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Testimony: 

Before the Subcommittee on Oversight, Committee on Ways and Means, 
House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EST:
Thursday, March 19, 2009: 

Troubled Asset Relief Program: 

Status of Efforts to Address Transparency and Accountability Issues: 

Statement of Gene L. Dodaro: 
Acting Comptroller General of the United States: 

GAO-09-484T: 

[End of section] 

Mr. Chairman, Ranking Member Boustany, and Members of the Subcommittee: 

I am pleased to be here today to discuss our work on the Troubled Asset 
Relief Program (TARP), under which the Department of the Treasury 
(Treasury) has the authority to purchase and insure up to $700 billion 
in troubled assets held by financial institutions through its Office of 
Financial Stability (OFS).[Footnote 1] As you know, Treasury was 
granted this authority in response to the financial crisis that has 
threatened the stability of the U.S. banking system and the solvency of 
numerous financial institutions. The Emergency Economic Stabilization 
Act (the act) that authorized TARP on October 3, 2008, requires GAO to 
report at least every 60 days on findings resulting from our oversight 
of the actions taken under the program.[Footnote 2] We are also 
responsible for auditing OFS's annual financial statements and for 
producing special reports on any issues that emerge from our oversight. 
To carry out these oversight responsibilities, we have assembled 
interdisciplinary teams with a wide range of technical skills, 
including financial market and public policy analysts, accountants, 
lawyers, and economists who represent combined resources from across 
GAO. In addition, we are building on our in-house technical expertise 
with targeted new hires and experts. The act also created additional 
oversight entities--the Congressional Oversight Panel (COP) and the 
Special Inspector General for TARP (SIGTARP)--that also have reporting 
responsibilities. We are coordinating our work with COP and SIGTARP and 
are meeting with officials from both entities to share information and 
coordinate our oversight efforts. These meetings help to ensure that we 
are collaborating as appropriate and not duplicating efforts. 

My statement today is based primarily on our January 30, 2009 report, 
the second under the act's mandate, which covers the actions taken as 
part of TARP through January 23, 2009, and follows up on the nine 
recommendations we made in our December 2, 2008 report.[Footnote 3] 
This statement also provides additional information on some recent 
program developments, including Treasury's new financial stability plan 
and, as you requested, provides some insights on our ongoing work on 
the implications of actions related to the financial crisis on federal 
debt management. Our oversight work under the act is ongoing, and our 
next report is due to be issued by March 31, 2009, as required. 

Specifically, this statement focuses on (1) the nature and purpose of 
activities that have been initiated under TARP; (2) the status of OFS's 
hiring efforts, use of contractors, and development of a system of 
internal control; (3) implications of TARP and other events on federal 
debt management, and (4) preliminary indicators of TARP's performance. 
To do this work, we reviewed documents related to TARP, including 
contracts, agreements, guidance, and rules. We also met with OFS, 
contractors, federal agencies, and officials from all eight of the 
first large institutions to receive disbursements. We plan to continue 
to monitor the issues highlighted in our prior reports, as well as 
future and ongoing capital purchases, other more recent transactions 
undertaken as part of TARP (for example, guarantees on assets of 
Citigroup and Bank of America), and the status of other aspects of 
TARP. 

We conducted this performance audit between December 2008 and March 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Summary: 

Treasury has announced a number of new programs to try to stabilize 
financial markets, but most of its activities during this period have 
continued to fall under its Capital Purchase Program (CPP). As of March 
5, 2009, Treasury had disbursed approximately $300 billion in TARP 
funds, about $197 billion of it for CPP. Treasury has recently 
announced the Financial Stability Plan, which outlines a set of 
measures to address the financial crisis and restore confidence in the 
U.S. financial and housing markets, and the Making Home Affordable 
program to mitigate foreclosures and preserve homeownership. Treasury 
also has taken important steps since our first report to implement all 
nine of our recommendations. However, due in part to the short time 
that has elapsed since our first report, we continued to identify a 
number of areas that warrant Treasury's ongoing attention. We 
recommended in our latest report that Treasury continue to take action 
to further improve the program's transparency and accountability and 
more clearly articulate and communicate a strategic vision for TARP. 
Specifically, we recommended that Treasury: 

* expand the scope of the monthly CPP surveys for the 20 largest banks 
to include collecting at least some information from all institutions 
participating in the program; 

* ensure that future CPP agreements include a mechanism that will 
better enable Treasury to track the use of the capital infusions and 
seek to obtain similar information from existing CPP participants; 

* establish a process to ensure compliance with all CPP requirements, 
including those associated with limitations on dividends and stock 
repurchase restrictions; 

* communicate a clearly articulated vision for TARP and how all 
individual programs are intended to work in concert to achieve that 
vision, which incorporates actions to preserve homeownership; and once 
this vision is clearly articulated, document the skills and 
competencies needed within the department to carry it out; 

* continue to expeditiously hire personnel needed to carry out and 
oversee TARP; 

* expedite efforts to ensure that sufficient personnel are assigned and 
properly trained to oversee the performance of all contractors, 
especially for contracts priced on a time-and-materials basis, and move 
toward fixed-price arrangements whenever possible as program 
requirements are better defined over time; 

* develop a comprehensive system of internal controls over TARP, 
including policies, procedures, and guidance for program activities 
that are robust enough to ensure that the program's objectives and 
requirements are met; 

* develop and implement a well-defined and disciplined risk-assessment 
process, which is essential to monitoring program status and 
identifying any risks of potential inadequate funding of announced 
programs; and: 

* review and renegotiate existing conflict-of-interest mitigation 
plans, as necessary, to enhance specificity and conformity with the new 
interim conflict-of-interest regulation and take continued steps to 
manage and monitor conflicts of interest and enforce mitigation plans. 

