**Status Report to the Court**

**Number Twenty-Five**

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**For the Period**

**January 1, 2006 through March 31, 2006**

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**May 1, 2006**

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**TABLE OF CONTENTS**

[**I.** **INTRODUCTION** 1](#__RefHeading___Toc134240030)

[**A.** **INFORMATION TECHNOLOGY** 2](#__RefHeading___Toc134240031)

[**B.** **CADASTRAL SURVEY** 11](#__RefHeading___Toc134240032)

[**C.** **MINERALS MANAGEMENT SERVICE**
13](#__RefHeading___Toc134240033)

[**D.** **OFFICE OF HISTORICAL TRUST ACCOUNTING**
14](#__RefHeading___Toc134240034)

[**II.** **OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN INDIANS**
17](#__RefHeading___Toc134240035)

[**A.** **TRUST REVIEW AND AUDIT** 19](#__RefHeading___Toc134240036)

[**B.** **OST-OFFICE OF THE CHIEF INFORMATION OFFICER**
21](#__RefHeading___Toc134240037)

[**1.** **RECORDS MANAGEMENT** 21](#__RefHeading___Toc134240038)

[**C.** **TRUST ACCOUNTABILITY** 24](#__RefHeading___Toc134240039)

[**1.** **TRUST BUSINESS PROCESS MODELING**
24](#__RefHeading___Toc134240040)

[**2.** **TRUST DATA QUALITY AND INTEGRITY**
26](#__RefHeading___Toc134240041)

[**3.** **INDIAN FIDUCIARY TRUST TRAINING PROGRAM**
28](#__RefHeading___Toc134240042)

[**4.** **RISK MANAGEMENT** 30](#__RefHeading___Toc134240043)

[**5.** **REGULATIONS, POLICIES AND PROCEDURES**
32](#__RefHeading___Toc134240044)

[**D.** **FIELD OPERATIONS** 34](#__RefHeading___Toc134240045)

[**1.** **APPRAISAL** 34](#__RefHeading___Toc134240046)

[**E.** **TRUST SERVICES** 37](#__RefHeading___Toc134240047)

[**1.** **CURRENT ACCOUNTING ACTIVITIES**
37](#__RefHeading___Toc134240048)

[**III.** **BUREAU OF INDIAN AFFAIRS** 41](#__RefHeading___Toc134240049)

[**A.** **TRUST REGULATIONS, POLICIES AND PROCEDURES**
41](#__RefHeading___Toc134240050)

[**B.** **FRACTIONATION** 43](#__RefHeading___Toc134240051)

[**C.** **PROBATE** 45](#__RefHeading___Toc134240052)

[**ACRONYMS AND ABBREVIATIONS** 47](#__RefHeading___Toc134240053)

I.  []{#__RefHeading___Toc134240030 .anchor}**INTRODUCTION**

This *Status Report to the Court Number Twenty-Five* (Report) represents
the period from January 1, 2006, through March 31, 2006. The Report is
presented for the purpose of informing the Court of actions taken since
the issuance of the preceding quarterly report. In addition, the Report
references some matters that might be of interest to the Court,
including delays in and obstacles to trust reform activities, and a
report on the progress of the historical accounting of individual Indian
beneficiary funds managed by Interior.[^1]

This Report is prepared in a manner consistent with previous reports to
the Court. Managers from the Office of the Chief Information Officer,
Bureau of Indian Affairs, Bureau of Land Management, Minerals Management
Service, Office of the Special Trustee for American Indians, and Office
of Historical Trust Accounting submit reports on the status of their
respective Indian trust activities.

A change in the Report format Interior brings to the Court's attention
is that there will not be a Secretary's Observations section in this
Report. The Acting Secretary, P. Lynn Scarlett, will sign the Report as
part of the transmittal of the Report to the Court.

A glossary of acronyms and abbreviations is included in this Report. The
glossary is located at the end of the Report.

A.  []{#__RefHeading___Toc134240031 .anchor}**INFORMATION TECHNOLOGY**

**[Introduction]{.underline}**

This section describes the status of Interior IT systems, particularly
the systems that house or provide access to IITD or provide various
computing capabilities, including functions critical to the proper
administration of the individual Indian trust responsibilities within
Interior. In addition, this section describes various efforts being made
to improve IITD security within Interior, pursuant to OMB Circular A-130
Appendix III, and the status of Internet connectivity.

**[Accomplishments and Completions]{.underline}**

**Computer Security:**

> The primary focus for this reporting period has been remediation of
> weaknesses, reduction of open POA&M items, and IT security policy.
> Interior continued to make progress in enhancing IT security, through
> continuous monitoring of Internet-accessible systems and implementing
> corrective actions for weaknesses identified by the Interior
> penetration tests and audits of financial systems. The most noteworthy
> accomplishments, completions and challenges during the reporting
> period are described below.
>
> ***ESN:***

-   Two Internet gateway routers were replaced with newer and more
    capable equipment. This upgrade is expected to enhance security and
    increase availability of Internet services.

-   BLM reconfigured Denver and Portland interfaces to the ESN to create
    a more consistent, layered approach to the perimeter security,
    including intrusion prevention systems, firewalls, routers, and
    application firewalls.

> ***Prevention and Monitoring:***

-   Interior continued its external perimeter extended vulnerability
    scan testing of Internet-accessible systems, using capabilities
    established at ESN. As of the end of this reporting period, all
    identified critical or major vulnerabilities in trust systems were
    either remediated or were identified as false positives.

-   Interior continued deployment of the Interior-wide internal scanning
    tool for BOR, NPS, FWS and OST. Interior also continued refining the
    internal scanning process in order to reduce the number of false
    positives. Reducing false positives should allow Interior to focus
    on remediating actual vulnerabilities.

-   BLM procured, configured and implemented a security event log
    consolidation and evaluation program that provides increased
    security response, including custom coding an automated quarantine
    tool to deny access to BLM resources to all potentially hostile
    contacts.

-   There were no successful security incidents detected during this
    reporting period that resulted in the compromise of trust systems or
    data.

> ***Policies and Guidance***

-   The Interior CIO issued "Information Resources Management (IRM)
    Internal Control Review (ICR) Guidance for FY 2006" to the heads of
    bureaus and offices on January 31, 2006. This directive transmitted
    Interior's "Guidelines for FY 2006 Internal Control and Audit
    Follow-up Programs," dated November 4, 2005, that requires
    performing annual ICR assessments by evaluating the security
    controls in place for all IT systems contained in Interior's IT
    system C&A master list.

-   The Interior Chief Information Security Officer and OIG agreed to
    "Rules of Engagement for IT Security Penetration Testing" on
    February 9, 2006. This document provides a framework of procedures
    and guidelines to be followed by OIG, its contractor and Interior in
    performing the independent evaluation of Interior's public-facing
    network infrastructure and ESN. It establishes the test objective,
    scope, timeframe, rules, and points of contact.

-   The Interior CIO issued "Software Piracy" to the heads of bureaus
    and offices on February 14, 2006. This directive sets Interior's
    policy for the prevention of software piracy.

-   The Interior CIO issued "Fiscal Year 2006 (FY06) Annual End-user
    Federal Information Systems Security Awareness Training" on February
    17, 2006, and "Fiscal Year 2006 (FY 2006) Annual End-user Federal
    Information Systems Security Awareness Training" on March 10, 2006,
    to the assistant secretaries and heads of bureaus and offices. These
    memoranda require that all personnel, including contractors and
    other external authorized users, with access to DOI information
    systems complete training that satisfies the annual FISMA
    requirement. It also mandates the use of a centralized source to
    standardize the training across Interior.

-   The Interior Deputy Secretary issued "Approval of the Interior\'s
    Enterprise Architecture" to the heads of bureaus and offices on
    February 27, 2006. This memorandum endorses the Interior's IT
    Investment Review Board approval of the IEA as outlined in Version
    2.0 of the ETP. The ETP provides a sequencing plan that describes
    the business transformation efforts required to move Interior from
    its current state to the target architecture. The ETP is in
    alignment with guidance from OMB.

-   The Interior CIO issued "Plan of Action and Milestones (POA&M)
    Process Standard" to the heads of bureaus and offices on February
    27, 2006. This revised guidance provides a set of standards and
    procedures for developing and maintaining bureau and office POA&Ms
    for identifying weaknesses, managing remediation, and providing
    quarterly reporting to OMB.

-   The Interior CIO issued "Interim Guidance for the Certification and
    Accreditation of Information Technology Systems" to the heads of
    bureaus and offices, SOL, OIG, and bureau and office CIOs on March
    14, 2006. This directive provides guidance on the C&A process to be
    used throughout Interior regarding implementation of the NIST
    Special Publications 800-37, 800-18, 800-30, 800-34, 800-47, 800-53,
    800-60, and FIPS Publications 199 and 200.

-   The Interior CIO issued "Information Technology (IT) System
    Inventory Requirements" to the heads of bureaus and offices on March
    20, 2006. This directive provides supplemental guidance to OCIO
    Directive 2004-010 "Population and Maintenance of the Department of
    the Interior Enterprise Architecture Repository" on system inventory
    requirements.

-   The Interior CIO issued "Instant Messaging, Internet Relay Chat, Web
    Conferencing, and Peer-to-Peer Usage Policy" to the assistant
    secretaries, and heads of bureaus and offices on March 20, 2006.
    This directive establishes usage policy and procedures for various
    collaborative programs. It also mandates standardization and
    technical controls to ensure the computing environment and data
    remain secure.

-   MMS issued security requirements for all network users to read and
    acknowledge the FY2006 MMS IT rules of behavior, which apply to all
    MMS IT systems.

> ***Training and Awareness***

-   Training was held for users of DEAR's new reporting and C&A
    self-guided capabilities in DC and Denver, a step-by-step process
    that allows for standardized and consistent input of data. The new
    enhancements to DEAR provide for one authoritative data source that
    links each information system to an overall C&A boundary, thus
    improving oversight and reporting with respect to FISMA
    requirements. Training focused on:

-   Assuring roles, processes, and tasks for collecting and maintaining
    information were clearly defined and reviewed;

-   Performing quality assurance checks on the information contained in
    DEAR using the new reporting features;

-   Using NIST Special Publication 800-60 guidance to assess the
    appropriate confidentiality, integrity and availability ratings of
    an accreditation boundary.

**Plans of Action and Milestones:**

-   Interior reduced POA&M weaknesses by 9.6 percent during this
    reporting period. Interior remediated and closed out 327 weaknesses.
    Interior continues to address the remaining 1,211 open weaknesses.

