The Community Development Capital Initiative (CDCI)  provided capital to Community Development Financial Institutions  by purchasing preferred stock. Treasury Has Implemented Most of Our Performance Audit Recommendations, but a Few Related to CPP and MHA Have Not Been Fully Addressed

As of August 2015, our performance audits of the TARP programs have  resulted in 72 recommendations to Treasury. Of the 72 performance audit  recommendations, Treasury has implemented 59, or approximately 82  percent; partially implemented 4—that is, taken some steps toward  implementation but needs to take more actions; and not implemented 3— that is, Treasury has not taken steps to implement them (see fig.1). Among the 7 recommendations that Treasury has taken some or no steps  to implement, 1 was directed at CPP and 6 directed at the MHA housing  programs. Due to Treasury’s inaction and the evolving  nature of the programs, we considered 3 of them to be outdated and no  longer applicable. Two of these 6 recommendations were related to CPP  and 2 were related to the MHA programs. While Treasury reported generally  on the results of its CPP auctions and the status of institutions remaining  in the program, as of August 2015, it had not yet considered analyzing  and reporting on remaining and former CPP participants separately and it  is not likely to do so, according to Treasury. Treasury Has Implemented the Majority of Recommendations for MHA

Since 2009, we have made 27 recommendations aimed at improving  MHA’s TARP-funded housing programs. Treasury established  quantitative and qualitative benchmarks for each of the three  performance categories for HAMP first-lien modifications and other  TARP-funded MHA programs. In February 2014, we recommended that Treasury issue clarifying  guidance to servicers on providing effective relationship management  to borrowers with limited English proficiency (LEP). Six of these recommendations remain  open, including 4 of which Treasury has taken some action. The four recommendations that Treasury has taken some action to  address are as follows:  In June 2010, we recommended that Treasury expeditiously report  activity under PRA, including the extent to which servicers determined  that principal reduction was beneficial to investors but did not offer it,  to ensure transparency in the implementation of this program feature  across servicers. Thus, we continue to maintain that Treasury should take  action to fully implement this recommendation. In July 2015, we recommended that Treasury develop and implement  policies and procedures that established a standard process to better  ensure that changes to TARP-funded housing programs were based  on evaluations that comprehensively and consistently met the key  elements of benefit-cost analysis. Appendix I: Status of Troubled Asset Relief Program (TARP) Performance Audit Recommendations, as of August 2015

The following table summarizes the status of our TARP performance  audit recommendations as of August 28, 2015. We classify each  recommendation as implemented, partially implemented (the agency took  steps to implement the recommendation but more work remains), open  (the agency has not taken steps to implement the recommendation), and  closed, not implemented (the agency decided not to take action to  implement the recommendation). The recommendations are listed by  report.
Why GAO Did This Study

The Emergency Economic Stabilization Act of 2008 (EESA) authorized the creation of TARP to address the most severe crisis that the financial system had faced in decades. Treasury has been the primary agency responsible for TARP programs. EESA provided GAO with broad oversight authorities for actions taken under TARP and included a provision that GAO report at least every 60 days on TARP activities and performance.
This 60-day report describes the status of GAO's TARP performance audit recommendations to Treasury as of August 2015. In particular, this report discusses Treasury's implementation of GAO's recommendations, focusing on two programs: CPP and MHA. GAO's methodologies included assessing relevant documentation from Treasury, interviewing Treasury officials, and reviewing prior TARP reports issued by GAO.

What GAO Found

As of August 2015, GAO's performance audits of the Troubled Asset Relief Program (TARP) activities have resulted in 72 recommendations to the Department of the Treasury (Treasury). Treasury has implemented 59 of the 72 recommendations (about 82 percent), some of which were aimed at improving transparency and internal controls of TARP. The status of the remaining recommendations is as follows:
Treasury has partially implemented four of the recommendations—that is, it has taken some steps toward implementation but needs to take more actions. All four recommendations are directed at the Making Home Affordable (MHA) program, a collection of housing programs designed to help homeowners avoid foreclosure. The recommendations call for Treasury to, for example, issue guidance and monitor servicer compliance on working with borrowers with limited English proficiency. Treasury issued applicable guidance and obtained the policies of the larger MHA servicers, but has not assessed the implementation of those policies at the servicers.
Three recommendations remain open—that is, Treasury has not taken steps to implement them. Among these open recommendations are one directed at the Capital Purchase Program (CPP), which provided capital to certain U.S. financial institutions, and two recommendations directed at the MHA housing programs. For example, in July 2015, GAO recommended that Treasury establish a standard process to better ensure that changes to TARP-funded MHA programs are based on comprehensive benefit-cost analyses. Treasury told GAO they would consider these recommendations at the time the recommendations were made.
Six recommendations have been closed but were not implemented. Four are related to CPP and MHA and two to other TARP activities. Generally, Treasury did not take action before the programs evolved or began to wind down, and therefore GAO determined that the recommendations were outdated and no longer applicable.

What GAO Recommends

GAO continues to maintain that Treasury should take action to fully implement the four partially implemented recommendations and three open recommendations.