oversight

Financial Institution Fraud: Effect of Regional Fraud Offices Unclear

Published by the Government Accountability Office on 1990-09-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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                     FINANCIAL
                     INSTITUTION FRAUD
                     Effect of Regional Fraud
                     Offices Unclear




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                       ,11
      United States
GAO   General Accounting  Office
      Washington, D.C. 20648

      General    Government       Division

      B-241059

      September 28,199O

      The Honorable Joseph R. Biden, Jr., Chairman
      The Honorable Strom Thurmond, Ranking
        Minority Member
      Committee on the Judiciary
      United States Senate

      The Honorable Donald W. Riegle, Jr., Chairman
      The Honorable Jake Garn, Ranking
        Minority Member
      Committee on Banking, Housing, and
        Urban Affairs
      United States Senate

      The Honorable Jack Brooks, Chairman
      The Honorable Hamilton Fish, Jr.
      Ranking Minority Member
      Committee on the Judiciary
      House of Representatives

      The Honorable Henry B. Gonzalez, Chairman
      The Honorable Chalmers P. Wylie, Ranking
        Minority Member
      Committee on Banking, Finance,
        and Urban Affairs
      House of Representatives

      The Honorable Doug Barnard, Jr., Chairman
      Subcommittee on Commerce, Consumer,
        and Monetary Affairs
      Committee on Government Operations
      House of Representatives

      This report responds to a legislative mandate and a request relating to
      financial institution fraud. Section 965 of the Financial Institutions
      Reform, Recovery, and Enforcement Act (FIRREA) mandates that the
      Department of Justice create a regional office of the Fraud Section of
      the Criminal Division’ in northern Texas. It also requires that we study
      and report to Congress on whether additional such offices should be
      established in other parts of the country. In addition, the Chairman,

      ‘The Fraud Section of the Criminal Division operates out of Washington, D.C., and assists U.S.
      Attorney offices in prosecuting complex fraud cases.



      Page 1                                               GAO/GGDSO-124      Financial   Institution   Fraud
                   B241059




                   Subcommittee on Commerce, Consumer, and Monetary Affairs, House
                   Committee on Government Operations, requested that we determine
                   whether Justice had created a regional office of the Fraud Section in
                   northern Texas as mandated by section 965 of FIRREA.


                   During the last 7 years, the need to prosecute financial institution fraud
Background         placed an increasing burden on Justice’s resources. Several U.S. Attor-
                   neys established task forces to combine the skills and resources of inves-
                   tigative agencies and federal prosecutors to focus on financial
                   institution fraud. One such task force was established in 1987 after a
                   request from the U.S. Attorney for the Northern District of Texas, who
                   said he needed more people to address the massive thrift and bank
                   fraud crisis. The task force, known as the Dallas Bank Fraud Task
                   Force, continues to operate today.

                   The Dallas Rank Fraud Task Force was different from the other task
                   forces established to address the thrift and bank fraud crisis in that it
                   was headed by a Fraud Section attorney who reported to the Deputy
                   Chief of the Fraud Section in Washington, D.C. Other task forces were
                   headed by the U.S. Attorney for that particular district.

                   FIHREA,   enacted in August 1989, was Congress’ response to the thrift
                   crisis. It provided $50 billion in “bail out” money for failed thrifts,
                   changed the way the government regulates the thrift and banking
                   industry, and authorized $75 million for Justice’s efforts to ferret out
                   and prosecute those involved in financial institution fraud. In another
                   provision of FIRREA (section 965 (a)), Congress also mandated that Jus-
                   tice “create a regional office of the Fraud Section of the Criminal Divi-
                   sion in the Northern District of Texas, and maintain such office, by
                   providing sufficient legal and other staff and office space, through fiscal
                   year 1992.”

                   The conference report accompanying FIRREA provides insight to the
                   intent of section 965 of the act. It states that the conferees intend that
                   the Criminal Division substantially reduce the numbers of Fraud Section
                   attorneys traveling from Washington, D.C., to Dallas by transferring
                   some senior or supervisory personnel to Dallas and by hiring additional
                   attorneys to work in Dallas.


