the agency's total budget increase at 9 of the 11 agencies in the most recent year for which data were available. Excluding the three agencies that the Dodd-Frank Act created (CFPB, Financial Stability Oversight Council (FSOC), and Office of Financial Research (OFR), the CFTC devoted the highest share of total agency resources (25 percent) to implementing the Dodd-Frank provisions. Agencies reported that most of the costs related to implementing the provisions will be recurring. The agencies are relying on a variety of sources to fund the implementation costs for the new provisions, including assessments and revenues, appropriations, offsetting collections, and transfers from other agencies. Six of the 11 agencies reported that their funding would be fully or partly met by assessments imposed on regulated institutions or revenues from their operations. Three others reported that they would have to rely at least partly on appropriations. SEC said that it would use offsets (e.g., fees collected), and CFPB would use transfers from the Federal Reserve to fully fund its activities. Nearly all the agencies plan to have some staff work specifically on responsibilities related to the Dodd-Frank Act. Agencies can hire new staff, redirect staff from other areas, or use staff transferred from other agencies. According to data from the agencies, full-time equivalents (FTE) related to implementing the Dodd-Frank provisions for the years 2011-2012 ranged from a low of 0 for FTC to a high of 1,225 for CFPB. More specifically, FTC reported that it would implement the Dodd-Frank Act using existing resources and did not anticipate that the new requirements would have a noticeable impact on the agency's budget or operations, since its responsibilities under the Act were relatively limited. CFPB reported that all of its estimated FTEs were new hires, as the agency is currently being established. Furthermore, some agencies will be receiving staff and resources transferred from other agencies. Agencies faced numerous challenges in reporting the resources associated with implementation of the Dodd-Frank Act. Agencies told us that their reported funding and FTE resources reflect their best estimate of the level of resources required to implement existing and new responsibilities but stated that these estimates were uncertain. Beyond the normal challenges associated with estimating resource needs in the future, agencies told us that pending and evolving implementation actions, such as interagency transfers (e.g., from OTS to OCC) and establishing new offices required by the Dodd-Frank Act, makes these estimates particularly uncertain and subject to change.
GAO-11-808T, Dodd-Frank Act: Eleven Agencies' Estimates of Resources for Implementing Regulatory Reform
This is the accessible text file for GAO report number GAO-11-808T
entitled 'Dodd-Frank Act: Eleven Agencies' Estimates of Resources for
Implementing Regulatory Reform' which was released on July 14, 2011.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as
part of a longer term project to improve GAO products' accessibility.
Every attempt has been made to maintain the structural and data
integrity of the original printed product. Accessibility features,
such as text descriptions of tables, consecutively numbered footnotes
placed at the end of the file, and the text of agency comment letters,
are provided but may not exactly duplicate the presentation or format
of the printed version. The portable document format (PDF) file is an
exact electronic replica of the printed version. We welcome your
feedback. Please E-mail your comments regarding the contents or
accessibility features of this document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Oversight and Investigations, Committee on
Financial Services, House of Representatives:
For Release on Delivery:
Expected at 2:00 p.m. EDT:
Thursday, July 14, 2011:
Dodd-Frank Act:
Eleven Agencies' Estimates of Resources for Implementing Regulatory
Reform:
Statement for the Record by A. Nicole Clowers, Director:
Financial Markets and Community Investment:
GAO-11-808T:
Chairman Neugebauer, Ranking Member Capuano, and Members of the
Subcommittee:
Thank you for the opportunity to provide information on selected
federal agencies' reported funding and staff resources associated with
implementing the Dodd-Frank Wall Street Reform and Consumer Protection
Act (Dodd-Frank Act) in 2010, 2011, and 2012. As you know, the recent
financial crisis is considered to be the worst since the Great
Depression, and data from the Board of Governors of the Federal
Reserve System (Federal Reserve) show that it resulted in the loss of
trillions of dollars in household wealth.[Footnote 1] Congress passed
the Dodd-Frank Act in 2010 in response to the ongoing crisis,
including in the legislation numerous provisions intended to
strengthen oversight of insured depository institutions and nonbank
financial companies and to consolidate consumer protection
responsibilities that had been fragmented across multiple agencies.
[Footnote 2] The Dodd-Frank Act also authorized the creation of new
offices and agencies to implement the reforms. The extensive reforms
and the need for new offices to implement them have raised questions
about the potential costs to agencies of complying with the provisions.
My statement today focuses on (1) the agencies' funding estimates and
the sources of funds associated with implementing the Dodd-Frank Act,
(2) agencies' estimates of the number of new entities that will be
created and the full-time equivalents (FTEs) they anticipate needing
to carry out new responsibilities, and (3) challenges that the
agencies faced in developing these estimates.[Footnote 3] My statement
draws on information we collected from 11 federal agencies in
preparation for an oversight hearing held by the Oversight and
Investigations Subcommittee, House Committee on Financial Services, on
March 30, 2011. We collected this information at the subcommittee
chairman's request and provided it to the subcommittee staff on March
18 and 25, 2011. Appendix I includes the information we collected from
the agencies.
