oversight

FCA's Office of Secondary Market Oversight

Published by the Farm Credit Administration, Office of Inspector General on 2018-03-20.

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

OFFICE OF
INSPECTOR GENERAL       Audit Report
                         The Farm Credit
                     Administra on's Office of
                    Secondary Market Oversight
                             A‐17‐03

                            Auditors
                          Sonya Cerne
                          Tori Kaufman

                     Issued March 20, 2018




                    FARM CREDIT ADMINISTRATION
Farm Credit Administration                                         Office of Inspector General
                                                                   1501 Farm Credit Drive
                                                                   McLean, Virginia 22102-5090




 



March 20, 2018

The Honorable Dallas P. Tonsager, Board Chairman
The Honorable Jeffery S. Hall, Board Member
The Honorable Glen. R. Smith, Board Member
Farm Credit Administration
1501 Farm Credit Drive
McLean, Virginia 22102-5090

Dear Board Chairman Tonsager and Board Members Hall and Smith:

The Office of Inspector General (OIG) completed an audit of the Farm Credit Administration’s
(FCA or Agency) Office of Secondary Market Oversight (OSMO). The objective of this audit was
to assess the staffing arrangements and reporting process for OSMO. We found that staff
resources are planned and projected each year and staff hours are tracked by office and by
employee. An annual assessment amount is calculated and communicated to the Federal
Agricultural Mortgage Corporation (FAMC).

We identified opportunities to improve OSMO’s processes and increase transparency. In
response to our report, OSMO agreed to:

    1. Revise OSMO Office Directive 3 to include the risks of specific conflicts of interest or bias
       from using examiners and other staff that also review, or provide services relating to,
       Farm Credit System associations and banks.

    2. Require independence documentation from rotational staff to mitigate the risks of
       conflicts of interest or impartiality concerns.

    3. Create an office directive on the assessment process roles and responsibilities.

The Office of the Chief Financial Officer agreed to:

    4. Document the methodology and process used to calculate the FAMC assessments to
       include:

           a. details on how the Agency arrives at direct, indirect, overhead, and blended rates.
            b. communicating quarterly reports showing charges against annual FAMC
               assessments to the OSMO Director for review and confirmation.

            c. a method to clearly separate the costs of shared OSMO employees also
               performing FCA work from the assessments to FAMC.

The Office of the Board agreed to:

   5. Document the reporting relationship between the OSMO Director and the FCA Board
      including delegations, supervisory relationships, and FCA Board oversight involvement of
      the OSMO Director.

OSMO and OCFO initiated corrective actions and we consider the Agreed-Upon Actions 1-4
resolved and closed. Agreed-Upon Action 5 remains open.

We appreciate the courtesies and professionalism extended by FCA personnel to the OIG staff.
If you have any questions about this audit, I would be pleased to meet with you at your
convenience.


Respectfully,




Wendy R. LaGuarda
Inspector General

Enclosure
                                                                                                                  




AGREED-UPON ACTIONS:
To improve OSMO’s processes and
increase transparency, OSMO agreed to:

  1.   Revise OSMO Office Directive 3 to
       include the risks of specific conflicts
       of interest or bias from using            The Farm Credit Administration (FCA or Agency) is an independent
       examiners and other staff that also       Federal agency responsible for regulating, examining, and supervising
       review, or provide services relating      the Farm Credit System and the Federal Agricultural Mortgage
       to, FCS associations and banks.           Corporation (FAMC).
  2.   Require independence
       documentation from rotational staff       FAMC is a government-sponsored enterprise with the mission of
       to mitigate the risks of conflicts of     providing a secondary market for agricultural real estate mortgage
       interest or impartiality concerns.        loans, rural housing mortgage loans, and rural utility cooperative
  3.   Create an office directive on the
                                                 loans. FAMC is regulated, examined, and supervised by FCA through
       assessment process roles and
                                                 the Office of Secondary Market Oversight (OSMO).
       responsibilities.
The Office of the Chief Financial Officer        The objective of this audit was to assess the staffing arrangements
agreed to:
                                                 and reporting process for OSMO. We found that staff resources are
  4.   Document the methodology and              planned and projected each year and staff hours are tracked by office
       process used to calculate the FAMC        and by employee. An annual assessment amount is calculated and
       assessments to include:                   communicated to FAMC.
         a. details on how the Agency
             arrives at direct, indirect,
                                                 In assessing staffing arrangements and the reporting process for
             overhead, and blended rates.
                                                 OSMO, we identified opportunities to clarify the process and improve
         b. communicating quarterly
             reports showing charges             documentation.
             against annual FAMC                       The current structure of OSMO staffing that utilizes staff from
             assessments to the OSMO                    other FCA offices necessitates increased due diligence to
             Director for review and
                                                        mitigate against conflicts of interest and impartiality concerns.
             confirmation.
         c. a method to clearly separate               The FAMC assessment process should be developed,
             the costs of shared OSMO                   documented, and communicated to increase accuracy,
             employees also performing                  fairness, and transparency of costs associated with FAMC.
             FCA work from the
             assessments to FAMC.                      The reporting relationship for the OSMO Director to the FCA
                                                        Board should be formalized and kept within the stipulations
The Office of the Board agreed to:
                                                        and spirit of the Farm Credit Act and Agency legal
  5.   Document the reporting                           interpretation.
       relationship between the OSMO
       Director and the FCA Board                The Agency agreed to take five actions in response to our report to
       including delegations, supervisory
                                                 increase transparency and improve processes related to OSMO. The
       relationships, and FCA Board
                                                 Agency completed corrective actions for four of the five actions,
       oversight involvement of the OSMO
       Director.
                                                 which are considered resolved and closed. One remains open.
                                   TABLE OF CONTENTS


ACRONYMS ______________________________________________________________________________________ 1

BACKGROUND ___________________________________________________________________________________ 1

AUDIT RESULTS __________________________________________________________________________________ 3

  Staff Utilization __________________________________________________________________________________3

    Staffing Structure _____________________________________________________________________________3
    Cost Calculations ______________________________________________________________________________6
  Reporting Relationship __________________________________________________________________________8

  Factors Contributing to OSMO Staffing and Reporting _________________________________________9

  Agreed-Upon Actions 1-5 _____________________________________________________________________ 10

OBJECTIVE, SCOPE, AND METHODOLOGY ____________________________________________________ 12
     



ACRONYMS



           COO             Chief Operating Officer

           FCA             Farm Credit Administration

           FCS             Farm Credit System

           FAMC            Federal Agricultural Mortgage Corporation

           FTEs            Full time equivalents

           OCFO            Office of the Chief Financial Officer

           OE              Office of Examination

           OGC             Office of General Counsel

           OIG             Office of Inspector General

           OSMO            Office of Secondary Market Oversight 


BACKGROUND

    The Farm Credit Administration (FCA or Agency) is an independent Federal agency responsible
    for regulating, examining, and supervising the Farm Credit System (FCS or System) and the
    Federal Agricultural Mortgage Corporation (FAMC). FCA ensures that System institutions and
    FAMC are safe, sound, and dependable sources of credit and related services for all creditworthy
    and eligible persons in agriculture and rural America.

    FAMC is a government-sponsored enterprise with the mission of providing a secondary market
    for agricultural real estate mortgage loans, rural housing mortgage loans, and rural utility
    cooperative loans. FAMC is regulated, examined, and supervised by FCA through the Office of
    Secondary Market Oversight (OSMO).

    OSMO was established by the Food, Agriculture, Conservation, and Trade Act Amendments of
    1991 (Public Law 102 – 237). Section 8.11 of the Farm Credit Act of 1971, as amended (Act),
    Supervision, Examination, and Report of Condition, describes OSMO authorities and
    requirements.




                                                     1
 


Each year, OSMO conducts an examination of FAMC to evaluate its safety and soundness,
compliance with applicable laws and regulations, and mission achievement. The examination
includes a review of FAMC’s:

        Capital adequacy,
        Asset quality,
        Management performance,
        Earnings,
        Liquidity, and
        Sensitivity to interest rate risk.