Consistent with our recommendations, the recently announced Financial 
Stability Plan outlined some steps Treasury is taking to improve the 
transparency and accountability of new programs going forward. But 
Treasury still faces several challenges. First, our December 2008 
report emphasized the lack of monitoring and reporting for CPP 
investments and recommended stronger measures for ensuring that 
participating institutions use the funds to meet the program's purpose 
and comply with CPP requirements on, for example, executive 
compensation and dividend payments. In response to our recommendation, 
Treasury completed its initial survey of the 20 largest institutions to 
monitor lending and other activities and announced plans to analyze 
quarterly monitoring data (call reports) for all reporting 
institutions.[Footnote 4] In addition, Treasury is developing a more 
limited monthly survey of lending by smaller institutions participating 
in the program. These efforts are important steps toward strengthening 
CPP's transparency and accountability, and we will continue to examine 
Treasury's effort to fully implement these monitoring efforts. Second, 
Treasury has continued to develop a system to ensure compliance with 
CPP requirements, including executive compensation, dividend payments, 
and repurchase of stocks, but it has not yet finalized its plans for 
detecting noncompliance and taking enforcement actions. Third, we noted 
that Treasury had made limited progress in articulating and 
communicating an overall strategic vision for TARP and continued to 
respond to institution-and industry-specific needs. This lack of 
clarity has complicated Treasury's ability to effectively communicate 
to Congress, the financial markets, and the public. As Treasury 
provides more details on its new Financial Stability Plan, its 
strategic approach to addressing the financial crisis may become 
clearer. 

Treasury had taken steps to help ensure a smooth transition to the new 
administration by keeping positions filled and using an expedited 
hiring process. However, it continues to face difficulty providing 
competitive salaries to attract skilled employees. Also, given the 
program's evolving nature and the changes under the new administration, 
Treasury needs to identify OFS's long-term organizational needs. 
Additionally, consistent with our recommendation about contracting 
oversight, Treasury has enhanced such oversight by tracking costs, 
schedules, and performance and addressing the training requirements of 
personnel who oversee the contracts. As we previously recommended, 
Treasury needs to continue to identify and mitigate conflicts of 
interest in contracting. Similarly, OFS has adopted a framework for 
developing and implementing its system of internal control for TARP 
activities that is consistent with our recommendation. However, as of 
our January report, OFS had yet to implement a disciplined risk- 
assessment process. 

Given that TARP activities have only recently been implemented and that 
time lags occur in the reporting of available data, it is too soon to 
see measurable results in many areas. Even with more time and better 
data, it will remain difficult to separate the impact of TARP 
activities from the effects of other economic forces. Credit market 
indicators we have identified demonstrate that between our December and 
January reports, the cost of credit declined in interbank, mortgage, 
and corporate debt markets. Conversely, while perceptions of risk (as 
measured by premiums over Treasury bonds) have declined in interbank 
markets, they appeared to have changed little in the corporate bond and 
mortgage markets. However, attributing any of these changes directly to 
TARP continues to be problematic because of the range of actions that 
have been and are being taken to address the current crisis. While our 
indicators may be suggestive of TARP's ongoing impact, no single 
indicator or set of indicators can provide a definitive determination 
of the program's impact. 

Finally, these financial stability efforts, as well as the economic 
slowdown and the government's policy response to the slowdown, all add 
to the borrowing needs of the government. Treasury's outstanding debt 
has increased significantly, and the share of it that is short-term has 
grown. The drop in interest rates--especially for shorter-term debt-- 
has lowered Treasury's cost of borrowing, but having such a large share 
of debt maturing in the short term presents challenges to Treasury. 
Market experts believe Treasury would benefit from lengthening its 
maturity profile. To support Congress' oversight of the use of TARP 
funds we have work underway looking at how Treasury has financed 
borrowing associated with the recent financial crisis and at additional 
ideas for debt management that might make sense going forward. 

Treasury Has Continued to Focus On CPP, but a Variety of Other Programs 
Have Been Created or Are Being Planned: 

Treasury has continued to focus on CPP, but a variety of other programs 
have been created or are in progress, as shown in table 1. As of March 
5, 2009, Treasury had disbursed almost 80 percent of the $250 billion 
it had allocated for CPP to purchase almost $197 billion in preferred 
shares of 467 qualified financial institutions (table 1).[Footnote 5] 
Treasury also has begun to receive dividend payments relating to 
capital purchases under CPP and other programs. According to Treasury, 
as of February 17, 2009, it had received about $2.4 billion. 