To address the Chairman's request for cost information before the
March 2011 hearing, we obtained and summarized budgetary information
from 11 federal agencies: Commodity Futures Trading Commission (CFTC),
Bureau of Consumer Financial Protection (also known as the Consumer
Financial Protection Bureau, or CFPB), Federal Deposit Insurance
Corporation (FDIC), Federal Housing Financing Agency (FHFA), Board of
Governors of the Federal Reserve System (Federal Reserve), Federal
Trade Commission (FTC), Financial Stability Oversight Council (FSOC),
Office of the Comptroller of the Currency (OCC), Office of Financial
Research (OFR), Securities and Exchange Commission (SEC), and
Department of the Treasury (Treasury). We judgmentally selected these
agencies because the Dodd-Frank Act assigned them new responsibilities
or created them.
We reviewed documents that these agencies provided to the subcommittee
regarding the costs of implementing the Dodd-Frank Act. In addition,
we requested data on the agencies' estimates of their funding and FTEs
agencywide and for activities related to the Dodd-Frank Act in 2010,
2011, and 2012. We also requested that agencies identify their sources
of funding (appropriations, assessments of supervised institutions,
revenue from investments or providing services, and transfers of funds
from other agencies), describe the extent to which new resources
related to the Dodd-Frank Act would be funded on a one-time or
recurring basis, and describe challenges they faced in developing the
estimates of requested funding and FTEs. We followed up with the
agencies to clarify any questions that we had about the information
they provided. To the extent possible, we corroborated the information
with other published sources, including the President's Fiscal Year
2012 Budget documents.[Footnote 4]
We conducted the work for this statement in March 2011 and sought
updates and verification of the information in July 2011.[Footnote 5]
Our work was performed in accordance with GAO's Quality Assurance
Framework. The framework requires that we plan and perform the
engagement to obtain sufficient and appropriate evidence to meet our
stated objectives and to discuss any limitations in our work. We
believe that the information and data obtained, and the analysis
conducted, provide a reasonable basis for any findings and conclusions.
The amount of new funding the agencies reported as associated with
implementing the Dodd-Frank Act varied significantly across the 11
agencies (table 1). For example, new funding resources related to Dodd-
Frank responsibilities during the years 2011-2012 ranged from a low of
$0 for FTC to a high of around $329 million for CFPB. Funding
resources to implement the Dodd-Frank Act accounted for at least 25
percent of the agency's total budget increase at 9 of the 11 agencies
in the most recent year for which data were available. Excluding the
three agencies that the Dodd-Frank Act created (CFPB, FSOC, and OFR),
the CFTC devoted the highest share of total agency resources (25
percent) to implementing the Dodd-Frank provisions. Agencies reported
that most of the costs related to implementing the provisions will be
recurring.
Table 1: Summary of 11 Federal Agencies' Reported New Funding
Resources Associated with the Implementation of the Dodd-Frank Act,
Fiscal Years 2010 through 2012:
Agency: Federal Reserve[A];
Dodd-Frank-related Funding Resources:
2010: $7,300,000;
2011: $77,500,000;
2012: Not available;
Total: $84,800,000.
Agency: CFTC;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $15,400,000;
2012: $77,000,000;
Total: $92,400,000.
Agency: FDIC[A];
Dodd-Frank-related Funding Resources:
2010: $2,345,000;
2011: $40,860,000;
2012: Not available;
Total: $43,205,000.
Agency: FHFA;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $3,800,000;
2012: $4,350,000;
Total: $8,150,000.
Agency: FTC;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $0;
2012: $0;
Total: $0.
Agency: OCC;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $34,850,000;
2012: $235,000,000;
Total: $269,850,000.
Agency: SEC;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $23,525,000;
2012: $108,982,000;
Total: $132,507,000.
Agency: Treasury;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $10,393,000;
2012: $5,525,000;
Total: $15,918,000.
Agency: CFPB;
Dodd-Frank-related Funding Resources:
2010: $9,200;
2011: $142,825,000;
2012: $329,045,000;
Total: $481,070,000.
Agency: FSOC;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $7,435,000;
2012: $7,885,000;
Total: $15,320,000.
Agency: OFR;
Dodd-Frank-related Funding Resources:
2010: $0;
2011: $33,890,000;
2012: $74,468,000;
Total: $108,358,000.
Source: Data from individual agencies.
[A] FDIC and the Federal Reserve report on a calendar year basis. The
figures for these two agencies reflect calendar years 2010 and 2011
estimates. At the time of this review, estimates were not available
for calendar year 2012.