                   Justice has established a Fraud Section regional office in Dallas as man-
Results in Brief   dated by FIRREA. It did so by taking two actions. First, it designated the


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B.241069




senior Fraud Section attorney who was heading the Dallas Bank Fraud
Task Force as the director of the new regional office. Second, it desig-
nated the other Fraud Section attorneys on that task force as staff of
the office. Justice took no further steps. For example, it established no
separate functions for the newly designated regional office. The regional
office head and staff continued to function as before-as attorneys
taking part on the Dallas Bank Fraud Task Force. The actions Justice
took were the minimum steps necessary to bring it into compliance with
section 965(a) of FIRREA.

Further, the reduction in the number of Fraud Section attorneys that
travel between Washington, D.C., and Dallas sought by the conferees so
that the attorneys could be on site working on financial institution fraud
cases has not been achieved even though five Fraud Section attorneys
now live in Dallas. Eleven attorneys now assigned to the task force com-
mute between Washington, D.C., and Dallas. The Fraud Section has not
been able to transfer attorneys or hire enough new attorneys to staff the
regional office without having attorneys commute from Washington,
D.C.

Justice opposes the concept of establishing Fraud Section regional
offices. Citing the more traditional role of the Fraud Section as a
resource for U.S. Attorneys, the Assistant Attorney General for the
Criminal Division said that the establishment of regional offices fails to
adequately recognize the U.S. Attorney’s role as the chief federal law
enforcement official in the 94 judicial districts. He also said such offices
would lead to needless friction between the Fraud Section and U.S.
Attorneys.

Because we found that the Fraud Section regional office had no observ-
able impact on Justice’s prosecution of financial institution fraud, apart
from what the office head and staff were already contributing as mem-
bers of a task force, we have no basis to determine whether regional
offices of the Fraud Section should be set up in other parts of the
country. The major thrust of Justice’s efforts in prosecuting financial
institution fraud has been to order the creation of task forces dedicated
to prosecuting fraud in 27 cities and to add over 400 prosecutor, investi-
gator, and accounting technician positions allocated by the Attorney
General in December 1989 to the task forces in these cities. In addition,
Justice created the Special Counsel for Financial Institution Fraud to
coordinate Justice’s efforts and ensure that resources are allocated to
the most significant cases.



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                       B-241069




                       In determining whether Justice established a regional office of the
Objective, Scope,and   Fraud Section in northern Texas in compliance with FIRREA, we first ana-
Methodology            lyzed section 965 of FIRREA and its associated legislative history to deter-
                       mine the Department of Justice responsibilities with respect to the
                       regional office. We interviewed officials of the Fraud Section in Wash-
                       ington, DC., and Fraud Section attorneys assigned to the regional office.
                       We interviewed Federal Bureau of Investigation (FBI) and Internal Rev-
                       enue Service (IRS) investigators and Office of Thrift Supervision attor-
                       neys and examiners assigned to the Dallas Bank Fraud Task Force. We
                       also talked with the US. Attorney for the Northern District of Texas
                       and the FBI Special Agent-in-Charge of the Dallas FBI Field Division. We
                       reviewed various correspondence and other documents provided by
                       these officials.

                       In considering whether other Fraud Section regional offices should be
                       established, we gathered information on the operations and accomplish-
                       ments of two Justice initiatives in Dallas. Our purpose was to gain an
                       insight as to how the initiatives helped Justice achieve its goals for
                       investigating and prosecuting financial institution fraud. One initiative
                       was a task force headed by the U.S. Attorney for the Northern District
                       of Texas that had Fraud Section attorneys working on it. This task
                       force, known as the I-30 Task Force, was formed in response to ques-
                       tionable banking and real estate transactions that resulted in a massive
                       oversupply of condominiums along the Interstate 30 corridor near
                       Dallas. The second initiative was the Dallas Bank Fraud Task Force.
                       Because it had been headed by a senior attorney from the Fraud Section
                       since its inception in 1987 and because Fraud Section attorneys working
                       on the task force became part of the Fraud Section regional office, this
                       task force came as close to constituting a “regional office” as we could
                       locate for the purpose of gathering information on a regional office.