As part of its supervisory duties, OSMO also performs a variety of other examination and
oversight activities, in addition to the annual report of examination. Such activities focus on all
aspects of FAMC operations. For example, the capital plan assessment includes a review of
regulatory capital planning requirements, capital policy, capital-adequacy modeling, and stress
testing methodologies. The loan and servicing review includes the evaluation of risk
identification, underwriting, loan servicing, and data integrity both at FAMC and its central
servicers. Following the activities, OSMO is authorized to issue activity letters providing a
summary of scope, conclusions, findings, and recommendations, if warranted.

OSMO also gathers information from FAMC and other sources on an ongoing basis about the
general and agricultural economic conditions used to identify, monitor, and evaluate emerging
risks. OSMO also performs a quarterly review and risk assessment of FAMC based on FCA’s
Financial Institution Rating System criteria. Finally, under its regulatory authority, OSMO
develops and issues policies and regulations, with the approval of the FCA Board, to ensure
FAMC’s safety and soundness.

OSMO is currently staffed with a Director, two Associate Directors, one Senior Financial Risk
Analyst, and a shared Administrative Specialist. OSMO currently supplements its staff each year
with examiners from the Office of Examination (OE) to assist with the FAMC examination and
with OSMO’s supervisory responsibilities. OSMO also receives service from various offices in
FCA, such as legal services from the Office of General Counsel (OGC) and information
technology services from the Office of Information Technology (OIT), as needed.

FAMC pays assessments to cover the costs of its regulation, supervision, and examination by
FCA, as required by section 8.11(d) of the Act. FCA’s Office of the Chief Financial Officer (OCFO)
calculates assessments based on projected needs and tracks OSMO expenses quarterly. OCFO
works with OSMO to understand staffing needs and other inputs included in the assessment
calculation.




                                                  2
      



AUDIT RESULTS
      
     The objective of this audit was to assess the staffing arrangements and reporting process for
     OSMO. To further understand staff utilization, we also reviewed how the Agency assesses FAMC
     for the costs of its regulation, examination, and supervision. We found that:

            OSMO plans and projects staff resources each year;
            Staff hours devoted to OSMO are tracked by office and by employee;
            OCFO calculates an annual assessment amount and communicates the amount to FAMC;
            OSMO evaluates staffing during planning cycles and projects future needs; and,
            The Agency recently made changes to the OSMO Director reporting relationship to the
             FCA Board.

     In assessing staffing arrangements and the reporting process for OSMO, we identified
     opportunities to clarify the process and improve documentation. These changes will improve
     transparency and the overall control environment.

     Staff Utilization

     To fulfill mission requirements, OSMO needs staff to perform regulatory, supervision, and
     examination work over FAMC. OSMO does not currently perform required work solely with its
     own staff due to its small size and the need for specialized expertise in certain areas on an
     intermittent basis. By using other FCA staff, the cost calculations for FAMC assessments become
     more difficult to allocate, both increasing the need for transparency of such costs and the need
     to mitigate potential conflicts of interest and impartiality concerns.

     Staffing Structure
     OSMO was originally established with minimal staff and a Director. Currently, OSMO continues
     to maintain a small staff of a shared administrative specialist and four other full-time employees,
     including the Director. OSMO uses supplemental staff from OE to complete its annual
     examination of FAMC and assist with OSMO’s supervisory initiatives. For certain oversight
     activities that require specialized experience, OSMO may obtain third party contracted staff in
     addition to staff from other FCA offices. Specialized expertise may be needed in areas such as
     stress test models and methodology and technical research and analysis on financial or
     regulatory matters.

     FAMC reported in its fiscal year (FY) 2016 Annual Report that its assets have grown by an
     average annual rate of more than 12 percent over the last 17 years. In fact, the annual report
     states business volume went from $2.3 billion in 1999 to $17.4 billion in 2016. In addition,


                                                       3
 


according to its 10K filings, from 2011 to 2017, FAMC increased its staff by 26 people, which is
about a 42 percent increase.

In December 2017, OSMO announced efforts to expand staff with four individuals selected for
OSMO rotational assignments. One individual is assigned to OSMO as an examiner-in-charge
for the rotation. OSMO also gained an assistant examiner-in-charge and two other staff on
limited rotations for career development opportunities.