[End of table]
The agencies are relying on a variety of sources to fund the
implementation costs for the new provisions, including assessments and
revenues, appropriations, offsetting collections, and transfers from
other agencies (table 2). Six of the 11 agencies reported that their
funding would be fully or partly met by assessments imposed on
regulated institutions or revenues from their operations. Three others
reported that they would have to rely at least partly on
appropriations. SEC said that it would use offsets (e.g., fees
collected), and CFPB would use transfers from the Federal Reserve to
fully fund its activities.[Footnote 6]
Table 2: Summary of 11 Federal Agencies' Types of Funding Sources:
Agency: Federal Reserve;
Assessments and Revenues: [Check][A];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Empty].
Agency: CFTC;
Assessments and Revenues: [Empty];
Appropriations: [Check];
Offsetting collections: [Empty];
Transfers: [Empty].
Agency: FDIC;
Assessments and Revenues: [Check][B];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Empty].
Agency: FHFA;
Assessments and Revenues: [Check];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Empty].
Agency: FTC;
Assessments and Revenues: [Empty];
Appropriations: [Check];
Offsetting collections: [Check];
Transfers: [Empty].
Agency: OCC;
Assessments and Revenues: [Check];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Check].
Agency: SEC;
Assessments and Revenues: [Empty];
Appropriations: [Empty];
Offsetting collections: [Check];
Transfers: [Empty].
Agency: Treasury;
Assessments and Revenues: [Empty];
Appropriations: [Check];
Offsetting collections: [Empty];
Transfers: [Empty].
Agency: CFPB;
Assessments and Revenues: [Empty];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Check].
Agency: FSOC;
Assessments and Revenues: [Check];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Check].
Agency: OFR;
Assessments and Revenues: [Check];
Appropriations: [Empty];
Offsetting collections: [Empty];
Transfers: [Check].
Source: Data from individual agencies.
[A] According to the Federal Reserve, its income is derived primarily
from the interest on U.S. government securities that it trades through
open market operations. Other sources of income are the interest on
foreign currency investments held by the System; fees received for
services provided to depository institutions, such as check clearing,
funds transfers, and automated clearinghouse operations; and interest
on loans to depository institutions (the rate on which is the so-
called discount rate). Under the Dodd-Frank Act (Section 318) the
Federal Reserve will receive new reimbursements through assessment
fees to large Bank Holding Companies, Savings and Loan Holding
Companies, and Systemically Important Financial Institutions
designated by the Financial Stability Oversight Council.
Reimbursements for 2011 assessment fees will be collected in 2012.
Preliminary estimates of the fees will be completed later this year.
After paying its expenses, the Federal Reserve turns the rest of its
earnings over to the U.S. Department of the Treasury.
[B] FDIC is funded by premiums that banks and thrifts pay for deposit
insurance coverage and from earnings on investments in U.S. Treasury
securities.
[End of table]
As table 3 shows, nearly all the agencies plan to have some staff work
specifically on responsibilities related to the Dodd-Frank Act.
Agencies can hire new staff, redirect staff from other areas, or use
staff transferred from other agencies. According to data from the
agencies, FTEs related to implementing the Dodd-Frank provisions for
the years 2011-2012 ranged from a low of 0 for FTC to a high of 1,225
for CFPB. More specifically, FTC reported that it would implement the
Dodd-Frank Act using existing resources and did not anticipate that
the new requirements would have a noticeable impact on the agency's
budget or operations, since its responsibilities under the Act were
relatively limited. CFPB reported that all of its estimated FTEs were
new hires, as the agency is currently being established. Furthermore,
some agencies will be receiving staff and resources transferred from
other agencies. For example, nearly all of OCC's new staff for fiscal
years 2010 through 2012 will come from the Office of Thrift
Supervision (OTS), which the Dodd-Frank Act dissolved as of July 21,
2011.
Table 3: Summary of 11 Federal Agencies' Reported FTEs Associated with
the Implementation of the Dodd-Frank Act, Fiscal Years 2010 through
2012:
Agency: Federal Reserve[A];
Dodd-Frank related FTEs:
2010: 69;
2011: 397;
2012: Not available.
Agency: CFTC;
Dodd-Frank related FTEs:
2010: 0;
2011: 121;
2012: 238.
Agency: FDIC[A];
Dodd-Frank related FTEs:
2010: 0;
2011: 55;
2012: Not available.
Agency: FHFA;
Dodd-Frank related FTEs:
2010: 0;
2011: 16;
2012: 2.
Agency: FTC;
Dodd-Frank related FTEs:
2010: 0;
2011: 0;
2012: 0.
Agency: OCC;
Dodd-Frank related FTEs:
2010: 0;
2011: 133[B];
2012: 0[B].
Agency: SEC;
Dodd-Frank related FTEs:
2010: 0;
2011: 14;
2012: 352.
Agency: Treasury;
Dodd-Frank related FTEs:
2010: 0;
2011: 24;
2012: 11.
Agency: CFPB;
Dodd-Frank related FTEs:
2010: 0;
2011: 342;
2012: 883.
Agency: FSOC;
Dodd-Frank related FTEs:
2010: 0;
2011: 17;
2012: 7.
Agency: OFR;
Dodd-Frank related FTEs:
2010: 0;
2011: 33;
2012: 135.