Table 1: Status of TARP Funds as of March 5, 2009 (dollars in 
billions): 

Program: Capital Purchase Program; 
Disbursed: $196.8. 

Program: Systemically Significant Failing Institutions; 
Disbursed: $40.0. 

Program: Targeted Investment Program; 
Disbursed: $40.0. 

Program: Automotive Industry Financing Program; 
Disbursed: $23.7. 

Program: Citigroup Asset Guarantee; 
Disbursed: $0.0. 

Program: Bank of America Asset Guarantee; 
Disbursed: $0.0. 

Program: Making Home Affordable Program; 
Disbursed: $0.0. 

Program: Term Asset-backed Securities Loan Facility; 
Disbursed: $0.0. 

Program: Consumer & Business Lending Initiative; 
Disbursed: $0.0. 

Program: Totals; 
Disbursed: $300.5. 

Source: Treasury OFS, unaudited. 

[End of table] 

Initially, Treasury approved $125 billion in capital purchases for nine 
of the largest public financial institutions that federal banking 
regulators and Treasury considered to be systemically significant to 
the operation of the financial system.[Footnote 6] At the time, these 
nine institutions held about 55 percent of U.S. banking assets. 
Subsequent purchases were made in qualified institutions of various 
sizes (in terms of total assets) and types. As we noted in our January 
report, most of the institutions that received CPP capital were 
publicly held institutions, although a limited number of privately held 
institutions and community development financial institutions (CDFI) 
also received funds.[Footnote 7] 

Treasury has taken a number of important steps toward better reporting 
on and monitoring of CPP. These steps are in keeping with our prior 
recommendations that Treasury bolster its ability to determine whether 
institutions are using CPP proceeds in ways that are consistent with 
the act's purposes and establish mechanisms to monitor compliance with 
program requirements. However, Treasury needs to take further steps in 
this area. Treasury has done an initial survey of the largest 
institutions to monitor their lending and other activities and 
announced plans to analyze quarterly monitoring data (call reports) for 
all reporting institutions. In addition, Treasury is developing a more 
limited monthly survey of lending by smaller institutions participating 
in the program. These efforts are important steps toward ensuring that 
all participating institutions are held accountable for their use of 
the funds and are consistent with our past recommendation that Treasury 
seek similar information from existing CPP participants.. We will 
continue to monitor Treasury's oversight efforts as well as the 
consistency of the approval process in future work. 

Treasury has also continued to take steps to increase its planned 
oversight of compliance with terms of the CPP agreements including 
limitations on executive compensation, dividends, and stock 
repurchases. Among these steps, Treasury has named an Interim Chief 
Compliance Officer. However, Treasury has not finalized its plans for 
detecting noncompliance with CPP requirements or for taking enforcement 
actions. Without a more structured mechanism in place to ensure 
compliance with all CPP requirements, and as more institutions continue 
to participate in the program, ensuring compliance with these aspects 
of the program will become increasingly important and challenging. In 
its recently announced Financial Stability Plan, Treasury called for 
banks receiving future government funds to be held responsible for 
appropriate use of those funds through (1) stronger restrictions on 
dividend payment and executive compensation, and (2) enhanced reporting 
to the public, including reporting on lending activity. In addition, 
Treasury is in the process of drafting new regulations to implement the 
executive compensation requirements in the American Recovery and 
Reinvestment Act of 2009 (the Recovery Act).[Footnote 8] We will also 
continue to monitor the system that Treasury develops to ensure 
compliance with the agreements and the implementation of additional 
oversight and accountability efforts under its new plan. 

Treasury has also continued to make some progress in improving the 
transparency of TARP and a few weeks ago announced its plans for the 
remaining TARP funds. In our December 2008 report, we first raised 
questions about the effectiveness of Treasury's communication strategy 
for TARP with Congress, the financial markets, and the public. These 
questions were further heightened in the COP's January report, which 
raised similar questions about Treasury's strategy for TARP. In 
response to our recommendation about its communication strategy, 
Treasury noted numerous publicly available reports, testimonies, and 
speeches. However, even after reviewing these items collectively, we 
found that Treasury's strategic vision for TARP remained unclear. For 
example, Treasury initially outlined a strategy to purchase whole loans 
and mortgage-backed securities from financial institutions, but changed 
direction to make capital investments in qualifying financial 
institutions as the global community opted to move in this direction. 
However, once Treasury determined that capital infusions were 
preferable to purchasing whole mortgages and mortgage-backed 
securities, it did not clearly articulate how the various programs-- 
such as CPP, the Systemically Significant Failing Institutions (SSFI) 
program, and the Targeted Investment Program (TIP)--would work 
collectively to help stabilize financial markets. For instance, 
Treasury has used similar approaches--capital infusions--to stabilize 
healthy institutions under CPP as well as SSFI and TIP, albeit with 
more stringent requirements. Moreover, with the exception of 
institutions selected for TIP being viewed as able to raise private 
capital, both SSFI and TIP share similar selection criteria. Further, 
the same institution may be eligible for multiple programs. At least 
two institutions (Citigroup and Bank of America) currently participate 
in more than one program, adding to the confusion about Treasury's 
strategy and vision for implementing TARP. Other actions also have 
raised additional questions about Treasury's strategy. For example, 
Treasury announced the first institution under TIP weeks before the 
program was established. Similarly, the Asset Guarantee Program was 
established after Treasury announced that it would guarantee assets 
under such a program, but many of the details of the program have yet 
to be worked out. 

