The important points produced by this review highly reinforce the issues and problems raised in the OIG’s earlier Audit. Within our view, the FDIC must candidly give consideration to its leadership methods, its procedure and procedures, plus the conduct of numerous people who made and applied the choice to require banks to exit RALs. The severity of the events warrants such consideration while we acknowledge that the events described in our report surrounding RALs involved only three of the FDIC’s many supervised institutions. The FDIC has to ask how a actions described inside our report could unfold because they did, in light of this FDIC’s reported core values of integrity, accountability, and fairness. Further, the organization must deal with just exactly how it may avoid occurrences that are similar the long term.
The FDIC removed the term “moral suasion” from its guidance in December 2015, in response to concerns raised in the Audit.