Conflicts of Interest in the Acquisition Process

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Date Issued

Monday, September 23, 2024

Submitting OIG

Federal Deposit Insurance Corporation OIG

Other Participating OIGs

Federal Deposit Insurance Corporation OIG

Agencies Reviewed/Investigated

Federal Deposit Insurance Corporation

Report Number

EVAL-24-06

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 7 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
Develop a means of identifying and documenting acquisition-specific team members from the Program Offices, Division of Administration Acquisition Services Branch, Legal Division, and Office of Minority and Women Inclusion.
2	No	$0	$0
Update the Acquisition Procedures and Guidance Manual to (1) define “reasonable planning,” (2) require the documentation of “reasonable planning” for all acquisitions, and (3) require a written description of potential or actual acquisition-specific conflict of interest-related risks in planning documentation.
3	No	$0	$0
Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to complete a conflict of interest certification in which each team member is to assess and document that they do not have a potential or actual conflict of interest related to the specific acquisition prior to participating in any phase of the acquisition lifecycle (from planning to closeout). These procedures should require that evidence of acquisition team members’ conflict of interest certifications is maintained in accordance with requisite FDIC records retention schedule requirements.
4	No	$0	$0
Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to re-certify annually that they remain free of actual or potential conflicts of interest as long as the acquisition is in place.
5	No	$0	$0
Develop and deliver specialized acquisition-related conflict of interest training on at least an annual basis to all acquisition team members to strengthen employee knowledge and skills related to ethics laws and regulations.
7	No	$0	$0
Evaluate whether there should be minimum qualifications and requirements for appointed Deputy Ethics Counselors (DEC), a desired ratio of DECs to filers across FDIC Divisions and Offices, and whether DEC duties should be incorporated into FDIC employee position descriptions to better equip DECs to monitor and respond to employees’ potential and actual conflicts of interest.
8	No	$0	$0
Develop and implement an action plan utilizing Deputy Ethics Counselor survey results and other relevant information to help identify strengths and opportunities for continuous improvement in the FDIC’s financial disclosure review program.