oversight

Seized/Forfeited Asset System Checklist: Systems Reviewed Under the Federal Financial Management Improvement Act of 1996 (Exposure Draft)

Published by the Government Accountability Office on 1997-12-01.

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

                   United States General AccountinPr Office

GAO                Financial     ‘.Management         Series




December   1997    Seized/Forfeited Asset
                   System Checklist
                   Systems Reviewed Under the Federal
                   Financial Management Improvement Act of
                   1996




                   Exposure       Draft




                                                               I

GAO/AIMD-9821.25
i
r
     PREFACE


     The, Feder+,~Finam&l Management Improvement Act (FFMIA) of 1996, requires, among
     other things, that agencies implement and maintain m&agementgystems    that comply
     with federal financial management systems requirements. These requirements are
     detailed in the Financial Management Systems Requirements series issued by the Joint
     Financial Management Improvement Program (JFMIP) and in the Office of Management
     and Budget (OMB) guidance referred to in those documents.

     To help agencies review their financial management systems and assist auditors with their
     responsibilities under FFMIA,’ we have developed eight checklists, which we are issuing
     concurrently for comment as exposure drafts. Seven of the checklists reflect the system
     requirements defined by JFMIP. The eighth checklist, based on the JFMIP framework
     document, describes a single integrated financial management system and is primarily a
     reference tool rather than a standard-setting document.

     As more system requirements are issued, we intend to develop additional checklists.
     When these checklists are issued in final form, they will be available on the Internet on
     GAO’s Home Page (www.gao.gov).
                                            ”
     Additional copies of the exposure draft of this checklist can be obtained from Room 1100,
     700 4th St. NW, U.S. General Accounting Office, Washington, D.C. 20548, or by calling
     (202) 512-6000. Please send comments by February 28, 1998 to Robert W. Gramling,
     Director, Corporate Audits and Standards, Accounting and Information Management
     Division, at

                            U.S. General Accounting Office
                            441 G Street NW, Room 5089
                            Washington, DC 20548


                    -3
&*    ene L. Dodaro
     Assistant Comptroller General
     Accounting and Information Management Division




     !l’he final form of this checklist will be included in GAO’s Financial Audit Manual.

     Page 1                         GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited   Asset Checklist   (E/97)
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                 Page 2             GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited   Asset Checklist (X2/97)            1,




_.   ~.   ~_
           ___                                                                                            . .“.._-----J
CONTENTS


Preface                                                                                                        1

Overview        .                                                                                          3
  Authoritative Guidance                                                                                   3
  How to Use This Checklist                                                                                3
  Agency System Architecture                                                                               5

Requirements Checklist                                                                                     9
  Seizure Activities                                                                                      10
  Asset Custody Activities                                                                                12
  Asset Disposition Activities                                                                            16




  Abbreviations

  FFMLA Federal Financial Management Improvement Act of 1996
  JFMIP Joint Financial Management Improvement Program
  OMB   Office of Management and Budget




Page 3                           GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited   Asset Checklist   (Q/97)
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    Page 4.   GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited          Asset Checklist                                                         (12/97)
                                                               :                     :
                      ,


                                                                                                  _;:            _,


                                                                                                                             I
            OVERVIEW
                                                                                                                             i

            The Federal Financial Management Improvement Ait (FFMJA) of 1996; requires, among
            other things, that agencies implement and maintain financial management systems that
            comply with federal financial management systems requiremeats., These systen-i :-
            requirements are detailed in the Financial Management Systems Requirements series
            issued by the Joint ..$*rll.
                                 Financial-Man
                                    ,Iur,& ~IzU~wl~.<l‘~~b,                       (JFMIP)~ and Office of
            Management and- Budjget       COMB)
                                       ,~~~*uas~~:~~~~~~~-~~~~~:,,,?,,     anagement,    Svsterns.. The
            JFMIP’requirements documents ident@ (1) a ikxtiework fdr financial manag~mkmt :
            systems, (2) core financial systems re&irem’ents, and (3):,16’oth’er’systerrrs, suppo.rting
            agency opertitions: Figure 1 illustrates: how, these; elements fit together in ‘an ,agency
            systems architecturk       .’    .. a’ ”                   J              ‘,         (7, ..I‘

            Figure 1: Agencv Svstem$ Architecture                  : I’   :                                           ‘3
                                   I,    ,:.   .’       i ,’                  .;.’                      .’ .J,          ,’
                                                                                     :, .,   ‘.