Source: Data from individual agencies listed.
Note: FTE estimates include all staff resources--that is, new hires,
redirects, and transfers from other agencies--devoted to implementing
Dodd-Frank responsibilities.
[A] FDIC and the Federal Reserve report on a calendar year basis. The
figures for these two agencies reflect calendar years 2010 and 2011
estimates. At the time of this review, estimates were not available
for calendar year 2012.
[B] According to OCC, the agency expects to receive an estimated 682
OTS staff transfers in fiscal year 2011. OCC estimates that these
transfers will represent 131 FTEs for fiscal year 2011 (based on their
July 21, 2011 transfer date). Because these FTEs will already be on
board at the beginning of FY 2012, they are not considered new Dodd-
Frank related FTEs in FY 2012.
[End of table]
Agencies faced numerous challenges in reporting the resources
associated with implementation of the Dodd-Frank Act. Agencies told us
that their reported funding and FTE resources reflect their best
estimate of the level of resources required to implement existing and
new responsibilities but stated that these estimates were uncertain.
Beyond the normal challenges associated with estimating resource needs
in the future, agencies told us that pending and evolving
implementation actions, such as interagency transfers (e.g., from OTS
to OCC) and establishing new offices required by the Dodd-Frank Act,
makes these estimates particularly uncertain and subject to change. In
collecting and analyzing this information, we also found challenges
and limitations that affected our efforts to aggregate the data. For
example, not all of the agencies are on a federal fiscal year, so the
reported budgetary activities for some agencies cover different time
frames. In addition, agencies may have used different approaches to
estimate the funding and FTE resources, potentially making the figures
harder to compare across agencies. Finally, the data collected shed
light only on direct costs to these agencies, as reported by them. The
information does not include other related direct and indirect costs,
such as the costs to market participants or the benefits of
implementation--information that would be needed to conduct a complete
analysis of the costs and benefits of implementing the Dodd-Frank Act.
Contacts and Staff Acknowledgments:
If you or your staff have any questions about matters discussed in
this testimony, please contact A. Nicole Clowers at (202) 512-8678 or
clowersa@gao.gov. Other key contributors to this testimony include
Daniel Garcia-Diaz (Assistant Director), Emily Chalmers, Joe Hunter,
Elizabeth Jimenez, Marc Molino, Akiko Ohnuma, and Michael Pahr.
[End of section]
Appendix I: Eleven Agencies' Estimates of Resources for Implementing
the Dodd-Frank Act:
Board of Governors of the Federal Reserve System:
CY 2011 Dodd-Frank resources[A]: $77,500,000;
CY 2011 agency-wide total resources: $3,840,000,000;
(Dodd-Frank resources = 2.0% of CY 2011 agency total);
CY 2011 agency-wide resources increase: $170,000,000;
(Dodd-Frank resources = 45.6% of CY 2011 agency increase).
CY 2011 Dodd-Frank new-hire FTEs: 290;
CY 2011 agency-wide FTE increase: 620;
(Dodd-Frank FTEs = 46.8% of agency increase).
[A] Resources made available or requested for Federal Reserve.
Sources of Federal Reserve CY 2011 resources:
Assessments and revenues: 100%.
Agency total resources[B]:
CY 2010 actual: $3,670,000,000;
CY 2011 approved: $3,840,000,000;
CY 2012: Not available.
Dodd-Frank related resources[B]:
CY 2010 actual: $7,300,000;
CY 2011 approved: $77,500,000;
CY 2012: Not available.
Agency new FTEs (net):
CY 2010 actual: -381;
CY 2011 approved: 620;
CY 2012: Not available.
Dodd-Frank new FTEs:
CY 2010 actual: 69;
CY 2011 approved: 397;
CY 2012: Not available.
Dodd-Frank new FTEs: New hires:
CY 2010 actual: 0;
CY 2011 approved: 290;
CY 2012: Not available.
Dodd-Frank new FTEs: Redirected from other work:
CY 2010 actual: 69;
CY 2011 approved: 107;
CY 2012: Not available.
[B] Resources totals provided exclude the cost for new currency and
pension costs of the Reserve Banks.
New offices required by Dodd-Frank Act:
* Office of Minority and Women Inclusion (at the Board and each of the
Reserve Banks).
New offices related to Dodd-Frank but not required by the Act:
* Office of Financial Stability Policy and Research
* Financial Market Infrastructures Risk Analytics
* Financial Market Infrastructures Oversight
Agency Notes: The FTE data reflect the Board's best estimates at this
time. The negative "Agency new FTEs (net)" for 2010 reflects the net
reduction of staff in the financial services (e.g. check processing
and support functions) partially offset by an increase in supervision
staff. CY 2012 budget and FTE estimates are not yet available. The
agency is staffing one-time studies and other one-time costs by
redirecting existing staff. Longer term work will be performed by new
staff hired to implement Dodd-Frank.