OSMO primarily uses OE examiners to supplement its small staff. For FAMC activities and
examinations, OSMO may also need specialized staff to perform mission requirements. OSMO
receives legal services from OGC and limited services from other offices, such as OIT. In addition,
OSMO shares an administrative specialist with the Office of Equal Employment Opportunity and
Inclusion.

Based on cost assessments completed by the OCFO, staff allocations from the various FCA
offices to OSMO activities were as follows for FYs 2015 and 2016:




              FCA Offices Contributing to OSMO Activities 
                              in FY 2015
                                              3%



                                                          25%




                                        72%




                                   OE          OSMO             Other
                                                                                                




                                                 4
 



                      FCA Offices Contributing to OSMO 
                            Activities in FY 2016
                                                    2.5%



                                                            25%




                                            72.5%




                                       OE            OSMO         Other
                                                                                               

For FY 2015, OSMO activities accounted for about 6.6 full time equivalents (FTEs) (2,080 hours a
person) and 6.4 FTEs for FY 2016. For both years, designated full-time OSMO staff accounted for
4.7 FTEs and 4.6 FTEs, respectively.

Currently, FCA has elected to supplement staff for OSMO with OE examiners who also tend to
be responsible for examining FCS banks and associations. Section 8.11(f) of the Act, states:

       The Farm Credit Administration Board shall ensure that

       (1) The Office of Secondary Market Oversight has access to a sufficient number
           of qualified and trained employees to adequately supervise the secondary
           market activities of the Corporation [FAMC]; and
       (2) the supervision of the powers, functions, and duties of the Corporation
           [FAMC] is performed, to the extent practicable, by personnel who are not
           responsible for the supervision of the banks and associations of the Farm
           Credit System [emphasis added].

The time sheet reports received from OAS showed that 27 different OE examiners charged time
to various OSMO activities during FY 2015 and 18 different examiners charged time to OSMO
activities during FY 2016. However, we note that OSMO is also used as a career development
opportunity for other examination staff due to the unique nature of FAMC and its specialized
accounting, loan, and credit activities. Examiners also may be assigned to OSMO for a short




                                                      5
 


time. Many of the OE staff in FYs 2015 and 2016 charged less than 80 hours for the year to
OSMO.

The dual role of OE examiners having to examine both the secondary market as well as the
market participants (FCS banks and associations), could create conflicts of interest or impartiality
concerns. Such real or perceived conflicts of interest or biases could stem from the fact that OE
examiners spend most of their time examining FCS banks and associations and a small portion
of their time examining FAMC. Given this imbalance, there is a potential danger that OE
examiners are more partial to System bank and association concerns when examining issues
involving FAMC.

In addressing the potential conflicts of interest or impartiality concerns with the placement of
OSMO in FCA, a 2002 FCA legal opinion recommended that FCA continue to supervise FAMC, to
the maximum extent practicable, through employees who are not responsible for the
supervision of the System banks and associations, as noted in the Act. Fifteen years later, and
despite the growth of FAMC, a portion of the OSMO staff still comes from other FCA offices
rather than having a workforce that is independent from those who also regulate, supervise and
examine the FCS banks and associations.

When OSMO uses staff from other offices, OSMO does not require such staff to certify that no
conflicts of interest or impartiality concerns are an issue. OSMO’s Office Directive on Examiner
Ethics addresses the overall Agency’s policy on examiner ethics and disclosure of information,
but does not address the potential conflicts of interest or impartiality concerns that may exist
with examiners who review both FCS banks and associations and FAMC. Having such
documentation in place would help to ensure that shared staff are aware of these potential
conflicts and are able to certify that they will remain impartial when engaging in OSMO matters.

Cost Calculations

To determine how staff utilization affects FAMC costs, we reviewed the Agency’s cost
assessment process. FCA regulation 607.4(b), states:

        Assessment of Federal Agricultural Mortgage Corporation. The FCA shall assess
        FAMC for the estimated cost of FCA's regulation, supervision, and examination of
        FAMC, including reasonably related administrative and overhead expenses.
        FAMC's assessment may be adjusted periodically to reflect changes in the FCA
        budget and to reconcile differences between FAMC's assessment and FCA's
        actual expenditures for regulation of FAMC in the prior fiscal year.