                                rstem ,
                                    / . .




                                                                                                                             -
                                                                                                                             i!z


           Source: JFMIP Federal Financid Management System Requirements documerks.

.:i-   ,   pige   5        .,    .’
                                            GAO/AIMD-98-21.2.5- Proposed Seized/Forfeited Asset Checldist (12/97)
To date, JFMIP has issued the framework and core’documents                          and 6 of the 16 systems
identified in the architecture.’   ’
                                                                         >/I/. ,’
                                                                                  /
GAO is issuing this and seven other checklists that correspond to the JFMIP documents
as part of its Financial Management Series. GAO will issue other checklists as additional
systems requirements are defined; I_                    :.’ ‘, ‘       ! .(
        .’          ,i.‘.  :).)                 ;
Authoritative      Guidance, J: :‘.
 >            ..   I,   ,,‘-i.‘,,         ‘I    ,’        ‘,,‘, /            ,,     J,I      .,,+:;
‘ON& Circular A-127and~~O~B’sImplemenmtion~ Guidance for. the ,Federal: Financial,
Management Improvement iAct (FFMLA) of 1996, issued September 9, 1997, provide .the
basisfor! assessing compliance ,tith; .the FFMIA requirement for agencies to implement
and. maintain financial management systems ,that comply, substantially. with federal
requirements.’ ,OMB!s September ‘1997 implementatioti ,guidance identifies various,criteria
that an agency must meet to be in substantial compliance with these requirements.

 The source of all the questions in this checklistis the JointFinancial-Management b
 Imnrovement Program Federal Financial Management Svstem Reauirements
, Seized/Forfeited Asset ,Svstem Reauirements (FFMRS-4, March 1993‘ (Reprinted January
  1995)).
                            ,. .’
Purpose     of This G&e      and H& to Use It
                    .                      ,.
                               ,,. ‘,’ ..,                               .    ‘,,
The purpose”of this,,document’ is to provide a checklist to assist (1) agencies in
implementing and m’onitoring, their systems and (2) management and auditors in
reviewing the systems to,,deteniine if they’ are in substantial compliance with FFMIA.
The checklist, the JFMIP source ‘document, and ,the two previously mentioned OMB                                        .
documents (Circular A-127 and the September 9,‘ 1997 implementation guidance) should
be used concurrently   by experienced staff:                                       :
                I                                    “
                                        .x,;.:
OMB’s 1997 implementation guidance provides indicators’for chief financial officers and
inspector generals to assist them in determining whether the agency’s financial
management systems~subst$ntially comply with federal financial management systems
requirements, Filling out this checklist will allow agencies to systematically determine
whether specific systems requirements are being met. Agencies can assess the
significance, of any noncompliances in ‘determining substantial compliance by considering
the “indicators” in OMB’s 1997 implementation guidance. For example, the annual agency
                           ,.,,    I               ,
                                 ’
2Thus far, the series includes the (1) Framework for Federal Financial Management
Svstems, (2) Core Financial Svstem Requirements, (3) Inventorv Svstem Reauirements, (4)
Seized/Forfeited Asset Svstem Reauirements, (5) Direct Loan Svstem Requirements, (6)
Guaranteed Loan Svstem Reauirements, (7) Travel Svstem:!: Reauirements, (8) and
Personnel-Pavroll Svstem Reauirements.

Page 6                                GAO/AIMD-98:2L2.5        - Proposed Seized/Forfeited    Asset Checklist (12/97)
assurance statement issued pursuant. to section 4 of the Federal Managers’ Financial
Integrity Act is one of those indicators. Agencies can use GAO’s checklists to help
determine annual compliance with the section 4 requirement.                                               I
                                                                                                          h.
The following Seized/Forfeited Asset System Requirements section contains a brief
narrative followed by the checklist, which is organized by functions contained in the
source JFMIP document.