                       In addition, we obtained information on other Justice initiatives-a      27-
                       city attack on savings and loan fraud and the creation of a Special
                       Counsel for Financial Institution Fraud-which       could have a bearing on
                       the decision to replicate the regional office in other locations. As part of
                       our work, we also talked with officials from 10 U.S. Attorney offices
                       and 7 FBI field divisions in Texas, California, and Florida about the
                       potential benefits of a regional fraud office in their localities.

                       We did our work from October 1989 to August 1990 in accordance with
                       generally accepted government auditing standards.




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                     Although section 965 requires that Justice provide “sufficient legal and
Fraud Section        other staff and office space” for the mandated regional office, the deter-
Regional Office      mination of what is “sufficient” is left to Justice. In response to the
Established as       mandate, Justice designated the Fraud Section attorney who already
                     headed the Dallas Bank Fraud Task Force as director of the regional
Mandated by FIRREA   office. In an August 4, 1989, memo to the Fraud Section staff, the Chief
                     of the Fraud Section stated:

                     “I have selected Richard M. Fishkin to be the Director of the Dallas Regional Office
                     of the Fraud Section, which office shall be responsible for the work of the Dallas
                     Dank Fraud Task Force. . .. Mr. Fishkin reports to the Section Chief of the Fraud
                     Section through the Deputy Chief responsible for bank and securities fraud cases
                     and matters.”

                     According to the Deputy Chief of the Fraud Section, no other actions
                     were necessary to comply with FIRREA. We noted, however, that Justice
                     has policies and procedures for opening regional offices (Department of
                     Justice Order 1000.2A). The order requires that organizational compo-
                     nents of Justice desiring to establish a regional office submit to the
                     Deputy Attorney General and the Attorney General plans for the new
                     office. According to a Justice Management Division official, the plans
                     should include such things as number of staff, where the staff will come
                     from, and a proposed operating budget. When approved, Office of Man-
                     agement and Budget and Justice’s legislative committees must be noti-
                     fied. Justice officials in the Justice Management Division and the Fraud
                     Section also told us that the order did not apply to the establishment of
                     the regional office because the office was mandated by FIRREA.

                     The Deputy Chief of the Fraud Section said that Fraud Section
                     employees assigned to cases being pursued by the Dallas Bank Fraud
                     Task Force make up the staff of the regional office. There were 10 such
                     attorneys as of August 4, 1989. These attorneys were to continue to
                     report to and be rated by the Fraud Section, so no personnel actions
                     were required. The Deputy Chief also said that there were no other doc-
                     uments or correspondence prepared relating to the establishment of the
                     regional fraud office.

                     Consistent with the Deputy Chief’s statement that no further actions
                     were necessary, we found no additional indications of a Fraud Section
                     regional office as a separate entity. There is no phone listing for the
                     regional office either in Dallas or in the Justice phone directory. There is
                     no organizational chart that shows the regional office as part of the
                     Fraud Section. In congressional testimony and other documents, Justice



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B-241069




officials, including the Attorney General, have often referred to the
Dallas Bank Fraud Task Force rather than the Fraud Section regional
office.

It should be noted that Fraud Section attorneys make up only a part of
the Dallas Bank Fraud Task Force. Other participants on the task force
include 7 Assistant US. Attorneys, 3 Tax Division attorneys, 49 FBI
agents, 13 FBI accounting technicians, 16 Internal Revenue Service
agents, 3 Office of Thrift Supervision examiners, and 1 Office of Thrift
Supervision attorney. Nearly all of these task force members are located
in Dallas. Together these task force members investigate and prosecute
cases that typically involve complex transactions and often take years
to complete. Fraud Section attorneys, serving full time on the task force,
have not assumed any cases or other responsibilities beyond those
assigned to them as members of the task force.

