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Reports
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Ensure Water Quality in GSA-Controlled Facilities
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by defining roles and responsibilities for maintaining water quality in GSA-controlled facilities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that: water quality is maintained through consistent policies and practices nationwide; deviations to PBS’s Drinking Water Quality Management policy and the PBS water safety guidance are approved by PBS’s Central Office; and any water safety policies or guidance developed by regional offices do not contradict policies and guidance issued at the national level.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS’s water safety activities are incorporated into O&M contracts, recorded in PBS’s National Computerized Maintenance Management System, and overseen by PBS personnel.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by incorporating PBS’s water safety oversight responsibilities into quality assurance surveillance plans for O&M contracts to ensure contractor compliance with water safety activities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS personnel and O&M contractors have access to tenant spaces so flushing can be performed.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending O&M and other contracts to ensure that energy efficiency and water conservation requirements do not conflict with PBS’s Drinking Water Quality Management policy and the PBS water safety guidance.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that water is tested in GSA’s child care centers as required by PBS’s Drinking Water Quality Management policy.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring water quality test results—especially those above EPA action levels—are communicated timely to building tenants, GSA child care center operators, and parents and guardians of affected children.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending and implementing PBS’s Drinking Water Quality Management policy to: include reduced occupancy or decreased water usage as additional criteria for lead, copper, Legionella bacteria, and other contaminant testing; ensure requirements in PBS’s Drinking Water Quality Management policy, its companion Desk Guide for Drinking Water Quality Management, and the PBS water safety guidance are incorporated into the amended policy, unless there are safety reasons why such requirements cannot or should not be incorporated; and formalize its requirement to complete additional testing at child care centers that close for extended periods of time.
FDIC Examinations of Government-Guaranteed Loans
Develop and implement guidance to examination staff on the credit, operational (including fraud), liquidity, and compliance risks related to Government-guaranteed loans to ensure staff adequately plans and conducts examinations to identify and address emerging risks.
Develop and implement a training plan to ensure examination staff are trained on the requirements and risks of Government-guaranteed loan programs.
Update, develop, and distribute to FDIC examination personnel a list of FDIC examiners who have significant experience examining banks that specialize in Government-guaranteed loan programs to regional offices.
Develop and implement a process to obtain improved data regarding Government-guaranteed lending activities of FDIC-supervised financial
institutions.
Update the [redacted] MOU to include the sharing of loan portfolio information such as historical loan performance, status of guaranty, and loan-level risk characteristics.
Establish arrangements with other Federal agencies that administer Government-guaranteed loan programs to facilitate information sharing and
proactive identification of risk.
Develop and implement processes and procedures for the routine sharing, receipt, and storage of confidential information with Federal agencies that administer Government-guaranteed loan programs.
Develop and implement guidance to provide instruction to FDIC bank examination staff requiring communication and information sharing with Federal agencies that administer Government-guaranteed loan programs to ensure FDIC staff and the Federal agencies are aware of any emerging risks.
Determine whether other Federal agencies that administer Government-guaranteed loan programs have a list of FDIC-supervised banks with high risk factors associated with such programs and develop protocols to share information with relevant FDIC personnel, including examiners.
Develop and implement guidance to ensure relevant risk information exchanged with Federal Government agencies that administer Government-guaranteed loan programs is shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
Develop and implement updated FDIC examination guidance to establish an appropriate timeframe for uploading complete supervisory business records to RADD.
Develop and implement guidance to examination staff to ensure the staff consistently evaluate Government-guaranteed loans in their review of loan classification, assessment of off-balance sheet risk, concentration risk, and ongoing monitoring.
Update and implement the Examination Profile Script to include additional questions on financial institution participation in Government-guaranteed loan programs in order to identify and address emerging risk.
Develop and implement additional items to the Safety and Soundness Request List to identify Government-guaranteed loans, the performance of those loans, and status of the guaranty.
Issue and implement guidance to require that examination staff conduct a fraud risk assessment on future Government-guaranteed loan programs involving FDIC-insured and FDIC-supervised financial institutions to inform policy decisions.
Ensure guidance on future Government-guaranteed loan programs includes all risks associated with such programs and has instructions to allow for consistency in supervisory activities.
Issue and implement guidance for examiners clarifying the FDIC supervisory expectations for reviewing bank PPP activities, including the level of PPP loan volume triggering a heightened review, how examiners should assess the PPP activities of banks that have existing BSA/AML weaknesses, and protocols for examination staff to communicate observed weaknesses.
Revise and implement FDIC guidance and practices for assessing concentrations and loan classification to ensure uniform application with the other Federal bank regulators of supervisory approaches to banks
Coordinate with the other Federal bank regulators to ensure uniform application of supervisory approaches to banks regarding concentrations and loan classification.