**A-130 Certification and Accreditation:**

-   BIA reviewed and updated all trust system security plans to be
    compliant with NIST Special Publications 800-60 and 800-53
    standards. This included following the FIPS Publication 199
    guidelines to determine the appropriate security categorization
    (high, medium, or low) for each system. NIST Special Publication
    800-53 requires the selection and employment of appropriate security
    controls for an information system based upon the security
    categorization of the system.

-   BIA performed tests on a new document scanning module for TAAMS. The
    test results will be evaluated to assess the impacts, if any, that
    the introduction of the module will have on the system as a whole.

-   BIA completed the ST&E and C&A documentation of the Trust Network
    Root Enterprise Active Directory system and is reviewing for
    submission to the DAA.

**E-Authentication and HSPD-12:**

-   BLM has transferred existing Smartcard technology to NBC for
    implementation of HSPD-12 Personal Identification Verification
    (PIV-II) requirements.

**Staffing:**

-   Interior filled several key positions this reporting period,
    including a Deputy CIO, IT Security Project Manager, IT Enterprise
    Security Architect, IT Security Trust Officer and an Information
    Systems Security Officer, OST Deputy CIO, and BIA IT Security and
    Privacy Deputy Office Director and Security Engineer.

**[Current Status]{.underline}**

**A-130 Certification and Accreditation:**

-   All trust systems have full ATO status except for one. The one
    exception is a BIA legacy system called the Land Ownership Tracking
    System. The system was operating under an IATO valid for 90 days
    from December 19, 2005. The IATO for this system is expected to be
    renewed and remain valid until the system is retired, which is
    expected by the end of CY2006. The risk of continued operation under
    an IATO has been determined to be necessary since the system is
    required for BIA to conduct its business.

**ZANTAZ:**

-   The contract to restore the ZStage tapes was awarded. All bureaus
    and offices affected by the ZStage issue from the last reporting
    period sent their tapes to ZANTAZ.

    -   OST sent 112 backup tapes and all were restored without
        incident.

    -   SOL sent 97 backup tapes and restoration is expected to be
        complete by the end of June 2006.

    -   NBC Denver sent 57 backup tapes and restoration is expected to
        be complete by the end of June 2006.

    -   NBC DC sent 409 backup tapes and restoration is expected to be
        complete by the end of June 2006. Three tapes have not been sent
        because of national security issues.

    -   BIA sent 280 backup tapes. Of the 280 tapes sent, 268 of these
        tapes are blank and 12 tapes have only partial data. BIA sent a
        technician to ZANTAZ in an attempt to confirm whether the tapes
        were blank. On March 31, 2006, BIA sent ZANTAZ one tape that it
        believes may contain some of the data that would have been
        captured on the 280 tapes.

-   The NBC Denver servers were upgraded on January 27, 2006, to correct
    the ZStage issues reported in the last reporting period.

-   BLM shipped a new router to the ZANTAZ Las Vegas data center for the
    connection to the archive servers. The new router is part of a
    technology refresh effort and will include implementing a buffer
    server between the BLM forwarder and the ZANTAZ data center. This
    will provide up to two weeks of buffer space in the event that
    connectivity to the datacenter is interrupted for an extended
    period.

-   BIA deployed a ZStage Alert script in late November 2005. During
    this period, the ZStage Alert script noted problems in three areas
    have been referred to ZANTAZ for further investigation.

-   A misconfiguration by one user caused that user's messages not to
    reach ZANTAZ. BIA expects to coordinate with ZANTAZ to deliver
    whatever messages can be recovered to the digital safe.

-   Notification messages informing the user of e-mail delivery failures
    were not being captured by ZANTAZ. Messages which the user attempted
    to send, but which were not actually sent, were captured by ZANTAZ.
    Therefore, ZANTAZ will show a discrepancy between the senders' and
    receivers' e-mail collections.

-   A process irregularity occurred whereby an incorrect ZStage value
    indicated that the e-mail was not captured when it actually has
    been. This created a false negative in the ZStage value.

**REPORTS:**

These reports were among those issued during this reporting period.

> ***FISMA***

-   OMB issued "FY 2005 Report to Congress on Implementation of The
    Federal Information Security Management Act of 2002," on March
    1, 2006. This report informs Congress and the public of the Federal
    government's security performance, and provides OMB's assessment of
    government-wide information technology security strengths and
    weaknesses and a plan of action to improve performance. It provides
    key security performance measures from FY2002 through FY2005 for
    each agency, based on the report issued by each agency's OIG. While
    Interior does not believe the FISMA report reflects the current
    status of Interior's information technology security, Interior
    acknowledges that the report identified some important areas that
    need improvement. These areas include, but may not be limited to
    network security, POA&M, and C&A.

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-   The House Government Reform Committee issued the "Federal Computer
    Security Grades - 2001-2005" on March 16, 2006. This document is
    compiled by the Committee from FISMA reports submitted to Congress
    by agency CIOs and OIGs. The Committee report, based on the FY2005
    report issued by Interior's OIG, indicates Interior's grade moved
    from "C+" in FY2004 to an "F" in FY2005. Interior is concerned that
    the FY2005 congressional FISMA report card did not reflect the
    current status of its information technology security.

-   The Interior CIO, in a letter to Congressman Davis, Chairman of the
    House Government Reform Committee, stated that the FISMA report "did
    not reflect the current status of \[Interior's\] information
    technology security ... despite further improvements to
    \[Interior's\] IT security." The letter notes the following
    "accomplishments that strengthened \[Interior's\] IT security":

-   Provided \$1.1 million to OIG for penetration testing in all
    bureaus;

-   Certified and accredited 98 percent of IT systems, with 100 percent
    quality assurance reviews;

-   Trained 98.7 percent of the workforce in user security awareness;

-   Ensured that 67 percent of IT security specialists completed
    role-based training;

-   Increased the number of certified security professionals from 63 to
    86;

-   Survived 650 million probes and attacks, with only a couple of web
    defacements, through sophisticated vulnerability scanning and
    enhanced intrusion detection and prevention devices;

-   Consolidated 13 networks into one with added security services;

-   Reduced Internet Service Providers from 35 to 5, which created
    simpler and more effective perimeter security;

-   Developed eight enterprise software and hardware agreements for
    standardization, cost efficiencies, and increased security;

-   Received OMB's top ranking for Interior's enterprise architecture
    with an integrated security architecture;

-   Submitted 60 IT investment proposals to OMB: each received passing
    IT security scores and OMB approval, and security was given special
    review in each case;

-   Established qualified project managers on major IT projects;

-   Maintained a privacy program recognized as a best practice by the
    Industry Advisory Council; and,

-   Completed the first departmental IT security assessment through an
    independent contractor. The nine major program areas received
    ratings of four good, four satisfactory and one unsatisfactory.

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-   GAO issued "INFORMATION TECHNOLOGY: Agencies Need to Improve the
    Accuracy and Reliability of Investment Information (Report No.
    GAO-06-250)," to Congressional Requesters on January 12, 2006. The
    report responds to a Congressional request to determine the extent
    to which selected agencies have underlying support for their FY2006
    investment information. It emphasizes the use of the GAO-developed
    IT Investment Management framework in implementing capital planning
    processes and notes Interior to be among those agencies using the IT
    Investment Management Framework. Interior was cited as having made
    significant improvements.

-   The Interior IG issued "Security Vulnerabilities at the Information
    Technology Center Place Sensitive Data at Risk (Report No.
    NSM-EV-OSS-0004-2006)," on January 17, 2006. The report details IT
    security vulnerabilities that would allow unauthorized users access
    to sensitive data located on the NBC network. The concern was that
    the Information Technology Center could be physically entered by
    anyone with access to the Main Interior Building. NBC has developed
    and implemented corrective actions for a majority of the
    vulnerabilities. Corrective actions have been developed and
    prioritized as POA&Ms for the remaining vulnerabilities identified
    in the report.

-   OMB issued "Report to Congress on the Benefits of the President's
    E-Government Initiatives," on January 20, 2006. This report provides
    a status update to Congress on E-Government initiatives which were
    approved by the President's Management Council. Initiatives included
    E-Authentication and the security line of business.

-   BIA and ESN issued "NBC Network Security Recommendations Report."
    The report, developed in collaboration with NBC, provides
    recommendations for improving the security of BIA connections to NBC
    applications and is intended to prevent the possibility of access to
    sensitive BIA data and systems from users on the NBC network. This
    has a low risk of occurrence and a configuration change has been
    developed and programmed for implementation to correct the weakness.

> ***MRM Legacy Media***
>
> As previously reported, MRM expected to dispose of 30,000 legacy
> backup tapes that contain data redundant to data in the new MRMSS. Due
> to objections by tribal litigants, MRM has postponed the disposal of
> these tapes pending resolution of objections.

**[Delays and Obstacles]{.underline}**

Like other federal agencies, Interior must address many challenges
regarding the integration, performance, funding, security, and data
integrity of IT systems. Interior initiated or completed steps to
address some of the challenges reported in this and previous reporting
periods. However, delays and obstacles listed below impede progress in
achieving Interior's IT management goals.

**Litigation**

-   Delays caused by last summer's extensive collection and production
    of documents and by Court appearances continue to put Interior
    several months behind in completing many required IT and IT security
    activities. These include completing corrective actions from audits
    and on POA&Ms, updating of required security policies and
    procedures, and implementing initiatives critical to continued
    improvements in IT security.

-   Employee fears about becoming personally implicated in the *Cobell*
    litigation continue to undermine communication and decision-making,
    and are contributing factors to low employee morale.

**Staffing**

-   Interior is experiencing high staff and management turnover in
    critical IT positions, particularly IT security. Recruitment
    challenges to attract qualified candidates continue, particularly in
    light of litigation impacts. The CISO position remains vacant and
    the Department's IT security staff is at 70 percent.

**Funding and Resources**

-   OCIO, along with Interior bureaus and offices, is responding to an
    extraordinary level of scrutiny, including OIG evaluations and
    audits, GAO evaluations and audits, and OMB required reviews. With
    the significant increase in review, Interior is expending
    considerable efforts in data collection, document production and
    related workloads, which diminishes the resources available for IT
    security-related activities. For example, staff has less time to
    implement and test security controls.

-   Funding availability will continue to dictate the timing of
    IT-related initiatives. Interior's FY2006 budget will require
    managing a variety of IT-related requirements and tradeoffs.
    Interior continues to prioritize its IT security needs in its budget
    requests within fiscal constraints.

**Denied Internet Access**

-   Several Interior bureaus and offices (BIA, OHA, OST and SOL) have
    not been permitted by the Court to have Internet access since
    December 5, 2001. Lack of Internet access impedes work processes and
    the ability to communicate effectively, both internally and
    externally. For example:

-   Coordination and dissemination of new policies and training is
    delayed due to the need to deliver material physically. Even after
    receipt, considerable re-work is required to tailor web-based
    training programs to run locally.

