Sept. 2003

Published by the Farm Credit Administration, Office of Inspector General on 2003-09-01.

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

Office of
Inspector General

                     Semiannual Report
                       to the Congress

                          April 1, 2003
                    September 30, 2003

                         October 2003
Farm Credit Administration                                    Office of Inspector General
                                                              1501 Farm Credit Drive
                                                              McLean, VA 22102-5090

October 27, 2003

The Honorable Michael M. Reyna
Chairman of the Board and
 Chief Executive Officer
Farm Credit Administration
McLean, Virginia 22102

Dear Mr. Reyna:

Enclosed is the semiannual report on the activities of the Farm Credit Administration’s Office of
Inspector General for the period from April 1, 2003 through September 30, 2003. We are filing
this report in accordance with the Inspector General Act of 1978, as amended (Act). This is the
twenty-ninth report since creation of the office on January 22, 1989. Section 5(b) of the Act
requires that you send this report to the appropriate Congressional committees and
subcommittees within 30 days after the date of this transmittal, with management’s report on the
status of audit recommendations.

With a full complement of Board members, we look forward to advancement in governance of
the Farm Credit Administration and its leadership to the Farm Credit System, continually aiming
to improve quality of life in rural America.


Stephen G. Smith
Inspector General


REPORTING REQUIREMENTS ______________________________________________________________ ii
EXECUTIVE SUMMARY ____________________________________________________________________ 1
BACKGROUND ____________________________________________________________________________ 2
MANAGEMENT CHALLENGES _____________________________________________________________ 2
  FARM CREDIT SYSTEM RISK _________________________________________________________________ 2
  ORGANIZATIONAL LEADERSHIP _______________________________________________________________ 2
  STRATEGIC PLANNING ______________________________________________________________________ 3
  HUMAN CAPITAL___________________________________________________________________________ 3
  FINANCIAL MANAGEMENT ___________________________________________________________________ 4
  SECURITY AND DISASTER PREPAREDNESS _______________________________________________________ 4
  LEVERAGING TECHNOLOGY__________________________________________________________________ 4
AUDIT AND INSPECTION REPORTS ISSUED _________________________________________________ 4
  LOAN ACCOUNT REPORTING SYSTEM __________________________________________________________ 4
  FEDERAL INFORMATION SECURITY MANAGEMENT ACT REVIEW ____________________________________ 5
  FCA BOARD POLICY STATEMENTS ____________________________________________________________ 5
STATUS OF UNIMPLEMENTED AGREED UPON ACTIONS ____________________________________ 5
  AUDITS___________________________________________________________________________________ 5
  INSPECTIONS ______________________________________________________________________________ 6
  INVESTIGATIONS ___________________________________________________________________________ 6
  LEGISLATION AND REGULATIONS _____________________________________________________________ 6
  OTHER ACTIVITIES _________________________________________________________________________ 7
   Management Advisories____________________________________________________________________ 7
   E-Government Study ______________________________________________________________________ 7
   Survey of Farm Credit System Institutions______________________________________________________ 7
   OIG Performance Measures_________________________________________________________________ 8
   Staff Participation in Activities of the Professional Community______________________________________ 8
   Staff Participation in Agency Organizations_____________________________________________________ 8
APPENDIX A_______________________________________________________________________________ 9
  AUDIT / INSPECTION REPORTS ISSUED BY FCA OIG ______________________________________________ 9
APPENDIX B ______________________________________________________________________________ 11
  FCA ORGANIZATION CHART ________________________________________________________________ 11
APPENDIX C______________________________________________________________________________ 12
  FCA OFFICE OF INSPECTOR GENERAL ORGANIZATION CHART ____________________________________ 12
                                                                                                       FCA SEMIANNUAL REPORT TO CONGRESS
                                                                                                            APRIL 1, 2003 – SEPTEMBER 30, 2003


INSPECTOR GENERAL ACT CITATION AND REQUIREMENT                                                                               PAGE

Section 4(a)(2) Review of Legislation and Regulations ......................................................................... 6

Section 5(a)(1) Significant Problems, Abuses and Deficiencies........................................................ none

Section 5(a)(2) Recommendations With Respect to Significant ........................................................ none
     Problems, Abuses and Deficiencies