Since our January report, Treasury has taken three key actions related 
to our recommendation about the need for a clearly articulated vision 
for the program. On February 10, Treasury announced the Financial 
Stability Plan, which outlined a set of measures to address the 
financial crisis and restore confidence in U.S. financial and housing 
markets. The plan appears to be an approach designed to resolve the 
credit crisis by restarting the flow of credit to consumers and 
businesses, strengthening financial institutions, and providing aid to 
homeowners and small businesses. On February 25, Treasury announced the 
standardized terms and conditions for eligible financial institutions 
participating in the Capital Assistance Program (CAP). Under CAP, an 
eligible institution that is found by its federal banking regulator to 
need additional capital to continue lending and absorb losses in a 
severe economic downturn will be eligible to participate in 
CAP.[Footnote 9] Such institutions will be eligible to receive a 
capital investment from Treasury, with regulatory approval, in the form 
of preferred securities that are convertible into common equity to help 
absorb losses and serve as a bridge to receiving private capital. A key 
element of Treasury's Financial Stability Plan, CAP is designed to 
ensure that, in severe economic conditions, the largest U.S. bank 
holding companies have sufficient capital to support lending to 
creditworthy homeowners and businesses. As part of this effort, the 
federal banking regulators--the Board of Governors of the Federal 
Reserve System, Office of the Comptroller of the Currency, Federal 
Deposit Insurance Corporation, and Office of Thrift Supervision-- 
announced that they will begin conducting a one-time forward-looking 
capital assessment (or stress test) of the balance sheets of the 19 
largest bank holding companies with assets exceeding $100 billion. 
These institutions are required to participate in the coordinated 
supervisory capital assessment and may obtain additional capital from 
CAP if necessary.[Footnote 10] Regulators noted that the capital 
assessment process for all eligible institutions is expected to be 
completed by April 30, 2009. 

On March 4, 2009, Treasury unveiled its Making Home Affordable program, 
which is based in part on the use of TARP funds. Among other things, 
the plan is designed to do the following: 

* It will use $75 billion ($50 billion from TARP funds) to modify the 
loans of up to 3-4 million homeowners to avoid potential foreclosure. 
The goal of modifying the mortgages of these homeowners is to reduce 
the amount owed per month to sustainable levels (a mortgage debt-to- 
income ratio of 31 percent). Treasury will share the cost of 
restructuring the mortgages with the other stakeholders (e.g., 
financial institutions holding whole loans or investors if loans have 
been securitized). Treasury announced a series of financial incentives 
for the loan servicers, mortgage holders/investors, and borrowers that 
are intended to "pay for success," encourage borrowers to continue 
paying on time under the modified loan, and encourage servicers and 
mortgage holders/investors to modify at-risk loans before the borrower 
falls behind on a payment. 

* It includes an initiative to help up to 4-5 million homeowners to 
refinance loans owned or guaranteed by Freddie Mac and Fannie Mae at 
current market rates. According to Treasury, these homeowners would not 
otherwise be able to refinance their loans at the conforming loan rates 
because the declining value of their homes has left them with little or 
no equity. Refinancing at current mortgage rates could help homeowners 
save thousands of dollars on their annual mortgage payments. 

* It increases Treasury's funding commitment to Fannie Mae and Freddie 
Mac to ensure the strength and security of the mortgage market and to 
help maintain mortgage affordability. The $200 billion funding 
commitment is based on authority granted to Treasury under the Housing 
and Economic Recovery Act of 2008.[Footnote 11] 

We will continue to monitor the development and implementation of 
Treasury's plan, including how its actions address the challenges we 
have previously identified.[Footnote 12] 

