Open Recommendations

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.

FHFA should train staff on the updated consumer communications procedures as needed.

(U) Rec 1: The DoD OIG recommended that the Under Secretary of Defense for Policy, in coordination with the director of the Defense Security Cooperation agency, work with the director of the Department of State Bureau of Political-Military Affairs office of Regional Security and Arms Transfers to develop and implement a policy stating that a single entity is responsible for notifying both the divesting and receiving security cooperation organizations of all approved, government-to-government third-party transfers of enhanced end-use monitoring-designated defense articles to a hostile environment. Additionally, the policy should require the divesting security cooperation organizations of all initiated transfers and…

FHFA’s Office of General Counsel should seek Freddie Mac legal counsel’s formal position regarding the privacy issues the Enterprise raised with respect to personally identifiable information contained in appraisals that are submitted to state licensing authorities.

FHFA’s Office of General Counsel should assess Freddie Mac legal counsel’s formal position and issue guidance to both Enterprises to ensure a consistent approach.

If FHFA’s assessment in recommendation No. 2 warrants, the Division of Public Interest Examinations should ensure that Freddie Mac resubmits complaints from our sample to the relevant state authorities and include copies of the full appraisal report without duplicating complaints previously submitted by Fannie Mae.

FHFA's Division of Public Interest Examinations should ensure that Freddie Mac updates its existing complaint submission practices so that future complaints filed against appraisers follow the instructions of state appraiser licensing authorities for each complaint, consistent with FHFA’s legal position and guidance to the Enterprises in conjunction with recommendation No. 2.

FHFA's Division of Public Interest Examinations should update its fair lending examination procedures to establish examination performance and documentation standards for ongoing monitoring of remediation activities that are no less rigorous than the standards established for examiners by the Division of Enterprise Regulation and require examiners to document the basis for determinations regarding completed corrective actions taken by the Enterprises to remediate time-sensitive examination findings.

Work with ARC to resolve the reporting discrepancies and revise the Final SF 270 to exclude the questioned cost of $52,706 for ARC funded cost and $14,650 for non-ARC match costs.

Work with ARC to resolve the questioned cost totaling $25,849 for ARC funded equipment costs.

Establish and implement policies and procedures for determining the allowability and allocability of costs, record retention, safeguarding of equipment, timekeeping, and procurement standards as required under the Uniform Guidance.

The IPA recommended that Departmental Offices (DO) management review DO-910 and FARS SSP password setting requirements to determine if they apply to all layers of system technologies (e.g., application, database, and operating system). If necessary, consider specifying distinct password setting requirements for the different layer.

The IPA recommended that DO management implement password authentication controls at the FARS database in accordance with the minimum requirements set by DO-910 and the FARS SSP, to include the number of failed login attempts allowed.

The IPA recommended that DO management: Develop policies and procedures for performing the quarterly review and reauthorization of privileged OS access, which specify: How to document the review of user access for continued appropriateness and the resulting determinations. Assignment of individual(s) responsible for performing the review(s) across the various privileged OS domains/groups/accounts, who are independent of the access they review and are of the appropriate authority. Identification/Inventory of the privileged OS domains/groups/accounts that are subject to review, to include any privileged OS service groups/accounts.

The IPA recommended that DO management disseminate said policies and procedures to control performers and re-perform a review and reauthorization of privileged OS access that enforces independence from an individual reviewing their own access, includes OS service groups/accounts, and is documented/retained, in accordance with the established policies and procedures.

The IPA recommended that Fiscal Service management reinforce policy requirements (through training or other means) for removing logical access of terminated and transferred Fiscal Service employees and contractors within 2 business days of their separation date.

The IPA recommended that Fiscal Service management perform ongoing monitoring to hold responsible control performers accountable for timely completion of such control activities.

The IPA recommended that Fiscal Service implement policies and controls for performing a user access review and recertification of AS Splunk Administrators supporting CAIA on a quarterly basis.

Fiscal Service management implement proper segregation of duties to ensure that an independent review of all user's access is performed as part of the semi-annual PAM Mainframe privileged user access review.

Fiscal Service management enforce accountability of individuals performing user access review control responsibilities in accordance with policies and procedures.

Fiscal Service finalize policies and procedures to review audit logs of production IBM Database 2 (DB2) servers.

Fiscal Service implement an oversight process to ensure that designated Fiscal Service management: (1) reviews the security logs for the UNIX and DB2 servers hosting the PIR, JFICS, and SPS applications on a pre-defined frequency, as indicated in the BLSR; (2) formally documents completion of their reviews and any escalations to the Information System Security Officer (ISS); and (3) retains the audit logs and documentation of its reviews for 18 months, as required by the BLSR.

Fiscal Service periodically review Fiscal Service management's implementation and operation of the review the security audit logs for the UNIX and DB2 servers hosting the PIR, JFICS, and SPS applications to determine that Fiscal Service management completes the reviews on a pre-defined basis, documents completion of the reviews and escalations, and maintains such documentation.

Fiscal Service establish an effective enforcement process or mechanism to ensure that (1) UNIX and DB2 events and monitoring controls are followed, and (2) Fiscal Service management has confidence it consistently reviews for potential unauthorized or inappropriate activity.

Fiscal Service develop and implement documentation to assign responsibility for ensuring adequacy of UNIX and database security and baseline settings.