Section 5(a)(3) Prior Recommendations Not Yet Implemented...........................................................5-6

Section 5(a)(4) Matters Referred to Prosecutive Authorities .............................................................. none

Section 5(a)(5) Summary of Instances Where Information ................................................................ none
     Was Unreasonably Refused or Not Provided

Section 5(a)(6) List of OIG Audit/Inspection Reports............................................................................. 4

Section 5(a)(7) Summary of Each Particularly Significant Report......................................................... 4

Section 5(a)(8) Statistical Table on Management Decisions................................................................. 9
     on Questioned Costs

Section 5(a)(9) Statistical Table on Management Decisions on............................................................ 9
     Recommendations that Funds be Put to Better Use

Section 5(a)(10) Summary of Each Audit Over Six Months Old for .................................................. none
     Which No Management Decision Has Been Made

Section 5(a)(11) Significant Revised Management Decisions ........................................................... none

Section 5(a)(12) Significant Management Decisions With Which ..................................................... none
     the Inspector General Disagrees

Section 5(a)(13) Compliance of Agency Financial Management System ............................................ 4

                                                              FCA SEMIANNUAL REPORT TO CONGRESS
                                                                    APRIL1, 2003 – SEPTEMBER 30, 2003


     This semiannual report to the Congress summarizes the activities and accomplishments of
     the Farm Credit Administration (FCA or Agency), Office of Inspector General (OIG) and
     covers the period April 1, 2003 through September 30, 2003. Our efforts were directed
     toward performing audits, inspections, and evaluations of the FCA programs and operations,
     conducting investigations, and providing technical assistance and advice on FCA programs.

     The FCA Board is at full strength. Moreover, the Board members are engaged in healthy
     discussions about regulatory and enforcement issues facing the FCA. The Board members
     are embracing a collegial relationship that is vital to the organization. We believe that the
     work we performed on governance will help serve as a building block for a strong Board.

     The Board is reaching out to the public to gain their views on FCA’s regulatory approach, in
     part, due to the comments from the survey on Regulatory Development that was conducted
     by OIG during a prior reporting period. The Board is making an effort to reach out to the
     public and Congress to gain broad input into carrying out the Agency’s mission.

     The OIG advised managers on multiple issues that came to our attention. This advice
     encourages managers to take proactive actions. For example, we encouraged Agency
     managers to evaluate prepayment penalty practices when we noted an increase in
     complaints to FCA. We also identified improvements needed in several Agency policies.
     OIG input contributed to improved efficiency and controls in areas such as emergency
     planning and large procurements.
                                                                  FCA SEMIANNUAL REPORT TO CONGRESS
                                                                        APRIL1, 2003 – SEPTEMBER 30, 2003


         The FCA is an independent Federal agency of the United States government responsible
         for the regulation, examination and supervision of institutions chartered under the Farm
         Credit Act of 1971, as amended (Farm Credit Act). FCA is a nonappropriated agency with
         a fiscal year (FY) 2003 budget of $38,033,000 for administrative costs. The FY 2003
         budget for the OIG was $829,601 and total obligations were $796,659. FCA is a
         “designated Federal entity” within the meaning of the Inspector General Act of 1978, as

         FCA currently has 284 employees, about half of which are examiners located at five field
         offices. The OIG maintains five positions. Appendix B displays the current organizational
         structure of FCA and Appendix C displays the OIG within that structure.


         Two years ago, the OIG added this part of the semiannual report to highlight major
         challenges confronting the Agency as it works to fulfill its mission. These challenges fall
         into two general categories. First are the challenges related to the FCA’s core mission of
         ensuring a dependable supply of credit to agriculture through the institutions it has
         chartered. These challenges are often shaped and influenced by events that are outside
         the control of the Agency. Second, but no less important, are those challenges related to
         the Agency’s operations. These management challenges were incorporated in the
         previous semiannual report but have been updated to reflect changes and progress in
         meeting the challenges.