Treasury also established the Auto Industry Financing Program (AIFP) in 
December 2008 to prevent a disruption of the domestic automotive 
industry that would pose systemic risk to the nation's economy. Under 
this program, Treasury has lent $13.4 billion to GM and $4 billion to 
Chrysler to allow the automakers to continue operating while working 
out details of their plans to become solvent, such as achieving 
concessions with stakeholders. The loans were designed to allow the 
automakers to operate through the first quarter of 2009 with 
recognition that after that point GM and Chrysler would need additional 
funds or have to take other steps, such as an orderly bankruptcy. 
[Footnote 13] As required by the terms of their loan agreements, GM and 
Chrysler submitted restructuring plans to Treasury in February that 
describe the actions the automakers will take to become financially 
solvent. Because of the continued sluggish economy and lower than 
expected revenues, GM and Chrysler are requesting an additional $16.6 
billion and $5 billion in federal financial assistance, respectively. 
Treasury is currently assessing the automakers' restructuring plans and 
determining what the government's role will be in future assistance. By 
March 31, 2009, GM and Chrysler must report to the Secretary of the 
Treasury on their progress in implementing these restructuring plans. 
The Secretary will then determine whether the companies have made 
sufficient progress in implementing the restructuring plans; if they 
have not, the loans are automatically accelerated and become due 30 
days later. As part of our oversight responsibilities for TARP, we are 
monitoring Treasury's implementation of AIFP, including the auto 
manufacturers' use of federal funds and development of the required 
restructuring plans. 

Efforts to Establish OFS Are Ongoing: 

Treasury has made progress in establishing its management 
infrastructure for TARP, including in hiring, overseeing contracts, and 
establishing internal controls. However, hiring for OFS is still 
ongoing, Treasury is working to improve its oversight of contractors, 
and its development of a system of internal control is still evolving. 

* In the hiring area--one that we highlighted in our first report-- 
Treasury took steps to help maintain continuity of leadership within 
OFS during and after the transition to the new administration. 
Specifically, Treasury ensured that interim chief positions would be 
filled to ensure a smooth transition and used direct-hire authority and 
various other appointments to bring a number of career staff on board 
quickly. OFS has increased its overall staff since our December 2008 
report from 48 to 90 employees as of January 26, which includes an 
increase of permanent staff from 5 to 38. Treasury officials recently 
told us that the number of permanent staff had increased to 60. While 
progress has been made since our last report, the number of temporary 
and contract staff who will be needed to serve long-term organizational 
needs remains unknown. Because TARP has added many new programs since 
it was first established in October and program activities are changing 
under the new administration, we recognize that Treasury may find it 
difficult to determine OFS's long-term organizational needs at this 
time. However, such considerations will be vital to retaining 
institutional knowledge in the organization. 

* Treasury's use of existing contract flexibilities has enabled it to 
enter into agreements and award contracts quickly in support of TARP. 
However, Treasury's use of time-and-materials contracts, although 
authorized when flexibility is needed, can increase the risk that 
government dollars will be wasted unless adequate mechanisms are in 
place to oversee contractor performance. In this regard, Treasury has 
improved its oversight of contractors, including those using time-and- 
materials pricing. In addition, while Treasury has taken the important 
step of recently issuing an interim regulation outlining the process 
for reviewing and addressing conflicts of interest among new 
contractors and financial agents, it is still reviewing existing 
contracts or agreements to ensure conformity with the new regulation. 
We believe this step is a necessary component of a comprehensive and 
complete system to ensure that all conflicts are fully identified and 
appropriately addressed. 

* OFS has adopted a framework for developing and implementing its 
system of internal control for TARP activities. OFS plans to use this 
framework to develop specific policies, drive communications on 
expectations, and measure compliance with internal control standards 
and policies. However, it has yet to develop comprehensive written 
policies and procedures governing TARP activities or implement a 
disciplined risk-assessment process. 

In each of these areas, we made additional recommendations. 
Specifically, we recommended that Treasury continue to expeditiously 
hire personnel needed to carry out and oversee TARP. For contracting 
oversight, we recommended that Treasury expedite efforts to ensure that 
sufficient personnel are assigned and properly trained to oversee the 
performance of all contractors, especially for contracts priced on a 
time-and-materials basis, and move toward fixed-price arrangements 
whenever possible as program requirements are better defined over time. 
We also recommended that Treasury review and renegotiate existing 
conflict-of-interest mitigation plans, as necessary, to enhance 
specificity and conformity with the new interim conflicts of interest 
regulation and that it take continued steps to manage and monitor 
conflicts of interest and enforce mitigation plans. Finally, we 
recommended that Treasury, in addition to developing a comprehensive 
system of internal controls, develop and implement a well-defined and 
disciplined risk-assessment process, because such a process is 
essential to monitoring the status of TARP programs and identifying any 
risks that announced programs will not be adequately funded. We will 
continue to monitor OFS's hiring and contracting practices and 
implementation of the internal control framework, which is vital to 
TARP's effectiveness. 