-   Policy discussion is hampered due to additional time required in
    coordinating group discussions via teleconferencing when e-mail
    collaboration would be more appropriate and timely.

-   Ensuring Continuity of Operations and Continuity of Government
    through the implementation of contingency plans requires rapid
    notification of an event. The lack of Internet access degrades
    Interior's capabilities to notify all of its bureaus and offices in
    a timely and efficient manner.

-   Maintaining security on internal systems is more difficult without
    access to the Internet for research, reporting, and patch
    management.

-   The concerns over potential future Court-ordered Internet shutdowns
    or other Court-ordered disruptions create uncertainty over how to
    proceed with enterprise initiatives and security improvements.
    Contingency planning for either external or internal disconnections
    (and all potential permutations) takes resources from planned and
    daily activities.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the
Information Technology section of the *Status Report to the Court Number
Twenty-Five*. The information provided in this section is accurate to
the best of my knowledge.

Date: April 20, 2006

Name: *Signature on File*

W. Hord Tipton

Interior Chief Information Officer

A.  []{#__RefHeading___Toc134240032 .anchor}**CADASTRAL SURVEY**

**[Introduction]{.underline}**

Cadastral surveys provide assurance that land boundaries for individual
Indian and tribal trust lands are identified appropriately. By federal
law, surveys of Indian lands are to be performed under BLM's direction
and control. Official surveys, whether preexisting or new, identify the
location of land boundaries of Indian trust assets and determine
official acreage. The official surveys are integral to realty
transactions, resource management activities, litigation support and the
federal system of patent, allotment and survey records maintained by
BLM. Ownership information, distribution of trust assets, and management
of trust accounts may be related to or based upon information recorded
in official surveys.

**[Accomplishments and Completions]{.underline}**

**BLM Indian Lands Surveyors**

During this reporting period, the FTM goal to hire and locate 12 BLM
Indian lands surveyors for the 12 BIA Regions was accomplished, with the
final six surveyors having reported to duty.

The BLM Indian lands surveyors for Eastern, Navajo, Pacific, Rocky
Mountain, Southwest and Western Regions reported to their respective
duty locations in this reporting period. All BLM Indian lands surveyors
are actively working with BIA staff and others in addressing survey
boundary issues.

**[Current Status]{.underline}**

**Interior Standards for Indian Trust Lands Boundary Evidence**

Reviews of the draft Standards for Indian Trust Lands Boundary Evidence
(previously referred as Draft Boundary Standards) were received from the
Office of the Solicitor, Division of Land and Water Resources, Branch of
Public Lands, and the Division of Indian Affairs, Branch of General
Indian Legal Affairs. The SOL comments were integrated into the revised
draft. The updated draft will be provided to the Directives Coordinator,
Office of Planning and Performance Management, Assistant Secretary -
Policy Management and Budget for inclusion in the Departmental
Directives system.

**Implementation of the FTM**

During this reporting period the FTM goals continued to be implemented.
These goals as they relate to cadastral survey are: (1) funding for the
12 BLM Indian lands surveyors located in the BIA Regions; (2) creation
of the Certified Federal Surveyor program (where state licensed land
surveyors can be certified to perform commercial activities under the
direction and control of BLM); (3) improving the maintenance of the
Public Land Survey System within Indian Country; and (4) creation of one
standardized source of land status information based on cadastral data
that delineates the official legal land descriptions.

The main focus of the CFedS program for this reporting period was the
development of the training program. The training will be offered
through distance learning. Approximately 30 hours of the planned 50
hours of video lecture were developed, and several web-based problems
and case studies nearly completed. The draft manual and handbook for the
administration and oversight of the CFedS program are in review. It is
anticipated that the CFedS program should assure better survey
integrity, and should increase the production of surveys.

An inventory of the survey conditions for all exterior boundaries on 325
Indian reservations was prepared during this reporting period as part of
the FTM implementation. The inventory consists of information about the
condition and era of the survey monumentation (on-the-ground survey
markers) along with their extent and location. This inventory will serve
as the basis for prioritizing funding allocations and the commitment of
resources to meet BLM's fiduciary trust responsibilities.

**[Delays and Obstacles]{.underline}**

**Disconnection from the Internet**

The Court-ordered disconnection from the Internet continues to adversely
impact the way communications are handled between BLM, BIA, OST and SOL,
including the way CARS is being implemented and the review of the
Interior Indian Trust Lands Boundary Standards**.** BLM's productivity
has decreased, and the cost associated with dual networks has caused the
cost of survey services to increase. This issue continues to impact
BLM's ability to provide cadastral services in an effective and cost
efficient manner to clients.

**Funding of the FTM**

Planning and scheduling of out-year FTM work is dependent on future
funding.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Cadastral
Survey section of the *Status Report to the Court Number Twenty-Five*.
The information provided in this section is accurate to the best of my
knowledge.

Date: April 19, 2006

Name: *Signature on File*

Donald A. Buhler

Chief Cadastral Surveyor

Bureau of Land Management

B.  []{#__RefHeading___Toc134240033 .anchor}**MINERALS MANAGEMENT
    SERVICE**

**[Introduction]{.underline}**

Minerals Revenue Management, an MMS program, is responsible for
collecting, accounting for, and distributing mineral revenues from both
federal and Indian mineral leases, and for evaluating industry
compliance with laws, regulations and lease terms. MRM maintains
reported information and distributes revenues at the lease level. BIA
maintains individual Indian ownership records that are used to provide
information to OST for disbursement of the lease revenues to individual
Indian beneficiaries.

**[Current Status]{.underline}**

**Indian Oil Rule**

MMS continued with the rulemaking process for the valuation of oil
produced from tribal and allotted Indian lands. The proposed rule was
published in February 2006, and the comment period ended on April 14,
2006.

**Payment Receipt Date Verification**

MMS continues to work with its contractor on system modifications to
finalize a listing of prior data errors in the Indian mineral revenue
distribution file. The data listings will be provided to BIA, OST, and
any affected tribes.

**MRM Legacy Media**

As previously reported, MRM expected to dispose of 30,000 legacy backup
tapes that contain data redundant to data in the new MRMSS. Due to
objections by tribal litigants, MRM has postponed the disposal of these
tapes pending resolution of objections.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Minerals
Management Service section of the *Status Report to the Court Number
Twenty-Five*. The information provided in this section is accurate to
the best of my knowledge.

Date: April 20, 2006

Name: *Signature on File*

Cathy J. Hamilton

Chief of Staff

Minerals Revenue Management

Minerals Management Service

C.  []{#__RefHeading___Toc134240034 .anchor}**OFFICE OF HISTORICAL TRUST
    ACCOUNTING**

**[Introduction]{.underline}**

OHTA was established by Secretarial Order No. 3231 on July 10, 2001, and
is charged with planning, organizing, directing and executing the
historical accounting of IIM and tribal trust accounts. Since its 2001
inception, neither OHTA nor its contractors have stored the IIM
transaction data used to perform historical accounting on a system
connected to the Internet.

**[Current Status]{.underline}**

**Judgment and Per Capita IIM Accounts**

OHTA continues to perform historical accounting procedures on Judgment
and Per Capita IIM accounts. During this reporting period, OHTA
reconciled an additional 3,818 Judgment IIM accounts and 2,022 Per
Capita IIM accounts.

Results through March 31, 2006, are summarized in the table below.

+----------------------------+-----------+-------+-----------+-------+
|                            | **        |       | **[Per    |       |
|                            | [Judgment |       | Capita    |       |
|                            | Accou     |       | Accou     |       |
|                            | nts]{.und |       | nts]{.und |       |
|                            | erline}** |       | erline}** |       |
+----------------------------+-----------+-------+-----------+-------+
|                            |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+
|                            | **Number  | **Pe  | **Number  | **Pe  |
|                            | of        | rcent | of        | rcent |
|                            | [Accou    | [of   | [Accou    | [of   |
|                            | nts]{.und | Total | nts]{.und | Total |
|                            | erline}** | ]{.un | erline}** | ]{.un |
|                            |           | derli |           | derli |
|                            |           | ne}** |           | ne}** |
+----------------------------+-----------+-------+-----------+-------+
|                            |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+
| Total at December 31, 2000 | 80,539    | 100%  | 19,033    | 100%  |
|                            |           |       |           |       |
| > (including accounts open |           |       |           |       |
| > at or after October 25,  |           |       |           |       |
| > 1994, but closed prior   |           |       |           |       |
| > to December 31, 2000)    |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+
| Reduction for accounts     | \(835\)   | (1%)  | N/A       | N/A   |
| subsequently               |           |       |           |       |
|                            |           |       |           |       |
| > determined to be outside |           |       |           |       |
| > of the scope of the      |           |       |           |       |
| > population               |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+
| Reconciled January 1,      | (50,519)  | (63%) | (15,086)  | (79%) |
| 2001, through              |           |       |           |       |
|                            |           |       |           |       |
| > December 31, 2005        |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+
| Reconciled this reporting  | ([3       | ([5   | ([2       | ([11  |
| period                     | ,818]{.un | %]{.u | ,022]{.un | %]{.u |
|                            | derline}) | nderl | derline}) | nderl |
|                            |           | ine}) |           | ine}) |
+----------------------------+-----------+-------+-----------+-------+
| Remaining to be reconciled | 25,367    | 31%   | 1,925     | 10%   |
| at                         |           |       |           |       |
|                            |           |       |           |       |
| > March 31, 2006           |           |       |           |       |
+----------------------------+-----------+-------+-----------+-------+

**Mailings to Judgment and Per Capita IIM Account Holders**

On March 9, 2006, a fourth submission for permission to mail 20,402
Historical Statements of Account was filed with the U.S. District Court.
The third submission to mail 28,107 Historical Statements of Account was
filed on March 24, 2005. Mailing of these 48,509 Historical Statements
of Account awaits approval from the Court.

In its October 22, 2004, Order, the Court permitted OHTA to transmit
Historical Statements of Account to 17,096 Judgment IIM account holders;
of this number, 4,974 Statements could not be sent because the account
holders were classified as WAU. OHTA has been working with OST and
contractors to identify addresses for the WAU account holders. During
this reporting period, OHTA mailed 826 Historical Statements of Account
to account holders for whom addresses had been located, bringing the
total number of Statements mailed to 12,948. OHTA will re-mail any of
these Statements that are returned as forwarding addresses become
available.