Farm Credit System Risk

         The Farm Credit System (FCS) is a single industry lender and therefore is vulnerable to
         economic swings. The FCA is challenged to balance the often-competing demands of
         ensuring the FCS fulfills it public purpose, proactively examining risk in the regulated
         institutions both individually and systemically, and controlling the cost of the regulator. For
         example, the FCA requested comments from the public on its interpretation of loan
         syndications. This is a significant issue to the FCS because loan syndications represent a
         material portion of the loan growth over the past several years. The FCA Board extended
         the comment period 3 times for a total of 9 months.

Organizational Leadership

         The Farm Credit Act provides for a full time three-member Board. The Board members
         are appointed by the President and confirmed by the Senate. The rapidly changing,
         complex financial and banking environment makes the Board’s task both challenging and
         important. The Board must be able to engage in professional policy debate and set a
         sound course for the Agency.

         The Board is in an important period of transition. Last year the Board returned to full
         strength ending a 19-month period with only two Board members. The return to a full
         strength Board is an important element in setting clear priorities and deliberating fully on

                                                                  FCA SEMIANNUAL REPORT TO CONGRESS
                                                                        APRIL1, 2003 – SEPTEMBER 30, 2003

         the issues. The Board must plan for and anticipate more changes especially in the
         succession of leadership. Chairman Reyna’s term expires in May 2004. The President
         will appoint the Chairman’s successor. However, a primary responsibility of an
         organization’s board is to ensure that there is a smooth transition in leadership. In addition
         to anticipating a new Chairman, the Board should prepare for other changes. For
         example, the Board needs to anticipate and be prepared to replace almost half of the top
         executives in the Agency over the next few years.

         A relatively small full-time Board also presents a challenge in terms of defining the roles
         and responsibilities of the Board members relative to the governance of the Agency. As
         the membership on the Board changes, it needs to update its rules of operation to ensure
         it fulfills its statutory role in the governance of FCA. Each Board member must accept the
         rules of operation and be comfortable with the degree of oversight and accountability
         within the FCA. During this reporting period an OIG report pointed out the need to update
         and revise the Board Policy Statements.

Strategic Planning

         The FCA Strategic Plan was updated and revised for FY 2000 to reflect the FCA Board’s
         priorities at that time. The current FCA Strategic Plan reflects an environment that has
         changed significantly since it was adopted—the composition of the Board, the economy,
         the structure of the FCS, and the President’s Management Agenda. The FCA Board has
         worked for more than 6 months getting input from a cross section of stakeholders and
         taking a fresh look at the substance of FCA’s mission, goals and objectives. The Board
         has the opportunity to set a course for FCA that focuses on the results that it wants to
         achieve through clear and balanced performance measures. The change in the Board’s
         composition has and will allow the new Board to develop a new perspective that is not
         unduly constrained by past practices but builds on the experience of prior FCA Boards.

Human Capital

         The President identified human capital as a critically needed management reform in the
         Federal government. The OIG recommended FCA develop a 5-year human capital plan
         in March 2001. FCA still does not have a plan 2½ years later. FCA needs to develop a
         comprehensive, integrated approach to human capital issues. In light of the changes in
         the competitive environment, advances in technology, and the tenure of its workforce; the
         Agency will be challenged to closely evaluate business processes, their associated costs,
         and alternatives available through competitive sourcing. The General Accounting Office’s
         (GAO) High-Risk1 report outlined four pervasive human capital challenges that the
         government faces:

                •   Planning strategic human capital and organizational alignment;
                •   Planning for succession and leadership continuity;
                •   Acquiring and developing staffs whose size, skills, and deployment meet agency
                    needs; and
                •   Creating results-oriented performance cultures.


                                                                   FCA SEMIANNUAL REPORT TO CONGRESS
                                                                         APRIL1, 2003 – SEPTEMBER 30, 2003

Financial Management

         During FY 2001, FCA successfully implemented a financial management system using
         the services of the Department of Interior’s National Business Center. FCA has received
         an unqualified audit opinion on its financial statements. However, financial management
         success goes beyond an unqualified financial statement audit opinion. Management’s
         challenge is to leverage the system to deliver timely financial information that is critical for
         making well-informed management decisions. This challenge will be compounded by the
         recent decision to move to a new financial management system. Meeting this challenge
         requires new measures of success. Measures such as delivering financial information that
         managers can use for day-to-day operations; and developing reports that capture the full
         cost of programs and projects can help bring about a transition.