                                                 6
 


FAMC is unique. Accordingly, FAMC’s assessments are not calculated using FCA’s assessment
module for all other FCS institutions1. Instead, OCFO calculates assessments using resource
projections from OSMO. Projections include planned staff hours and travel costs. Based on
OSMO’s projections, OCFO provides assessment calculations to the OSMO Director for approval.
OCFO then finalizes and communicates the assessments to FAMC.

For the assessment calculation, OCFO uses an estimated blended rate in combination with staff
projections of needed staff hours. Although this process is not documented, OCFO stated this
blended rate is calculated from the prior year’s actual charges, including overhead and
administrative charges, which are then divided into hourly rates based on staff hours. As an
example, if in the prior year there were 1,000 staff hours devoted to OSMO at a cost of $100,000
for direct costs and $50,000 for indirect hours, the total hourly rate charged to FAMC would be
$150. The Agency would then add overhead and administrative items to the hourly rate to arrive
at the total estimated blended rate for the assessment calculation. The Agency maintains a
spreadsheet with assessment data from the financial management system. The OSMO Director
approves the overall assessment calculation.

When we reviewed the signed, approved copy of the assessment calculations from the OSMO
Director for prior assessments, we identified that the shared administrative specialist’s total
hours, which included an estimate of the projected hours that the specialist would work for the
Office of Equal Employment Opportunity and Inclusion, were included in FAMC’s original
assessment calculations. The information provided by OCFO that such hours had been removed
was inconsistent with the signed version from the OSMO Director. OCFO personnel stated the
assessment calculation was revised, but that they erred in not having the Director sign the
revised version. The revised calculation showed the overall hours reduced, but the hourly
blended rate increased, resulting in the same overall assessment to FAMC. Because this process
is not fully documented, it is difficult to follow how the OCFO arrived at the blended rate and
assessment calculations.

In addition, we found that quarterly cost assessments, which include overhead and
administrative charges to FAMC, are maintained by OCFO and are not always provided to the
Director of OSMO. Throughout the year, OCFO prepares quarterly cost assessments to track
actual costs at the Agency by project codes, including FAMC costs. At year end, OCFO reconciles
actual costs with these quarterly cost assessments for FAMC. OCFO personnel stated that they
send some information to OSMO staff during the assessment and budgeting process. However,
the OSMO Director is not receiving the more detailed, quarterly information. We also found that


                                                            
1
 The assessment module for all other FCS institutions is based on FCA regulations at 12 C.F.R. Part 607 for
the assessment and apportionment of administrative expenses.

                                                               7
 


FCA had not fully documented its methodology for calculating FAMC assessments and costs.
OCFO Standard Operating Procedures included the following steps for assessing FAMC:

       Obtain estimated hours and travel costs from OSMO for the upcoming FY examination;
       Exclude estimated FAMC costs to calculate total assessments for the System;
       Notify FAMC of assessment amount;
       Calculate actual exam costs for the year;
       Reconcile estimated assessments with actual exam costs; and
       Adjust the subsequent year’s assessment up or down based on the difference.

The OCFO procedures did not address specific details of OCFO’s methodology and process,
especially how it calculates the overhead and administrative costs. The methodology also did
not address how OSMO assessments, whether overall projections or actual costs, account for the
shared administrative specialist. During our review, OCFO provided a copy of assessment
procedures with more details of the assessment calculation for FAMC. In response to our report,
OCFO adopted updated assessment procedures and revised the cost policy statements.

Reporting Relationship

As part of our audit, we also reviewed OSMO’s reporting process. Section 8.11(a)(3)(C) of the Act
stipulates that the OSMO Director “shall be selected by, and report to, the Farm Credit
Administration Board.” The Agency’s current organizational structure has the OSMO Director
reporting to the Board Chairman and Chief Executive Officer for administrative purposes and to
the FCA Board for policy.

However, we found that though the FCA organizational chart shows the OSMO Director
reporting directly to the Board Chairman, the reporting relationship has changed over the last
few years.