**OHTA SDA Distribution Project - Undistributed SDA Balances at December
31, 2002**

During this reporting period, 148 SDA involving \$826,508 were resolved
and distributed. There remain 11,670 SDA involving \$18,530,532 to
resolve and distribute. Distributions of SDA balances to rightful owners
during the period January 1, 2003, through March 31, 2006, total
\$39,840,578, including interest of \$2,878,375 posted from January 1,
2003, through the date of distribution.

**Imaging/Coding -- Individual Indian Trust Documents**

During this reporting period, OHTA completed scanning 456,262 pages,
coding 73,041 documents and loading 116,493 documents into ART. All
documents are checked for quality and accuracy before they are loaded
into ART for reconciliation.

**Accounting Standards Manual**

As previously reported, periodic revisions are routinely made to the
*Accounting Standards Manual*. Another revision was issued on March 17,
2006.

**Accounting Plan**

As previously reported, Interior expects to modify the January 6, 2003,
accounting plan. Modifications will be based on lessons learned from the
work already completed, court decisions, statistical sampling
parameters, accounting costs, and the history of congressional funding.

**[Delays and Obstacles]{.underline}**

Enacted appropriations for FY2003 through FY2006 have been below the
President's requests, thus limiting the historical accounting that could
be performed.

**[Assurance Statement]{.underline}**

I concur with the contents of the information contained in the Office of
Historical Trust Accounting section of the *Status Report to the Court
Number Twenty-Five*. The information provided in this section is
accurate to the best of my knowledge.

Date: April 24, 2006

Name: *Signature on File*

> Bert T. Edwards, Executive Director
>
> Office of Historical Trust Accounting

II. []{#__RefHeading___Toc134240035 .anchor}**OFFICE OF THE SPECIAL
    TRUSTEE FOR AMERICAN INDIANS**

**[Introduction]{.underline}**

The Office of the Special Trustee for American Indians was created by
the American Indian Trust Fund Management Reform Act of 1994. The 1994
Act provides direction to the Department of the Interior on accounting
for Indian trust funds and reforming the operation of the Indian
fiduciary trust. The Special Trustee's responsibilities under the Act
include creating a comprehensive strategic plan for the operation of the
trust and providing oversight of the accounting for Indian trust funds
and the reform of the trust.

**[Special Trustee's Observations]{.underline}**

During this reporting period, work continued in the Rocky Mountain and
Great Plains BIA region offices toward conversion of IT systems and
reengineering business processes. Meetings were held with officials of
these two regions to help develop plans for the conversion process.

The Interior Regulatory Initiative working group held two consultation
sessions during this reporting period. Attendees included Interior
officials and tribal representatives, among others. Publication of
proposed regulations in the Federal Register is expected to begin during
CY2006.

Continued absence of Internet connectivity continues to cause loss of
productivity and requires use of expensive, alternative methods to
obtain and transmit information. Appraisers often travel to access
public Internet systems for research of local property values in order
to prepare appraisals. BLM surveyors are often delayed in getting access
to information to perform survey work. Probate specialists are wasting
many hours of time attempting to locate prospective heirs while using
telephone and fax resources instead of the Internet. In addition, by
accessing Internet databases, OST could locate account holders whose
whereabouts are unknown and distribute funds to them.

Internet is a key delivery mechanism for communications and services to
individuals and Tribes, and must be available to Indians and Tribes as
access becomes available. With Internet access, many account holders
would be able to obtain account and asset information "online" rather
than having to use the call center or make personal visits to field
offices. The President of the National Congress of American Indians, Joe
Garcia, during the fourth annual State of the Indian Nations address
said, "Because of our often-remote location relative to superior
professional services, it is crucial for us to join the
telecommunications revolution of distance learning, telemedicine, public
safety, e-commerce, and electronic government. Not enough Indians have
access."

During this reporting period, one hearing was held by the Senate Indian
Affairs Committee and a second hearing was held jointly with Senate
Indian Affairs and the House Resources Committee regarding a proposed
*Cobell* settlement bill S. 1439. Congressional leaders have strongly
indicated they would like to see an end to the litigation in favor of
more direct use of resources in the trust reform area. Also, during this
reporting period, staff from these two committees were hosted at the
Lenexa record center where they saw the approximately 300 million pages
of records, including trust records, the indexing project and the record
imaging project, followed by a demonstration of the accounting tool that
reconciles IIM accounts to the source documents.

During this reporting period, Secretary Norton advised Congress that the
proposed FY2007 budget for trust management, including the ongoing trust
reform efforts, is \$536 million. This budget includes funding for BIA
trust asset management responsibilities, accounting and distribution of
trust funds by OST, funding for the OHTA historical accounting efforts
and tribal litigation work, as well as funding for the Indian land
consolidation project. In addition, funding for trust reform activities
including the conversion to new technology at all BIA locations,
encoding of documents and cleanup of records is included in the budget.

The FY2007 budget includes a requested increase of \$25.4 million from
this year's budget for the Indian land consolidation program.
Fractionation is one of the most challenging problems in Indian country.
This money will help direct attention to acquiring the most highly
fractionated tracts of land.

The budget also includes an increase of \$6.5 million for other trust
programs. This money is expected to provide survey work, including
adding a cadastral surveyor in each BIA region, continue support of the
probate project and to assist Tribes in their development of energy
resources on reservations.

**[Assurance Statement]{.underline}**

The comments and observations are provided by the Special Trustee for
American Indians and reflect the opinion of the Special Trustee only.

Date: April 21, 2006

Name: *Signature on File*

Ross O. Swimmer

Special Trustee for American Indians

A.  []{#__RefHeading___Toc134240036 .anchor}**TRUST REVIEW AND AUDIT**

**[Introduction]{.underline}**

OTRA reports directly to the Special Trustee for American Indians. OTRA
was created by OST as a response to trust initiatives developed during
the tribal consultation process of 2002. OTRA conducts performance
audits, examinations and reviews of Interior entities as well as Tribes
that manage fiduciary trust activities. Examinations are routinely
conducted at locations that perform trust operations, and are planned to
result in a performance rating. Also, compliance reviews are undertaken
in response to information and complaints received from beneficiaries,
employees and the public.

**[Current Status]{.underline}**

**Indian Trust Examinations**

During this reporting period, OTRA performed seven trust reviews. Nine
draft reports were issued for comment and ten final reports were issued.

OTRA completed four trust record assessments and issued five final
reports during this reporting period.

During this reporting period, OTRA started follow-up on the findings in
the reports already issued. Twenty-six letters were sent to regions,
agencies and Tribes asking for updates on the findings reported in our
reviews. OTRA received three responses by the end of this reporting
period.

**Compliance Reviews**

During this reporting period, nine cases were in inventory. Three
reviews were closed. Field work or report drafting continued on the
remaining cases.

**[Delays and Obstacles]{.underline}**

Lack of Internet access impedes OTRA's work processes and its ability to
communicate effectively, both internally and externally.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Trust
Review and Audit section of the *Status Report to the Court Number
Twenty-Five*. The information provided in this section is accurate to
the best of my knowledge.

Date: April 28, 2006

Name: *Signature on File*

D. Jeff Lords

Director, Office of Trust Review and Audit

Office of the Special Trustee for American Indians

B.  []{#__RefHeading___Toc134240037 .anchor}**OST-OFFICE OF THE CHIEF
    INFORMATION OFFICER**

    1.  []{#__RefHeading___Toc134240038 .anchor}**RECORDS MANAGEMENT**

**[Introduction]{.underline}**

The Office of Trust Records was established in 1999 to develop and
implement a program for the economical and efficient management of trust
records, consistent with the 1994 Act, the Federal Records Act, and
other statutes and implementing regulations. The OTR records management
program has been developed and implemented, and continues to evolve, to
ensure that necessary Indian records are maintained, records retention
schedules are consistent with retention needs, and records are
safeguarded throughout their life-cycles.

**[Accomplishments and Completions]{.underline}**

**American Indian Records Repository**

Approximately 136,471 indexed boxes are located in the AIRR as of the
end of this reporting period. As previously reported, OTR has
historically reported the number of boxes transferred to AIRR for
storage. However, NARA uses cubic feet as the measure for records
stored. Thus far, NARA reports that they are currently storing 142,433
cubic feet of indexed inactive records at AIRR. Some boxes are larger
than one cubic foot (e.g., map boxes).

**Records Indexing Project**

Indexing of approximately 138,425 boxes has been completed as of the end
of this reporting period. The number of completed boxes (indexed and
quality reviewed) differs from the number of boxes stored at AIRR
because not all completed boxes were sent to AIRR from the Annex before
the end of the reporting period.

Approximately 3,890 boxes of inactive records were moved from BIA/OST
field locations to the Lenexa Annex for indexing during this reporting
period. Once indexed, these boxes will be stored in the AIRR.

**Training**

OTR provided records management training for 121 BIA and OST identified
records contacts and 51 tribal employees during this reporting period.

**Equipment Purchases**

242 pieces of fireproof filing equipment were delivered to BIA, OST and
tribal offices during this reporting period.

**[Current Status]{.underline}**

**Safeguarding Records**

As reported, 283 boxes of inactive records that were or may have been
damaged or contaminated by mold, mildew, mouse droppings or other
adverse elements were shipped to NARA for remediation in June 2005. As
reported in the OTR Activity Report for November 2005, the number of
boxes increased to 289 as a result of holdings maintenance being
performed. Some boxes cannot hold the entire contents of the original
box and are placed in an "overflow box" which is kept with the original
box.

OTR reported in December 2005 that 145 boxes were released by NARA and
sent for indexing and storage in the AIRR. NARA subsequently informed
OTR that the number released in December 2005 was actually 146 boxes. Of
the 143 boxes (289 -- 146) [^2] remaining to be treated by NARA, 48 of
60 boxes requiring holding maintenance were completed; 12 of 21 boxes
requiring humidification flattening were completed; and 37 of 54 boxes
requiring conservation treatment were completed. The completed boxes
have been sent to the Annex for indexing. NARA anticipates that the
remaining 46 original boxes will be completed by the end of April 2006,
except for those materials which are beyond NARA's capabilities to
repair.

**Records Retention Schedules**

During this reporting period, OTR received approval from the Archivist
of the United States for the following five BIA electronic systems
records schedules: MADS, Keyfile System, GLADS, Alaska Title Plant Data
Base, and Land Title Mapper. The Archivist also approved the Box Index
Search System records schedule.

**Records Evaluation**

As previously reported, 31 boxes set aside for evaluation remain at OTR
in Albuquerque pursuant to a litigation hold. There has been no change
during this reporting period.

