Open Recommendations

Meet load and unload scan goals consistently at the Boston Processing and Distribution Center.

In order for senior leadership to be able to consider and decide matters potentially raising constitutional separation of powers issues, we recommend that the Department evaluate when advance notification to a senior Department official, such as the Deputy Attorney General or Attorney General, should be required before compulsory process is issued, and any corresponding NDOs are sought, for records of a Member of Congress or congressional staffers and establish, as necessary, implementing policies and guidance.

We recommend that the Department consider whether there are circumstances in which an exhaustion requirement should be a prerequisite for issuing compulsory process to obtain records of Members of Congress and congressional staffers.

Establish and implement an agency-wide resource committee to monitor and report on corporate resource needs, including existing recruiting strategies, staffing levels, and information technology resources in order to strengthen resource planning and response capabilities for large regional bank resolutions.

Establish a practice of regular interdivisional participation in the development and review of the Regional Resolution Framework procedural documents, as appropriate.

Develop and implement a resolution readiness training program for key personnel responsible for executing the Regional Resolution Framework and related procedures. The training program should address awareness, plan-specific, role-based, and functional training.

Establish and implement a process of periodic interdivisional exercises of large regional bank resolution activities, to test the ongoing effectiveness of agency-wide response and coordination.

Identify from after action review documents the recommendations that are the most critical for large
regional bank resolutions and prioritize them with formal tracking and monitoring.

Establish a plan for ensuring that CISR regularly conducts internal reviews of its large regional bank resolution planning activities, as appropriate based on risk.

Mint management should reinforce and monitor the policy related to access removal tickets for separated Mint employees to effectively remove/disable access within five business days of separation.

Mint management should ensure a thorough review of the obligations classified as "de-obligate" is performed to verify that the obligation is de-obligated timely.

We recommend that BIE develop and implement a plan to monitor identified deficiencies at Tate Topa Tribal School for resolution and correction in accordance with abatement plan timelines.

We recommend that BIE during each health and safety inspection, ensure the inspector verifies that deficiencies identified in the prior year's inspection were corrected or documents them as repeat deficiencies.

We recommend that BIE develop a plan focused on hiring additional maintenance and grounds staff at Tate Topa Tribal School.

We recommend that BIE provide all Tate Topa Tribal School facilities maintenance staff the necessary computer hardware, software, and training to access the facility management system.

We recommend that BIE review and analyze all Tate Topa Tribal School work orders in the Facility Management System and update work order status as needed to ensure accuracy.

We recommend that BIE develop an updated and accurate map of the Tate Topa Tribal School campus.

We recommend that BIE develop and deliver training to emphasize the importance of accurate and complete recordkeeping in the facility management system.

Update SALA’s Accounting Manual to include a specific, compliant method for charging support staff salaries directly to sponsored funding sources as well as policies and procedures to account for hours worked in excess of the SALA 35 hours per week requirement.

Once the Accounting Manual is updated, provide training to its accounting staff.

Update the SALA Accounting Manual with detailed second-party review procedures to ensure that unallowable expenses are not charged to the LSC grants.

Once the Accounting Manual is updated with detailed procedures, train applicable SALA staff on the timecard and second-party review procedures.

Develop detailed review procedures and/or checklists to be used in oversight reviews of records created to support accounting entries and/or compliance assessments.

FHFA should ensure proper staffing and train staff on existing consumer communications requirements as to: (a) timeliness of responses to consumers; and (b) completeness, accuracy, and timeliness in processing documentation.

FHFA should update existing consumer communications procedures as needed to include new controls, or improve existing controls, to ensure: (a) the timeliness of FHFA’s responses to consumers; and (b) the completeness, accuracy, and timeliness of the Agency’s processing of documentation.