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Reports
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.
The RRB Did Not Have Detailed Project Plans to Expend Information Technology Modernization Funds
The Railroad Retirement Board's Bureau of Information Services should identify, and document detailed project plans for their Information Technology Modernization initiatives through the Information Resources Management Strategic Plan, which should include the agency's goals, project milestones, and a description of the work necessary, as required by the Office of Management and Budget Circular A-130.
Railroad Retirement Board Did Not Implement Sufficient Internal Controls in the Mobile Phones Deployed as a Result of the Pandemic
The Bureau of Information Services should update their mobile phone policies to include and implement a National Archives and Records Administration-approved records schedule and transfer procedures for electronic records associated with mobile phones.
The Bureau of Information Services should develop and implement a records management and retention system for electronic records.
The Bureau of Information Services should research the capabilities of Railroad Retirement Board's Microsoft Azure Cloud's functionality to determine feasibility of incorporating the automated records management and retention capabilities to govern the mobile phones electronic records.
The Bureau of Information Services should submit a yearly affidavit to confirm electronic records associated with mobile phones have been identified and retained until the full transition into Microsoft Azure Cloud.
The Railroad Retirement Board's Director of Administration should define and communicate 'personal usage' establishing Railroad Retirement Board's core hours of 5:00 am to 7:00 pm. Any usage outside of core hours would be considered personal usage excluding business management purposes.
The Railroad Retirement Board's Bureau of Information Services should 1) continue efforts to update the Telecommuting and Mobile Security Computing Policy with current laws and regulations and 2) develop a periodic monitoring control to assess personal usage and address it according to agency guidance.
The Bureau of Information Services should incorporate the mobile phones in an existing assessable unit and update their mobile phone policies to include documentation regarding the specific roles and responsibilities of each office overseeing the mobile phone program.
The Bureau of Information Services should enforce and execute a review and approval process for application and software download and restrict access to specified applications found in their Railroad Retirement Board G-6 Rules of Behavior.
The Bureau of Information Services should implement procedures to periodically track, log, and monitor iPhone usage and the completion of the G-6 Acknowledgement Statement.
The Bureau of Information Services should periodically review the mobile phone inventory for completeness and accuracy to include a comparison with Railroad Retirement Board's personnel position index.
The Bureau of Information Services should implement the use of unique identifiers between disparate data sets (e.g., mobile phone inventory, personnel position index) to facilitate comparisons and reconcile inconsistent information.
Management Information Report - Railroad Retirement Board's Actions in Response to Pandemic Funding
The Bureau of Fiscal Operations should reconcile the obligations as reported to USAspending.gov and the weekly outlay report to determine the correct total for Coronavirus Disease 2019 obligations charged to the $5 million technology appropriation.
The Railroad Retirement Board's Executive Committee should establish a group tasked with hiring decisions for appropriated funds from the American Rescue Plan Act. This group should use documented and reliable procedures that are based on accurate and reliable data sources to determine hiring and staffing levels using appropriated funders from the American Rescue Plan Act.
The Railroad Retirement Board's Executive Committee should reconsider and revise its plans concerning hiring based on the American Rescue Plan Act appropriation because adequate supporting documentation had not been prepared.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University
Resolve the $1,252 in questioned Award Cash Management $ervice drawdowns for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $14,167 of questioned costs for which it has agreed to reimburse NSF.
Direct FIU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes should ensure FIU appropriately documents how it calculates the final draw amounts for awards with expiring appropriations, to ensure it only uses the draws to cover costs incurred before the appropriation expired.
Direct FIU to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Resolve the $791 in questioned fringe benefit costs for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $5,934 of questioned promotional and salary costs for which it has agreed to reimburse NSF.
Direct FIU to establish clear guidance regarding the <span class="tx-tooltip" tabindex="0">
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of participant support cost funding. This guidance should address: a. Allowable uses of participant support cost funding. b. How to verify personnel did not apply fringe benefit rates to participant stipends or other non-salary expenses.
Direct FIU to strengthen its monitoring procedures surrounding costs charged to its NSF Research Experiences for Undergraduates programs. Updated procedures should ensure FIU charges costs associated with promotional and/or other unallowable items to nonFederal funding sources.
Direct FIU to update its current practices to ensure it only applies fringe benefits using fringe benefit rates that have been approved by its cognizant audit agency.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – State University of New York at Stony Brook
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $20,530 of questioned Award Cash Management $ervice drawdowns associated with unspent funds.
Direct Stony Brook to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes could include validating that Stony Brook only draws down funding based on immediate cash needs and/or adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $6,913 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to provide additional guidance to ensure personnel reimburse NSF timely for cash drawn down for unused travel advances.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $3,898 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to strengthen its monitoring procedures and internal controls surrounding the allocation of travel expenses to sponsored projects. Processes could include reviewing and assessing the allocation of all travel expenses charged to NSF awards.
Direct Stony Brook to separately track its on-campus and off-campus activities so that it can appropriately apply the approved on-campus and off-campus indirect cost rates.
Direct Stony Brook to update its current budget proposal process to eliminate the use of blended indirect cost rates.
Direct Stony Brook to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct Stony Brook to update its current award set-up practices to remove the establishment of indirect cost budget caps.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of New Mexico
Resolve the $17,269 in questioned unreasonable per diem, airfare, and ground transportation costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to strengthen its administrative and management procedures for reviewing travel expenses incurred on sponsored projects. Updated procedures could include periodic training for Principal Investigators to ensure they understand when NSF Grant Officer approval should be requested and how to appropriately document that only reasonable costs were charged to NSF awards.
Direct UNM to strengthen its policies and procedures regarding the reasonableness of per diem expenses incurred when employees are temporarily relocated for a period longer than 30 days.
Resolve the $3,613 in questioned tuition costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to provide documentation supporting that it has repaid or otherwise credited the $83 of questioned travel costs for which it has agreed to reimburse NSF.
Direct UNM to strengthen its controls surrounding the approval of expense reimbursements to ensure approvers appropriately verify that travelers are reimbursed at the appropriate U.S. General Services Administration per diem rate(s).
Direct UNM to strengthen its policies and procedures surrounding the use of participant support cost funding to cover tuition remission expenses. Specifically, UNM should update its current tuition remission policies and procedures to ensure that it does not use participant support costs to cover costs associated with credit hours that do not benefit student participants.
Direct UNM to update its award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct UNM to require subawardees to apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the subaward agreement, rather than using the rates included within the subaward budget and proposal.
Management Information Report - Interim Review of Railroad Retirement Board CARES Act Benefit Payments During the Pandemic
The Office of Inspector General recommended that the Office of Programs allocate resources for the Railroad Retirement Board’s Unemployment and Programs Support Division – Sickness and Unemployment Benefit Section to work on fraud referrals as provided in the Adjudication Instruction Manual, Part 16, and as instructed by the Office of Inspector General, Office of Investigations.
The Office of Inspector General recommended that the Executive Committee commit additional resources necessary to ensure the implementation of an automated debt recovery process for CARES Act payments.
Management Information Report - Interim Report Regarding CARES Act Expenditures and Controls
We recommend that the Executive Committee reconsider the need for all Railroad Retirement Board employees to have the mobile phone and the related recurring costs.
We recommend that the Executive Committee make the mobile phone numbers available internally for the Railroad Retirement Board employees since these are considered secondary contact methods.
We recommend that the Executive Committee obtain state wage and unemployment data in a timelier manner in order to match with CARES Act Railroad Retirement Board payments; thereby identifying potential fraudulent CARES Act payments quicker and increasing program integrity.