[End of estimate]
Commodity Futures Trading Commission:
FY 2012 Dodd-Frank resources[A]: $77,000,000;
FY 2012 agency-wide total resources: $308,000,000;
(Dodd-Frank resources = 25% of agency total);
FY 2012 agency-wide resources increase: $105,730,000;
(Dodd-Frank resources = 72.8% of agency increase).
FY 2012 Dodd-Frank new-hire FTEs: 238;
FY 2012 agency-wide FTE increase: 308;
(Dodd-Frank FTEs = 77.3% of agency increase).
[A] Resources made available or requested for CFTC.
Sources of CFTC FY 2012 resources:
Appropriations: 100%.
Agency total resources:
FY 2010 actual: $168,344,000;
FY 2011 approved: $168,800,000;
FY 2012: $308,000,000.
Dodd-Frank related resources[B]:
FY 2010 actual: $0;
FY 2011 approved: $15,400,000;
FY 2012: $77,000,000.
Agency new FTEs (net):
FY 2010 actual: 107;
FY 2011 approved: 70;
FY 2012: 308.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 121;
FY 2012: 238.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 35;
FY 2012: 238.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 86;
FY 2012: Unknown.
New offices required by Dodd-Frank Act:
* None.
New offices related to Dodd-Frank but not required by the Act:
* Division of Swaps Dealers and Intermediary Oversight;
* Consumer Outreach/Whistleblower.
Agency Notes: Dodd-Frank related costs and staffing needs are expected
to recur indefinitely; the agency expects that the steady-state
requirement for execution of Dodd-Frank will be closer to 400 FTEs. FY
2011 Dodd-Frank new FTEs are currently being recruited and will be on-
board near the end of the fiscal year. Estimating FT costs was
challenging for CFTC because its new technology solutions must be
dynamic and capable of evolving along with the regulated markets. User
fees may begin to reimburse appropriations beginning in FY 2012 or FY
2013 pending enactment of authorizing legislation.
Source: CFM-provided information.
[End of estimate]
Federal Deposit Insurance Corporation:
CY 2012 Dodd-Frank resources[A]: $40,860,000;
CY 2012 agency-wide total resources: $3,877,108,000;
(Dodd-Frank resources = 1.1% of agency total);
CY 2012 agency-wide resources increase: -$112,172,000[B].
CY 2012 Dodd-Frank new-hire FTEs: 45;
CY 2012 agency-wide FTE increase: 444;
(Dodd-Frank FTEs = 10.1% of agency increase).
[A] Resources made available or requested for FDIC.
[B] The reduction is primarily due to a decrease in financial
institution failures, offset by a smaller increase in supervision
expenses.
Sources of FDIC CY 2012 resources:
Transfer from another agency: 100%.
Agency total resources:
CY 2010 actual: $3,989,280,000;
CY 2011 approved: $3,877,108,000;
CY 2012: Not available.
Dodd-Frank related resources:
CY 2010 actual: $2,345,000;
CY 2011 approved: $40,860,000;
CY 2012: Not available.
Agency new FTEs (net):
CY 2010 actual: 502;
CY 2011 approved: 444;
CY 2012: Not available.
Dodd-Frank new FTEs:
CY 2010 actual: 0;
CY 2011 approved: 55;
CY 2012: Not available.
Dodd-Frank new FTEs: New hires:
CY 2010 actual: 0;
CY 2011 approved: 45;
CY 2012: Not available.
Dodd-Frank new FTEs: Transfers from OTS;
CY 2010 actual: 0;
CY 2011 approved: 10;
CY 2012: Not available.
Dodd-Frank new FTEs: Redirected from other work:
CY 2010 actual: Unknown;
CY 2011 approved: Unknown;
CY 2012: Not available.
New offices required by Dodd-Frank Act:
* Office of Minority and Women Inclusion.
New offices related to Dodd-Frank but not required by the Act:
* Office of Complex Financial Institutions;
* Living Will Review and Oversight Section within the Division of
Risk Management Supervision;
* Complex Financial Institutions Section within the Legal Division.
Agency Notes: The "Transfers from OTS" 10 FTEs for 2011 reflect the
net of FDIC receiving 20 Dodd-Frank related FTEs from OTS and FDIC
providing 10 Dodd-Frank related FTEs to the CFPB. One-time expenses
totaling $3,575,000 for FT systems development are included in the
2011 total. All other known costs are recurring and are expected to
grow as the FDIC's 74 positions dedicated to Dodd-Frank Act functions
become fully staffed (only 45 FTEs are expected to be on board during
2011). The costs associated with the OTS transfers are not included.
Source: FDIC-provided information.
[End of estimate]
Federal Housing Finance Agency:
FY 2012 Dodd-Frank resources[A]: $3,800,000;
FY 2012 agency-wide total resources: $166,900,000;
(Dodd-Frank resources = 2.3% of agency total);
FY 2012 agency-wide resources increase: $11,300,000;
(Dodd-Frank resources = 33.6% of agency total).
