According to the inspector general's report (PDF), the OTS should have designated IndyMac a troubled institution as early as May 2008. Yet the OTS did not issue any formal enforcement action against IndyMac until early July, just days before it failed. It downgraded the bank's rating to a level where the FDIC was able to take action on its own on July 1, at which point IndyMac lost the right to accept brokered deposits. After the IndyMac scandal broke, Reich reassigned Darrel Dochow, the regional OTS director who approved the IndyMac backdating.