The House and Senate conferees envisioned that Fraud Section attor-
neys would live in Dallas rather than commute from Washington, D.C.
As of August 1990, five attorneys assigned full time to the regional
office lived in Dallas. (One of the five lived in Dallas prior to passage of
FIHRISA.) Eleven other attorneys assigned full time to the regional office
commuted from Washington, D.C., to Dallas. In August 1989 nine Fraud
Section attorneys commuted from Washington, D.C., to Dallas. IJlti-
mately, Justice plans to assign 22 Fraud Section attorneys to the
regional office full time.

The Director of the regional office of the Fraud Section told us that he
has attempted to get Washington-based Fraud Section attorneys to
transfer to Dallas, but these efforts have been largely unsuccessful. We
talked with three Fraud Section attorneys who confirmed they had been
asked to transfer to Dallas; none expressed an interest in a transfer. The
Fraud Section also has encountered difficulty recruiting newly hired
attorneys to work in Dallas. The conferees expected that a number of
the 24 additional attorneys for the Fraud Section hired with funds
appropriated under FIRREA would be hired to work in Dallas. Fraud Sec-
tion officials often cited the pay differential as the primary cause of
their inability to hire new attorneys. They said that in the private sector
a qualified financial attorney can make a much higher salary than that
offered by the Fraud Section. For example, a Fraud Section official said
he recently interviewed a person in private industry who had 3 years
experience. The person was earning $148,000 a year and Justice could
offer him only about $42,000 a year. The Fraud Section official added



Page 6                                  GAO/GGJMO-124   Financial   Institution   Fraud
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                        that even the U.S. Attorney in Dallas could offer higher salaries to new
                        employees than he could.


                        There was no quantifiable information available for us to use in con-
No Basis to Determine   eluding whether or not Fraud Section regional offices should be repli-
Whether Regional        cated in other locations. Examining two task force approaches in
Fraud Offices Should    Dallas-one headed by the U.S. Attorney and one headed by a senior
                        Fraud Section attorney-provided     little insight into which approach
Be Replicated           would be better.

                          U.S. Attorney I-30 Task Force-In the early 198Os, an oversupply of
                          condominiums existed along the Interstate 30 corridor east of Dallas.
                          A series of fraudulent transactions were discovered involving bor-
                          rowers and officers of savings and loan institutions. These transac-
                          tions had been made in order to finance the development of the
                          condominiums. The U.S. Attorney, building on the initial investigative
                          work of the FBI and the Texas Department of Public Safety, formed a
                          task force in 1985 to develop cases and to prosecute those cases as
                          warranted. This task force-known      as the I-30 Task Force-was
                          headed by the U.S. Attorney and included several Assistant US.
                          Attorneys and FBI investigators. The task force also included Fraud
                          Section attorneys. The staff of the I-30 Task Force was located in
                          secure office space in Dallas.

                          As of August 1990, the I-30 Task Force had charged 115 individuals
                          with bank fraud-related charges of which 103 had been convicted.
                          The defendants ranged from outsiders, such as lawyers, accountants,
                          and appraisers, to insiders and borrowers at the institutions. Sen-
                          tencing in these cases has varied from probation to 35 years in prison,
                          and prosecution has resulted in restitution orders of more than $12
                          million. However, its most significant case to date-involving     a con-
                          spiracy trial of seven major participants-ended    in a mistrial. For the
                          remaining five individuals, one has been acquitted, charges against
                          two were dismissed, and charges are still pending for two others.

                          Dallas Bank Fraud Task Force-This task force differs from the I-30
                          task force in that it was established in response to the growing sav-
                          ings and loan crisis in northern Texas and it is headed by a senior
                          Fraud Section attorney reporting to the Justice headquarters in Wash-
                          ington, D.C. It was established in August 1987 after the U.S. Attorney
                          for the Northern District of Texas and the FBI Special Agent-In-Charge



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   in Dallas made urgent requests for increases in staffing to handle the
   mounting workload.

