Open Recommendations

FHFA's DHMG Deputy Director should review and update, as necessary, the design of all scoring templates to reflect current practices and provide clarity regarding what fields require completion.

FHFA's DHMG Deputy Director should develop and implement written review and reconciliation procedures to ensure that all scoring template evaluations are complete, accurate, and correspond to the final qualitative impact scores used to rate the Enterprises’ annual Duty to Serve performance.

FHFA's DHMG Deputy Director should revise internal written guidance for the oversight of the Enterprises’ compliance with Duty to Serve requirements to incorporate up-to-date practices that include the following:
a. Review and approval procedures for assigning and documenting scores and ratings for evaluation of the Enterprises’ Plans and performance;
b. Review and approval procedures to ensure that DHMG accurately calculates annual evaluation scores and ratings;
c. Procedures for the practice and frequency of conducting routine meetings with the Enterprises and documenting and communicating results to relevant FHFA stakeholders; and
d. Procedures for the documentation and submission of quarterly monitoring reviews…

FHFA’s SAOP in coordination with the System Owner, should conduct a review of all current privileged user accounts in the FHFA.gov production environment to ensure that each privileged user account has documented access requests and approvals.

FHFA’s SAOP in coordination with the System Owner, should update FHFA’s FHFA.gov Customer Controls to document account management requirements for non-privileged users to include account creation and authorization procedures.

FHFA’s SAOP in coordination with the System Owner, should evaluate and implement additional FHFA.gov audit logging capabilities to ensure the FHFA.gov audit logs captures access and deactivation events for all user accounts.

Develop and implement formal written policies and procedures to ensure all subaward agreements fully comply with federal requirements, including the inclusion of the Federal Award Identification Number. These procedures should also require that subrecipients provide final written certification to the federal awarding agency or pass-through entity at the conclusion of each federal award, confirming that the project or activity was completed or that the agreed-upon level of effort was expended.

Provide staff training on these policies and procedures, and establish a process for periodic internal reviews or monitoring to verify compliance.

Establish and implement policies and procedures to ensure timely preparation and submission of financial and progress reports in accordance with the Uniform Guidance and ARC grant agreement requirements.

We recommend that DRP management update policies and internal guidance to (a) require that staff document the reasons and relevant risk factors for conducting elective annual report reviews, (b) provide clear direction for scoping annual report reviews, and (c) require that staff document scoping decisions.

We recommend that DRP management coordinate with the SEC Office of the General Counsel to finalize the Sarbanes-Oxley Act of 2002 section 408(b) guidance, including a description of all six factors to be considered when selecting issuer filings for elective reviews, and finalize its interpretation of the minimum review period mandate from section 408(c) of the Act.

We recommend that DRP management consider developing a plan that prioritizes Disclosure Review Program goals and requirements in the event of significant staffing decreases and/or significant workload increases.

The OIG recommends that the Executive Director for Operations establish an assessment process to periodically assess the Reactor OpE Program.

The OIG recommends that the Executive Director for Operations update LIC-401 to include a description of the current process by which staff assess the significance of OpE information.

The OIG recommends that the Executive Director for Operations update the Staff Handbook to provide step-by-step guidance for implementing the requirements stated in the updated LIC-401.

The OIG recommends that the Executive Director for Operations include within the updated LIC-401 and Staff Handbook guidance a description of the purpose of “Instruction Sheets” as interim guidance and indicate where they are located, as needed.

The OIG recommends that the Executive Director for Operations develop, communicate, and implement policies and procedures for the EDG TRGs.

The OIG recommends that the Executive Director for Operations systematically inform EDG TRG members about their membership, update the OpE SharePoint site to show the current membership of TRGs, and record TRG evaluations in a centralized location.

The OIG recommends that the Executive Director for Operations provide and promote EDG TRG training to current members on all SharePoint sites.

Issue and distribute to all employees, and prominently post an annual anti-harassment policy statement signed by the Chairman
reinforcing:
• Harassment will not be tolerated,
• Certain conduct is prohibited,
• How to report harassment, and
• Consequences of engaging in harassment and retaliation.

Develop a plan to ensure a culture of accountability and commitment to the CFTC anti-harassment effort. The plan should:
• Include a schedule for training employees and supervisors and a consistent and repeatable mechanism to monitor
attendance.
• Create a reporting mechanism to receive harassment complaints that ensures confidentiality.
o Notify the workforce of this reporting mechanism.
• Develop procedures to ensure consistency in tracking complaints and documenting delays to EEOC-mandated timelines for
sexual and non-sexual harassment claims.

Devote sufficient independent support to harassment prevention efforts to reinforce the credibility of leadership’s commitment to creating a workplace free of harassment.

Promptly resolve instances where non-federal employees are performing prohibited
supervisory functions, such as conducting an employee’s annual performance rating,
engaging in performance-based or adverse action procedures, or rewarding employees.

Promptly update existing and/or implement new human capital management policies
and procedures that comply with the Office of Personnel Management’s hiring guidance
by ensuring non-federal employees do not perform supervisory functions.

We recommend the OFO San Diego Field Office Director, CBP, in coordination with partner agencies, regularly and continuously refine current strategies and identify new strategies to manage delays in detainee transfers to partners to meet time in custody standards at Calexico West POE.