In the checklist, two columns follow each question. Use the first column to answer each                   i
question “Yes, ” “No,” or “NA.” Use the sec,ond column to explain your answer. A “Yes”                    1
answer should indicate that the agency’s system or systems provide for the capability
described in the question. For each “Yes” answer, briefly describe how the system(s)
contain the capability and refer to a source that explains or shows the capability.

A “No” answer indicates that the capability dqes not exist. For a “No” answer, the second
column should provide an explanation.and a reference to the supporting -documentation.
Such explanations could include the following: (1) The agency is working on modifying
or implementing its system(s) to have the capability available in subsequent years. (2)
Management believes the capability is not cost effective and will not enhance the systems’
ability to manage operations. Refer to any cost-benefit studies that support such
explanation. If there are none, provide a full explanation.

Not every guide may apply to an agency;‘. Further, while a guide may be applicable to an
agency, certain questions within. the guide may not be applicable. Answer such
nonapplicable question(s) with an “NA” and provide an appropriate explanation in the
second column.




Page 7                        GAO/AIMD-9%2L2.5   - Proposed Seized/Forfeited   Asset Checklist   (B/97)
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Page 8   GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited   Asset Ch&list   (12/97)
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                                                                                                                                               I
      SEIZED/FORFEITED.                  ASSET.       SYSTEM:r,RE&UIREMENTS                                        ,:,: ;:                     I

       The seized/forfeited asset systern’requirements helps agencies’ track the’~status’~of a seized
       asset from’ the time of seizure through%arious processing steps, Which ~mayir-iclude
      forfeiture,
               ;,_.: until
                       I final disposition ,(,of ‘<’
                                                 the asset.
                                                       ; .:: ,I,.
                                                              ,   ,” : ; ,, .’ ,. _ .:.,
      The three components of the seized/forfeited&set                        system are ‘discussed ‘b&o&.                   :

       1.    Seizure Activities - When certain civil and crimmalla~s, are v@lated~, certain
             enforcement agencies have the authori?, to, seize the possessions,, of .the violator.
             (The checklist questions for this area are dra$ri f?om’page:.I3 of”lthe source,
                                                           :      :. . I ,,        .I.
             document.)                              i                .‘//    ,,,.
                                                                                                  8,           :


       2.    Asset Custodv Activities .- .Organizations that have. custody of seized..and forfeited
             assets must have adequate policies and procedures to..make sure all assets are
             properly received, recorded, valued, maintamed, and, controlled. throughout the
             seizure and forfeiture process. (The che&list,,questions for this area are drawn
             from pp. 13-14 of the source document.)               j     !,:    ;.: ‘;
                                                          .. /.‘,      ;b “: :,’ ‘,‘,
       3.    Asset Disnosition ‘Activities - A. ‘key .component of an effective asset seizure ‘and
             forfeiture process is the orderly disposition of the assets in. accordance with the
             law applicable to those assets. (The checklist questions for, this area are drawn
             from   pp.’ 14-15’ of’ tk$.$o$ce     db&m&t.)’          ” ‘- ;                               -.                       .
                                                                  .’ ,j.            Ii,,   i       ,‘.I             .
       The checklist questions follow the JF’MIP source document: It shoul’d be noted that not
       all questions will apply in all situations and, as with the “use ,bf any checklist; professional
      judgement should be exercised. tUsing the JI?MIP source. document along with the two
      previously mentioned OMB documents will help ensure that the user is cog.nizant of the
       background information and definitions necessary to fully ,tiderstand’ the questions.
                                                                                   ,“’ ,1




                                                                                                                                           I


3..                      “,         *’      GAO/AIMD-98-2’1.2.5     h Proposed Seized/Forfeited   Asset Checklist                (12/97)
          SeizedLFotifbite’d           ‘As&et’ Syst,“&~ R;eq&etie&+’                                 : ‘..I,A , !, ‘, l ::,::,:‘.