   Initially, the Fraud Section attorney heading the task force had lim-
   ited managerial authority. Plea agreement and prosecution decisions
   had to be made by the Fraud Section Chief in Washington, D.C.
   According to task force attorneys, this resulted in excessive time
   being spent before cases could be brought to indictment. In February
    1990, the Fraud Section delegated to the task force head (with the
   agreement of the U.S. Attorney for the Northern District of Texas)
   the authority to make plea agreements and prosecution decisions. As
   the chief federal prosecutor in the district, the U.S. Attorney has con-
   tinued to sign all indictments prepared by the task force. According to
   Justice officials, this delegation should expedite the process for
   obtaining plea agreements and prosecution decisions by eliminating
   headquarters’ reviews.

   The Dallas Bank Fraud Task Force has made progress in its fight
   against financial institution fraud since its establishment in August
   1987. As of August 23, 1990, the task force had charged 86 individ-
   uals of whom 60 had been convicted and 2 had been acquitted
   (charges were still pending on 24 individuals). In fiscal years 1988,
   1989, and 1990 (through August 23) the task force obtained 12,26,
   and 22 convictions, respectively. About half of the individuals con-
   victed were senior executives. The individuals convicted included
   bank and savings and loan owners and officers, real estate brokers
   and developers, accountants, and borrowers. Sentences for those con-
   victed ranged from probation to 35 years in prison, and fines and res-
   titution orders ranged from $1,000 to $2.5 million. The first
   significant case indicted in 1988 resulted in acquittal of the defend-
   ants; however, there has been only one further acquittal. The task
   force has over 500 individuals targeted for investigation and has open
   investigations on over 40 financial institutions.

We observed common elements in both approaches that we believe are
important in dealing with complex issues such as the investigation and
prosecution of financial institution fraud. In both approaches a wide-
ranging and complex problem was identified, resources were dedicated
solely to the resolution of the problem, and personnel assigned to the
problem were accountable to a designated task force head.

It should be noted that two Justice initiatives have been undertaken that
may have rendered moot the question of whether additional regional


Page 8                                  GAO/GGD-90-124   NnanciaI   Institution   Fraud
                          B-241059




                          offices should be established. In December 1989, the Attorney General
                          announced the establishment of task forces in 27 cities across the
                          country for investigating and prosecuting financial institution fraud. He
                          allocated over 400 prosecutors, investigators, and accounting techni-
                          cians to the task forces, most of which were from increased staffing
                          levels authorized under FIRREA. As of June 1990, most of these positions
                          had been filled. In addition, Justice recently created the position of Spe-
                          cial Counsel for Financial Institution Fraud to be the focal point for Jus-
                          tice’s efforts in this area. The role of Special Counsel, who reports to the
                          Deputy Attorney General, is to ensure that resources are allocated to the
                          most significant cases, ensure good coordination between Justice and the
                          thrift and bank regulatory agencies, and track and maintain data on
                          criminal enforcement actions. As part of his efforts to achieve these
                          goals, the Special Counsel plans to meet with U.S. Attorney office offi-
                          cials to discuss the status of their financial institution fraud cases. The
                          Special Counsel expects that through this review, he will gain a better
                          understanding of where resources are needed.


                          Based on discussions with officials from 10 U.S. Attorney offices in
Justice Officials         Texas, California, and Florida, attempts to establish Fraud Section
Generally Opposethe       regional offices would encounter much resistance from U.S. Attorneys.
Concept of Regional       These officials, with the exception of the U.S. Attorney in the Northern
                          District of Texas, opposed the establishment of Fraud Section regional
Fraud Offices             offices in their districts. The reasons given for their opposition included
                          the following:

                      l Experience and pay. Trial experience was considered important to the
                        successful prosecution of these cases, and Fraud Section attorneys tend
                        to have far less trial experience than Assistant U.S. Attorneys. Further,
                        the pay disparity between the Fraud Section and the Assistant U.S.
                        Attorneys makes it easier for the U.S. Attorneys to attract qualified per-
                        sonnel. For example, an attorney with 7 years of experience can earn an
                        average of $9,000 more in the U.S. Attorney’s office than in the Fraud
                        Section and other headquarters offices.
                      l Jurisdictional conflicts. Many of these officials believed that the
                        regional offices would result in Fraud Section attorneys and U.S. Attor-
                        neys competing over investigative resources and over which office
                        would handle the cases,
                      . Unfamiliarity with the local environment. Prosecutors from outside the
                        district are less likely to be familiar with the local banking situation
                        (e.g., the interrelation between various targets of investigations, or who
                        the best sources are for specialized expertise within the various state