**Records Management Policies and Procedures**

As reported in the OTR Activity Report for February 2006, OTR was
notified of allegations of destruction of trust and non-trust records at
the BIA Fort Defiance Agency. OTR and OTRA conducted a joint examination
of the allegations and concluded that approximately one cubic foot of
documents, comprised of original incomplete sand and gravel permits
(which were considered to be records) and non-record duplicate copies of
archaeological clearances and reports were shredded by Agency staff. As
a follow-up to the destruction of records at the BIA Fort Defiance
Agency, OTR provided records management briefings specifically targeted
to the managers of BIA programs in the BIA Navajo Region. The purpose of
the training was to reinforce the record keeping responsibilities of
managers.

Also as reported in the OTR Activity Report for March 2006, OTR received
a request from the OST Northwest Regional Fiduciary Trust Administrator
to conduct an investigation into possible unauthorized destruction of
federal records or non-records material stored at the OST field office
in Portland, on or about February 16, 2006. OTR and OTRA conducted a
joint examination March 28 -- 30, 2006. It is anticipated that a report
will be prepared in the next reporting period.

**[Delays and Obstacles]{.underline}**

Lack of Internet access continues to hinder OTR's ability to provide
remote access to the record index database for authorized users of the
records. If Internet access were available, authorized researchers could
conduct their searches from their respective work sites and only visit
AIRR when necessary to inspect specific boxes or request documents from
specific boxes.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Records
Management section of the *Status Report to the Court Number
Twenty-Five.* The information provided in this section is accurate to
the best of my knowledge.

Date: April 20, 2006

Name: *Signature on File*

Ethel J. Abeita

Director, Office of Trust Records

Office of the Special Trustee for American Indians

C.  []{#__RefHeading___Toc134240039 .anchor}**TRUST ACCOUNTABILITY**

    1.  []{#__RefHeading___Toc134240040 .anchor}**TRUST BUSINESS PROCESS
        MODELING**

**[Introduction]{.underline}**

Interior is working to build a highly effective fiduciary trust services
organization by implementing the business objectives contained in the
CTM. Those business objectives are being used to guide implementation of
the FTM. Implementation of the FTM is a collaborative effort of BIA,
OST, BLM, MMS and OHA, and is integrated with Interior's other trust
reform initiatives. The FTM is being implemented to transform the
current trust business processes into more efficient, consistent,
integrated and fiscally responsible business processes that meet the
needs and priorities of the beneficiaries.

**[Accomplishments and Completions]{.underline}**

Standardized leasing and permitting, rights-of-way, and LTRO handbooks
were adopted by BIA. The final standardized handbooks were distributed
at the March 2006 National BIA Realty Conference.

Based on the skill sets developed in the previous reporting period, BIA
revised its position description for new hires in key trust realty
positions.

**[Current Status]{.underline}**

As a part of the DOI Regulatory Initiative, reengineering staff
participated in the consultation meetings, evaluated comments received
and also participated in revising the draft regulations.

The reengineering staff also participated in the initial drafting of new
rights-of-way and appraisal regulations with BIA and OAS. It is expected
that these regulations will become a part of the Regulatory Initiative.

Validation of managerial skill sets is continuing and is expected to be
completed during the next reporting period. Once completed, the skill
sets will be used to update the current position descriptions. This will
allow supervisors to determine additional training needs for managers to
perform their jobs in accordance with FTM requirements.

Reengineering staff conducted follow-up site visits to further assess
post-conversion activities and lockbox implementation at pilot agencies.
A report on the site visits will be available during the next reporting
period. Recommendations are expected to be included as a part of the
report.

Initial drafting began of the following handbook chapters: Sales and
Exchanges of Tribal Trust or Restricted Land; Negotiated Sales, Gifts
and Exchanges of Individually Owned Lands; Tribal Tract Purchases;
Consolidation by Sale of Highly Fractionated Tracts; Partitions in Kind;
and Mortgages and Deeds of Trust. The Fluid Minerals handbook and Sand,
Gravel and Aggregates handbook have been delivered to BIA.

The reengineering staff began documenting the impact of the lock box
process on existing procedures in order to develop DOPs for future use.

Two of three sections of the DOPs for Reporting and Reconciliation have
been drafted and are in review. All three sections are expected to be
completed during FY2006.

**[Delays and Obstacles]{.underline}**

Lack of Internet access impedes communication with other trust bureaus
and offices, and hinders the expansion of reengineered processes that
utilize the Internet. This exacerbates the sheer complexity of
reengineering the existing trust business processes.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Trust
Business Process Modeling section of the *Status Report to the Court
Number* *Twenty-Five.* The information provided in this section is
accurate to the best of my knowledge.

Date: May 1, 2006

Name: *Signature on File*

Margaret Williams

Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

2.  []{#__RefHeading___Toc134240041 .anchor}**TRUST DATA QUALITY AND
    INTEGRITY**

**[Introduction]{.underline}**

The success of trust reform depends, in part, on the accuracy of data
generated from the maintenance of trust assets, ownership of trust
assets, distribution of trust income, and management of trust accounts.
The DQ&I project focuses on three primary initiatives: (1) assisting BIA
with document encoding into the trust systems, (2) validating/correcting
CDE to their respective source documents and (3) implementing Post-QA
processes.

**[Accomplishments and Completions]{.underline}**

During this reporting period, TPMC\'s contractors:

-   Conducted DQ&I site assessments for the Ft. Hall Agency, Yakama
    Agency, EORO-LTRO and the SWRO-LTRO.

-   Completed encoding of encumbrance documents into TAAMS Leasing for
    Horton, Pawnee and Shawnee Agencies.

-   Validated beneficiary ownership data for Horton Agency and Pawnee
    Agency land tracts. Provided these Agencies and LTRO with a
    tract-level summary of identified variances for further research and
    corrections, if necessary.

**[Current Status]{.underline}**

The DQ&I Project expanded to include NWRO-LTRO; Ft. Hall and Yakama
Agencies; EORO-LTRO and SWRO-LTRO. Operations continued for: (1) SPRO,
(2) GPRO, (3) Pima Agency, (4) PRO-LTRO, (5) RMRO and (6) Miami Agency.
Through the project, agencies and regions:

-   Continued validation/correction of Shawnee Agency beneficiary
    ownership data.

-   Performed additional global ID changes in TAAMS Title for SPRO,
    achieving 84% completion.

-   Scanned 5,853 active encumbrance documents at RMRO-LTRO to prepare
    for future validation/correction task.

-   Recorded an additional 2,315 for a total of 4,333 documents at
    RMRO-LTRO.

-   Encoded missing required data into TAAMS Title for 4,932 RMRO-LTRO
    encumbrance documents, allowing the full record to be mapped
    electronically into TAAMS Leasing.

-   Initiated encoding of active encumbrance documents into TAAMS
    Leasing at Rosebud Agency.

-   Scanned encumbrance documents for Crow Creek, Lower Brule, Yankton,
    Sisseton and Ft. Totten Agencies. Utilized scanned images to conduct
    the Post-QA task on BIA encoding into TAAMS Leasing for these
    locations.

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-   Analyzed ownership data for 155 Miami Agency tracts and provided
    assistance with researching and correcting variances identified.

-   Continued encoding of active encumbrances into TAAMS Leasing for
    Miami Agency.

**[Delays and Obstacles]{.underline}**

Lack of access to the Internet has resulted in: (1) communication
delays; (2) adverse project coordination issues; (3) increased
administrative program costs; and (4) the overall DQ&I project being
unable to take full advantage of available information technology.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in this Trust
Data Quality and Integrity section of the *Status Report to the Court
Number Twenty-Five.* The information provided in this section is
accurate to the best of my knowledge.

Date: April 21, 2006

Name: *Signature on File*

John E. White

Trust Reform Officer

Office of the Special Trustee for American Indians

1.  []{#__RefHeading___Toc134240042 .anchor}**INDIAN FIDUCIARY TRUST
    TRAINING PROGRAM**

**[Introduction]{.underline}**

Interior has a continuing responsibility to provide adequate staffing,
supervision and training for trust fund management and accounting
activities. Fiduciary trust training is essential to the success of
Interior's trust reform efforts and forms an integral part of all
training for Interior employees who are involved in the management of
Indian trust assets.

**[Accomplishments and Completions]{.underline}**

OST offered two sessions of the course, *Fiduciary Overview Program*,
presented by Cannon Financial Institute, with 57 OST, BIA and tribal
personnel attending during this reporting period. A total of 793 people
have attended this course since March 2003. This course compares and
contrasts the federal Indian trust administered through Interior with
private sector trusts administered through banks and other financial
institutions.

During this reporting period, Cannon Financial Institute personnel
presented all six of the specialty courses to 100 OST, BIA and tribal
personnel. The specialty courses, *Risk Management, Probate*, *Trust
Accounting*, *Asset Management*, *Fiduciary Behavior* and
*Guardianships* are part of the *Certified Indian Fiduciary Trust
Specialist* certification program as described in previous reports.

During this reporting period, OST training staff conducted 10 training
sessions in TFAS, CSS, StrataVision and the historical query database
for 60 OST, BIA and contractor staff.

OST and BIA staff presented the three-day course, *Trust Fundamentals*,
to 21 OST, BIA and tribal staff. This course includes such topics as the
history and policy of Indian trust, current trust reform activities, job
roles and responsibilities, and organization and working relationships.

**[Current Status]{.underline}**

During this reporting period, 11 OST personnel attended the *Certified
Indian Fiduciary Trust Specialist* review and exam session, and are
expected to receive their certifications during the next reporting
period.

Dedication ceremonies for the NIPTC are scheduled for Thursday, April
27, 2006.

**[Delays and Obstacles]{.underline}**

The lack of Internet access inhibits electronic communication with other
governmental agencies and contractors, hinders the research of training
tools and potential contractors, and restricts OST's ability to access
online training programs.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Indian
Fiduciary Trust Training Program section of the *Status Report to the
Court Number Twenty-Five.* The information provided in this section is
accurate to the best of my knowledge.

Date: April 19, 2006

Name: *Signature on File*

Dianne M. Moran

Director, Trust Training

Office of the Special Trustee for American Indians

2.  []{#__RefHeading___Toc134240043 .anchor}**RISK MANAGEMENT**

**[Introduction]{.underline}**

The objectives of the risk management initiative are to design, deliver,
and implement a comprehensive risk management program that includes
extensive management controls for monitoring and evaluating Interior's
Indian trust asset management program. The risk management program
continues to be implemented by TPMC. OTRA monitors and evaluates
management corrective action plans to mitigate control deficiencies.

**[Accomplishments and Completions]{.underline}**

During this reporting period, a revised concept of operations was
developed to administer a comprehensive risk management program for
Indian trust assets in order to capture the new requirements of OMB
Circular A-123. In addition, a Senior Management Council and Senior
Assessment Team were established in OST as required by the revisions to
A-123.

OST updated and closed out 60 corrective action plans that mitigated
identified risks. The remaining corrective action plans are expected to
be completed during the next reporting period.