:i                        :,,.-            . ”              I        I           ;,:               >i., ._/. .,,
            2. :Timely recording of the .date                ‘.
                 of seizure; the type of asset; ’                    -                                 : .;*
     ‘1         the locatibfi wh&& ‘seized, ,t& :’                                    :                 t ‘. i. ’
                physical condition, the                              ...       ‘I”                        .,/ ‘f; ,,
                physical location, owner(s) if
                known, arid’ entities, involvedj\                            ,..;:.
                                                                                 ,I I                                          I
                in the seizure?,) “,                ‘..                  ,,                        ,.        1.0
                                   :. I,,.         1‘(                    ‘.: L         ,,   :         ;
                                                        i ‘,,                     >li’ii                      : .’
            3. Timely and accurate recording
                of* the; originally assigned.,                                                 i
                value and the ba;si.s,’for :the:         1’                 I’ :   ,.      .     i                                 /
                initiaJ vaJue .placed on each .,                ‘. ,                  ‘,. ‘i(,.’          : ‘:            .’
                seized.assetandthe.              ,, .’ I.                              ..s,                        I               ‘.
                identification of vvho assigned,
                the asset value?

            4. Timely recording of any
               mortgage and claim liabilities
               against each seized asset?

            5. Capability to query the current
               information on processing
               status of any seized asset
               captured in the database?



          Page 10                                  GAO/AIMD-9841.25        - Proposed Seized/Forfeited       Asset Checklist            (E/97)
 Seized/Forfeited           Asset .System, Requireinents                   j           i’ ‘.    ‘.


     Seizure   activities   cotiponent          Yesho
                                                  NA

    6. Information necessary to
       enable verification that seizure
       authorization exists and that
       the seizure/forfeiture criteria
       established by management
       have been observed?

    7. Provide for the correction,
       amendment;. m&cmcellat~on           .~
        of the seizure authorization,
        with appropriate controls and
        reports to responsible
        program officials and other
        affected parties?

    8. Prompt payment of properly
       authorized and billed services?
       This system ,must interact      _
       with the core financial system
       to accomplish this task.




,,Page 11                           GAO/AIMD-98-21.2.5   - Proposed Seized/Forfeited     Asset Checklist   (12/97)
              Seized/Forfeited           Ass,et &stem,           Requirements             : ,. : ,,..:4:I ,’ ;’ ;,..:,: .,;.


                   Asset ,Ctistody Activities;               ” ,Yes/No                 ; ,,’       Explanation                 ”
                          Component                   :           NAi                                 I
                                                                                                                        I.
               Does the system component have                                       .: ‘. ,’ I            r.., ,i. .’
               the capability to:                                            . ; .,j. :,.J,,;~ ,‘,.           :        j:
       ,,
                                                                         .i.. ,. ,, :_ : .’          ‘(.. : :
               1. Capture, record, and maintain                         : ., c, !I            ,’      :;. I:,          j’
                  accurate information on the                                  ; “i, ‘,A. ., ‘..i            ‘:(
                  current physical condition,’                                     1:                                  1;
                                                                                                 :  ‘
                  legal status, geographic
                                            ,I.,..,       .                                                         ._.
                  location, responsible          i                                  .,; : ‘, ‘,, :,:.<:, .* :I
                  custodian,..andth~-._c~~~~.~~..._.. _ _ ..~~~..
                                                               . ._ __. _ _._. _..._~1 .._                _           ..
      ,’
                  recorded value of each seized                         I,           .~                        :
                                                                                                              ! .,
                  asset in custody?              \
                                                                            ,’                                  ,.
                                                                                                                       ‘!
                                                                                             ,, i.
               2. Provide a record that                                               :.
”      :          advertising and the issuance                                                                        ,.
                  of notice of property seized
                  have been accomplished, if                                      ,.’ ..,
                  required?

               3. Provide information to enable                                                .
                   seized cash to be deposited                             ‘.
                   promptly into cash holding
                                           :.                                                          ,‘.
                  “acco’unts? ’

               4. Track and promptly record
                  the deposit of income
                  generated by seized
                  businesses on an asset-by-
                  asset basis?