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                 and federal bank regulatory agencies), the idiosyncrasies of district
                judges, and the attitudes of district residents.
              . Unnecessary duplication of effort. These officials felt that providing
                 sufficient training, office space, and support staff for federal prosecu-
                tors in a second office was unnecessary.

                It should be noted that the U.S. Attorney for the Northern District of
                Texas had originally requested that additional resources be assigned
                directly to his office and be under his control. When such resources were
                not forthcoming, he said he accepted the establishment of a Fraud Sec-
                tion-controlled task force in his jurisdiction. Further, although he said
                he now cooperates with and supports the Fraud Section’s regional
                office, he would have preferred that the additional resources were
                under his authority rather than under the Fraud Section’s.

                FBI officials that we spoke with in six field offices in California and
                Florida were also opposed to Fraud Section regional offices. Some FBI
                officials said that they had already established good working relation-
                ships with the U.S. Attorneys and could not see the advantage in cre-
                ating another office to do essentially the same thing. Another concern
                raised was the potential for competition for preferred cases between
                agents assigned to assist the regional office and those working with the
                U.S. Attorney.

                 The Assistant Attorney General for the Criminal Division said that the
                 establishment of regional offices fails to adequately recognize the U.S.
                 Attorney’s role as the chief federal law enforcement official in the 94
                judicial districts. He also said such offices would lead to needless fric-
                 tion between the Fraud Section and U.S. Attorneys. Similar concerns
                 were expressed by the Fraud Section officials we spoke with. The Acting
                Chief of the Fraud Section told us that establishing regional offices
                 would constitute a major change in the structure and function of the
                 Fraud Section. The Fraud Section would no longer be assisting districts
                that request aid but would instead be establishing a permanent and per-
                 haps unwanted presence. He also said that clearly designating such
                 offices as Washington-run operations would diminish their potential for
                 success by alienating local officials responsible for the investigation and
                 prosecution of financial institution fraud.


                Justice initiated the minimum necessary actions to bring itself into com-
Conclusions     pliance with FIRREA requirements for a regional office of the Fraud Sec-
                tion in northern Texas. However, the reduction in the number of Fraud


                Page 10                                 GAO/GGD90-124 Flnanclal Institution   Fraud
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Section attorneys traveling back and forth between Washington, D.C.,
and Dallas has not been achieved.

-Justice opposes the concept of establishing regional fraud offices.
Because we found that the Fraud Section regional office had no observ-
able impact on Justice’s prosecution of financial institution fraud, apart
from what the office head and staff were already contributing as mem-
bers of a task force, we have no basis to determine whether regional
offices should be set up in other parts of the country. Further, we
believe that subsequent actions by the Justice Department to establish
task forces in 27 cities and create the position of Special Counsel for
Financial Institution Fraud may have rendered moot the question of
whether additional regional offices should be established.


We discussed the information in this report with officials from the
Fraud Section and the Regional Fraud Office in Dallas. These officials
concurred with the results of our work. Copies of this report are being
sent to the Attorney General, Justice’s Criminal Division, and other
interested parties.

Major contributors to this report are listed in the appendix. If you have
any questions about this report, please call me on 275-8389.




Lowell Dodge
Director, Administration
  of *Justice Issues




Page 11                                GAO/GGD9@124 Fiuancial Institution   Fraud
Appendix I

Major Contributors to This Report


benerar bovernment           .Justice Issues
Division, Washington,      Robert L. Giusti, Evaluator-in-Charge
DC.                        Richard Sherman, Evaluator



Da11as Regiona1   Office   Philip Caramia7Evaluator




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