FY 2012 Dodd-Frank new-hire FTEs: 1;
FY 2012 agency-wide FTE increase: 48;
(Dodd-Frank FTEs = 2.1% of agency increase).
[A] Resources made available or requested for FHFA.
Sources of FHFA FY 2012 resources:
Transfer from another agency: 100%.
Agency total resources:
FY 2010 actual: $155,600,000;
FY 2011 approved: $166,900,000;
FY 2012: Not available.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $3,800,000;
FY 2012: $4,350,000.
Agency new FTEs (net):
FY 2010 actual: 23;
FY 2011 approved: 48;
FY 2012: Not available.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 16;
FY 2012: 2.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 1;
FY 2012: 2.
Dodd-Frank new FTEs: Redirected from other work:
CY 2010 actual: Unknown;
CY 2011 approved: 15;
CY 2012: 0.
New offices required by Dodd-Frank Act:
* Office of Minority and Women Inclusion.
* New offices related to Dodd-Frank but not required by the Act:
* Office of Systemic Risk and Market Surveillance.
Agency Notes: FHFA's agency-wide FY 2012 budget information is not yet
available. However, the agency surveyed its staff and provided
estimates of funding and staffing that will be devoted to Dodd-Frank
related activities in FY 2012. One challenge FHFA identified in
estimating these figures is that many of its Dodd-Frank related
activities are collaborative efforts with other agencies; the
estimates are based on FHFA's supporting role to these collaborative
working groups.
Source: FHFA-provided information.
[End of estimate]
Federal Trade Commission:
FY 2012 Dodd-Frank resources[A]: $0;
FY 2012 agency-wide total resources: $326,000,000;
(Dodd-Frank resources = 0% of agency total);
FY 2012 agency-wide resources increase: $34,300,000;
(Dodd-Frank resources = 0% of agency total).
FY 2012 Dodd-Frank new-hire FTEs: 0;
FY 2012 agency-wide FTE increase: 25;
(Dodd-Frank FTEs = 0% of agency increase).
[A] Resources made available or requested for FTC.
Sources of FTC FY 2012 resources:
Offsetting collections: 54.4%;
Appropriations: 39.6%.
Agency total resources:
FY 2010 actual: $291,700,000;
FY 2011 approved: $291,700,000;
FY 2012: $326,000,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $0;
FY 2012: $0.
Agency new FTEs (net):
FY 2010 actual: 51;
FY 2011 approved: 9;
FY 2012: 25.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: Unknown;
FY 2012: Unknown.
New offices required by Dodd-Frank Act:
* None.
New offices related to Dodd-Frank but not required by the Act:
* None.
Agency Notes: FTC does not anticipate that the passage of Dodd-Frank
will have any noticeable impact on its budget and the agency will
implement its Dodd-Frank related responsibilities using existing
resources. FTC did not attempt to estimate the number of existing FTEs
performing Dodd-Frank related responsibilities or their associated
costs.
Source: FM-provided information.
[End of estimate]
Office of the Comptroller of the Currency:
FY 2012 Dodd-Frank resources[A]: $235,000,000;
FY 2012 agency-wide total resources: $1,040,000,000;
(Dodd-Frank resources = 22.6% of agency total);
FY 2012 agency-wide resources increase: $225,500,000;
(Dodd-Frank resources = 104.2% of agency total).
FY 2012 Dodd-Frank new-hire FTEs: 0;
FY 2012 agency-wide FTE increase: Unknown.
[A] Resources made available or requested for OCC.
Sources of FTC FY 2012 resources:
Assessments and revenues: 79.7%;
Transfer from OTS: 20.3%.
Agency total resources:
FY 2010 actual: $791,700,000;
FY 2011 approved: $814,500,000;
FY 2012: $1,040,000,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $34,850,000;
FY 2012: $235,000,000.
Agency new FTEs (net):
FY 2010 actual: Not provided;
FY 2011 approved: 76;
FY 2012: Unknown.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 133;
FY 2012: 0.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
Dodd-Frank new FTEs: Transfers from OTS:
FY 2010 actual: 0;
FY 2011 approved: 131[B];
FY 2012: 0[B].
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 2;
FY 2012: Unknown.
[B] Represents FTEs for estimated 682 OTS transfers on-board from July
21, 2011 (transfer date) until end of FY 2011. Since these FTEs are on-
board at start of FY 2012, they are not considered new Dodd-Frank
FTEs.
New offices required by Dodd-Frank Act:
* Office of Minority and Women Inclusion;
* Deputy Comptroller for Thrift Supervision.
New offices related to Dodd-Frank but not required by the Act:
* None.
Agency Notes: Nearly all of OCC's new FTEs will perform ongoing work
related to supervision of thrifts that will recur in future years.
However, these FTEs were previously incurring cost at OTS and
therefore do not represent new costs to the financial system. OCC's
primary challenge in determining these costs was estimating the
dollars related to FTEs. Also, the number of transfers from OTS to OCC
and from OCC to FDIC and CFPB has not been finalized.