Measuring the Impact of TARP on the Credit Markets and the Economy 
Continues to Be Challenging: 

It is still too early in TARP's implementation to see measurable 
results in many areas given that program actions have only recently 
occurred and there are time lags in the reporting of data. Even with 
more time and better data, it will remain difficult to separate the 
impact of TARP activities from the effects of other economic forces. 
Some indicators suggest that the cost of credit has declined in 
interbank, mortgage, and corporate debt markets since the December 
report. However, while perceptions of risk (as measured by premiums 
over Treasury securities) have declined in interbank markets, they have 
changed very little in corporate bond and mortgage markets. Finally, as 
noted in December, these indicators may be suggestive of TARP's ongoing 
impact, but no single indicator or set of indicators can provide a 
definitive determination of its effects because of the range of actions 
that have been and are being taken to address the current crisis. These 
include coordinated efforts by U.S. regulators--namely, the Federal 
Deposit Insurance Corporation, the Board of Governors of the Federal 
Reserve System, and the Federal Housing Finance Agency--as well as 
actions by financial institutions to mitigate foreclosures. For 
example, a large drop in mortgage rates occurred shortly after the 
Federal Reserve announced it would purchase up to $500 billion in 
mortgage-backed securities, highlighting the fact that policies outside 
of TARP may have important effects on credit markets. We will continue 
to refine and monitor the indicators. Additionally, we plan to use the 
Treasury survey data in our efforts to evaluate changes in lending 
activity resulting from CPP. We recognize that the data has certain 
limitations primarily that it is self-reported and difficult to 
benchmark because it is unique. Nonetheless, we think it will prove 
valuable in future analyses. 

Federal Debt Management Challenges: 

You also asked that I discuss the impact of TARP and related activities 
on the national debt and borrowing. Congress has assigned to the 
Treasury Department the responsibility to borrow the funds necessary to 
finance the gap between cash in and cash out subject to a statutory 
limit. Since the onset of the current recession in December 2007, the 
gap between revenues and outlays has grown. Because the Treasury must 
borrow the funds disbursed, TARP and other actions taken to stabilize 
the financial markets increase the need to borrow so adding to the 
federal debt. Also, federal borrowing needs typically increase during 
an economic downturn--largely because tax revenues decline while 
expenditures increase for programs to assist those affected by the 
downturn. In addition, the American Recovery and Reinvestment Act 
enacted on February 17, 2009 contains both decreases in revenues and 
increases in spending. Further, all of this takes place in the context 
of the longer-term fiscal outlook, which will present Treasury with 
continued financing challenges even after the return of financial 
stability and economic growth. 

Treasury's primary debt management goal is to finance the government's 
borrowing needs at the lowest cost over time. Issuing debt through 
regularly scheduled auctions lowers borrowing costs because investors 
and dealers value liquidity and certainty of supply. Treasury issues 
marketable securities that range in maturity from one month to 30 years 
and sells them at auction on a pre-announced schedule.[Footnote 14] The 
mix of securities that Treasury has outstanding changes regularly as 
new debt is issued. The mix of securities is important because it can 
have a significant influence on the federal government's interest 
payments. Longer-term securities typically carry higher interest rates-
-or cost to the government--primarily due to concerns about future 
inflation. However, these longer-term securities offer the government 
the certainty of knowing what the Treasury's payments will be over a 
longer period. 

At the end of February 2009, Treasury's outstanding marketable 
securities stood at just under $6 trillion--an increase of $1.476 
trillion since December 31, 2007. As shown in figure 1, a large portion 
of this debt increase was in the form of short-term cash management 
bills (CM bills). Between October 1, 2008 and February 28, 2009 
Treasury issued $1.035 trillion in CM bills, of which $510 billion were 
outstanding at the end of February. 

Figure 1: Changes in Outstanding Marketable Treasury Securities from 
Dec. 31, 2007 to Feb. 28, 2009 (Total Outstanding as of February 28, 
2009 = $5,989 billion): 

[Refer to PDF for image: stacked vertical bar graph] 

Treasury notes: 
Outstanding marketable Treasury securities as of 12/31/2007: $2488 
billion; 
Increase in marketable Treasury securities from 12/31/2007 to 
2/28/2009: $403 billion. 

Treasury bills: 
Outstanding marketable Treasury securities as of 12/31/2007: $1004 
billion; 
Increase in marketable Treasury securities from 12/31/2007 to 
2/28/2009: $472 billion. 

Treasury bonds: 
Outstanding marketable Treasury securities as of 12/31/2007: $559 
billion; 
Increase in marketable Treasury securities from 12/31/2007 to 
2/28/2009: $51 billion. 

Treasury inflation protected securities: 
Outstanding marketable Treasury securities as of 12/31/2007: $472 
billion; 
Increase in marketable Treasury securities from 12/31/2007 to 
2/28/2009: $40 billion. 

Cash management bills: 
Outstanding marketable Treasury securities as of 12/31/2007: 0; 
Increase in marketable Treasury securities from 12/31/2007 to 
2/28/2009: $510 billion. 

Source: GAO analysis of Treasury data. 

Note (1): Does not include $14 billion in marketable securities 
outstanding for the Federal Financing Bank. 

Note (2): Treasury bills have maturities of 1 year or less. Notes have 
maturities of a year or more to 10 years and bonds have maturities of 
greater than 10 years. Currently Treasury issues Treasury Inflation 
Protected Securities with maturities ranging from 5 to 20 years. 

[End of figure] 

Interest rates have decreased dramatically since the start of the 
financial crisis, particularly for short-term debt. Figure 2 below 
illustrates the size of that drop. 