Security and Disaster Preparedness

         In the recent report on information security, the OIG found a strong foundation for security
         practices. However, the speed of change in the security environment will be a challenge
         for all government organizations. This is especially true for smaller organizations like FCA
         where an increased emphasis on physical and information security will compete with
         program areas for tight budget funding. Therefore, security remains a major challenge for
         the Agency. The Continuity of Operations Plan needs to be updated and practiced. OIG
         previously provided suggestions to management to facilitate an expedited effort in this
         regard. Some actions have taken place, although continued planning, finalization and
         communication of emergency preparedness policies needs to be accomplished.

Leveraging Technology

         The Agency has recognized that in order to meet the constraints of its budget, it must be
         able to maximize its return on investment in technology. FCA will need effective
         mechanisms to ensure that current and future staff has the technical skills to use
         technology to operate in an efficient manner.


         We issued an audit report on the Loan Account Reporting System and an inspection
         report on FCA Board Policies. We also performed a review of the Federal Information
         Security Management Act (FISMA). We conduct all audits in accordance with the
         standards established by the Comptroller General of the United States for audits of
         Federal organizations, programs, activities, and functions. Inspections are in accordance
         with the President’s Council on Integrity and Efficiency’s Quality Standards for Inspections.
         For the FISMA review, we followed guidance published by the Office of Management and
         Budget. Copies of most OIG reports are available on FCA’s Web site (www.fca.gov/oig),
         by contacting the OIG on 703/883-4030, or by e-mail at IG_information@fca.gov.

Loan Account Reporting System

         The OIG completed an audit of the Loan Account Reporting System (LARS) at FCA. The
         overall objective of this audit was to determine whether LARS is effectively utilized.
         Specific audit objectives included: (1) determining the adequacy of LARS data; (2)
         determining whether information provided is duplicative; and (3) assessing LARS future

                                                                    FCA SEMIANNUAL REPORT TO CONGRESS
                                                                          APRIL1, 2003 – SEPTEMBER 30, 2003

             data use. Wee found that LARS is not providing sufficient and efficient loan data to
             support the Agency’s mission. Specifically LARS data is deficient, the system is
             outmoded, and system improvements are challenging. As a result, LARS is underutilized
             and without significant reengineering, we question whether the system is effective in
             realizing Agency mission and goals.

Federal Information Security Management Act Review

             OIG engaged an independent audit firm, Harper, Rains, Knight & Company to conduct a
             review of the information security in accordance with procedures essential for establishing
             compliance with the Federal Information Security Management Act. The Federal Financial
             System, Consolidated Reporting System, Lotus Domino, Personnel Payroll Systems, and
             Windows 2000 were reviewed. The auditors found no security issues concerning the
             Agency-wide security program.

FCA Board Policy Statements

             OIG conducted an inspection of FCA Board Policy Statements. The objective of this
             inspection was to determine if policies are consistent with sound business practices and
             provide appropriate governance for FCA. We found many policy statements need
             updating and refinement. It appears the Board’s role in overseeing the operations of FCA
             could be enhanced if it establishes a methodical approach to develop, review and update
             its policies. These practices would be more consistent with sound business practices and
             the standards established in the FCA Examination Manual.


             At the beginning of the period there were five unimplemented agreed upon actions.
             During the reporting period, management took final action on one of the agreed upon
             actions. During this period, nine more agreed upon actions were issued. At the end of
             this reporting period, 13 agreed upon actions remain unimplemented.


             The following table summarizes the final actions management took on open audit items.

                                         AUDIT AGREED UPON ACTIONS

                                                        Open during
                                                                           Management             Open on
                          Audit Report                  this 6-month
                                                                          Actions during         10/01/2003
                                                                            this period
Performance Budgeting
………Issued March 23, 2001                                      3                   1                   2
Office of Chief Financial Officer
………Issued January 24, 2002                                    2                   0                    2
Loan Account Reporting System
      Issued August 28, 2003                                  9                   0                   9

             Totals                                          14                   1                   13

                                                                    FCA SEMIANNUAL REPORT TO CONGRESS
                                                                          APRIL1, 2003 – SEPTEMBER 30, 2003

             The audit report of Performance Budgeting was issued more than 2 ½ years ago. Two of
             the original 14 agreed upon actions remain open. Remaining open are agreed upon
             actions to establish 5-year financial management and human capital plans. When
             implemented, these actions will further the Agency’s financial accountability and improve
             strategic planning by providing a roadmap for future human capital and financial
             management needs.