Source: OCC-provided information.
[End of estimate]
Securities and Exchange Commission:
FY 2012 Dodd-Frank resources[A]: $108,982,100;
FY 2012 agency-wide total resources: $1,407,483,130;
(Dodd-Frank resources = 7.7% of agency total);
FY 2012 agency-wide resources increase: $186,347,414;
(Dodd-Frank resources = 58.5% of agency total).
FY 2012 Dodd-Frank new-hire FTEs: 331;
FY 2012 agency-wide FTE increase: 588;
(Dodd-Frank FTEs = 56.3% of agency increase).
[A] Resources made available or requested for SEC.
Sources of SEC FY 2012 resources:
Offsetting collections: 100%.
Agency total resources:
FY 2010 actual: $1,118,753,000;
FY 2011 approved: $1,221,136,000;
FY 2012: $1,407,483,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $23,525,000;
FY 2012: $108,982,000.
Agency new FTEs (net):
FY 2010 actual: 92;
FY 2011 approved: 124;
FY 2012: 588.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 14;
FY 2012: 352.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 9;
FY 2012: 331.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 5;
FY 2012: 21.
New offices required by Dodd-Frank Act:
* Office of Investor Advocate;
* Office of Credit Ratings;
* Office of Municipal Securities;
* Office of Whistleblower Protection;
* Office of Minority and Women Inclusion.
Agency Notes: $39,137,000 (35.9%) of the FY 2012 Dodd-Frank related
costs are for one-time costs such as FT projects costs. Budget and FTE
estimates depend on timing of Congressional approval of reprogramming
of the budget for new offices.
Source: SEC-provided information.
[End of estimate]
Department of the Treasury:
Includes only departmental offices salaries and expenses:
FY 2012 Dodd-Frank resources[A]: $5,525,100;
FY 2012 agency-wide total resources: $324,889,130;
(Dodd-Frank resources = 1.7% of agency total);
FY 2012 agency-wide resources increase: $20,001,414;
(Dodd-Frank resources = 27.6% of agency total).
FY 2012 Dodd-Frank new-hire FTEs: 11;
FY 2012 agency-wide FTE increase: 75;
(Dodd-Frank FTEs = 14.7% of agency increase).
[A] Resources made available or requested for Treasury.
Sources of Treasury DO FY 2012 resources:
Appropriations: 100%.
Agency total resources:
FY 2010 actual: $304,888,000;
FY 2011 approved: $304,888,000;
FY 2012: $324,889,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $10,393,000;
FY 2012: $5,525,000.
Agency new FTEs (net):
FY 2010 actual: 77;
FY 2011 approved: 100;
FY 2012: 75.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 24;
FY 2012: 11.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 24;
FY 2012: 11.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: Unknown;
FY 2011 approved: Unknown;
FY 2012: Unknown.
New offices required by Dodd-Frank Act:
* Office of Minority and Women Inclusion;
* Federal Insurance Office;
* Bureau of Consumer Financial Protection (independent);
* Financial Stability Oversight Council (support to independent
council);
* Office of Financial Research.
New offices related to Dodd-Frank but not required by the Act:
* Office of Financial Stability Oversight Council.
Agency Notes: All identified costs are recurring. Treasury did not
separately track existing FTEs and o he resources utilized for
implementation of the Act, so estimates do not include use of existing
resources. The legislation has directly and indirectly impacted the
work assignments of many throughout the Departmental Offices,
particularly those in the office of Domestic Finance.
Source: Treasury-provided information.
[End of estimate]
Bureau of Consumer Financial Protection:
FY 2012 Dodd-Frank resources[A]: $329,045,000;
FY 2012 agency-wide total resources: $329,045,000;
(Dodd-Frank resources = 100% of agency total);
FY 2012 agency-wide resources increase: $186,220,000.
FY 2012 Dodd-Frank new-hire FTEs: 883;
FY 2012 agency-wide FTE increase: 883;
(Dodd-Frank FTEs = 100% of agency increase).
[A] Resources made available or requested for CFPB.
Sources of CFPB FY 2012 resources:
Transfer from Federal Reserve: 100%.
Agency total resources:
FY 2010 actual: $9,200,000;
FY 2011 approved: $142,825,000;
FY 2012: $329,045,000.
Dodd-Frank related resources:
FY 2010 actual: $9,200,000;
FY 2011 approved: $142,825,000;
FY 2012: $329,045,000.
Agency new FTEs (net):
FY 2010 actual: 0;
FY 2011 approved: 342;
FY 2012: 883.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 342;
FY 2012: 883.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 342;
FY 2012: 883.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
New offices required by Dodd-Frank Act:
* The Bureau of Consumer Financial Protection is itself a new office
required by Dodd-Frank.