               5. Segregate forfeited assets
                  from those in seized status?




    Page 12                                        GAO/AIMD-9S-21.2.5    - Proposed Seized/Forfeited         Asset Checklist       (12/97)
            Seized/Forfeited      &set   ..System~ Requi~~ments:.~~                                                                   Y                                   .$J ‘:

                                              ‘:          “.    !



                 Asset Crqtody Activities~         ‘:     ;yeS/NO                                                                     Explanation                                  :
                       Component                        :, 1 NA
                                     _
              6. Allocate and record all                                                                                    :                              :/



                 maintenance and overhead,                                                                                                  ,,.                 I/I


                 costs on an asset by asset                                                                                                                           :


                 basis?
                  _.           ..,..                                                            ..,



                                                                                                 ,I.,                                                                     i


              7. Record and account .for all                                                :


                 theft, loss, and damage     !                                                              :



                 expenses on an asset by asset
                 basis?                                                      .,                         :




              8. Provide accurate and timely.                           .,


                 reconciliations between     :                                                                  .;:,                   ‘.



                 agency seized-asset records                                           .’                              ‘,


                 and records of contractors.
                                                                                                                                                                                                 i
                 being used to maintain, store,
                 and dispose of seized assets?

                                                                                                                                                      ‘,                      ,
              9. Provide information to allow
                 the independent verification
                 that each asset exists and that
                 the recorded physical
                 condition, legal status,
                 geographic location, and asset
                 value are accurate?                                                                                                              .

                                                                                                                                ,;,

             10. Provide information to allow                                     ,,                                    ”                                       .


                 an independent verification
                 that all billed contractor/
                 vendor services were actually
                 performed?

             11. Record and track cost bonds?


Page: ‘13                                    GAO/AIMD-98-21.2.5     - Proposed Seized/Forfeited                                                       Asset Checklist                  (12/97)
          Seized/Forfeited       Asset System’liiequiretients                                  :           .l,.            .: * i

                                   .,

               Asset Ctistody Activities               YidNo                        ’         ,Eqjlanation
                      Component                          NA                                         ‘,
                            .._.
           12. Obtain collateral coverage                                                                    ) ‘.2:,>               .!
               from financial institutions as                                             i                 _, ; :
               needed?                                                          :                             > :,,I
                                                                                                                : ,’‘,
           13. Accumulate performance :                                                                               ./
               histories on all vendors and                                                                    ‘: ,, .,”
               contractors (both private and                                        _‘, ‘..                  ,* ,’
               government) that perform                          ,                   ‘.’ :_,                     ,,._
               asset custodial/maintenance
               services?                                                                   .                               I
                                                                                         .,                      ,:
           14. Pay promptly all contractors/                                                                 :
               vendors performing asset                                                                ‘I ,,          ,: ,
               maintenance/management                                                                   ‘. ,            ‘, c,
               services? The system must                                                           :
               interact with the core                             ‘. ,.                   !                                    :
               financial system to accomplish               .
               ‘this task.                                                                                            ,+
                                                                               ,,        :’
                                                                          .,            ..
           15. Inform system users regarding                                                   2
               compliance with established
               asset ,custody controls?
                                                                                                   .,

           16. Retrieve quickly detailed
               information on the current
               location, value, and condition                                                                              ..
               of individual assets?

           17. Record accurately and timely
               the forfeiture action for each
               ‘asset?



Page 14                                    GAO/AIMD-98i21.2.5   - Proposed Seized/Forfeited                       Asset Checklist        (12/97)
                                                                                                                             I




          Seized/Forfeited      Asset      System        ,Requirements.                     ‘.      y


               Asset. Custody Activities                Yes/No              ‘_        Explanation
                      Component                       I’ 1.NA.                   .~        ./

           18. Produce exception reports?:              -                                             .
                                                                                                    : .’

                                                                   ,:                                   ‘,
                                                                                                             ,.




    4’




   ,I




   :.