             The OIG issued the audit report on the Office of Chief Financial Officer more than 20
             months ago. The two remaining agreed upon actions address the role of the Chief
             Financial Officer and the staffing of the organization.


             The following table summarizes the final action management took on recommendations
             contained in an inspection report.

                                          INSPECTION RECOMMENDATIONS

                                                        Open during
                                                                           Management             Open on
                 Inspection Report                      this 6-month
                                                                          Actions during          10/1/2003
                                                                            this period
FCA Board Policies
..............Issued September 15, 2003                       3                   0                   3

             Totals                                           3                   0                   3


             Most OIG Hotline calls and e-mails dealt with borrower complaints concerning FCS
             institutions and were referred to the FCA office responsible for reviewing such matters. All
             other Hotline calls were addressed or were referred to the appropriate FCA office or other
             Federal agency.

             One investigation was open at the beginning of this reporting period. This investigation
             substantiated allegations related to leave practices at FCA. The OIG advised
             management to take certain administrative actions and change practices to prevent future
             problems. Two new investigations were opened this period, with one being closed

Legislation And Regulations

             OIG staff reviewed several FCA regulations in both proposed and final form. Statutory
             and regulatory compliance issues were reviewed as they arose in the evaluative process.
             Also, we reviewed and commented on proposed legislation affecting the Inspectors
             General community through the legislation committee of the President’s Council on
             Integrity and Efficiency and the Executive Council on Integrity and Efficiency (PCIE/ECIE).

                                                                 FCA SEMIANNUAL REPORT TO CONGRESS
                                                                       APRIL1, 2003 – SEPTEMBER 30, 2003

          The FCA requested comments from the public concerning regulations and policies that
          may duplicate other requirements, are ineffective, or impose burdens that are greater than
          benefits received. A former solicitation for comments on regulatory burden went out to the
          public in 1993. OIG is also in the process of reviewing the public comments requested by
          the Agency on syndication loans and scope and eligibility regulations. We continue to
          gather information on the Basel Accord and information relating to preferred stock and
          permanent capital.

          This office is involved in workgroups that create guidance for use in the investigation
          review process. We are working with the ECIE/PCIE to prepare for participating in the
          quality assurance review of investigations.

Other Activities

          Management Advisories

          During this reporting period, the OIG has continued the use of management advisories.
          These advisories provide management with feedback on issues that came to our attention
          during the process of performing other OIG work. In this 6-month period, we advised
          Agency managers on issues including processing in of new employees, selecting a new
          financial management system, billings for reimbursable activities, credit card issuance and
          monitoring processes, securing Agency credit cards, travel policies, security practices,
          continuity of operations planning, and Agency outreach activities.

          E-Government Study

          The OIG conducted a study on the best practices of E-Government. The study identified
          several efforts underway in other Federal agencies that may be appropriate for FCA to
          consider. Some of these areas involve electronic corporate applications and making the
          FCA Web site more user friendly. The study is available on the FCA OIG Web site,

          Survey of Farm Credit System Institutions

          OIG administers an ongoing Agency survey of the regulated institutions of the FCS. This
          survey is designed to provide the FCA Board and senior management with independent
          feedback about how well FCA performs its examination and enforcement activities. The
          feedback is based on confidential responses received from FCS institutions. We surveyed
          the Chairman of the Board and the Chief Executive Officer of each FCS institution,
          following their receipt of FCA’s report of examination, for their voluntary feedback on the
          quality and consistency of the examination and enforcement processes. OIG reports the
          results of the survey annually. During this 6-month period we mailed 45 surveys and
          received 29 responses, equating to a 64 percent response rate. Overall, the average
          rating for the questions answered during this reporting period was slightly more favorable
          (1.5) [1=completely agree; 5=completely disagree] than the prior semiannual reporting
          period (1.7).