**[Current Status]{.underline}**

RM-PLUS content for OST trust programs is under review to meet the
revised OMB Circular

A-123 requirements. These revisions became effective in FY2006 and
include strengthening requirements for documentation, monitoring and
reporting.

TBCC RM-PLUS content is still under development and is expected to be
completed during the next reporting period.

OST continues to work with OSM and BLM on the IT security requirements
to allow training to begin on the RM-PLUS tool in order for them to
conduct their risk assessments.

During FY2006, OST expects BIA to update and/or close out its open
corrective action plans from FY2005.

**[Delays and Obstacles]{.underline}**

The lack of Internet access complicates the implementation and use of
RM-PLUS, since it is designed as a web-based application.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Risk
Management section of the *Status Report to the Court Number
Twenty-Five*. The information provided in this section is accurate to
the best of my knowledge.

Date: May 1, 2006

Name: *Signature on File*

Margaret Williams

Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

3.  []{#__RefHeading___Toc134240044 .anchor}**REGULATIONS, POLICIES AND
    PROCEDURES**

**[Introduction]{.underline}**

OTP in OST was established on April 21, 2003, to assist Interior in
establishing "consistent, written policies and procedures for trust fund
management and accounting" as stated in the 1994 Act. OTP oversees and
facilitates the development, promulgation and coordination of
trust-related regulations, policies, procedures and other materials to
guide the proper discharge of Interior's fiduciary responsibilities. OTP
is separate from BIA's PPA, which is responsible for policies,
procedures and regulations affecting all BIA activities. PPA activities
thus are reported in the BIA section of the reports to the Court.

**[Accomplishment and Completions]{.underline}**

**25 CFR 1200 -- American Indian Trust Fund Management Reform Act.**
During this reporting period the technical amendments were submitted in
final form and published in the Federal Register.

**[Current Status]{.underline}**

The OST Directives System Handbook is awaiting final approval from OST
management. Publication of the handbook is expected during the next
reporting period.

Work on the Reporting and Reconciliation DOP, which includes procedures
for reconciling financial transactions and preparing financial
statements, as well as reporting to Treasury, IRS and beneficiaries, was
realigned after priorities were established among various DOP chapters.
Groups of completed processes were circulated for surnaming; drafting
and review continues on the remainder. Approval and issuance of the
entire DOP is expected during the next reporting period.

Proposed changes to the Account Maintenance DOP and the Disbursing DOP,
specific to the Osage Nation, were reviewed by field staff. Upon
completion of management review, the DOPs will be put into the surname
process. Final issuance is now expected in the next reporting period.

**[Delays and Obstacles]{.underline}**

Lack of access to the Internet and its repository of online statutes,
the Federal Register and other resources continues to present challenges
to this office.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Office of
Trust Regulations, Policies and Procedures section of the *Status Report
to the Court Number Twenty-Five*. The information provided in this
section is accurate to the best of my knowledge.

Date: May 1, 2006

Name: *Signature on File*

Philip Viles, Director

Office of Trust Regulations, Policies and Procedures

Office of the Special Trustee for American Indians

A.  []{#__RefHeading___Toc134240045 .anchor}**FIELD OPERATIONS**

    1.  []{#__RefHeading___Toc134240046 .anchor}**APPRAISAL**

**[Introduction]{.underline}**

The Office of Appraisal Services, under a management contract with
NBC-ASD, is responsible for Indian land valuations. The contract was
established to provide impartial estimates of market value for a variety
of real property interests on land owned in trust or restricted status
by individual Indians, Alaska Natives, and Indian Tribes. Various
regulations governing Indian trust lands require valuations. To meet
this requirement, an appraisal or other valuation method is used to
determine fair market value of Indian lands.

**[Accomplishments and Completions]{.underline}**

A Deputy Chief Appraiser for Policy and Compliance and a Deputy Chief
Appraiser for OAS Operations were hired and reported for duty during the
reporting period.

The position of the director of OME was filled during this reporting
period, and the office is expected to be fully staffed during the next
reporting period. The OME will perform mineral evaluation services in
support of ILCA.

OAS has contracted to develop an automated Indian Trust Appraisal
Request Tracking System (ITARS), conduct a fractionated interest study,
and provide appraisal services.

**[Current Status]{.underline}**

ASD, in coordination with OST, continues to conduct a comprehensive
analysis of OAS staff and training requirements. Temporary review
appraisers continue to be used to reduce the backlog. The use of
contracted appraisal services is expected to provide additional support
in Rocky Mountain and Northwest to supplement the existing workforce.

A department-wide appraisal policy handbook, which incorporates the OAS
handbook section, was completed in draft form and circulated for
comment. The handbook is expected to be issued in final form before the
end of FY2006.

**Appraisal Backlog**

As of this reporting period, the appraisal backlogs are as follows:

+-----------------------+-----------------------+-----------------------+
| **Region**            | **Appraisal Backlog** | **Appraisal Backlog   |
|                       |                       | \***                  |
|                       | **As of 12/30/05**    |                       |
|                       |                       | **As of 03/31/06**    |
+-----------------------+-----------------------+-----------------------+
| Northwest             | 285                   | 166                   |
+-----------------------+-----------------------+-----------------------+
| Rocky Mountain        | 758                   | 661                   |
+-----------------------+-----------------------+-----------------------+
| Midwest               | 62                    | 42                    |
+-----------------------+-----------------------+-----------------------+
| Western               | 153                   | 69                    |
+-----------------------+-----------------------+-----------------------+
| Southwest             | 12                    | 15                    |
+-----------------------+-----------------------+-----------------------+
| Eastern Oklahoma      | 85                    | 75                    |
+-----------------------+-----------------------+-----------------------+
| Navajo                | 30                    | 80                    |
+-----------------------+-----------------------+-----------------------+
| Pacific               | 0                     | 4                     |
+-----------------------+-----------------------+-----------------------+
| Alaska                | 407                   | 399                   |
+-----------------------+-----------------------+-----------------------+
| Eastern               | 0                     | 0                     |
+-----------------------+-----------------------+-----------------------+
| Southern Plains       | 4                     | 45                    |
+-----------------------+-----------------------+-----------------------+
| Great Plains          | 5                     | 0                     |
+-----------------------+-----------------------+-----------------------+
| **TOTAL**             | **1,801**             | **1,556**             |
+-----------------------+-----------------------+-----------------------+

> \* The backlog includes all requests from BIA whether or not they are
> required for a proposed transaction. The requests are addressed in
> priority order based on factors such as court-ordered transactions,
> economic transactions, and rights-of-way transactions. The remaining
> appraisal requests for which no transaction is pending may appear on
> the backlog list until appraisal staff has completed priority
> assignments.

This table does not include appraisal backlog information from the
compacted and contracted Tribes. This information is being requested
from the tribes and is expected to be included in the next report.

**[Delays and Obstacles]{.underline}**

The inability to utilize the Internet as a tool to communicate with
outside contacts to research comparable sales and other information is a
continuing hardship.

Difficulties continue in recruiting qualified appraisers for permanent,
temporary and contract positions, particularly in remote locations.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Appraisal
section of the *Status Report to the Court Number Twenty-Five.* The
information provided in this section is accurate to the best of my
knowledge.

Date: May 1, 2006

Name: *Signature on File*

Brian M. Holly, MAI

Appraisal Services Directorate

National Business Center

B.  []{#__RefHeading___Toc134240047 .anchor}**TRUST SERVICES**

    1.  []{#__RefHeading___Toc134240048 .anchor}**CURRENT ACCOUNTING
        ACTIVITIES**

**[Introduction]{.underline}**

Current accounting activities focus on: (a) whereabouts unknown
accounts; (b) trust funds accounting system; (c) special deposit
accounts; (d) small balance accounts; and (e) accounting discrepancies.

WAU are classified as such for various reasons, including (1) new
accounts established without an address, (2) mail returned for invalid
address and (3) account holder refused or did not claim mail. A variety
of methods and means are used to locate WAU account holders.

TFAS is a generic term for a COTS trust fund accounting system that
provides the basic receipt, accounting, investment, disbursing and
reporting functions common to commercial trust funds management
operations.

SDA are temporary accounts for the deposit of trust funds that cannot
immediately be credited to the proper account holders. As explained in
the BIA/OST Interagency Procedures Handbook, this type of account is to
be used only as an exception to the rule that trust funds immediately be
deposited to the credit of, and then distributed as soon as practicable
to, the individual and tribal beneficiaries. The SDA project has two
sub-projects: the retrospective (pre-January 1, 2003, receipts) and the
prospective (post-December 31, 2002, receipts) phases. OHTA has
responsibility for "resolution" (i.e., research and distribution of
funds) of the retrospective phase, while BIA has comparable
responsibility for the prospective phase. This section of the report to
the Court thus addresses only the prospective phase.

Small balance accounts are defined as those with balances of \$.01 -
\$1.00 and no activity in the preceding eighteen months. Management
expenses for these accounts are considerable, in part because (as
directed by Congress) annual statements must be sent to these account
holders.

Various accounting discrepancies that existed prior to the conversion to
TFAS still need research and resolution. Some may impact individual
accounts. At present, OST has a daily and monthly reconciliation process
in place to ensure that transactional reporting to Treasury is accurate
and that any discrepancies are researched and reconciled during the next
accounting period. While this process ensures resolution of current
discrepancies in timely fashion, separate research and reconciliation
efforts are needed to address the pre-TFAS discrepancies.

1.  **a. Whereabouts Unknown Accounts**

**[Current Status]{.underline}**

During this reporting period, 5,421 accounts with a combined balance of
\$3 million were added to the WAU list, and 3,663 account holders with a
combined balance of \$7.5 million were located.

Priority continues to be placed on securing current addresses for
account holders of the rolling top 100 highest dollar balance WAU
accounts. During this reporting period, 21 of the top 100 WAU accounts,
with combined account balances in excess of \$2.9 million, were updated
with current addresses.

As of March 31, 2006, there were 46,450 WAU accounts with a combined
balance of \$61,372,720. The following table illustrates the number of
accounts stratified by account balance and WAU category.

