OIG reviewed 17 lending-facility contracts and specifically examined the BlackRock SMCCF contract after public scrutiny. It found established processes and oversight generally reduced risks, while identifying acquisition-policy clarification issues later addressed.
The reviews concluded that vendors maintained policies and procedures that were reasonably designed to ensure compliance with the contract requirements related to personal trading, safeguarding nonpublic and confidential information, and mitigating conflicts of interest.
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OIG reviewed 17 lending-facility contracts and specifically examined the BlackRock SMCCF contract after public scrutiny. It found established processes and oversight generally reduced risks, while identifying acquisition-policy clarification issues later addressed. Approximately $21.4 million is aggregate fees across the reviewed contracts as of 2022-12-31, not BlackRock-only compensation.