What GAO Found
The Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System, and Office of the Comptroller of the Currency help develop financial standards by participating in international standard-setting bodies, such as the Basel Committee on Banking Supervision. These banking agencies also conduct joint work with or provide technical assistance to certain bodies in which they are not members.
Federal Banking Agencies’ Participation in Key International Standard-Setting Bodies, 2010–2025
The banking agencies were active participants in developing or updating international standards, guidelines, or informational publications from 2010 through 2025. Along with other standard-setting body members, they helped develop 22 standards and at least 120 guidelines and informational publications, according to GAO’s review of standard-setting body documentation and agency staff. Members generally are expected but are not legally required to implement standards domestically, whereas implementation of guidelines and informational publications is encouraged but not expected.
The banking agencies implemented international standards primarily through domestic rulemaking. For example, Basel Committee implementation-monitoring reports state that, as of May 2026, the banking agencies had proposed 27 rules to implement the Basel standards, 18 of which had been finalized. They also adopted some guidelines and informational publications developed by international standard-setting bodies. Standard-setting bodies promoted implementation through assessments, peer reviews, and other monitoring activities. However, agency staff stated that domestic policy objectives and internal deliberations primarily drove agency implementation actions.
The banking agencies used several mechanisms to oversee their participation in standards development. Through multilayered internal review processes, senior officials reviewed staff work, while agency leaders approved policy positions and represented their respective agencies in key meetings. The agencies are also subject to several external forms of oversight and transparency, including congressional hearings and reporting, public consultations by standard-setting bodies, and disclosures in annual reports.
Why GAO Did This Study
Some Members of Congress have raised questions about the transparency of international standard setting. For example, some Members of Congress have stated that the banking agencies have implemented domestic regulations that closely reflect international standards developed with limited input from U.S. stakeholders.
GAO was asked to review federal banking agencies’ participation in developing international standards. This report examines, for 2010 through 2025, (1) the extent to which federal banking agencies participated in the development of international standards; (2) how the federal banking agencies have implemented the standards and how standard-setting bodies promote their implementation; and (3) the mechanisms for overseeing the federal banking agencies’ development of international standards, among other objectives.
GAO analyzed federal banking agency documents, including policies, procedures, and annual reports; standard-setting body publications; and relevant academic and policy literature. GAO also interviewed officials from the banking agencies. GAO also interviewed 18 stakeholders—eight academics, three private sector lawyers, and seven advocacy organizations—selected for their expertise in international financial standard setting and range of views on oversight of developing such binding agreements or nonbinding instruments.
For more information, contact Michael E. Clements at clementsm@gao.gov.
Source: GAO Reports & Testimonies · 2026-11-05