+---------------+-------------+-------+-------------+---------+------+
| **Account     | **Corres    | *     | *           | **Ref   | *    |
| Balance**     | pondence/** | *Acco | *Awaiting** | used/** | *Tot |
|               |             | unt** |             |         | al** |
|               | **Check     |       | **Address   | **Uncl  |      |
|               | Returned**  | **Se  | Con         | aimed** |      |
|               |             | tup** | firmation** |         |      |
|               |             |       |             | *       |      |
|               |             | *     |             | *Mail** |      |
|               |             | *No** |             |         |      |
|               |             |       |             |         |      |
|               |             | *     |             |         |      |
|               |             | *Addr |             |         |      |
|               |             | ess** |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Equal to or   | 16          | 9     | 0           | 0       | 25   |
| over          |             |       |             |         |      |
| \$100,000     |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under         | 37          | 10    | 0           | 0       | 47   |
| \$100,000 and |             |       |             |         |      |
| equal to or   |             |       |             |         |      |
| over \$50,000 |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under         | 1,905       | 808   | 0           | 1       | 2    |
| \$50,000 and  |             |       |             |         | ,714 |
| equal to or   |             |       |             |         |      |
| over \$5,000  |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under \$5,000 | 5,850       | 1,530 | 3           | 7       | 7    |
| and equal to  |             |       |             |         | ,390 |
| or over       |             |       |             |         |      |
| \$1,000       |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under \$1,000 | 7,939       | 3,040 | 12          | 2       | 10   |
| and equal to  |             |       |             |         | ,993 |
| or over \$100 |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under \$100   | 11,301      | 4,748 | 19          | 3       | 16   |
| and equal to  |             |       |             |         | ,071 |
| or over \$1   |             |       |             |         |      |
+---------------+-------------+-------+-------------+---------+------+
| Under \$1     | 3,139       | 6,048 | 20          | 3       | 9    |
|               |             |       |             |         | ,210 |
+---------------+-------------+-------+-------------+---------+------+
| **Total**     | 30,187      | 1     | 54          | 16      | 46   |
|               |             | 6,193 |             |         | ,450 |
+---------------+-------------+-------+-------------+---------+------+

**[Delays and Obstacles]{.underline}**

The influx of WAU accounts categorized as "Account Setup No Address"
causes the total number of WAU accounts to remain relatively constant.
These accounts primarily result from a lack of current addresses for
individual heirs named in probate orders or recipients of per capita
distributions. Also, accounts are being created in TFAS for
non-financial asset owners in order to generate asset statements. Many
of these owners do not have current addresses. As a result, the total
number of WAU is expected to increase significantly.

There presently are 16,422 supervised IIM account holders (minors,
emancipated minors, adults in need of assistance, and non-compos mentis)
coded as WAU. Updating supervised account addresses coded as WAU
presents a challenge, since BIA Social Services must verify and update
the address changes to these accounts.

The lack of Internet access limits communication effectiveness. OST and
its contractor must rely primarily on mail and telephone communication
with IIM account holders.

1.  **b. Trust Funds Accounting System**

**[Accomplishments and Completions]{.underline}**

During this reporting period, the remaining agencies in the Southern
Plains Region and the Miami Agency from the Eastern Oklahoma Region were
converted to the TAAMS Leasing module. The interface between TAAMS and
TFAS allows for quarterly account statements of performance to be
produced for beneficiaries, including ownership and encumbrance
information of trust assets located in Southern Plains Regional LTRO.

> **c. Special Deposit Account Activity**

**[Current Status]{.underline}**

BIA has the responsibility for distribution of SDA funds received since
January 1, 2003 (prospective receipts). It is the policy of BIA to
distribute funds within 30 days of receipt into SDA. During this
reporting period, there were 13,623 receipt transactions posted to SDA.
Of these, 2,074 were undistributed and aged more than 30 days as of
March 31, 2006.

During this reporting period, aged funds were held in 16 fewer SDA than
in the previous reporting period. Undistributed aged receipts decreased
by 5,176 and the combined dollar amount decreased by \$1,779,963.51. As
of March 31, 2006, funds were held in SDA with a combined dollar amount
of \$1,984,760.47, which represented 4,109 undistributed receipts aged
over 30 days from January 1, 2003, through March 31, 2006. As of March
31, 2006, there were 695 receipts in 188 SDA aged more than one year for
a combined dollar amount of \$441,021.35.

During this reporting period, OST contractors continued to assist the
Fort Belknap Agency to reduce its backlogs by encoding probate orders
into BIA's IRMS. Reducing backlogs assists agencies with their SDA
distribution efforts. OST staff and contractors also assisted BIA staff
in performing work necessary to distribute aged receipts at the Pima,
Eastern Navajo, Fort Hall, Northern Idaho and Coeur d'Alene Agencies.

**[Delays and Obstacles]{.underline}**

Lack of use of the Internet continues to delay access to information
useful to resolving SDA.

1.  **d. Small Balance Accounts**

As of March 31, 2006, there were 15,842 accounts that have a \$.01 -
\$1.00 balance with no activity for the previous 18 months. The total
sum included in those accounts is \$2,548.19. Statements are sent to
account holders for these accounts on an annual basis pursuant to
direction from Congress.

> **e. Accounting Discrepancies**

As previously reported, Interior submitted to Congress a legislative
proposal to resolve the approximate \$6 million difference between the
subsidiary account ledger (liabilities) and the investment pool
(assets). Additional and detailed information regarding the proposal was
submitted to congressional staff during this reporting period.

[**Assurance Statements**]{.underline}

I concur with the content of the information contained in the Accounting
Discrepancies subsection of the Current Accounting Activities section of
the *Status Report to the Court Number Twenty-Five.* The information
provided in this subsection is accurate to the best of my knowledge.

Date: April 27, 2006

Name: *Signature on File*

Charlene Toledo

Deputy Special Trustee, Trust Services

Office of the Special Trustee for American Indians

I express no opinion on the content of the Accounting Discrepancies
subsection, above. I concur with the content of the information
contained in the balance of the Current Accounting Activities section of
the *Status Report to the Court Number Twenty-Five*, and this
information is accurate to the best of my knowledge.

Date: May 1, 2006

Name: *Signature on File*

Margaret Williams

Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

III. []{#__RefHeading___Toc134240049 .anchor}**BUREAU OF INDIAN
     AFFAIRS**

     A.  []{#__RefHeading___Toc134240050 .anchor}**TRUST REGULATIONS,
         POLICIES AND PROCEDURES**

**[Introduction]{.underline}**

The Office of Planning and Policy Analysis (PPA) in the Office of the
Assistant Secretary -- Indian Affairs was established on April 21, 2003.
PPA is responsible for developing and promulgating Indian Affairs
directives. PPA is separate from OST\'s Office of Trust Regulations,
Policies and Procedures, whose activities are reported in the OST
section of the status reports to the Court.

**[Accomplishments and Completions]{.underline}**

**Grants of Easement for Right-of-Way on Indian Lands --** The handbook
was completed and issued to all Regions during this reporting period.

**Land Titles and Records** -- The handbook was completed and issued to
all Regions during this reporting period.

**Leasing and Permitting** -- The handbook was completed and issued to
all Regions during this reporting period.

**Indian Probate** -- The draft handbook was issued to all Regions
during this reporting period.

**[Current Status]{.underline}**

**Regulatory Initiative --** Preliminary draft regulations have been
distributed to Indian Affairs staff and Tribes as part of the
consultation effort prior to publication in the Federal Register. During
this reporting period, two consultation sessions were held. Publication
of the regulations is expected to begin during CY2006.

**25 CFR 216 -- Surface Exploration, Mining, and Reclamation of Lands
--** The project is on schedule, with publication of the proposed
revisions expected during the third quarter of CY2006.

**25 CFR 162 -- Leases and Permits, Subparts C and D -- Residential
Leases and Business Leases --**Publication of this rule is expected
during FY2006.

**25 CFR 224 -- Tribal Energy Resource Agreements --**This rulemaking is
required by the Energy Policy Act of 2005, which mandates the Secretary
to establish and implement an Indian energy resource development
program. This rule is expected to establish a cohesive and comprehensive
means of development of energy resources on tribal trust lands. Tribal
consultations were held during the last reporting period. The proposed
rule is expected to be published in the second quarter of CY2006.

**25 CFR 292 -- Gaming on Trust Lands Acquired After October 17, 1998
--**The proposed rule establishes the criteria that the Department will
consider when determining whether a parcel of land acquired in trust
after October 17, 1988, qualifies under any of the exceptions listed in
25 U.S.C. 2719. During this reporting period, draft regulations were
distributed to tribal leaders. The proposed rule is expected to be
published during the second quarter of CY2006.

**[Delays and Obstacles]{.underline}**

Lack of access to the Internet has hindered PPA's ability to research
statutes and departmental manuals and makes distribution of documents
for review by Tribes more difficult and costly.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Trust
Regulations, Policies and Procedures -- BIA section of the *Status
Report to the Court Number Twenty-Five*. The information provided in
this section is accurate to the best of my knowledge.

Date: April 20, 2006

Name: *Signature on File*

Debbie L. Clark

Deputy Assistant Secretary -- Indian Affairs (Management)

Bureau of Indian Affairs

B.  []{#__RefHeading___Toc134240051 .anchor}**FRACTIONATION**

**[Introduction]{.underline}**

Fractionation of Indian trust and restricted land stems from the federal
Indian policy of the 19^th^ Century. Fractionation occurs as land passes
from one generation to the next and more and more heirs or devisees
acquire an undivided interest in the land. This is a complex and
potentially emotionally-charged issue, due primarily to cultural
differences, historical legacy and family associations of the present
owners with the original Indian owners of those lands. Efforts to
address this complex issue are coordinated primarily through the BIA
Indian Land Consolidation Office, which seeks to help Tribes make use of
the opportunities offered by the Indian Land Consolidation Act, as
amended in 2004. ILCO is operating several acquisition projects and,
from there, a nationwide plan is being implemented to promote
consolidation of the ownership of Indian land.

**[Accomplishments and Completions]{.underline}**

-   Acquired 10,941 fractional interests during this reporting period,
    for a cumulative total of 213,716 interests for ILCP in the Midwest,
    Northwest, Western, Eastern Oklahoma, Navajo, Rocky Mountain and
    Great Plains Regions.

-   Of the total interests acquired, 86% were interests of less than 2%
    ownership in the respective tracts of land.

-   Acquired a cumulative total equivalent of 245,122.18 acres for the
    project reservations.

**[Current Status]{.underline}**

ILCO proposed a new strategy during this reporting period, including
refocusing its acquisition activities on reservations with the most
highly fractionated tracts. The proposal is under review by the TESC,
and a decision is expected during the next reporting period. "Highly
fractionated" is defined as tracts having 200 or more interests.

ILCO is discontinuing acquisition activities for three reservations that
contain fewer highly fractionated tracts. During this reporting period,
three reservations with more highly fractionated tracts were added to
the program. Acquisition on these reservations is expected to begin
during FY2006 and FY2007.

Other ILCP activities include:

-   Coordinating with OAS and LTRO to prepare for acquisitions at
    reservations added to the program.

-   Continuing to target and acquire additional *Youpee* interests.