       In 2012, the OSMO Director’s performance evaluation rating official (rater) and reviewing
        official (reviewer) was the Chairman of the Board.
       Over the next four years, from 2013 to 2016, the Chief Operating Officer (COO) became
        the OSMO Director’s rater with the Board Chair as the reviewer.
       In 2017, the OSMO Director’s performance plan and mid-year evaluation were
        completed by the COO as they had been since 2013, but the final rater and reviewer was
        the Chairman of the Board.
       As of 11/30/17, the COO remained the supervisor of record in the Agency’s personnel
        system and supervisory database for the OSMO Director.




                                                    8
 


The OSMO Director stated a previous Board Chair had changed the reporting relationship and
the subsequent Chair kept the same reporting structure. However, the current Board Chairman
elected to change the structure.

The legal opinions we reviewed by the Agency’s OGC on the establishment of OSMO opined on
the reporting relationship of the OSMO Director only in context of what is stated in the Act. We
also did not find any official record in current FCA regulations, delegations or designations
documenting the reporting relationship or supervision of the OSMO Director to outside the FCA
Board.

In a legal opinion from 1992, FCA’s OGC opined that OSMO must act under the control and
guidance of the FCA Board. The opinion stated that, in accordance with the Act, the OSMO
Director reports to the FCA Board, but it appeared nothing would prevent the Board from
delegating its reportee function to a board committee, a board member, or the Chief Executive
Officer (CEO). The four options presented made no mention of delegating the reporting
relationship outside of a Board Member, the Chairman and CEO, or FCA Board.

Hence, the OSMO Director’s reporting relationship should comply with the Act and Agency legal
interpretation. Given the nature of FCA organizational structure, there is constant change within
the Board leadership. Documenting the Agency’s position on the OSMO Director independence
and reporting relationship will increase transparency and ensure that the FCA Board has
considered and accepted potential political and practical concerns associated with any reporting
changes.

Factors Contributing to OSMO Staffing and Reporting

OSMO utilizes staff from other offices to maintain flexibility. By not hiring additional full-time
staff, OSMO can utilize different examiners and other Agency staff, benefit from their different
perspectives, and adjust personnel levels based on resource needs. OSMO can also utilize
specialized staff for unique needs to meet its mission, and bring them in only when the activities
necessitate specialization, allowing for budgetary and staffing efficiencies.

However, this structure necessitates increased due diligence. Documenting and mitigating the
risks of this staffing approach will ensure that OSMO and the FCA Board have properly
considered that the benefits outweigh the risks. Further, documenting consideration of staff’s
potential or perceived conflicts of interest or biases increases transparency and helps to ensure
that shared staff will be impartial when considering FAMC issues. Although OSMO Directive 3,
Examiner Ethics, covers examiner ethics and confidentiality, it can be improved by including the
specific risks of conflicts of interest or bias from using examiners and other staff that also work
on examination, regulatory, and supervisory matters involving FCS banks and associations.


                                                  9
 


The assessment methodology described in FCA regulation 607.3, Assessment of banks,
associations, and designated other System entities, does not apply to FAMC. Instead, OCFO
developed a unique process and methodology for determining FAMC assessments and actual
costs. Because FAMC’s assessment calculation is unique, documentation of the process is
particularly important. In addition, because OCFO has primary responsibility for calculating
assessments and tracking costs, the OSMO Director should receive quarterly cost assessments as
an additional internal control to ensure that the process is accurate, fair, and transparent.

Although the OSMO Director holds monthly meetings with the FCA Board Chairman, the
supervisor of record for the position in the personnel system is the COO. The personnel system
did not include a record of when this supervisory relationship was implemented. Based on FCA
legal opinions, the Agency has discretion to delegate certain OSMO oversight responsibilities, as
long as such oversight remains within the FCA Board. However, the reporting relationship
should be properly documented, justified, and reflected in the Agency’s human resource records
to ensure it complies with the requirements and intent of the Act and Agency legal
interpretation.