Figure 2: Interest Rates on Treasury Securities: 

[Refer to PDF for image: multiple line graph] 

Treasury security: 1-month bills; 
Daily average Treasury rate in 2007: 4.41%; 
Daily average Treasury rate January 1 - March 5, 2009: 0.13%. 

Treasury security: 3-month bills; 
Daily average Treasury rate in 2007: 4.48	
Daily average Treasury rate January 1 - March 5, 2009: 0.21%. 

Treasury security: 6-month bills; 
Daily average Treasury rate in 2007: 4.62%; 
Daily average Treasury rate January 1 - March 5, 2009: 0.38%. 

Treasury security: 1-year bills; 
Daily average Treasury rate in 2007: 4.53%; 
Daily average Treasury rate January 1 - March 5, 2009: 0.55%. 

Treasury security: 2-year notes; 
Daily average Treasury rate in 2007: 4.36%; 
Daily average Treasury rate January 1 - March 5, 2009: 0.89%. 

Treasury security: 3-year notes; 
Daily average Treasury rate in 2007: 4.35%; 
Daily average Treasury rate January 1 - March 5, 2009: 1.26%. 

Treasury security: 5-year notes; 
Daily average Treasury rate in 2007: 4.43%; 
Daily average Treasury rate January 1 - March 5, 2009: 1.74%. 

Treasury security: 7-year notes; 
Daily average Treasury rate in 2007: 4.51%; 
Daily average Treasury rate January 1 - March 5, 2009: 2.18%. 

Treasury security: 10-year notes; 
Daily average Treasury rate in 2007: 4.63%; 
Daily average Treasury rate January 1 - March 5, 2009: 2.71%. 

Treasury security: 20-year bond; 
Daily average Treasury rate in 2007: 4.91%; 
Daily average Treasury rate January 1 - March 5, 2009: 3.66%. 

Treasury security: 30-year bond; 
Daily average Treasury rate in 2007: 4.84%; 
Daily average Treasury rate January 1 - March 5, 2009: 3.38%. 

Source: GAO analysis of Federal Reserve data. 

[End of figure] 

The impact of this drop can be seen in lower borrowing costs--indeed, 
the budget shows net interest declining in fiscal year 2009. Although 
these relatively low interest rates have reduced Treasury's borrowing 
costs, the increasing amount of short-term debt that needs to be rolled 
over does present challenges. As shown in figure 3, approximately $2.5 
trillion--or 41 percent of total outstanding marketable securities will 
mature in 2009--and will have to be refinanced. As Treasury borrows to 
meet its current needs, Treasury must also plan for rolling over large 
amounts of debt in the short term. 

Figure 3: Marketable Securities by Year of Maturity, as of February 28, 
2009 (Total Outstanding - $5,989 billion): 

[Refer to PDF for image: vertical bar graph] 

Year of maturity: 2009: 
Amount: $2464 billion; 
Percentage: 41%. 

Year of maturity: 2010-2014: 
Amount: $2111 billion; 
Percentage: 35%. 

Year of maturity: 2015-2019; 
Amount: $794 billion; 
Percentage: 13%. 

Year of maturity: 2020-2029; 
Amount: $439 billion; 
Percentage: 7%; 

Year of maturity: 2030-2039; 
Amount: $167 billion; 
Percentage: 3%. 

Source: GAO analysis of Treasury data. 

Note: Does not include $14 billion in marketable securities outstanding 
for the Federal Financing Bank. 

[End of figure] 

Treasury has said that it "recognizes the need to monitor short-term 
issuance versus longer dated issuance." Market experts generally 
believe that Treasury needs to increase the average maturity of its 
debt portfolio in part to lock in relatively low long-term rates and to 
ensure adequate borrowing capacity in the coming years. To support 
Congress' oversight of the use of TARP funds we have work underway 
looking at how Treasury has financed borrowing associated with the 
recent financial crisis and at additional ideas for debt management 
that might make sense going forward. 

Total borrowing will increase by trillions of dollars this year, not 
solely due to TARP and other activities aimed at stabilizing the 
financial system. Debt also grows in response to the economic slowdown 
as revenues fall and spending for some programs grows. Further, both 
the tax and spending provisions of the Recovery Act will also increase 
debt. All of this contributes to the borrowing challenge faced by the 
Treasury. As this Committee well knows, debt is also held in 
governmental accounts--such as the Social Security Trust Fund. This 
debt is included in the total debt subject to limit.[Footnote 15] The 
debt limit was increased by the Emergency Economic Stabilization Act of 
2008 and the Recovery Act, but with only $1.2 trillion remaining under 
the limit, it will have to be raised again. 

The combination of slower growth and greater debt lead to increases in 
publicly-held debt as a share of our economy--The President's budget 
projects debt reaching 65 percent of gross domestic product in 2010 and 
remaining at that level for the rest of the decade. Today Congress, the 
executive branch and the American people are understandably focused on 
restoring financial stability and economic growth. At some point, 
however, the nation's leaders will need to apply the same level of 
intensity to the serious long-term fiscal challenges facing the federal 
government. 

Mr. Chairman and Members of the Subcommittee, I appreciate the 
opportunity to discuss this critically important issue and would be 
happy to answer any questions that you may have. Thank you. 

