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Management Challenges
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Reports
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Meet the Ventilation and Acceptable Indoor Air Quality Standard in GSA-Owned Buildings
We recommend that the PBS Commissioner complete a comprehensive assessment to determine whether GSA-owned building air handlers meet the ASHRAE ventilation standard’s minimum outdoor air requirements and develop a comprehensive plan to address deficiencies identified.
We recommend that the PBS Commissioner create and implement a plan to notify building occupants whenever deficiencies and hazards associated with outdoor air requirements are identified.
We recommend that the PBS Commissioner ensure that all PBS staff with ventilation system responsibilities, including contracting officer’s representatives, contracting officers, project managers, and building managers, are trained on the requirements of the ASHRAE ventilation standard.
We recommend that the PBS Commissioner ensure operations and maintenance contracts define requirements for regular testing, adjusting, and balancing of air handlers.
We recommend that the PBS Commissioner ensure that GSA’s Guidance for COVID-19 HVAC Operations adheres to CDC COVID-19 guidance for improved building ventilation.
FDIC Examinations of Government-Guaranteed Loans
Develop and implement guidance to examination staff on the credit, operational (including fraud), liquidity, and compliance risks related to Government-guaranteed loans to ensure staff adequately plans and conducts examinations to identify and address emerging risks.
Develop and implement a training plan to ensure examination staff are trained on the requirements and risks of Government-guaranteed loan programs.
Update, develop, and distribute to FDIC examination personnel a list of FDIC examiners who have significant experience examining banks that specialize in Government-guaranteed loan programs to regional offices.
Develop and implement a process to obtain improved data regarding Government-guaranteed lending activities of FDIC-supervised financial
institutions.
Update the [redacted] MOU to include the sharing of loan portfolio information such as historical loan performance, status of guaranty, and loan-level risk characteristics.
Establish arrangements with other Federal agencies that administer Government-guaranteed loan programs to facilitate information sharing and
proactive identification of risk.
Develop and implement processes and procedures for the routine sharing, receipt, and storage of confidential information with Federal agencies that administer Government-guaranteed loan programs.
Develop and implement guidance to provide instruction to FDIC bank examination staff requiring communication and information sharing with Federal agencies that administer Government-guaranteed loan programs to ensure FDIC staff and the Federal agencies are aware of any emerging risks.
Determine whether other Federal agencies that administer Government-guaranteed loan programs have a list of FDIC-supervised banks with high risk factors associated with such programs and develop protocols to share information with relevant FDIC personnel, including examiners.
Develop and implement guidance to ensure relevant risk information exchanged with Federal Government agencies that administer Government-guaranteed loan programs is shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
Develop and implement updated FDIC examination guidance to establish an appropriate timeframe for uploading complete supervisory business records to RADD.
Develop and implement guidance to examination staff to ensure the staff consistently evaluate Government-guaranteed loans in their review of loan classification, assessment of off-balance sheet risk, concentration risk, and ongoing monitoring.
Update and implement the Examination Profile Script to include additional questions on financial institution participation in Government-guaranteed loan programs in order to identify and address emerging risk.
Develop and implement additional items to the Safety and Soundness Request List to identify Government-guaranteed loans, the performance of those loans, and status of the guaranty.
Issue and implement guidance to require that examination staff conduct a fraud risk assessment on future Government-guaranteed loan programs involving FDIC-insured and FDIC-supervised financial institutions to inform policy decisions.
Ensure guidance on future Government-guaranteed loan programs includes all risks associated with such programs and has instructions to allow for consistency in supervisory activities.
Issue and implement guidance for examiners clarifying the FDIC supervisory expectations for reviewing bank PPP activities, including the level of PPP loan volume triggering a heightened review, how examiners should assess the PPP activities of banks that have existing BSA/AML weaknesses, and protocols for examination staff to communicate observed weaknesses.
Revise and implement FDIC guidance and practices for assessing concentrations and loan classification to ensure uniform application with the other Federal bank regulators of supervisory approaches to banks
Coordinate with the other Federal bank regulators to ensure uniform application of supervisory approaches to banks regarding concentrations and loan classification.
Ventilation Issues Persist in Unrenovated Wings of GSA Headquarters Building
The Public Buildings Service Commissioner should continue to monitor IAQ in Wings 0 and 3 of the Headquarters Building, in
accordance with the PBS Desk Guide.
The Public Buildings Service Commissioner should expeditiously notify Headquarters Building occupants of any IAQ results that do not
meet ASHRAE standards.
COVID-19: PBS Faces Challenges in Its Efforts to Improve Air Filtration in GSA-Controlled Facilities
We recommend that the PBS Commissioner for GSA-owned facilities: a. Conduct an accurate and complete assessment of HVAC systems to identify deficiencies in air filtration. Based upon the assessment, PBS should maximize central air filtration in existing HVAC systems without significantly reducing design airflow; b. Review and update current and future operations and maintenance contracts to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; c. Establish controls to ensure that PBS obtains and maintains complete preventive maintenance records; and d. Ensure that contracting officer representatives conduct inspections of mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
We recommend that the PBS Commissioner for GSA-leased space: a. Review and update current and future lease agreements to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; b. Ensure that lessors maintain and provide required preventive maintenance records and provide timely access to mechanical rooms; and c. Ensure that PBS representatives inspect mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
PBS Did Not Always Follow CDC and Internal Guidance to Limit the Risk of COVID-19 Exposure
Issue timely notification of all COVID-19 incidents in GSA-controlled facilities to all occupant agencies, contractors, and visitors. In addition, take steps to maximize awareness of COVID-19 incidents in GSA-controlled facilities.
Ensure that tenant agencies are aware of the requirement to immediately notify PBS of COVID-19 incidents.
Ensure that Scope 3 – COVID-19 Cleaning is followed whenever a COVID-19 incident occurs in a GSA-controlled facility.
Ensure inspection procedures and guidance are clear, concise, and include appropriate processes to conduct and document inspections for Scope 3 – COVID-19 Cleaning. Also, ensure that inspection requirements are communicated to staff.
Implement quality assurance procedures that ensure PBS’s consistent oversight of the delivery of safe, efficient, and effective custodial services.