Agreed-Upon Actions 1-5

To improve OSMO’s processes and increase transparency, OSMO agreed to:

    1. Revise OSMO Office Directive 3 to include the risks of specific conflicts of interest or bias
       from using examiners and other staff that also review, or provide services relating to, FCS
       associations and banks.

    2. Require independence documentation from rotational staff to mitigate the risks of
       conflicts of interest or impartiality concerns.

    3. Create an office directive on the assessment process roles and responsibilities.

OCFO agreed to:

    4. Document the methodology and process used to calculate the FAMC assessments to
       include:

           a. details on how the Agency arrives at direct, indirect, overhead, and blended rates.

           b. communicating quarterly reports showing charges against annual FAMC
              assessments to the OSMO Director for review and confirmation.

           c. a method to clearly separate the costs of shared OSMO employees also
              performing FCA work from the assessments to FAMC.



                                                 10
 


The Office of the Board agreed to:

    5. Document the reporting relationship between the OSMO Director and the FCA Board
       including delegations, supervisory relationships, and FCA Board oversight involvement of
       the OSMO Director.

In response to our report, OSMO revised Office Directive 3 and developed a conflict of interest
questionnaire for examiners participating on FAMC activities. OSMO also included a statement
addressing conflict of intertest and impartiality concerns in rotational assignment agreements.
Lastly, OSMO created a directive on FAMC assessment procedures. Based on the completed
actions, we consider Agreed-Upon Actions 1-3 resolved and closed.

OCFO provided updated and adopted assessment procedures in response to Agreed-Upon
Action 4. OCFO also revised the cost policy statements in response to our report. Therefore, we
consider the action resolved and closed.

For Agreed-Upon Action 5, the Office of the Board agreed with the recommendation and is
working on a decision on how best to implement. This action remains open.       




                                               11
      



OBJECTIVE, SCOPE, AND METHODOLOGY
      
     The objective of this audit was to assess the staffing arrangements and reporting process for
     OSMO. We conducted the audit at FCA’s Headquarters in McLean, VA from May 2017 through
     March 2018. We limited our scope to staffing processes and the reporting relationship between
     the FCA Board and the OSMO Director.

     We took the following steps to accomplish the objective:

            Identified and reviewed applicable Federal laws and regulations related to the audit
             objective.

            Reviewed FCA legal opinions relating to OSMO.

            Reviewed other audits related to the audit objective for background purposes.

            Conducted interviews with the OSMO Director, OSMO staff, OCFO staff, and OAS staff.

            Identified and reviewed applicable internal FCA policies and procedures and office
             directives.

            Assessed internal control structure in OSMO within the context of the objective.

            Requested and analyzed FAMC assessment process. Reviewed OCFO and OAS data on
             staffing hours devoted to activities related to FAMC.

            Reviewed staffing structure and compared the structure to requirements in the Act.

            Reviewed OSMO’s reporting processes and relationships within FCA and compared
             reporting to requirements set forth in the Act.

     This audit was performed in accordance with the Generally Accepted Government Auditing
     Standards. Those standards require that we plan and perform the audit to obtain sufficient,
     appropriate evidence to provide a reasonable basis for our findings and conclusions based on
     our audit objectives. We assessed internal controls and compliance with laws and regulations to
     the extent necessary to satisfy the objective. Because our review was limited, it would not
     necessarily have disclosed all internal control deficiencies that may have existed at the time of
     our audit. We assessed the computer-processed data relevant to our audit objective and
     determined that the data was sufficiently reliable. We assessed the risk of fraud related to our
     audit objectives while evaluating audit evidence. Overall, we believe the evidence obtained
     provides a reasonable basis for our conclusions based on our audit objective.

      




                                                     12
 


 


            FARM CREDIT ADMINISTRATION

            OFFICE OF INSPECTOR GENERAL




                                               
                                 


                             REPORT 
    Fraud   |   Waste    |   Abuse     |    Mismanagement

        Phone: Toll Free (800) 437-7322; (703) 883-4316

                      Fax: (703) 883-4059

                 E-mail: fca-ig-hotline@rcn.com

                Mail: Farm Credit Administration
                  Office of Inspector General
                     1501 Farm Credit Drive
                    McLean, VA 22102-5090