Contact: 

For further information on this testimony, please contact Thomas J. 
McCool on (202) 512-2642 or mccoolt@gao.gov. 

[End of section] 

Footnotes: 

[1] GAO, Troubled Asset Relief Program: Status of Efforts to Address 
Transparency and Accountability Issues, [hyperlink, 
http://www.gao.gov/products/GAO-09-296] (Washington D.C.: Jan. 30, 
2009) and Troubled Asset Relief Program: Additional Actions Needed to 
Better Ensure Integrity, Accountability, and Transparency, [hyperlink, 
http://www.gao.gov/products/GAO-09-161] (Washington, D.C.: Dec. 2, 
2008). 

[2] Emergency Economic Stabilization Act of 2008, Pub. L. No. 110-343, 
122 Stat. 3765 (2008). The act requires the U.S. Comptroller General to 
report at least every 60 days, as appropriate, on findings resulting 
from oversight of TARP's performance in meeting the act's purposes; the 
financial condition and internal controls of TARP, its representatives, 
and agents; the characteristics of asset purchases and the disposition 
of acquired assets, including any related commitments entered into; 
TARP's efficiency in using the funds appropriated for its operations; 
its compliance with applicable laws and regulations; and its efforts to 
prevent, identify, and minimize conflicts of interest among those 
involved in its operations. 

[3] Information is current as of January 23, 2009, unless otherwise 
noted in the statement. 

[4] Call reports are quarterly reports that collect basic financial 
data of commercial banks in the form of a balance sheet and income 
statement (formally known as Report of Condition and Income). 

[5] Through December 31, 2008, TARP capital purchases and loans totaled 
$247 billion. Congressional Budget Office (CBO) estimated the subsidy 
cost for these transactions at $64 billion, or 26 percent, using 
valuation procedures similar to those specified in the Federal Credit 
Reform Act and adjusted for market risk as specified in the Emergency 
Economic Stabilization Act. See Congressional Budget Office, The 
Troubled Asset Relief Program: Report on Transactions Through December 
31, 2008 (Jan. 2009). COP estimated the subsidy cost at $78 billion, or 
31 percent, using multiple valuation methods and an evaluation of 
similar private transactions. See Congressional Oversight Panel, 
February Oversight Report: Valuing Treasury's Acquisitions (Feb. 6, 
2009). In connection with our audit of TARP's financial statements, we 
will be evaluating and testing the credit subsidy model that TARP uses 
to value capital purchases and loans for financial reporting purposes. 

[6] While Treasury approved $125 billion to the nine largest 
institutions, it initially disbursed funds to eight. The $10 billion to 
Merrill Lynch was not disbursed until January 9, 2009, after its merger 
with Bank of America was completed. 

[7] CDFIs are specialized financial institution working in market 
niches that are underserved by traditional financial institutions. 
CDFIs provide a range of financial products and services such as 
mortgage financing for low-income and first-time homebuyers and not- 
for-profit developers; flexible underwriting and risk capital for 
needed community facilities; and technical assistance, commercial loans 
and investments to small start-up or expanding businesses in low-income 
areas. 

[8] Pub. L. No. 111-5, div. B, title VII, § 7001 (Feb. 17, 2009) 
(amending section 111 of EESA). 

[9] According to Treasury and the federal banking regulators, 
eligibility will be consistent with the criteria and deliberative 
process established for identifying qualified financial institutions in 
the existing Capital Purchase Program. 

[10] Eligible institutions with less than $100 billion in risk-weighted 
assets are also eligible to participate in CAP. Risk-weighted assets 
are the total of all assets held by the bank that are weighted for 
credit risk according to a formula established in regulation by the 
Federal Reserve. 

[11] Pub. L. No. 110-289, 122 Stat. 2654 (2008). 

[12] See GAO, Troubled Asset Relief Program, Status of Efforts to 
Address Defaults and Foreclosures on Home Mortgages, [hyperlink, 
http://www.gao.gov/products/GAO-09-231T] (Washington, D.C.: Dec. 4, 
2008) for a discussion of challenges facing loan modification programs. 

[13] Under AIFP, Treasury also lent $884 million to GM to enable it to 
participate in GMAC's--a financing company owned in part by GM--new 
rights offering related to its reorganization as a bank holding 
company--and bought $5 billion in preferred stock investment plus 
warrants from GMAC. In addition, Treasury agreed to lend $1.5 billion 
to a special purpose entity created by Chrysler Financial Services 
Americas LLC (Chrysler Financial) to finance the extension of new 
consumer automotive loans, of which $0.4 billion been disbursed to 
Chrysler Financial. 

[14] Cash management bills are not auctioned on a regular schedule, 
rather they are announced, auctioned, and have maturity dates based on 
the Treasury's immediate cash needs. 

[15] Debt held by the public--and the interest paid on it--represents a 
burden on current taxpayers; debt held in government accounts 
represents a claim on future resources. Together they equal total debt. 

[End of section] 

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