Page 15                                    GAO/AIIviD-98-21.2.5   - Proposed Seized/Forfeited    Asset Checklist   (12/97)
                                                                                                                       ..,
            &set    &spo&ion      activities           !     ~y&/ir;o           ‘:’ 1; :                Explanation’         2    !;
                                                           ; :,I NA:                            /,’., ,,,,r, :,.
               ,.     component                                      .’
    ,:

          Does the system component have                                        ..! ”           ‘,‘Y.’                  :.’ I’S
          the capability to:            c                                                                                         ./’
                                                                                                                                  ,.
                 :::              _,.. ,.                                                                        ,: ’ ‘.
          1. Record accurately and timely
             each asset disposition,
             including the unique identifier                                               ‘.
             of specific asset, type of asset,
             type of disposition, location of
             disposition, responsible
             official, and current asset
             value at time of disposition?

          2. Flag low-value and time-
             sensitive assets to ensure
             their timely recording and
             liquidation?

          3. Record and account
             accurately for all revenues
             and asset specific expenses
             generated from asset
             disposition activities (sale,
             quick release, settlement,
             remission, or dismissal) on an
             asset-by-asset basis?

          4. Verify that proper
             authorization exists for all
             seized asset dispositions?




Page 16                                        GAO/AIMD-98-21.2.5         1 Proposed Seized/Forfeited          Asset Checklist      (E/97)’
           Seized/Forfeited              Asset   .Sys.tem:.Require~en~~                                   ;,     t            .”    , I: ‘: :.   ;.



                                    .I




                 Asset dispqsition   activities                 Yes/no’                                          Explanation
                          component                            : NA.                                  ;           /,.
                                   .                                                                                                                  ,,
              5. Record detailed information                       \      i        -;                 ,:” 1 ‘: ‘,, :;:.I,,;, I;,
                  on each specific asset
                  disposition transaction,                                                                     .‘,       I’,.   ,,
                  including the name, Social                                             ;;1< ,:,                    ‘,.‘,, ,;I,,
                  Security number or tax        :                                                                     ,.    j r,                      -.
                  identification number,   address                                                1
              ,,. ‘,                                                                    ,.                       .“’          ”
                  and employment affiliations of                                                                          :
                  the person(s) receiving the.
                  asset?                                                                     ‘.

              6. Record and account             ’
                 accurately for all distributions
                 of excess revenues over
                 expenses?

              7. Provide a complete
                 accounting for both the     :
                 applicable asset forfeiture
                 fund balances and the seized
                 asset deposit fund balance?

              8. Record deposits of funds
                 associated viith the asset
                 seizure and forfeiture program
                 made into other law
                 enforcement related accounts?

              9. Provide an audit trail for
                 assets distributed to other.
                                                                              .’
                 entities?




Page’l7,                                         GAO/AI&ID-98-21.2.5           - Proposed Seized/Forfeited                         Asset Checklist (E/97)


                                                                                                                                                            --
          Seized/Forfeited       Asset System Requirements                                    :              :L       z


              Asset dispositian  activities           Yes/no                                 Explanation                  ’
                       component                        NA

           10. Record promptly the deposit                                  ..,         +
               of all proceeds from the sale                                                  ,.,‘.
               of forfeited assets into the ;
               applicable Asset Forfeiture                                              (8                       .’
               Fundaccount?                                                       ‘t:          ,.          ,.’            ‘,
                                                                 ,* ,: .i               ,,
           11. Record promptly transfers of
               cash from the applicable
               Seized Asset Deposit Account
               to the applicable Forfeiture:
               Fund account?

           12. Test periodically asset
               disposition transactions to
               ensure that the process is not
               being victimized by insider
               transactions?

           13. Verify independently that all
               billed contractor services
               were actually performed?

          14. Pay promptly innocent owners
               or approved petitions for
               mitigation? The system must.
               interact with the core
              financial system to
               accomplish this task.




Page 18                                  GAO/AIMD-98-21.2.5    - Proposed Seized/Forfeited            Asset Checklist         (12/97)
                                                                          _,        .,j’            ., y ‘,

                                                                    >
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    .   .-



                                                                                           1   ,/




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