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Develop and implement formal procedures that monitor nondepository institution participants and address at-risk and unresolved collateral.
Finalize measurable objectives and establish a completion date for the company-specific reports pilot process.
Establish written guidance for issuing company-specific reports.
Periodically monitor the company-specific reports pilot process to measure its effectiveness in improving company responsiveness.
We recommend that the Board’s Legal Division and FRB Boston’s Legal Department document a framework outlining the general process for identifying, determining, and pursuing action on ineligible loans as well as the key roles and responsibilities for addressing potentially ineligible MSLP loans.
Document the key decision to rely on Reserve Bank internal controls to gain assurance over publicly reported transaction-specific CARES Act data, as well as the rationale for that decision.
Identify and document learning opportunities from the CARES Act reporting experience so that they may be used by the Board when future exigent circumstances arise.