-   Continuing implementation of LCTS. The LCTS project is expected to
    be completed during FY2006.

**[Delays and Obstacles]{.underline}**

-   Probate and LTRO backlogs and *Youpee* issues continue to impede
    acquisitions.

-   Lack of Internet access results in slower processing of applications
    from potential sellers and hinders searches for WAU account holders.

-   Delay in obtaining land and mineral values impedes acquisitions.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the
Fractionation section of the *Status Report to the Court Number
Twenty-Five.* The information provided in this section is accurate to
the best of my knowledge.

Date: April 13, 2006

Name: *Signature on File*

Brenda Walhovd

Program Specialist, Indian Land Consolidation Office

Bureau of Indian Affairs

A.  []{#__RefHeading___Toc134240052 .anchor}**PROBATE**

**[Introduction]{.underline}**

Federal law permits Indian owners to pass title to their trust assets by
testamentary devise or by intestate succession, and imposes upon
Interior the duty of determining the legal heirs. BIA, OHA and OST must
coordinate their work to complete the probates of Indian estates.
Information on the status of probates is contained within the ProTrac
system. Each BIA regional office and corresponding agency is responsible
for encoding new cases, examining "initial load" cases and making
corrections. Data cleanup continues in an effort to make ProTrac a more
complete source of probate data.

**[Current Status]{.underline}**

**Case Preparation**

According to ProTrac, 8,308 probate cases are in the case preparation
stage.

**Case Adjudication**

According to ProTrac, 5,022 probate cases are in the case adjudication
stage. As reported by OHA, deciding officials received 1,622 cases and
issued decisions in 1,114 cases. OHA reported 3,942 cases pending.

**Case Closure**

According to ProTrac, there are 3,620 cases in the closing stage. Cases
in the closing stage are ones that have been adjudicated but not
distributed in TFAS, LTRO, or in the Lease Distribution System.
According to ProTrac, 2,702 cases have been closed during this reporting
period.

**Financial Case Closure**

OST reported that it distributed funds and closed 1,868 accounts in
TFAS, representing 1,786 estates. As of the end of March 2006, TFAS
contained 30,580 open estate accounts, which is an increase of 212 from
the 30,368 estate accounts at the end of the last reporting period.

**Probate Handbook**

Publication was delayed and is expected to be completed during the next
reporting period.

**[Delays and Obstacles]{.underline}**

The following obstacles have been identified as having an impact on the
progress of the probate program:

-   Lack of access to the Internet, which includes the inability to use
    electronic mail communication between OHA and BIA/OST;

-   Continued fractionation of ownership of Indian lands;

-   Numerous initiatives competing for resources (e.g., *Youpee*
    revestitures, *Cobell* requirements);

-   Cultural diversities regarding the subject of death;

-   BIA probate reorganization has not been completed.

**[Assurance Statement]{.underline}**

I concur with the content of the information contained in the Probate
section of the *Status Report to the Court Number Twenty-Five*. The
information provided in this section is accurate to the best of my
knowledge.

Date: May 1, 2006

Name: *Signature on File*

William Titchywy

Acting Special Projects Director

Western Region

Bureau of Indian Affairs

[]{#__RefHeading___Toc134240053 .anchor}**ACRONYMS AND ABBREVIATIONS**

1994 Act (or Act) American Indian Trust Fund Management Reform Act of
1994

A-130 Office of Management and Budget Circular A-130 Appendix III

ADM Attorney Decision Makers

AFMSS Automated Fluid Mineral Support System

AIMS ActivCard Identity Management System

AIPRA American Indian Probate Reform Act

AIRR American Indian Records Repository

ALIS Alaska Land Information System

ALJ Administrative Law Judges

ARO Alaska Region office

ARRTS Appraisal Request and Review Tracking System

ART Accounting Reconciliation Tool

AS-IA Assistant Secretary-Indian Affairs

ASD Appraisal Services Directorate

ATO authority to operate

BIA Bureau of Indian Affairs

BIAM Bureau of Indian Affairs Manual

BISS Box Index Search System

BLM Bureau of Land Management

BOR Bureau of Reclamation

BPA Blanket Purchase Agreement

BRM Business Reference Model

C&A Certification and Accreditation

CARS Cadastral Automated Request System

CDE Critical Data Elements

CFedS Certified Federal Surveyor

CFI Continuous Forest Inventory

CGI Software vendor successor to TAAMS vendor

CGIS Cadastral Geographic Information Systems

CIFTA Certified Indian Fiduciary Trust Analyst

CIFTS Certified Indian Fiduciary Trust Specialist

CIO Chief Information Officer

CIRC Computer Incidents Response Center

CISSP Certified Information System Security Professional

CMS Credential Management System

COTS Commercial off-the-shelf

CPIC Capital Planning and Investment Control

CSIRC Computer Security Incident Response Capability

CSIRT Computer Security Incident Response Team

CSS Customer StrataStation

CTM Comprehensive Trust Management Plan

DAA Designated Approving Authority

DEAR DOI Enterprise Architecture Repository

DDoS Distributed Denial of Service

DLRM DOI Land and Resource Management

DM Departmental Manual

DMZ De-Militarized Zone

DNS Domain Name Server

DOI Department of the Interior

DOP Desk Operating Procedure

DoS Denial of Service

DQ&I Data Quality and Integrity

DRM Data Reference Model

EA Enterprise Architecture

ENA Eastern Navajo Agency

EORO Eastern Oklahoma Region office

ERO Eastern Region office

ESN Enterprise Services Network

ETP Enterprise Transition Plan

FAMS Facilities Asset Management System

FAR Federal Acquisition Regulation

FFMIA Federal Financial Management Improvement Act

FIMO Farmington Indian Minerals Office

FIPS Federal Information Processing Standards

FISMA Federal Information Security Management Act

FMFIA Federal Managers' Financial Integrity Act

FRC Federal Records Center

FRD Functional Requirements Document

FTM Fiduciary Trust Model

FTO Fiduciary Trust Officer

GAO Government Accountability Office

GCDB Geographic Coordinate Data Base

GIS Geographic Information System

GLO General Land Office

GLADS Great Lakes Agency Database System

GPRO Great Plains Region office

GPS Global Positioning System

GSA General Services Administration

GSS General Support Systems

HSPD-12 Homeland Security Presidential Directive 12

IAM Indian Affairs Manual

IATO Interim Approval to Operate

ICR Internal Control Review

IEA Interior Enterprise Architecture

IFTR Indian Fiduciary Trust Records

IG Inspector General

IIM Individual Indian Money

IITD Individual Indian Trust Data

ILCA Indian Land Consolidation Act

ILCO Indian Land Consolidation Office

ILCP Indian Land Consolidation Project

IM Instruction Memorandum

InfoDat Indian Forestry Database

Interior Department of the Interior

IP Internet Protocol

IPJ Indian Probate Judges

IPv6 Internet Protocol Version 6

IQCS Incidence Qualification and Certification System

IRM Information Resources Management

IRMS Integrated Records Management System

IRS Internal Revenue Service

ISA Information Security Assessment

IT Information Technology

ITARS Indian Trust Appraisal Request Tracking System

IV&V independent verification and validation

LAN Local area network

LCTS Land Consolidation Tracking System

LMS Learning Management System

LR2000 Legacy Rehost 2000 System

LRIS Land Records Information System

LTIC Land Tenure in Indian Country

LTRO Land Titles and Records Office

MA Major Applications

MAD/LCP Management Accounting Distribution/Land Consolidation Program

MADS Management Accounting Distribution System

MMD Missing Mandatory Documents for Unrestricted Accounts

MMS Minerals Management Service

MOU Memorandum or Memoranda of Understanding

MRM Minerals Revenue Management

MRMSS Minerals Revenue Management Support System

MWRO Midwest Region office

NARA National Archives and Records Administration

NBC National Business Center

NILS National Integrated Lands System

NIPTC National Indian Programs Training Center

NIST National Institute of Standards and Technology

NPS National Park Service

NRO Navajo Region office

NWRO Northwest Region office

O&G Oil and Gas

OAS Office of Appraisal Services

OCIO Office of the Chief Information Officer

OHA Office of Hearings and Appeals

OHTA Office of Historical Trust Accounting

OIG Office of the Inspector General

OME Office of Minerals Evaluation

OMB Office of Management and Budget

OSM Office of Surface Mining

OST Office of the Special Trustee for American Indians

OTFM Office of Trust Funds Management

OTP Office of Trust Regulations, Policies and Procedures

OTR Office of Trust Records

OTRA Office of Trust Review and Audit

PAR Performance and Accountability Report

PIV Personal Identity Verification

PLSS Public Land Survey System

PMSO Project Management Support Office

POA&M Plans of Actions and Milestones

Post-QA Post Quality Assurance

PPA Office of Planning and Policy Analysis

PRIS Production and Response Information System

PRO Pacific Region office

ProTrac Probate Case Management and Tracking System

QA Quality Assurance

QC Quality Control

RAF Recommended Action Forms

RAS Rangeland Administration System

RDRS Royalty Distribution and Reporting System

REM Real Estate Module

RFP Request for Proposal

RM-PLUS Risk Management Assessment/Evaluation tool

RMRO Rocky Mountain Region office

ROW Rights-of-Way

SANS SysAdmin, Audit, Network, Security

SCADA Supervisory Control and Data Acquisition

SDA Special Deposit Accounts

SDLC System Development Life Cycle

SMEs Subject Matter Experts

SMS System Management Servers

SOL Office of the Solicitor

SPRO Southern Plains Region office

SSA Social Security Administration

SSM System Security Manager

SSP System Security Plan

ST&E Security Test and Evaluation

STIGs Security Technical Implementation Guides

SUS System Update Servers

SWRO Southwest Region office

TAAMS Trust Asset and Accounting Management System

TAP Technical Architecture Profile

TBCC Trust Beneficiary Call Center

TESC Trust Executive Steering Committee

TFAS Trust Fund Accounting System

TPMC Trust Program Management Center

TRAC Trust Tracking and Coordination

Treasury Department of the Treasury

TRM Technical Reference Model

TRO Temporary Restraining Order

UAT User Acceptance Testing

USGS United States Geological Survey

USPAP Uniform Standards of Professional Appraisal Practice

VBNS Very High Performance Backbone Network Service

VPN Virtual Private Network

WAN Wide area network

WAU Whereabouts Unknown

WRO Western Region office

[^1]: This Report contains information on the broad trust reform efforts
    underway at Interior. Accordingly, it may include information on
    reform efforts that are not within the scope of the *Cobell*
    litigation.

[^2]: The OTR Monthly Activity Reports for January and February 2006
    inadvertently referenced the original number of 283 boxes.