                                                       FCA SEMIANNUAL REPORT TO CONGRESS
                                                             APRIL1, 2003 – SEPTEMBER 30, 2003

OIG Performance Measures

OIG’s performance measures were developed in 1995. Each year we review these
measures and issue a report on our performance. It is available on the FCA OIG Web
page at www.fca.gov/oig.

Staff Participation in Activities of the Professional Community

OIG staff members are encouraged to take part in organizations that contribute to the
mission of the Inspector General community, as well as their individual professional
development. Most staff is actively involved in one or more professional organizations as
well as ad hoc activities of the PCIE/ECIE.

Staff Participation in Agency Organizations

Staff is active on several Agency workgroups and task forces. During this reporting period
the OIG was represented in Blacks in Government, FCA Employees’ Council,
Administrative Burden Reduction Workgroup, the Federal Women’s Program, the Budget
and Planning task force, Budget Workgroup, the Laptop Replacement Workgroup and the
Farm Credit Club.

The IG sponsored a drive in the Farm Credit Building to collect school supplies for a local
public school with a large population of at-risk children.

                                                                      FCA SEMIANNUAL REPORT TO CONGRESS
                                                                            APRIL1, 2003 – SEPTEMBER 30, 2003
                                                                                                 APPENDIX A



                                                NUMBER OF
                                             RECOMMENDATIONS/                           RECOMMENDATIONS
                                               AGREED UPON            QUESTIONED        THAT FUNDS BE PUT
            TITLE OF REPORT                      ACTIONS                COSTS             TO BETTER USE

     Loan Account Reporting System                   9                      0                      0

      FCA Board Policy Statements                    3                      0                      0

                  Total                             12                     $0                     $0


                                                         Number                        Dollar Value

                                                                            Questioned         Unsupported
                                                  Reports       Recs.         Costs               Costs
A.    For which no management decision
      has been made by the commencement              0            0             $0                  $0
      of the reporting period

B.    Which were issued during the
                                                     0            0             $0                  $0
      reporting period

Subtotals (A+B)                                      0            0             $0                  $0

C.    For which a management decision was
                                                     0            0             $0                  $0
      made during the reporting period

      (i) dollar value of disallowed costs           0            0             $0                  $0

      (ii) dollar value of costs not disallowed      0            0             $0                  $0

D.    For which no management decision
      has been made by the end of the                0            0             $0                  $0
      reporting period

E.    For which no management decision
      was made within six months of                  0            0             $0                  $0

                                                                FCA SEMIANNUAL REPORT TO CONGRESS
                                                                      APRIL1, 2003 – SEPTEMBER 30, 2003
                                                                                           APPENDIX A


                                                          Reports              Recs.            Dollar Value
A. For which no management decision has been
   made by the commencement of the reporting                0                    0                   $0

B. Which were issued during the reporting period            0                    0                   $0

Subtotals (A + B)                                           0                    0                   $0

C. For which a management decision was made
                                                            0                    0                   $0
   during the reporting period

    (i) dollar value of recommendations            that
                                                            0                    0                   $0
        were agreed to by management

        --based on proposed management
                                                            0                    0                   $0

        -- based on proposed legislative action             0                    0                   $0

    (ii) dollar value of recommendations           that
                                                            0                    0                   $0
         were not agreed to by management

D. For which no management decision has been
                                                            0                    0                   $0
   made by the end of the reporting period

E. For which no management decision was made
                                                            0                    0                   $0
   within six months of issuance

                              FCA SEMIANNUAL REPORT TO CONGRESS
                                   APRIL 1, 2003 – SEPTEMBER 30, 2003
                                                         APPENDIX B


     FCA Organization Chart
                                                                   FCA SEMIANNUAL REPORT TO CONGRESS
                                                                        APRIL 1, 2003—SEPTEMBER 30, 2003
                                                                                            APPENDIX C


                  Farm Credit Administration
                  Office of Inspector General

                                              Inspector General
                                                Stephen G. Smith

                     Investigator     Counsel to IG            Auditor          Management Analyst
                   Joan D. Ohlstrom   Elizabeth Dean       Veronica McCain      Mary Beth Barbagallo

FCA Office of Inspector General Organization Chart