Agency Notes: Other agencies (OCC, OTS, FDIC, National Credit Union
Administration, Department of Housing and Urban Development, and the
Federal Reserve) will likely see cost and FTE reductions when their
consumer protection functions are transferred to the CFPB. CFPB's
spending to date (March 2011) contains significant one-time expenses,
close to 40 percent. As the bureau continues to grow, these onetime
expenses should decrease. A reasonable estimate for one-time expenses
in FY 2012 is up to 20 percent of the total budget. Creating estimates
for FY 2011 and FY 2012 was especially challenging for the agency
given the uncertainty of a stand-up phase.
Source: Treasury-provided information.
[End of estimate]
Financial Stability Oversight Council:
FY 2012 Dodd-Frank resources[A]: $7,885,000;
FY 2012 agency-wide total resources: $7,885,000;
(Dodd-Frank resources = 100% of agency total);
FY 2012 agency-wide resources increase: $450,000.
FY 2012 Dodd-Frank new-hire FTEs: 7;
FY 2012 agency-wide FTE increase: 7;
(Dodd-Frank FTEs = 100% of agency increase).
[A] Resources made available or requested for FSOC.
Sources of FSOC FY 2012 resources:
Transfer from Federal Reserve: 75%;
Assessments and revenues: 25%.
Agency total resources:
FY 2010 actual: $0;
FY 2011 approved: $7,435,000;
FY 2012: $7,885,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $7,435,000;
FY 2012: $7,885,000.
Agency new FTEs (net):
FY 2010 actual: 0;
FY 2011 approved: 17;
FY 2012: 7.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 17;
FY 2012: 7.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 17;
FY 2012: 7.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
New offices required by Dodd-Frank Act:
* The Financial Stability Oversight Council is itself a new office
required by Dodd-Frank.
Agency Notes: Beginning in July 2012, all resources will come from
assessments. The FY 2012 budget reflects ongoing staff needs to carry
out the mission of the office. However, as the FSOC continues to
assess its needs, estimates may change.
Source: Treasury-provided information.
[End of estimate]
Office of Financial Research:
FY 2012 Dodd-Frank resources[A]: $74,468,000;
FY 2012 agency-wide total resources: $74,468,000;
(Dodd-Frank resources = 100% of agency total);
FY 2012 agency-wide resources increase: $40,578,000.
FY 2012 Dodd-Frank new-hire FTEs: 135;
FY 2012 agency-wide FTE increase: 135;
(Dodd-Frank FTEs = 100% of agency increase).
[A] Resources made available or requested for OFR.
Sources of OFR FY 2012 resources:
Transfer from Federal Reserve: 75%;
Assessments and revenues: 25%.
Agency total resources:
FY 2010 actual: $0;
FY 2011 approved: $33,890,000;
FY 2012: $74,468,000.
Dodd-Frank related resources:
FY 2010 actual: $0;
FY 2011 approved: $33,890,000;
FY 2012: $74,468,000.
Agency new FTEs (net):
FY 2010 actual: 0;
FY 2011 approved: 33;
FY 2012: 135.
Dodd-Frank new FTEs:
FY 2010 actual: 0;
FY 2011 approved: 33;
FY 2012: 135.
Dodd-Frank new FTEs: New hires:
FY 2010 actual: 0;
FY 2011 approved: 33;
FY 2012: 135.
Dodd-Frank new FTEs: Redirected from other work:
FY 2010 actual: 0;
FY 2011 approved: 0;
FY 2012: 0.
New offices required by Dodd-Frank Act:
* The Office of Financial Research is itself a new office required by
Dodd-Frank.
Agency Notes: Beginning in July 2012, all resources will come from
assessments. FY 2012 estimate includes $10 million in one-time capital
data center costs. As the agency's data architecture and IT
infrastructure plans are developed, the resource and FTE estimates may
change.
Source: Treasury-provided information.
[End of estimate]
[End of section]
Footnotes:
[1] Federal Reserve Flow of Funds database (March 6, 2008 and March
11, 2010). Available at [hyperlink,
http://www.federalreserve.gov/releases/z1].
[2] Pub. L. No. 111-203, 124 Stat. 1376 (2010).
[3] FTE is a staffing measure that reflects the total number of
regular hours employees work divided by the number of compensable
hours in a fiscal year.
[4] We also reviewed the Congressional Budget Office's updated
estimate of the changes in revenue and spending that would result from
implementation of the requirements under the Dodd-Frank Act over the
2010-2020 period. See [hyperlink,
http://www.cbo.gov/doc.cfm?index=12120].
[5] We provided a draft of this statement to the 11 federal agencies
for review and comment. All of the agencies except Treasury provided
technical comments, which we incorporated as appropriate. Treasury did
not have any comments on the information presented on the Department
or on CFPB, FSOC, and OFR.
[6] CFPB will be fully funded through transfers from the earnings of
the Federal Reserve. The amount of funding will be limited to a
certain percentage of the 2009 total operating expenses of the Federal
Reserve, adjusted annually for inflation.
[End of section]
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Phone:
The price of each GAO publication reflects GAO‘s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO‘s Web site,
[hyperlink, http://www.gao.gov/ordering.htm].
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional
information.
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548:
